1 

U.S. Department 

Of Transportation 

National Highway 

Traffic Safety Administration 

Final Regulatory Impact Analysis 

Corporate Average Fuel Economy 

for MY 2017-MY 2025 

Passenger Cars and 

Light Trucks
 

Office of Regulatory Analysis and Evaluation 

National Center for Statistics and Analysis 

August 2012 
2 

Contents 

EXECUTIVE SUMMARY ............................................................................................................ 3
 

I. INTRODUCTION.................................................................................................................... 56
 

II. NEED OF THE NATION TO CONSERVE ENERGY .......................................................... 60
 

III. BASELINE AND ALTERNATIVES..................................................................................... 65
 

IV. IMPACT OF OTHER GOVERNMENTAL VEHICLE STANDARDS ON FUEL
 

ECONOMY ................................................................................................................................ 110
 

V. FUEL ECONOMY ENHANCING TECHNOLOGIES AND THE CAFE MODEL ........ 123
 

VI. MANUFACTURER CAFE CAPABILITIES ..................................................................... 615
 

VII. COST AND SALES IMPACTS.......................................................................................... 674
 

VIII. BENEFITS FROM IMPROVED FUEL ECONOMY...................................................... 847
 

IX. IMPACT OF WEIGHT REDUCTION ON SAFETY ...................................................... 1013
 

X. NET BENEFITS AND SENSITIVITY ANALYSIS ......................................................... 1051
 

XI. FLEXIBILITIES IN MEETING THE STANDARD ........................................................ 1120
 

XII. PROBABILISTIC UNCERTAINTY ANALYSIS .......................................................... 1122
 

XIII. REGULATORY FLEXIBILITY ACT AND UNFUNDED MANDATES REFORM ACT 

ANALYSIS ............................................................................................................................... 1174 
                                                      

 

3 

EXECUTIVE SUMMARY 

This Final Regulatory Impact Analysis (FRIA) has been prepared by the National Highway 

Traffic Safety Administration (NHTSA) to examine the costs and benefits of increasing the 

Corporate Average Fuel Economy standards for passenger cars and light trucks for model years 

(MY) 2017 through MY 2025. NHTSA is required to set CAFE standards by the Energy Policy 

and Conservation Act of 1975 (EPCA), as amended by the Energy Independence and Security 

Act of 2007 (EISA). NHTSA does not have the discretion to not set CAFE standards each model 

year for passenger cars and light trucks. CAFE standards must be set at least 18 months prior to 

the beginning of the model year, must be “attribute-based and defined by a mathematical 

function,” and must be set at the maximum feasible level that NHTSA determines manufacturers 

can reach for that fleet in that model year, among other requirements. See 49 U.S.C. 32902 and 

Section IV.D of the preamble that this FRIA accompanies for more information. 

This assessment examines the costs and benefits of improving the fuel economy of passenger 

cars and light trucks for the final MY 2017-2021 standards and the augural1 MY 2022-2025 

standards.2

 It also examines the costs and benefits of improving the fuel economy of those 

vehicles at alternative rates of increase (both higher and lower) during those model years. As 

part of that examination, it includes a discussion of the technologies that can improve fuel 

economy, analysis of the potential impact on retail prices, safety, lifetime fuel savings and their 

1 For the PRIA, NHTSA described the proposed standards for MYs 2022-2025 as “conditional.” “Conditional” was 

understood and objected to by some readers as implying that the future proceeding would consist merely of a 

confirmation of the conclusions and analysis of the current rulemaking, which would be incorrect and inconsistent 

with the agency’s obligations under both EPCA/EISA and the Administrative Procedure Act. The agency must 

conduct a de novo rulemaking for model years 2022-2025. To avoid creating an incorrect impression, the agency is 

changing the descriptor for the 2022-2025 standards that are presented and discussed in these documents. The 

descriptor must convey that the standards we are now presenting for MYs 2022-2025 reflect the agency’s current 

estimate of what we would have set at this time had we the authority to do so, but also avoid suggesting that the 

future process for establishing final standards for 2022-2025 would be anything other than a rulemaking based on a 

totally white-sheet-of-paper evaluation looking at all of the freshly gathered and solicited information before the 

agency at that future time and reflecting a fresh balancing of all statutorily relevant factors, in light of the 

considerations existing at the time of the evaluation. The agency deliberated extensively, considering many 

alternative descriptors, and concluded that the best descriptor was “augural,” from the verb “to augur,” meaning to 

foretell future events based on current information (as in, “these standards may augur well for what the agency 

might establish in the future”). This is precisely what the MYs 2022-2025 standards presented in these documents 

are – our best estimate of what we would set, based on the information before us today, but knowing that future 

information and thus our future decision may just as well be different as not.

2

 Throughout the FRIA, cost and benefit analyses are presented for individual model years as well as the 9-year 

total; however, 9-year totals include costs and benefits of MYs 2022-2025, for which the CAFE standards are 

augural at present. 
 

                                                      

4 

value to consumers, and other societal benefits such as improved energy security and reduced 

emissions of pollutants and greenhouse gases.3 

As explained above, EISA requires NHTSA to set attribute-based CAFE standards that are based 

on a mathematical function. The CAFE standards for MY 2017-2025 passenger cars and light 

trucks are based on vehicle footprint, as were the standards for MYs 2012-2016.4 The 

mathematical function or “curve” representing the footprint-based standards is a constrained 

linear function that provides a separate fuel economy target for each vehicle footprint, generally 

with more stringent targets for smaller vehicles and less stringent targets for larger vehicles. 

Different parameters for the continuous mathematical function are derived. Individual 

manufacturers will be required to comply with a single fuel economy level that is based on the 

distribution of its production for that year among the footprints of its vehicles. Although a 

manufacturer’s compliance obligation is determined in the same way for both passenger cars and 

light trucks, the footprint target curves for the different fleets are established with different 

continuous mathematical functions that are intended to be specific to the vehicles’ design 

capabilities, to reflect the statutory requirement that the standards are supposed to be “maximum 

feasible” for each fleet separately. 

In order to evaluate the costs and benefits of the rule, a baseline prediction of the fuel economy 

and mix of vehicles that would be sold in MYs 2017 to 2025 in the absence of the new standards 

was constructed. As was done for the MY 2012-2016 final rule and in the Preliminary 

Regulatory Impact Analysis (PRIA) for the MY 2017-2025 rule, a baseline was developed using 

each manufacturer’s MY 2008 fleet as represented in CAFE certification data available to EPA; 

however, in the final MY 2017-2025 rule, NHTSA included an additional baseline fleet that was 

developed using each manufacturer’s MY 2010 fleet, also derived from CAFE certification data. 

Throughout this FRIA, the majority of tables present results calculated separately using the 2008 

and 2010 baselines. In order to conduct these analyses, we assume that similar vehicles will be 

produced through MY 2025 and technologies are added to each of these baseline fleets to 

determine what mpg levels could be achieved by the manufacturers in the MYs 2017-2025 

timeframe. The main analysis includes a “flat” baseline, for which we assume that 

manufacturers would have made no fuel economy improvements above the MY 2016 CAFE 

standards. In the sensitivity analysis section, we examine an alternative baseline, for which we 

assume that manufacturers would meet market demand for slightly higher fuel economy levels in 

light of higher real prices of fuel and given the recently promulgated fuel economy labeling rule, 

3

 This analysis does not contain NHTSA’s assessment of the potential environmental impacts of the final rule for 

purposes of the National Environmental Policy Act (NEPA), 42 U.S.C. 4321-4347, which is contained in the 

agency’s Environmental Impact Statement (EIS) accompanying the final rule. 4

 Vehicle Footprint is defined as the wheelbase (the distance from the center of the front axle to the center of the 

rear axle) times the average track width (the distance between the centerline of the tires) of the vehicle (in square 

feet). 
                                                      

 

5 

and would supply technologies that have a consumer payback (defined by fuel savings exceeding 

retail price increases) in one year or less. 

NHTSA examined nine alternatives, including six that are defined as annual percentage 

improvements over the baseline – 2%/year, 3%/year, 4%/year, 5%/year, 6%/year, and 7%/year. 

In addition to those six are what NHTSA has called the “Preferred Alternative,” the “Maximum 

Net Benefits” alternative, which Executive Orders 12866 and 13563 encourage the agency to 

choose unless statutory considerations mandate otherwise; and the “Total Costs Equal Total 

Benefits” alternative. Looking at the “required” mpg levels in Tables 3a and 3b, the “Preferred 

Alternative” for passenger cars would require fuel economy levels that are generally between the 

3 and 4 percent annual increase alternatives, although the percentage increase varies from year to 

year. The “Preferred Alternative” for light trucks starts at less than the 2% alternative in MY 

2017 and increases to between the 3 and 4 percent alternative in MY 2025. The “Maximum Net 

Benefits” alternative is based upon the agency’s assessment of the availability of technologies 

and a marginal cost/benefit analysis. In this case the agency continues to include additional 

technologies in its analysis until the marginal cost of adding the next technology exceeds the 

marginal benefit. The “Maximum Net Benefits” alternative maximizes net benefits within each 

of the nine years, but it does not attempt to maximize benefits over all 9 years together. The 

“Maximum Net Benefit” for passenger cars would require levels that are higher than the 

“Preferred Alternative” in all years. The “Maximum Net Benefit” required mpg level for light 

trucks is higher in every year than the levels in the “Preferred Alternative.” The “Total Costs 

Equal Total Benefits” alternative represents an increase in the standard to a point where 

essentially total costs of the technologies added together over the baseline added equals total 

benefits over the baseline. In this analysis, for brevity, at times it is labeled “TC = TB.” The 

“TC = TB” levels are higher than the “Preferred” alternative levels in all years.5 

The agency performed a variety of sensitivity analyses to examine the variability of the CAFE 

model’s results to certain economic assumptions. Sensitivity analyses were performed on the 

following: 

1) The price of gasoline: The main analysis uses the Reference Case AEO 2012 Early 

Release estimate for the price of gasoline. As the AEO 2012 Early Release does not 

contain Low and High Price Cases, ranges derived from the Low and High Price 

Cases from the AEO 2011 were utilized in conjunction with the Reference Case AEO 

5

The agency notes that the “TC = TB” alternative would be expected to show costs and benefits that exactly offset 

each other, so that the resulting net benefits would be zero. However, the agency’s analysis accounts for certain 

real-world manufacturer constraints, and because of those constraints the “TC=TB” alternative has net benefits that 

are greater than zero. Because economic and technology-related considerations impose certain limitations on 

manufacturers’ abilities to add fuel-saving technologies during specific model years, technology is sometimes 

“exhausted” before total costs reach the level of total benefits. When this occurs in a given model year, this 

regulatory alternative is defined by the stringency leading to this exhaustion of available technology 
                                                      

6 

2012 Early Release to study the effect of the Low and High Price Cases on the model 

results. 

2)	 The rebound effect: The main analysis uses a rebound effect of 10 percent to project 

increased miles traveled as the cost per mile decreases. In the sensitivity analysis, we 

examine the effect of using a 5, 15, or 20 percent rebound effect. 

3)	 The value of CO2 benefits: The main analysis uses an initial value of $22 per ton to 

quantify the benefits of reducing CO2 emissions. Sensitivity analysis surrounding this 

assumption considers the use of alternate base values of $5, $36, and $68.6 

4)	 Global Warming Potential (non-CO2 GHG benefits): The main analysis does not 

monetize benefits associated with the reduction of non-CO2 GHGs (methane, nitrous 

oxide, HFC-134a). This sensitivity analysis uses a GWP approach to convert nonCO2 gases to CO2-equivalence to monetize these benefits using the same methods 

with which the benefits of CO2 reductions are valued. 

5)	 The military security component: The main analysis does not assign a value to the 

military security benefits of reducing fuel consumption. In the sensitivity analysis, 

we examine the impact of using a value of 12 cents per gallon instead. 

6)	 Consumer benefit: The main analysis assumes there is no loss in value to consumers 

resulting from vehicles that have an increase in price and higher fuel economy. This 

sensitivity analysis assumes that there is a 25, or 50 percent loss in value to 

consumers – equivalent to the assumption that consumers will only value the 

calculated benefits they will achieve at 75, or 50 percent, respectively, of the main 

analysis estimates. 

7) Post-warranty repair costs: The main analysis includes repair costs during the 

warranty period; post-warranty repair costs are addressed in a sensitivity analysis. 

The warranty period is assumed to be 5 years for the powertrain and 3 years for the 

rest of the vehicle. This sensitivity analysis scales the frequency of repair by vehicle 

survival rates, assumes that per-vehicle repair costs during the post-warranty repair 

period are the same as in the in-warranty period, and that repair costs are proportional 

to incremental direct costs (therefore vehicles with additional components will have 

increased repair costs). 

8)	 ICM and RPE cost methods: The main analysis uses the ICM cost method with an 

overall markup factor from variable cost to equivalent retail price of 1.2 to 1.25. The 

retail price equivalent (RPE) cost method results in higher cost estimates for each of 

the technologies, as it uses a markup factor of 1.5. A sensitivity analysis involving 

the RPE method was conducted. The agency also performed a sensitivity analysis 

using the ICM method, but with NAS estimates of technology costs. 

9) Technology costs with NAS cost estimates: The agency conducted a sensitivity 

analysis using values that were derived from the 2011 NAS report.7 This analysis 

used a RPE markup factor of 1.5 for non-electrification technologies, which is 

consistent with the NAS estimation for technologies manufactured by suppliers, and a 

6

 These values are rounded to the nearest dollar; the values used in the sensitivity analysis are unrounded. The 

unrounded values are presented in Chapter X. 

7

 Committee on the Assessment of Technologies for Improving Light-Duty Vehicle Fuel Economy; National 

Research Council. “Assessment of Fuel Economy Technologies for Light-Duty Vehicles” (2011). Available at 

http://www.nap.edu/catalog.php?record_id=12924 (last accessed November 13, 2011) 
7 

RPE markup factor of 1.33 for electrification technologies (HEV, PHEV and EV); 

three types of learning which include no learning for mature technologies, 1.25 

percent annual learning for evolutionary technologies, and 2.5 percent annual learning 

for revolutionary technologies; technology cost estimated for 52 percent (33 out of 

63) technologies; and technology effectiveness estimates for 56 percent (35 out of 63) 

of technologies. Cost learning was applied to technology costs in a manner similar to 

how cost learning is applied in the central analysis for many technologies which have 

base costs which are applicable to recent or near-term future model years. As noted 

above, the cost learning factors used for the sensitivity case are different than the 

values used in the central analysis. For the other inputs in the sensitivity case, where 

the NAS study has inconsistent information or lacks projections, NHTSA used the 

same inputs NHTSA used in the central analysis. 

10) Battery cost: The agency conducted a sensitivity analysis of battery costs in relation 

to HEV, PHEV, and EV batteries. For HEV batteries, a sensitivity analysis was 

performed with a +/- 10 percent variation in cost per kWh, while sensitivity analyses 

involving PHEV and EV batteries utilized alternate ranges contingent on the type of 

battery cathode (see chapter X for additional detail). PHEV and EV battery costs 

ranged between -20 percent and +35 percent in this sensitivity analysis. 

11) Mass reduction cost: A sensitivity analysis was performed examining the impact of 

vehicle mass reduction that could feasibly be accomplished with a +/- 40 percent 

impact on vehicle cost. 

12) Market-driven response: A sensitivity analysis was performed to simulate potential 

increases in fuel economy over the compliance level required if MY 2016 standards 

were to remain in place. The key assumption for this sensitivity analysis is that the 

market would drive manufacturers to put technologies into their vehicles that they 

believe consumers would value and be willing to pay for, applying a payback period 

of one year for purposes of calculating the value of future fuel savings when 

simulating whether manufacturers would apply additional technology to an already 

CAFE-compliant fleet. 

13) Transmission shift optimization technology disabled: As part of the simulation work 

for the final rule, ANL attempted to replicate the shift optimizer technology but 

produced different results than those of Ricardo, particularly in the application of 

shift optimization to naturally aspirated engines. Because of this uncertainty in 

effectiveness values, NHTSA conducted a sensitivity case analysis with transmission 

shift optimizer technology disabled. 

The agency also performed a probabilistic uncertainty analysis on the model results of the 

preferred alternative using the 2010 fleet baseline, as mandated by OMB Circular A-4. Over all 

nine MYs covered by the final (2017-2021) and augural (2022-2025) standards of this rule, the 

higher CAFE standards will produce an impact ranging from a net cost of $69.3 billion to a net 

benefit of $774.7 billion. Across all nine model years, each model year’s passenger car fleet has, 

at minimum, an 88.9 percent certainty that higher CAFE standards will produce a net benefit. 
8 

For light truck fleets, this value is 97.2 percent. The uncertainty analysis is presented in detail in 

Chapter XII. 

The final MY 2017-2021 and augural MY 2022-2025 CAFE standards, like the MYs 2012-2016 

CAFE standards, are being issued jointly with the Environmental Protection Agency (EPA), 

which is concurrently establishing greenhouse gas (GHG) standards for the same vehicles for the 

same model years. The joint standards extend the National Program established for MYs 2012­

2016 into the future. In working together to establish the final standard for MYs 2017-2021 and 

augural standards for MYs 2022-2025, NHTSA and EPA built on the success of the first phase 

of the National Program to regulate fuel economy and GHG emissions from U.S. light-duty 

vehicles, which established the strong and coordinated standards for model years 2012-2016. As 

for the MYs 2012-2016 rulemaking, collaboration with California Air Resources Board (CARB) 

and with industry and other stakeholders has been a key element in developing the agencies’ 

rules. Continuing the National Program would ensure that all manufacturers can build a single 

fleet of U.S. vehicles that would satisfy all requirements under both programs as well as under 

California’s program, helping to reduce costs and regulatory complexity while providing 

significant energy security and environmental benefits. The coordinated program would achieve 

important reductions of fuel consumption and GHG emissions from passenger cars and light 

trucks, based on technologies that either are commercially available or that the agencies project 

will be commercially available in the rulemaking timeframe and that can be incorporated at a 

reasonable cost. Consistent with Executive Order 13563, this rule was developed with early 

consultation with stakeholders, employs flexible regulatory approaches to reduce burdens, 

maintains freedom of choice for the public, and helps to harmonize federal and state regulations. 

Because the agencies are collaborating on the National Program, however, it is important to note 

throughout this analysis that there is significant overlap in costs and benefits for NHTSA’s 

CAFE program and EPA’s GHG program, and therefore combined program costs and benefits 

are not a sum of the two individual programs. 

Table 1 presents the total costs (technology and social), benefits, and net benefits for NHTSA’s 

2017-2025 final and augural preferred alternative CAFE levels. The values in Table 1 display 

(in total and annualized forms) costs for all MY 2011-2025 vehicles and the benefits and net 

benefits represent the impacts of the standards over the full lifetimes of the vehicles projected to 

be sold during model years 2011-2025. Impacts to MYs 2011 - 2016 represent additional costs 

and benefits over and above those of the previously-issued light duty CAFE 2012 - 2016 

standards that occur as a result of manufacturer preparation for the MY 2017 - 2025 standards. 

In the annualization of costs, benefits, and net benefits shown in Table 1, impacts to years prior 

to 2017 are considered to be MY 2017 impacts. In the following Executive Summary tables, 

tables that present total or net costs or benefits include a column documenting the estimated 

cumulative impact of this rule resulting from fuel economy improvements in MY 2011 - 2016 
 

9 

vehicles that manufacturers will make in preparation for the MY 2017 and beyond standards set 

forth in this rule. 

This is the first CAFE rulemaking wherein the agency has included operating costs other than 

outlays for fuel purchases in its analysis of the costs and benefits of new standards. In past 

CAFE rulemakings, reported monetized costs of new standards included only the costs (on an 

MSRP basis) of technology estimated to be added in response to the new standards. All other 

monetized impacts occur as incremental changes to social costs between the baseline and 

regulatory alternatives, and were reported as benefits and, if negative, as negative benefits (i.e., 

disbenefits). 

In considering how to report monetized impacts on different costs to own and operate a new 

vehicle, the agency has more generally revisited its approach to categorizing different monetized 

effects as either costs or benefits. Noting that OMB guidance generally calls for agencies to treat 

positive monetized impacts as benefits, and negative monetized impacts as costs, NHTSA 

revised its reporting of costs and benefits to follow this approach. Thus, for example, while we 

have previously treated monetized damages related to additional congestion, accidents, and noise 

attributable to the rebound effect as negative benefits, we now report those impacts as social 

costs. This change in reporting in no way changes the agency’s resultant calculations of net 

benefits which has always correctly accounted for the sign of monetized impacts. 

However, NHTSA notes that, while straightforward in principle, the concept of categorizing 

negative monetized impacts as costs and positive negative monetized impacts as benefits is 

subject to considerable practical complications. For example, in NHTSA’s current analysis, 

monetized impacts on highway fatalities change sign between model years and between 

passenger car and light truck fleets. Also, disaggregation of criteria pollutant emissions would 

lead increased tailpipe emissions to be treated as costs, and reduced upstream emissions to be 

treated as benefits. For future fuel economy rulemaking analysis, NHTSA plans to further 

consider how best to report monetized impacts as either costs or benefits. 
 

 

10 

Table 1 

NHTSA’s Estimated 2011-2025 Model Year Costs, Benefits, and Net Benefits under the 

Preferred Alternative CAFE Standards
 

(Billions of 2010 Dollars)
 

Cumulative Across MYs 2011 - 2021 (Final Standards Only) 

Baseline 

Fleet 

Totals Annualized 

3% Discount 

Rate 

7% Discount 

Rate 

3% Discount 

Rate 

7% Discount 

Rate 

Costs 2010 

2008 

($60.6) ­

($56.5) 

($57.9) ­

($53.6) 

($2.4) ­

($2.2) 

($3.6) ­

($3.3) 

Benefits 2010 

2008 

$243.1 -

$240.2 

$195.2 -

$194.3 

$9.2 ­

$9.0) 

$11.3 ­

 $11.0 

Net Benefits 2010 

2008 

$182.5 -

$183.8 

$137.3 -

$140.7 

$6.8 ­

$6.8 

$7.7 ­

$7.8 

Cumulative Across MYs 2011 - 2025 (Includes Augural Standards) 

Baseline 

Fleet 

Totals Annualized 

3% Discount 

Rate 

7% Discount 

Rate 

3% Discount 

Rate 

7% Discount 

Rate 

Costs 2010 

2008 

($154.3) ­

($155.7) 

($146.8) ­

($148.1) 

($5.4) ­

($5.4) 

($7.6) ­

$7.5) 

Benefits 2010 

2008 

$629.7 -

$639.0 

$502.7 -

$510.0 

$21.0 ­

$21.3 

$24.2 ­

$24.4 

Net Benefits 2010 

2008 

$475.5 -

$483.2 

$356.0 -

$361.9 

$15.7 ­

$15.9 

$16.7 ­

$16.9 

Table 2 shows the overall analysis summary of costs, benefits, and net benefits for the 15 model 

years (2011 through 2025) by alternative for the combined light duty fleet. Table 4 shows the 

agency’s projection of the estimated actual harmonic average that would be achieved by the 

manufacturers, assuming that some manufacturers will pay fines rather than meet the required 

levels. Table 3 shows the estimated required levels. Tables 3 and 4 present values for model 

years 2017 through 2025 only, as this rule does not change the fuel economy standards 

previously established in the 2012 through 2016 rule. All of the tables in this analysis compare 

the flat MY 2016 baselines to the projected achieved harmonic average. Additionally all of the 

tables in the Executive Summary and in the analysis as a whole use the central value for the 

Social Cost of Carbon (SCC), which is the average SCC across models at the 3 percent discount 

rate. The SCC is discussed in more detail in Chapter VIII. For purposes of capturing the 

uncertainties involved in regulatory impact analysis, we emphasize the importance and value of 

considering the full range of SCC values. 

Costs: Costs were estimated based on the specific technologies that were applied to improve 

each manufacturer’s fuel economy up to their achieved level under each alternative or fines that 
                                                      

 

 

11 

would be assessed. Table 5 provides the cost and fine estimates on an average per-vehicle basis 

(for MYs 2017 through 2025 only), and Tables 6 and 9 provide those estimates (including social 

costs and excluding fines) on a fleet-wide basis in millions of dollars at 3 and 7 percent discount 

rates, respectively, for all model years. Note that for fleet-wide estimates, the determination of 

whether the value associated with an individual line item (e.g., value of reduced fatalities -- see 

Executive Summary Tables 13 and 14 for a complete list of line items) for each model year is 

performed independently; this approach was employed to address the potential for certain line 

items to be positive (a benefit) in some model years and negative (a cost) in others. Due to this 

approach, the sum of social costs computed separately for the passenger car fleet and the light 

truck fleet may not be identical to the total social costs shown in Tables 13 and 14 for the 

combined fleet. These differences are not due to error or rounding; rather, they are consequences 

of instances in which a given line item is negative (a cost) for either of the two fleets in a given 

year and positive (a benefit) for the other fleet in the same year. The resulting offset manifests as 

a very slight difference in total social costs as seen in Tables 13 and 14. Total net benefits, 

however, are unaffected. 

Throughout this FRIA, the following conventions are applied to the presentation of costs: 

- Tables that exclusively present costs display all costs as positive values (e.g., Table 5 in 

the Executive Summary). 

- Tables that contain a mix of costs and benefits that are aggregated to a net or total value 

(e.g., Tables 13 and 14 in the Executive Summary) display costs as parenthesized values 

to aid the reader in following the summation logic. 

Benefits: Benefits are determined mainly from fuel savings over the lifetime of the vehicle, but 

include any line item (see Executive Summary Tables 13 and 14 for a complete list of line items) 

in which the rule is projected to result in a societal benefit. As noted above in the discussion of 

costs, due to this approach, the sum of social benefits computed separately for the passenger car 

fleet and the light truck fleet may not be identical to the total social benefits shown in Tables 13 

and 14 for the combined fleet. These differences are not due to error or rounding; rather, they 

are consequences of instances in which a given line item is positive (a benefit) for either of the 

two fleets in a given year and negative (a cost) for the other fleet in the same year. The resulting 

offset manifests as a very slight difference in total social benefits as seen in Tables 13 and 14. 

Total net benefits, however, are unaffected. The agency uses a 3 percent and 7 percent discount 

rate to value intra-generational future benefits and costs. Inter-generational8

 benefits from future 

carbon dioxide reductions are discounted at 3 percent in the main analysis, even when intragenerational benefits are discounted at 7 percent. Sensitivity analyses in Chapter X consider 

other inter-generational discount rates that accompany alternative estimates of the social cost of 

carbon. Table 7 provides those estimates on an industry-wide basis at a 3 percent discount rate 

8

 Inter-generational benefits, which include reductions in the expected future economic damages caused by increased 

global temperatures, a rise in sea levels, and other projected impacts of climate change, are anticipated to extend 

over a period from approximately fifty to two hundred or more years in the future, and will thus be experienced 

primarily by generations that are not now living. 
 

12 

and Table 10 provides the estimates at a 7 percent discount rate; both Tables 7 and 10 present 

estimates for model years 2011 through 2025. 

Net Benefits: Tables 8 and 11 compare total net benefits of each alternative at the 3 percent and 

7 percent discount rates, respectively, for model years 2011 through 2025. 

Liquid Fuel Savings: Tables 12a through 12c show the lifetime fuel savings in millions of 

gallons of liquid fuel, for model years 2011 through 2025. 

Change in Electricity Consumption: Tables 12d through 12f show the lifetime net change in 

electrical consumption, in gigawatt-hours, for model years 2011 through 2025. 
13 

Table 2 

Total Costs, Benefits, and Net Benefits

Passenger Cars and Light Trucks 

MYs 2011-2025 Combined 

(Millions of 2010 Dollars) 

Passenger Cars & Light Trucks Baseline Fleet 3% Discount Rate 7% Discount R

Costs Benefits Net Benefits Costs Benefits 

Preferred Alternative 2010 2008 ($154,266) - ($155,745) $629,730 - $638,957 $475,465 - $483,211 ($146,786) - ($148,074) $502,749 - $509,987 

2% Annual Increase 2010 2008 ($102,455) - ($93,872) $415,077 - $439,025 $312,622 - $345,152 ($97,193) ­ ($88,357) $330,940 - $350,058 3% Annual Increase 2010 2008 ($142,891) - ($134,011) $615,110 - $629,811 $472,218 - $495,800 ($135,603) - ($126,639) $490,527 - $502,208 4% Annual Increase 2010 2008 ($192,520) - ($188,182) $764,785 - $792,084 $572,264 - $603,903 ($183,713) - ($179,271) $610,071 - $631,640 5% Annual Increase 2010 2008 ($256,995) - ($256,852) $861,224 - $902,008 $604,229 - $645,156 ($246,447) - ($246,144) $686,890 - $719,081 6% Annual Increase 2010 2008 ($323,141) - ($347,730) $938,564 - $1,004,451 $615,422 - $656,720 ($310,804) - ($333,810) $748,347 - $800,259 7% Annual Increase 2010 2008 ($387,383) - ($417,165) $993,836 - $1,066,051 $606,453 - $648,886 ($373,215) - ($401,120) $792,351 - $849,296 Max Net Benefits 2010 2008 ($287,685) - ($315,127) $926,440 - $1,017,426 $638,755 - $702,299 ($249,132) - ($266,152) $712,807 - $767,897 Total Cost = Total Benefit 2010 2008 ($313,999) - ($365,437) $955,125 - $1,077,946 $641,125 - $712,509 ($302,120) - ($351,789) $761,720 - $858,888 
14 

Table 3a 

Alternative CAFE Levels 

Estimated Required Average for the Passenger Car Fleet, in mpg9

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 39.6 - 40.1 41.1 - 41.6 42.5 - 43.1 44.2 - 44.8 46.1 - 46.8 48.2 - 49.0 50.5 - 51.2 

2% Annual Increase 2010 2008 39.0 - 39.5 39.8 - 40.3 40.6 - 41.2 41.4 - 42.0 42.3 - 42.9 43.2 - 43.9 44.1 - 44.7 

3% Annual Increase 2010 2008 39.4 - 39.9 40.7 - 41.2 41.9 - 42.5 43.2 - 43.8 44.6 - 45.2 46.0 - 46.7 47.4 - 48.2 

4% Annual Increase 2010 2008 39.9 - 40.4 41.5 - 42.1 43.2 - 43.9 45.1 - 45.7 47.0 - 47.7 49.1 - 49.8 51.1 - 51.9 

5% Annual Increase 2010 2008 40.3 - 40.8 42.4 - 43.0 44.7 - 45.3 47.1 - 47.7 49.6 - 50.4 52.3 - 53.1 55.1 - 56.0 

6% Annual Increase 2010 2008 40.7 - 41.2 43.4 - 44.0 46.1 - 46.8 49.2 - 49.9 52.4 - 53.2 55.8 - 56.7 59.5 - 60.4 

7% Annual Increase 2010 2008 41.2 - 41.7 44.3 - 44.9 47.7 - 48.4 51.4 - 52.1 55.4 - 56.2 59.7 - 60.6 64.3 - 65.3 

Max Net Benefits (3% Discount Rate) 

2010 2008 

44.6 -

45.4 

46.9 -

47.5 

49.1 -

49.8 

50.6 -

51.4 

51.9 -

52.5 

52.8 -

53.6 

53.8 -

54.6 

Max Net Benefits (7% Discount Rate) 

2010 2008 

44.1 -

45.2 

46.0 -

47.1 

47.8 -

48.5 

49.6 -

50.0 

50.9 -

50.8 

51.7 -

51.1 

52.5 -

51.9 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

45.3 -

46.8 

47.2 -

48.8 

49.1 -

50.3 

50.6 -

52.1 

52.5 -

53.3 

54.1 -

55.5 

55.5 -

57.3 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

45.3 -

46.8 

47.2 -

48.8 

49.1 -

50.3 

50.6 -

52.1 

52.5 -

53.3 

54.1 -

55.5 

55.5 -

57.3 

9 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios. 

scenarios are not impacted by choice of discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both M

Cost = Total Benefit scenarios. 
15 

Table 3b 

Alternative CAFE Levels 

Estimated Required Average for the Light Truck Fleet, in mpg 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 29.1 - 29.4 29.6 - 30.0 30.0 - 30.6 30.6 - 31.2 32.6 - 33.3 34.2 - 34.9 35.8 - 36.6 

2% Annual Increase 2010 2008 29.7 - 30.1 30.3 - 30.8 30.9 - 31.5 31.5 - 32.1 32.2 - 32.8 32.8 - 33.5 33.5 - 34.2 

3% Annual Increase 2010 2008 29.9 - 30.3 30.9 - 31.4 31.9 - 32.5 32.9 - 33.5 33.9 - 34.6 35.0 - 35.7 36.1 - 36.9 

4% Annual Increase 2010 2008 30.2 - 30.6 31.6 - 32.1 32.9 - 33.6 34.3 - 34.9 35.8 - 36.5 37.3 - 38.1 38.9 - 39.8 

5% Annual Increase 2010 2008 30.5 - 30.9 32.2 - 32.8 34.0 - 34.7 35.8 - 36.4 37.7 - 38.5 39.8 - 40.6 42.0 - 42.9 

6% Annual Increase 2010 2008 30.8 - 31.2 32.9 - 33.4 35.1 - 35.8 37.4 - 38.1 39.8 - 40.6 42.5 - 43.4 45.3 - 46.3 

7% Annual Increase 2010 2008 31.1 - 31.6 33.6 - 34.2 36.3 - 37.0 39.1 - 39.8 42.1 - 43.0 45.4 - 46.3 49.0 - 50.1 

Max Net Benefits (3% Discount Rate) 

2010 2008 

32.0 -

35.7 

32.9 -

37.5 

35.3 -

39.3 

37.5 -

40.9 

40.9 -

42.2 

41.6 -

43.3 

42.5 -

43.9 

Max Net Benefits (7% Discount Rate) 

2010 2008 

32.0 -

35.0 

32.9 -

36.7 

35.1 -

38.6 

37.3 -

40.2 

40.3 -

41.5 

40.9 -

42.0 

41.8 -

42.3 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

32.3 -

36.1 

33.3 -

37.7 

35.3 -

39.5 

37.5 -

41.3 

41.2 -

42.6 

41.8 -

43.1 

42.7 -

44.1 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

32.3 -

36.1 

33.3 -

37.7 

35.3 -

39.5 

37.5 -

41.3 

41.2 -

42.6 

41.8 -

43.1 

42.7 -

44.1 
16 

Table 3c 

Alternative CAFE Levels 

Estimated Required Average for the Combined Fleet, in mpg 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 35.1 - 35.4 36.1 - 36.5 37.1 - 37.7 38.3 - 38.9 40.3 - 41.0 42.3 - 43.0 44.3 - 45.1 

2% Annual Increase 2010 2008 35.1 - 35.5 35.8 - 36.3 36.6 - 37.2 37.4 - 37.9 38.2 - 38.8 39.0 - 39.6 39.8 - 40.5 

3% Annual Increase 2010 2008 35.4 - 35.8 36.6 - 37.0 37.7 - 38.3 39.0 - 39.6 40.2 - 40.9 41.5 - 42.2 42.9 - 43.6 

4% Annual Increase 2010 2008 35.8 - 36.2 37.4 - 37.8 38.9 - 39.6 40.7 - 41.3 42.4 - 43.1 44.3 - 45.0 46.2 - 47.0 

5% Annual Increase 2010 2008 36.2 - 36.5 38.1 - 38.7 40.2 - 40.9 42.4 - 43.1 44.8 - 45.5 47.2 - 48.0 49.8 - 50.7 

6% Annual Increase 2010 2008 36.5 - 36.9 39.0 - 39.5 41.5 - 42.2 44.3 - 45.0 47.3 - 48.0 50.4 - 51.3 53.8 - 54.8 

7% Annual Increase 2010 2008 36.9 - 37.3 39.8 - 40.3 42.9 - 43.6 46.3 - 47.0 49.9 - 50.8 53.9 - 54.8 58.2 - 59.2 

Max Net Benefits (3% Discount Rate) 

2010 2008 

39.1 -

41.3 

40.8 -

43.4 

43.1 -

45.5 

45.1 -

47.1 

47.5 -

48.4 

48.3 -

49.5 

49.4 -

50.4 

Max Net Benefits (7% Discount Rate) 

2010 2008 

38.9 -

40.8 

40.3 -

42.7 

42.4 -

44.5 

44.5 -

46.1 

46.7 -

47.2 

47.4 -

47.6 

48.3 -

48.2 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

39.6 -

42.3 

41.1 -

44.1 

43.1 -

45.9 

45.1 -

47.7 

47.9 -

49.0 

49.2 -

50.5 

50.4 -

52.0 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

39.6 -

42.3 

41.1 -

44.1 

43.1 -

45.9 

45.1 -

47.7 

47.9 -

49.0 

49.2 -

50.5 

50.4 -

52.0 
17 

Table 3d 

Estimated Required Preferred Alternative CAFE Levels

Projected Required Average for the Fleet, in gallons per 100 miles 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Passenger Cars 2010 2008 2.5247 - 2.4936 2.4359 - 2.4043 2.3515 - 2.3190 2.2633 - 2.2313 2.1713 - 2.1385 2.0728 - 2.0424 1.9815 - 1.9517 

Light Trucks 2010 2008 3.4391 - 3.3969 3.3818 - 3.3307 3.3304 - 3.2683 3.2627 - 3.2064 3.0636 - 3.0019 2.9219 - 2.8657 2.7918 - 2.7308 

Combined 2010 2008 2.8485 - 2.8232 2.7703 - 2.7379 2.6966 - 2.6553 2.6109 - 2.5715 2.4788 - 2.4387 2.3631 - 2.3256 2.2555 - 2.2155 
18 

Table 4a 

Alternative CAFE Levels 

Projected Achieved Harmonic Average for the Passenger Car Fleet, in mpg10

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 202

Preferred Alternative 2010 2008 39.4 - 39.5 41.1 - 41.5 43.3 - 43.8 45.1 - 46.3 47.1 - 47.9 48.1 - 49.3 49.6 - 50.0 

2% Annual Increase 2010 2008 38.2 - 38.8 39.4 - 40.1 40.5 - 41.4 41.8 - 42.7 42.8 - 43.6 43.3 - 44.2 44.0 - 44.9 

3% Annual Increase 2010 2008 38.9 - 39.2 40.3 - 41.1 42.1 - 42.9 43.9 - 45.1 44.9 - 46.1 45.8 - 47.2 47.0 - 47.7 

4% Annual Increase 2010 2008 39.6 - 39.9 41.3 - 42.2 43.6 - 44.3 46.1 - 46.8 48.1 - 48.5 49.2 - 49.7 50.5 - 50.7 

5% Annual Increase 2010 2008 40.2 - 40.5 42.3 - 42.9 45.3 - 45.3 48.0 - 48.6 50.0 - 50.9 51.4 - 52.3 53.2 - 53.5 

6% Annual Increase 2010 2008 40.8 - 41.2 43.0 - 43.9 46.6 - 46.3 49.1 - 49.7 52.0 - 52.5 53.3 - 55.1 55.8 - 56.7 

7% Annual Increase 2010 2008 41.7 - 42.0 44.1 - 44.9 47.7 - 47.6 50.3 - 51.1 52.6 - 54.3 55.6 - 57.8 58.0 - 59.2 

Max Net Benefits (3% Discount Rate) 

2010 2008 

42.4 -

43.2 

44.1 -

45.1 

47.4 -

47.3 

49.6 -

49.7 

51.1 -

51.5 

52.1 -

52.2 

53.2 -

52.7 

Max Net Benefits (7% Discount Rate) 

2010 2008 

42.1 -

43.1 

43.7 -

44.6 

46.4 -

46.4 

48.7 -

48.4 

50.2 -

49.9 

50.8 -

50.6 

51.6 -

51.2 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

42.6 -

44.8 

44.2 -

46.4 

47.7 -

48.2 

49.9 -

50.8 

51.7 -

52.6 

52.9 -

53.8 

54.9 -

54.8 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

42.6 -

44.8 

44.2 -

46.4 

47.7 -

48.2 

49.9 -

50.8 

51.7 -

52.6 

52.9 -

53.8 

54.9 -

54.8 

10 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios

scenarios are not impacted by choice of discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both M

Cost = Total Benefit scenarios. 
19 

Table 4b 

Alternative CAFE Levels 

Projected Achieved Harmonic Average for the Light Truck Fleet, in mpg 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 28.8 - 29.3 29.3 - 30.3 31.3 - 31.9 32.8 - 33.3 34.9 - 35.2 35.5 - 36.1 36.5 - 36.8 

2% Annual Increase 2010 2008 29.8 - 30.0 30.2 - 30.7 31.4 - 31.9 32.3 - 32.8 32.9 - 33.8 33.3 - 34.3 33.8 - 34.6 

3% Annual Increase 2010 2008 30.2 - 30.5 30.7 - 31.4 32.3 - 33.3 33.9 - 34.7 35.3 - 36.1 36.0 - 36.8 36.9 - 37.4 

4% Annual Increase 2010 2008 30.2 - 31.0 31.1 - 32.2 32.9 - 34.6 34.9 - 36.4 36.9 - 38.1 37.6 - 38.9 38.6 - 39.9 

5% Annual Increase 2010 2008 30.5 - 31.3 31.3 - 32.9 33.7 - 35.8 36.2 - 38.4 38.7 - 40.3 39.6 - 41.4 41.4 - 42.5 

6% Annual Increase 2010 2008 30.8 - 31.9 31.8 - 33.5 34.1 - 36.5 36.8 - 39.9 39.5 - 42.0 40.6 - 43.4 42.4 - 44.3 

7% Annual Increase 2010 2008 31.1 - 32.2 32.2 - 34.1 34.7 - 37.2 37.8 - 40.2 40.5 - 42.8 41.4 - 44.2 43.1 - 45.6 

Max Net Benefits (3% Discount Rate) 

2010 2008 

31.2 -

34.0 

32.1 -

35.2 

34.3 -

37.5 

36.7 -

40.2 

39.1 -

42.1 

39.9 -

42.8 

41.3 -

43.6 

Max Net Benefits (7% Discount Rate) 

2010 2008 

31.3 -

33.8 

32.1 -

35.0 

34.3 -

37.4 

36.6 -

39.3 

38.9 -

41.0 

39.6 -

41.7 

41.1 -

42.2 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

31.4 -

34.2 

32.2 -

35.4 

34.2 -

37.8 

36.9 -

40.4 

39.4 -

42.3 

39.9 -

43.0 

41.3 -

43.9 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

31.4 -

34.2 

32.2 -

35.4 

34.2 -

37.8 

36.9 -

40.4 

39.4 -

42.3 

39.9 -

43.0 

41.3 -

43.9 
20 

Table 4c 

Alternative CAFE Levels 

 Projected Achieved Harmonic Average for the Combined Fleet, in mpg 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 34.8 - 35.0 36.0 - 36.6 38.2 - 38.7 39.9 - 40.8 42.0 - 42.6 42.9 - 43.8 44.2 - 44.6 

2% Annual Increase 2010 2008 34.7 - 35.0 35.6 - 36.1 36.7 - 37.5 37.9 - 38.6 38.8 - 39.6 39.2 - 40.2 39.9 - 40.8 

3% Annual Increase 2010 2008 35.3 - 35.5 36.3 - 37.0 38.0 - 38.9 39.8 - 40.8 41.1 - 42.1 41.9 - 43.0 43.0 - 43.7 

4% Annual Increase 2010 2008 35.7 - 36.1 37.0 - 38.0 39.1 - 40.3 41.5 - 42.6 43.6 - 44.3 44.5 - 45.4 45.7 - 46.5 

5% Annual Increase 2010 2008 36.1 - 36.6 37.6 - 38.7 40.4 - 41.4 43.1 - 44.5 45.4 - 46.6 46.7 - 48.0 48.5 - 49.2 

6% Annual Increase 2010 2008 36.6 - 37.2 38.2 - 39.5 41.2 - 42.3 44.0 - 45.8 46.9 - 48.3 48.1 - 50.4 50.4 - 51.8 

7% Annual Increase 2010 2008 37.2 - 37.8 39.0 - 40.3 42.1 - 43.4 45.1 - 46.7 47.7 - 49.7 49.7 - 52.3 51.9 - 53.8 

Max Net Benefits (3% Discount Rate) 

2010 2008 

37.6 -

39.3 

38.9 -

41.0 

41.8 -

43.3 

44.2 -

45.9 

46.2 -

47.8 

47.1 -

48.5 

48.5 -

49.2 

Max Net Benefits (7% Discount Rate) 

2010 2008 

37.5 -

39.2 

38.7 -

40.6 

41.2 -

42.8 

43.7 -

44.8 

45.6 -

46.4 

46.3 -

47.1 

47.5 -

47.8 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

37.8 -

40.2 

39.1 -

41.7 

41.9 -

43.9 

44.5 -

46.6 

46.7 -

48.5 

47.6 -

49.5 

49.4 -

50.6 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

37.8 -

40.2 

39.1 -

41.7 

41.9 -

43.9 

44.5 -

46.6 

46.7 -

48.5 

47.6 -

49.5 

49.4 -

50.6 
21 

Table 4d 

Preferred Alternative CAFE Levels 

 Projected Achieved Harmonic Average for the Fleet, in gallons per 100 miles 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Passenger Cars 2010 2008 2.5378 - 2.5332 2.4316 - 2.4083 2.3069 - 2.2815 2.2175 - 2.1579 2.1224 - 2.0870 2.0789 - 2.0301 2.0182 - 1.9985 1

Light Trucks 2010 2008 3.4751 - 3.4136 3.4105 - 3.3040 3.1968 - 3.1343 3.0481 - 3.0015 2.8684 - 2.8400 2.8167 - 2.7690 2.7405 - 2.7154 2

Combined 2010 2008 2.8697 - 2.8545 2.7776 - 2.7309 2.6207 - 2.5836 2.5064 - 2.4522 2.3794 - 2.3488 2.3311 - 2.2842 2.2624 - 2.2412 2
22 

Table 5a 

Average Incremental Technology Costs and Fines Per Vehicle11

Passenger Cars (2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $284 - $208 $424 - $377 $603 - $571 $762 - $837 $934 - $1,034 $1,024 - $1,168 $1,129 - $1,255 

2% Annual Increase 2010 2008 $130 - $125 $232 - $224 $333 - $322 $443 - $449 $546 - $529 $592 - $578 $638 - $631 

3% Annual Increase 2010 2008 $209 - $172 $317 - $330 $476 - $455 $608 - $656 $673 - $764 $755 - $865 $833 - $885 

4% Annual Increase 2010 2008 $346 - $255 $482 - $455 $693 - $623 $894 - $882 $1,062 - $1,064 $1,149 - $1,201 $1,246 - $1,332 

5% Annual Increase 2010 2008 $414 - $315 $592 - $550 $944 - $747 $1,208 - $1,196 $1,418 - $1,541 $1,579 - $1,723 $1,832 - $1,927 

6% Annual Increase 2010 2008 $453 - $453 $676 - $734 $1,108 - $933 $1,405 - $1,381 $1,866 - $1,887 $2,040 - $2,416 $2,700 - $2,761 

7% Annual Increase 2010 2008 $664 - $584 $959 - $979 $1,461 - $1,251 $1,688 - $1,712 $2,136 - $2,424 $3,048 - $3,275 $3,705 - $3,606 

Max Net Benefits (3% Discount Rate) 

2010 2008 

$774 -

$830 

$908 -

$981 

$1,373 -

$1,287 

$1,515 -

$1,525 

$1,634 -

$1,680 

$1,722 -

$1,710 

$1,831 -

$1,756 

Max Net Benefits (7% Discount Rate) 

2010 2008 

$696 -

$797 

$816 -

$899 

$1,048 -

$1,090 

$1,281 -

$1,265 

$1,427 -

$1,384 

$1,466 -

$1,408 

$1,522 -

$1,462 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

$804 -

$1,351 

$929 -

$1,422 

$1,485 -

$1,562 

$1,626 -

$1,775 

$1,849 -

$1,930 

$1,965 -

$2,069 

$2,325 -

$2,199 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

$804 -

$1,351 

$929 -

$1,422 

$1,485 -

$1,562 

$1,626 -

$1,775 

$1,849 -

$1,930 

$1,965 -

$2,069 

$2,325 -

$2,199 

11 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios

scenarios are not impacted by choice of discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both M

Cost = Total Benefit scenarios. 
23 

Table 5b 

Average Incremental Technology Costs and Fines Per Vehicle 

Light Trucks (2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $158 - $87 $187 - $179 $416 - $331 $596 - $470 $863 - $648 $911 - $752 $1,000 - $808 

2% Annual Increase 2010 2008 $376 - $133 $379 - $205 $457 - $280 $509 - $376 $555 - $449 $590 - $512 $626 - $524 

3% Annual Increase 2010 2008 $435 - $172 $445 - $258 $570 - $409 $739 - $583 $876 - $706 $928 - $777 $996 - $820 

4% Annual Increase 2010 2008 $468 - $280 $526 - $399 $679 - $635 $917 - $864 $1,071 - $1,083 $1,163 - $1,166 $1,247 - $1,255 

5% Annual Increase 2010 2008 $489 - $363 $568 - $534 $870 - $851 $1,334 - $1,301 $1,667 - $1,567 $1,819 - $1,792 $2,004 - $1,906 

6% Annual Increase 2010 2008 $542 - $506 $639 - $704 $1,012 - $1,057 $1,507 - $1,770 $1,960 - $2,046 $2,132 - $2,320 $2,371 - $2,462 

7% Annual Increase 2010 2008 $670 - $535 $797 - $801 $1,191 - $1,240 $1,805 - $1,907 $2,178 - $2,339 $2,361 - $2,685 $2,641 - $3,144 

Max Net Benefits (3% Discount Rate) 

2010 2008 

$756 -

$1,070 

$798 -

$1,167 

$1,130 -

$1,370 

$1,481 -

$1,990 

$1,780 -

$2,175 

$1,860 -

$2,237 

$2,011 -

$2,315 

Max Net Benefits (7% Discount Rate) 

2010 2008 

$755 -

$1,019 

$788 -

$1,121 

$1,106 -

$1,320 

$1,438 -

$1,692 

$1,726 -

$1,873 

$1,811 -

$1,915 

$1,939 -

$1,927 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

$791 -

$1,144 

$827 -

$1,221 

$1,081 -

$1,427 

$1,574 -

$2,076 

$1,855 -

$2,265 

$1,907 -

$2,338 

$2,054 -

$2,447 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

$791 -

$1,144 

$827 -

$1,221 

$1,081 -

$1,427 

$1,574 -

$2,076 

$1,855 -

$2,265 

$1,907 -

$2,338 

$2,054 -

$2,447 
24 

Table 5c 

Average Incremental Technology Costs and Fines Per Vehicle 

Passenger Cars and Light Trucks Combined (2010 Dollars) 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $239 - $164 $340 - $306 $537 - $486 $704 - $709 $909 - $900 $985 - $1,025 $1,085 - $1,104 

2% Annual Increase 2010 2008 $217 - $128 $284 - $217 $377 - $308 $466 - $423 $549 - $501 $591 - $555 $634 - $595 

3% Annual Increase 2010 2008 $289 - $172 $362 - $304 $509 - $439 $653 - $630 $743 - $744 $814 - $834 $888 - $863 

4% Annual Increase 2010 2008 $389 - $264 $497 - $435 $688 - $627 $902 - $875 $1,065 - $1,071 $1,154 - $1,189 $1,246 - $1,306 

5% Annual Increase 2010 2008 $441 - $333 $583 - $545 $918 - $784 $1,252 - $1,233 $1,504 - $1,550 $1,661 - $1,747 $1,890 - $1,920 

6% Annual Increase 2010 2008 $485 - $472 $663 - $723 $1,074 - $977 $1,440 - $1,516 $1,899 - $1,942 $2,071 - $2,383 $2,589 - $2,660 

7% Annual Increase 2010 2008 $666 - $566 $902 - $915 $1,366 - $1,247 $1,729 - $1,780 $2,150 - $2,395 $2,813 - $3,072 $3,345 - $3,450 

Max Net Benefits (3% Discount Rate) 

2010 2008 

$767 -

$918 

$869 -

$1,048 

$1,287 -

$1,316 

$1,503 -

$1,687 

$1,684 -

$1,852 

$1,769 -

$1,891 

$1,892 -

$1,945 

Max Net Benefits (7% Discount Rate) 

2010 2008 

$717 -

$878 

$806 -

$979 

$1,068 -

$1,172 

$1,336 -

$1,414 

$1,530 -

$1,554 

$1,584 -

$1,582 

$1,663 -

$1,619 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

$799 -

$1,276 

$893 -

$1,349 

$1,343 -

$1,514 

$1,608 -

$1,880 

$1,851 -

$2,046 

$1,945 -

$2,162 

$2,234 -

$2,283 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

$799 -

$1,276 

$893 -

$1,349 

$1,343 -

$1,514 

$1,608 -

$1,880 

$1,851 -

$2,046 

$1,945 -

$2,162 

$2,234 -

$2,283 
25 

Table 6a 

Incremental Total Costs by Societal Perspective12, by Alternative 

Passenger Cars, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $5,736 ­ $4,252 $3,491 ­ $2,607 $5,168 ­ $4,683 $7,638 ­ $7,291 $9,601 ­ $10,810 $12,106 ­ $13,242 $13,430 ­ $15,277 $15,119 ­ $16,605 

2% Annual Increase 2010 2008 $2,345 ­ $2,777 $1,605 ­ $1,607 $2,803 ­ $2,859 $4,270 ­ $4,244 $5,803 ­ $6,007 $7,217 ­ $7,131 $8,036 ­ $8,071 $9,060 ­ $9,116 3% Annual Increase 2010 2008 $6,762 ­ $5,823 $2,606 ­ $2,180 $3,894 ­ $4,167 $6,079 ­ $5,916 $7,922 ­ $8,674 $8,907 ­ $10,121 $10,167 ­ $11,685 $11,645 ­ $12,362 4% Annual Increase 2010 2008 $10,997 ­ $8,332 $4,164 ­ $3,145 $5,761 ­ $5,595 $8,574 ­ $7,791 $11,189 ­ $11,269 $13,569 ­ $13,639 $14,852 ­ $15,612 $16,440 ­ $17,455 5% Annual Increase 2010 2008 $7,785 ­ $6,809 $5,012 ­ $3,842 $7,065 ­ $6,644 $11,417 ­ $9,169 $14,716 ­ $14,620 $17,395 ­ $18,733 $19,669 ­ $21,332 $22,848 ­ $24,232 6% Annual Increase 2010 2008 $8,399 ­ $9,895 $5,531 ­ $5,361 $8,018 ­ $8,602 $13,240 ­ $11,105 $16,863 ­ $16,597 $22,173 ­ $22,413 $24,372 ­ $29,313 $31,536 ­ $34,180 7% Annual Increase 2010 2008 $13,565 ­ $13,078 $7,847 ­ $6,806 $10,987 ­ $11,131 $16,890 ­ $14,395 $19,740 ­ $20,165 $24,429 ­ $28,395 $34,527 ­ $39,071 $42,017 ­ $43,210 Max Net Benefits 2010 2008 $16,908 ­ $17,814 $8,895 ­ $9,396 $10,319 ­ $11,118 $15,851 ­ $14,538 $17,866 ­ $17,970 $19,681 ­ $20,307 $21,194 ­ $21,259 $23,039 ­ $22,387 Total Cost = Total Benefit 2010 2008 $17,641 ­ $23,750 $9,126 ­ $14,897 $10,572 ­ $15,664 $17,021 ­ $17,382 $19,073 ­ $20,695 $21,891 ­ $23,075 $23,719 ­ $25,237 $28,568 ­ $27,487 

12 “Societal perspective” includes technology costs and societal costs, but does not include payment of civil penalties by manufacturers 

the CAFE standards. 
26 

Table 6b 

Incremental Total Costs by Societal Perspective, by Alternative 

Light Trucks, 3% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $1,862 ­ $493 $1,056 ­ $644 $1,255 ­ $1,385 $2,889 ­ $2,543 $3,977 ­ $3,608 $5,781 ­ $4,925 $6,227 ­ $5,717 $6,895 ­ $6,130 

2% Annual Increase 2010 2008 $5,809 ­ $1,743 $2,477 ­ $1,055 $2,495 ­ $1,624 $3,122 ­ $2,204 $3,430 ­ $2,992 $3,769 ­ $3,563 $4,112 ­ $4,051 $4,463 ­ $4,146 3% Annual Increase 2010 2008 $6,651 ­ $1,956 $2,885 ­ $1,374 $2,957 ­ $2,050 $3,856 ­ $3,160 $4,975 ­ $4,432 $5,921 ­ $5,342 $6,347 ­ $5,941 $7,041 ­ $6,280 4% Annual Increase 2010 2008 $7,007 ­ $2,600 $3,083 ­ $2,104 $3,465 ­ $3,008 $4,535 ­ $4,648 $6,070 ­ $6,273 $7,182 ­ $7,697 $7,751 ­ $8,330 $8,531 ­ $8,945 5% Annual Increase 2010 2008 $6,880 ­ $3,555 $3,241 ­ $2,641 $3,736 ­ $3,869 $5,658 ­ $6,019 $8,474 ­ $8,965 $10,564 ­ $10,708 $11,527 ­ $12,190 $12,974 ­ $12,887 6% Annual Increase 2010 2008 $7,734 ­ $6,351 $3,601 ­ $3,552 $4,187 ­ $4,906 $6,414 ­ $7,208 $9,364 ­ $11,731 $12,128 ­ $13,622 $13,139 ­ $15,423 $14,617 ­ $16,199 7% Annual Increase 2010 2008 $8,676 ­ $6,717 $4,340 ­ $3,765 $5,092 ­ $5,544 $7,419 ­ $8,306 $11,036 ­ $12,508 $13,212 ­ $15,351 $14,138 ­ $17,401 $15,486 ­ $19,411 Max Net Benefits 2010 2008 $10,852 ­ $16,621 $4,747 ­ $6,982 $5,094 ­ $7,671 $7,052 ­ $8,903 $9,232 ­ $12,788 $10,967 ­ $14,149 $11,609 ­ $14,686 $12,811 ­ $15,253 Total Cost = Total Benefit 2010 2008 $11,022 ­ $17,325 $4,930 ­ $7,383 $5,269 ­ $7,996 $6,807 ­ $9,232 $9,707 ­ $13,367 $11,357 ­ $14,762 $11,809 ­ $15,378 $12,980 ­ $16,105 
27 

Table 6c 

Incremental Total Costs by Societal Perspective, by Alternative 

Passenger Cars and Light Trucks Combined, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $7,598 ­ $4,745 $4,547 ­ $3,251 $6,423 ­ $6,067 $10,528 ­ $9,834 $13,578 ­ $14,417 $17,887 ­ $18,167 $19,657 ­ $20,994 $22,013 ­ $22,735 

2% Annual Increase 2010 2008 $8,154 ­ $4,520 $4,082 ­ $2,662 $5,298 ­ $4,484 $7,392 ­ $6,449 $9,232 ­ $8,999 $10,987 ­ $10,694 $12,148 ­ $12,122 $13,523 ­ $13,262 3% Annual Increase 2010 2008 $13,413 ­ $7,779 $5,490 ­ $3,554 $6,851 ­ $6,218 $9,935 ­ $9,076 $12,897 ­ $13,106 $14,828 ­ $15,463 $16,514 ­ $17,626 $18,686 ­ $18,642 4% Annual Increase 2010 2008 $18,004 ­ $10,932 $7,247 ­ $5,249 $9,227 ­ $8,603 $13,109 ­ $12,439 $17,259 ­ $17,541 $20,751 ­ $21,336 $22,603 ­ $23,942 $24,971 ­ $26,400 5% Annual Increase 2010 2008 $14,665 ­ $10,364 $8,253 ­ $6,483 $10,801 ­ $10,513 $17,075 ­ $15,188 $23,190 ­ $23,586 $27,959 ­ $29,440 $31,196 ­ $33,521 $35,822 ­ $37,119 6% Annual Increase 2010 2008 $16,133 ­ $16,246 $9,132 ­ $8,913 $12,205 ­ $13,509 $19,654 ­ $18,313 $26,228 ­ $28,328 $34,301 ­ $36,035 $37,511 ­ $44,736 $46,152 ­ $50,379 7% Annual Increase 2010 2008 $22,241 ­ $19,795 $12,187 ­ $10,571 $16,079 ­ $16,674 $24,309 ­ $22,701 $30,777 ­ $32,672 $37,641 ­ $43,746 $48,665 ­ $56,472 $57,503 ­ $62,621 Max Net Benefits 2010 2008 $27,760 ­ $34,435 $13,641 ­ $16,379 $15,412 ­ $18,788 $22,904 ­ $23,441 $27,098 ­ $30,758 $30,647 ­ $34,455 $32,803 ­ $35,945 $35,850 ­ $37,640 Total Cost = Total Benefit 2010 2008 $28,663 ­ $41,075 $14,056 ­ $22,281 $15,841 ­ $23,660 $23,828 ­ $26,614 $28,780 ­ $34,062 $33,248 ­ $37,837 $35,528 ­ $40,615 $41,548 ­ $43,592 
28 

Table 7a 

Present Value of Lifetime Societal Benefits13, by Alternative 

Passenger Cars, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $21,819 - $19,735 $12,907 - $10,806 $18,736 - $18,668 $28,873 - $27,786 $35,979 - $38,398 $44,882 - $45,214 $49,850 - $51,915 $56,963 - $56,756 

2% Annual Increase 2010 2008 $9,462 - $12,652 $5,837 - $6,938 $9,334 - $11,448 $14,408 - $15,901 $20,483 - $21,837 $25,159 - $25,879 $28,024 - $29,368 $32,250 - $33,833 3% Annual Increase 2010 2008 $26,039 - $27,205 $9,919 - $9,455 $14,567 - $16,773 $22,637 - $23,710 $30,754 - $33,073 $35,437 - $37,947 $39,941 - $43,515 $46,372 - $47,564 4% Annual Increase 2010 2008 $37,891 - $38,216 $13,906 - $13,355 $19,540 - $22,085 $29,969 - $29,907 $39,996 - $40,478 $48,846 - $47,604 $53,826 - $53,705 $60,116 - $59,242 5% Annual Increase 2010 2008 $28,921 - $31,883 $17,365 - $16,047 $24,279 - $25,387 $36,863 - $34,222 $47,250 - $46,910 $55,294 - $55,843 $60,933 - $61,541 $67,990 - $67,320 6% Annual Increase 2010 2008 $32,559 - $38,402 $20,141 - $19,577 $27,546 - $29,371 $41,832 - $37,952 $50,211 - $50,491 $59,960 - $59,418 $65,225 - $68,535 $73,709 - $75,196 7% Annual Increase 2010 2008 $41,692 - $46,171 $24,124 - $23,157 $32,035 - $33,353 $45,415 - $42,565 $53,534 - $54,400 $61,517 - $63,139 $70,425 - $73,626 $77,671 - $79,531 Max Net Benefits 2010 2008 $51,991 - $62,497 $27,812 - $28,457 $32,030 - $33,766 $44,228 - $40,246 $51,352 - $49,366 $57,354 - $56,328 $61,814 - $60,264 $67,230 - $64,227 Total Cost = Total Benefit 2010 2008 $54,272 - $73,670 $28,621 - $34,195 $32,625 - $38,340 $45,037 - $43,337 $52,566 - $52,880 $58,957 - $59,629 $64,273 - $65,194 $71,657 - $70,606 

13 These benefits are considered from a “societal perspective” because they include externalities. They are distinguished from a consum

consumers generally would not think about the value of carbon dioxide, energy security, etc. Table 7 includes only social benefits; soc

Table 6. 
29 

Table 7b 

Present Value of Lifetime Societal Benefits, by Alternative 

Light Trucks, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $7,245 - $2,676 $4,388 - $3,430 $5,868 - $7,976 $14,954 - $14,829 $19,870 - $21,498 $27,579 - $29,219 $30,592 - $33,374 $34,742 - $36,035 

2% Annual Increase 2010 2008 $21,081 - $13,015 $9,939 - $7,528 $10,723 - $10,510 $15,393 - $14,918 $17,403 - $19,141 $19,356 - $22,746 $21,270 - $25,347 $23,726 - $26,818 3% Annual Increase 2010 2008 $24,986 - $15,860 $11,983 - $10,205 $13,299 - $14,101 $19,689 - $21,375 $24,595 - $27,770 $29,699 - $33,034 $32,616 - $36,078 $36,653 - $38,540 4% Annual Increase 2010 2008 $25,361 - $18,658 $12,424 - $13,062 $15,080 - $18,041 $22,708 - $27,140 $28,976 - $34,540 $35,597 - $40,576 $38,631 - $43,886 $42,757 - $47,289 5% Annual Increase 2010 2008 $25,809 - $21,615 $13,587 - $14,886 $16,288 - $21,130 $25,710 - $31,711 $32,799 - $41,217 $40,027 - $47,024 $43,494 - $50,923 $49,223 - $54,129 6% Annual Increase 2010 2008 $30,559 - $30,047 $15,518 - $17,355 $18,317 - $23,627 $27,050 - $34,101 $34,537 - $44,752 $42,482 - $50,979 $46,264 - $55,322 $51,805 - $57,468 7% Annual Increase 2010 2008 $31,708 - $33,096 $16,678 - $18,772 $19,817 - $26,200 $29,088 - $36,181 $37,251 - $45,423 $44,825 - $52,959 $48,012 - $57,010 $53,251 - $60,351 Max Net Benefits 2010 2008 $33,809 - $54,484 $16,794 - $26,116 $19,135 - $29,996 $27,735 - $36,862 $34,273 - $45,119 $41,705 - $51,142 $44,660 - $53,847 $49,478 - $56,135 Total Cost = Total Benefit 2010 2008 $35,474 - $55,377 $17,491 - $26,847 $19,733 - $30,611 $27,100 - $37,631 $34,841 - $45,375 $42,388 - $51,005 $44,579 - $53,652 $49,320 - $56,245 
30 

Table 7c 

Present Value of Lifetime Societal Benefits, by Alternative 

Passenger Cars and Light Trucks Combined, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $29,064 - $22,410 $17,295 - $14,236 $24,604 - $26,644 $43,827 - $42,615 $55,849 - $59,896 $72,461 - $74,433 $80,442 - $85,289 $91,704 - $92,791 

2% Annual Increase 2010 2008 $30,543 - $25,666 $15,776 - $14,466 $20,057 - $21,959 $29,801 - $30,818 $37,885 - $40,978 $44,515 - $48,625 $49,295 - $54,715 $55,976 - $60,651 3% Annual Increase 2010 2008 $51,025 - $43,064 $21,903 - $19,660 $27,865 - $30,874 $42,325 - $45,085 $55,349 - $60,842 $65,136 - $70,981 $72,558 - $79,593 $83,025 - $86,103 4% Annual Increase 2010 2008 $63,253 - $56,874 $26,329 - $26,416 $34,620 - $40,126 $52,677 - $57,046 $68,972 - $75,018 $84,442 - $88,180 $92,457 - $97,592 $102,873 - $106,531 5% Annual Increase 2010 2008 $54,730 - $53,498 $30,952 - $30,933 $40,567 - $46,517 $62,573 - $65,934 $80,049 - $88,128 $95,321 - $102,867 $104,428 - $112,464 $117,213 - $121,449 6% Annual Increase 2010 2008 $63,119 - $68,449 $35,659 - $36,932 $45,863 - $52,998 $68,882 - $72,053 $84,748 - $95,243 $102,443 - $110,396 $111,490 - $123,857 $125,514 - $132,664 7% Annual Increase 2010 2008 $73,400 - $79,267 $40,802 - $41,930 $51,851 - $59,554 $74,502 - $78,747 $90,785 - $99,823 $106,342 - $116,098 $118,436 - $130,637 $130,922 - $139,882 Max Net Benefits 2010 2008 $85,800 - $116,981 $44,606 - $54,573 $51,165 - $63,762 $71,963 - $77,108 $85,625 - $94,485 $99,059 - $107,470 $106,475 - $114,111 $116,708 - $120,362 Total Cost = Total Benefit 2010 2008 $89,747 - $129,048 $46,113 - $61,043 $52,359 - $68,950 $72,137 - $80,968 $87,407 - $98,254 $101,345 - $110,633 $108,852 - $118,846 $120,977 - $126,851 
31 

Table 8a 

Present Value of Net Total Benefits14 by Alternative 

Passenger Cars, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $16,084 - $15,483 $9,416 - $8,199 $13,568 - $13,985 $21,234 - $20,495 $26,378 - $27,589 $32,776 - $31,972 $36,420 - $36,638 $41,844 - $40,151 

2% Annual Increase 2010 2008 $7,117 - $9,874 $4,232 - $5,331 $6,531 - $8,589 $10,138 - $11,656 $14,680 - $15,830 $17,942 - $18,749 $19,989 - $21,298 $23,190 - $24,718 3% Annual Increase 2010 2008 $19,277 - $21,381 $7,314 - $7,275 $10,673 - $12,606 $16,558 - $17,794 $22,832 - $24,399 $26,530 - $27,826 $29,774 - $31,830 $34,727 - $35,202 4% Annual Increase 2010 2008 $26,894 - $29,883 $9,742 - $10,209 $13,778 - $16,490 $21,395 - $22,116 $28,807 - $29,209 $35,276 - $33,965 $38,974 - $38,093 $43,676 - $41,787 5% Annual Increase 2010 2008 $21,136 - $25,074 $12,354 - $12,205 $17,214 - $18,744 $25,446 - $25,053 $32,535 - $32,290 $37,898 - $37,110 $41,265 - $40,209 $45,142 - $43,088 6% Annual Increase 2010 2008 $24,160 - $28,507 $14,610 - $14,216 $19,528 - $20,769 $28,592 - $26,847 $33,347 - $33,894 $37,787 - $37,005 $40,853 - $39,222 $42,173 - $41,017 7% Annual Increase 2010 2008 $28,128 - $33,093 $16,277 - $16,351 $21,048 - $22,223 $28,525 - $28,170 $33,794 - $34,235 $37,088 - $34,744 $35,898 - $34,555 $35,654 - $36,321 Max Net Benefits 2010 2008 $35,083 - $44,682 $18,917 - $19,061 $21,712 - $22,648 $28,376 - $25,708 $33,486 - $31,396 $37,674 - $36,022 $40,620 - $39,004 $44,191 - $41,840 Total Cost = Total Benefit 2010 2008 $36,631 - $49,921 $19,495 - $19,298 $22,054 - $22,676 $28,016 - $25,954 $33,493 - $32,184 $37,066 - $36,553 $40,554 - $39,957 $43,089 - $43,119 

14 This table is from a societal perspective, thus, civil penalties are deleted from the costs because they are a transfer payment (from ma

Treasury). 
32 

Table 8b 

Present Value of Net Total Benefits by Alternative 

Light Trucks, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $5,383 - $2,183 $3,332 - $2,786 $4,613 - $6,591 $12,064 - $12,286 $15,893 - $17,890 $21,798 - $24,294 $24,365 - $27,657 $27,847 - $29,905 

2% Annual Increase 2010 2008 $15,272 - $11,272 $7,462 - $6,473 $8,228 - $8,886 $12,270 - $12,713 $13,973 - $16,150 $15,587 - $19,183 $17,158 - $21,296 $19,264 - $22,671 3% Annual Increase 2010 2008 $18,335 - $13,904 $9,099 - $8,830 $10,342 - $12,051 $15,833 - $18,215 $19,619 - $23,337 $23,778 - $27,692 $26,270 - $30,138 $29,612 - $32,260 4% Annual Increase 2010 2008 $18,355 - $16,058 $9,340 - $10,957 $11,614 - $15,033 $18,173 - $22,492 $22,906 - $28,268 $28,415 - $32,879 $30,879 - $35,556 $34,226 - $38,344 5% Annual Increase 2010 2008 $18,929 - $18,060 $10,346 - $12,245 $12,552 - $17,261 $20,052 - $25,692 $24,325 - $32,252 $29,464 - $36,316 $31,968 - $38,733 $36,249 - $41,242 6% Annual Increase 2010 2008 $22,825 - $23,696 $11,917 - $13,803 $14,130 - $18,720 $20,636 - $26,893 $25,173 - $33,021 $30,354 - $37,356 $33,126 - $39,899 $37,188 - $41,269 7% Annual Increase 2010 2008 $23,032 - $26,379 $12,338 - $15,007 $14,724 - $20,657 $21,669 - $27,875 $26,214 - $32,915 $31,613 - $37,608 $33,874 - $39,609 $37,765 - $40,940 Max Net Benefits 2010 2008 $22,957 - $37,863 $12,048 - $19,134 $14,041 - $22,325 $20,683 - $27,959 $25,041 - $32,331 $30,738 - $36,993 $33,051 - $39,161 $36,667 - $40,882 Total Cost = Total Benefit 2010 2008 $24,453 - $38,052 $12,561 - $19,464 $14,464 - $22,615 $20,294 - $28,399 $25,134 - $32,008 $31,031 - $36,242 $32,770 - $38,274 $36,340 - $40,140 
33 

Table 8c 

Present Value of Net Total Benefits by Alternative 

Passenger Cars and Light Trucks Combined, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $21,466 - $17,666 $12,748 - $10,986 $18,181 - $20,576 $33,299 - $32,781 $42,271 - $45,479 $54,574 - $56,266 $60,785 - $64,295 $69,691 - $70,056 

2% Annual Increase 2010 2008 $22,389 - $21,146 $11,693 - $11,804 $14,759 - $17,475 $22,408 - $24,370 $28,653 - $31,980 $33,528 - $37,931 $37,147 - $42,594 $42,453 - $47,389 3% Annual Increase 2010 2008 $37,613 - $35,285 $16,413 - $16,106 $21,015 - $24,656 $32,391 - $36,009 $42,452 - $47,736 $50,308 - $55,519 $56,044 - $61,967 $64,339 - $67,462 4% Annual Increase 2010 2008 $45,249 - $45,941 $19,082 - $21,167 $25,393 - $31,523 $39,568 - $44,607 $51,713 - $57,477 $63,691 - $66,844 $69,853 - $73,649 $77,902 - $80,131 5% Annual Increase 2010 2008 $40,065 - $43,134 $22,700 - $24,450 $29,766 - $36,004 $45,498 - $50,746 $56,859 - $64,542 $67,362 - $73,426 $73,232 - $78,942 $81,391 - $84,330 6% Annual Increase 2010 2008 $46,986 - $52,203 $26,527 - $28,019 $33,658 - $39,489 $49,227 - $53,740 $58,520 - $66,915 $68,141 - $74,362 $73,979 - $79,121 $79,361 - $82,285 7% Annual Increase 2010 2008 $51,159 - $59,472 $28,616 - $31,358 $35,773 - $42,879 $50,194 - $56,046 $60,008 - $67,150 $68,701 - $72,352 $69,772 - $74,164 $73,418 - $77,262 Max Net Benefits 2010 2008 $58,040 - $82,546 $30,965 - $38,194 $35,753 - $44,974 $49,059 - $53,667 $58,527 - $63,727 $68,412 - $73,015 $73,671 - $78,165 $80,858 - $82,722 Total Cost = Total Benefit 2010 2008 $61,084 - $87,973 $32,057 - $38,762 $36,517 - $45,290 $48,309 - $54,354 $58,627 - $64,192 $68,098 - $72,796 $73,324 - $78,231 $79,429 - $83,259 
34 

Table 9a 

Incremental Total Costs by Societal Perspective15, by Alternative 

Passenger Cars, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $5,498 ­ $4,044 $3,355 ­ $2,477 $4,965 ­ $4,447 $7,281 ­ $6,906 $9,168 ­ $10,289 $11,514 ­ $12,655 $12,753 ­ $14,595 $14,324 ­ $15,851 

2% Annual Increase 2010 2008 $2,243 ­ $2,644 $1,540 ­ $1,516 $2,696 ­ $2,702 $4,062 ­ $3,994 $5,502 ­ $5,682 $6,856 ­ $6,761 $7,602 ­ $7,630 $8,526 ­ $8,604 3% Annual Increase 2010 2008 $6,478 ­ $5,519 $2,499 ­ $2,063 $3,733 ­ $3,944 $5,783 ­ $5,578 $7,514 ­ $8,222 $8,441 ­ $9,621 $9,617 ­ $11,102 $10,957 ­ $11,714 4% Annual Increase 2010 2008 $10,587 ­ $7,919 $4,016 ­ $2,995 $5,551 ­ $5,323 $8,197 ­ $7,395 $10,686 ­ $10,734 $12,930 ­ $13,029 $14,136 ­ $14,912 $15,614 ­ $16,674 5% Annual Increase 2010 2008 $7,470 ­ $6,473 $4,827 ­ $3,664 $6,803 ­ $6,339 $10,946 ­ $8,722 $14,099 ­ $14,004 $16,667 ­ $18,020 $18,814 ­ $20,498 $21,872 ­ $23,271 6% Annual Increase 2010 2008 $8,043 ­ $9,494 $5,316 ­ $5,147 $7,721 ­ $8,251 $12,717 ­ $10,624 $16,184 ­ $15,934 $21,335 ­ $21,596 $23,434 ­ $28,209 $30,356 ­ $32,833 7% Annual Increase 2010 2008 $13,115 ­ $12,596 $7,591 ­ $6,557 $10,642 ­ $10,734 $16,313 ­ $13,847 $19,019 ­ $19,415 $23,575 ­ $27,366 $33,324 ­ $37,574 $40,488 ­ $41,534 Max Net Benefits 2010 2008 $14,783 ­ $16,835 $7,784 ­ $8,700 $9,029 ­ $9,797 $11,891 ­ $11,923 $14,665 ­ $14,443 $16,635 ­ $16,294 $17,461 ­ $17,112 $18,539 ­ $18,246 Total Cost = Total Benefit 2010 2008 $17,050 ­ $22,974 $8,822 ­ $14,398 $10,222 ­ $15,128 $16,421 ­ $16,764 $18,352 ­ $19,928 $21,059 ­ $22,191 $22,786 ­ $24,248 $27,436 ­ $26,401 

15 “Societal perspective” includes technology costs and societal costs, but does not include civil penalties. 
35 

Table 9b 

Incremental Total Costs by Societal Perspective, by Alternative 

Light Trucks, 7% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $1,798 ­ $471 $1,019 ­ $612 $1,207 ­ $1,298 $2,759 ­ $2,381 $3,817 ­ $3,380 $5,534 ­ $4,640 $5,940 ­ $5,386 $6,559 ­ $5,774 

2% Annual Increase 2010 2008 $5,633 ­ $1,639 $2,394 ­ $992 $2,407 ­ $1,517 $2,990 ­ $2,055 $3,283 ­ $2,784 $3,600 ­ $3,330 $3,908 ­ $3,791 $4,218 ­ $3,878 3% Annual Increase 2010 2008 $6,441 ­ $1,828 $2,783 ­ $1,289 $2,846 ­ $1,915 $3,687 ­ $2,957 $4,761 ­ $4,161 $5,649 ­ $5,037 $6,036 ­ $5,592 $6,665 ­ $5,906 4% Annual Increase 2010 2008 $6,794 ­ $2,447 $2,979 ­ $1,995 $3,340 ­ $2,832 $4,343 ­ $4,389 $5,824 ­ $5,937 $6,860 ­ $7,340 $7,392 ­ $7,936 $8,118 ­ $8,510 5% Annual Increase 2010 2008 $6,665 ­ $3,381 $3,127 ­ $2,519 $3,601 ­ $3,670 $5,437 ­ $5,720 $8,165 ­ $8,563 $10,169 ­ $10,280 $11,082 ­ $11,705 $12,447 ­ $12,370 6% Annual Increase 2010 2008 $7,480 ­ $6,108 $3,472 ­ $3,410 $4,036 ­ $4,686 $6,183 ­ $6,899 $9,046 ­ $11,261 $11,710 ­ $13,105 $12,667 ­ $14,835 $14,069 ­ $15,587 7% Annual Increase 2010 2008 $8,413 ­ $6,450 $4,201 ­ $3,613 $4,925 ­ $5,300 $7,165 ­ $7,973 $10,665 ­ $12,041 $12,753 ­ $14,821 $13,628 ­ $16,797 $14,898 ­ $18,758 Max Net Benefits 2010 2008 $10,504 ­ $15,549 $4,610 ­ $6,512 $4,885 ­ $7,129 $6,688 ­ $8,250 $8,670 ­ $10,622 $10,343 ­ $11,891 $10,919 ­ $12,296 $11,989 ­ $12,433 Total Cost = Total Benefit 2010 2008 $10,728 ­ $16,880 $4,785 ­ $7,150 $5,107 ­ $7,718 $6,570 ­ $8,884 $9,369 ­ $12,872 $10,951 ­ $14,218 $11,378 ­ $14,797 $12,481 ­ $15,499 
36 

Table 9c 

Incremental Total Costs by Societal Perspective, by Alternative 

Passenger Cars and Light Trucks Combined, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $7,297 ­ $4,515 $4,373 ­ $3,089 $6,172 ­ $5,745 $10,040 ­ $9,286 $12,985 ­ $13,669 $17,047 ­ $17,295 $18,693 ­ $19,981 $20,883 ­ $21,625 

2% Annual Increase 2010 2008 $7,876 ­ $4,283 $3,934 ­ $2,508 $5,103 ­ $4,219 $7,053 ­ $6,049 $8,786 ­ $8,466 $10,456 ­ $10,092 $11,510 ­ $11,420 $12,745 ­ $12,482 3% Annual Increase 2010 2008 $12,919 ­ $7,347 $5,283 ­ $3,351 $6,578 ­ $5,859 $9,470 ­ $8,535 $12,275 ­ $12,383 $14,090 ­ $14,657 $15,653 ­ $16,694 $17,622 ­ $17,620 4% Annual Increase 2010 2008 $17,381 ­ $10,366 $6,994 ­ $4,990 $8,891 ­ $8,155 $12,540 ­ $11,784 $16,510 ­ $16,670 $19,790 ­ $20,369 $21,528 ­ $22,847 $23,732 ­ $25,184 5% Annual Increase 2010 2008 $14,135 ­ $9,853 $7,955 ­ $6,183 $10,403 ­ $10,009 $16,383 ­ $14,442 $22,264 ­ $22,568 $26,835 ­ $28,300 $29,896 ­ $32,203 $34,319 ­ $35,640 6% Annual Increase 2010 2008 $15,523 ­ $15,602 $8,788 ­ $8,557 $11,757 ­ $12,937 $18,899 ­ $17,523 $25,230 ­ $27,196 $33,045 ­ $34,701 $36,101 ­ $43,044 $44,425 ­ $48,420 7% Annual Increase 2010 2008 $21,528 ­ $19,046 $11,792 ­ $10,170 $15,567 ­ $16,034 $23,478 ­ $21,820 $29,683 ­ $31,456 $36,328 ­ $42,187 $46,952 ­ $54,371 $55,385 ­ $60,291 Max Net Benefits 2010 2008 $25,287 ­ $32,384 $12,394 ­ $15,212 $13,914 ­ $16,926 $18,578 ­ $20,173 $23,334 ­ $25,066 $26,978 ­ $28,186 $28,379 ­ $29,408 $30,528 ­ $30,679 Total Cost = Total Benefit 2010 2008 $27,779 ­ $39,854 $13,607 ­ $21,548 $15,329 ­ $22,847 $22,991 ­ $25,648 $27,721 ­ $32,800 $32,011 ­ $36,409 $34,163 ­ $39,045 $39,917 ­ $41,901 
37 

Table 10a 

Present Value of Lifetime Societal Benefits16, by Alternative 

Passenger Cars, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $17,447 - $15,781 $10,334 - $8,655 $15,012 - $14,957 $23,133 - $22,270 $28,828 - $30,770 $35,972 - $36,237 $39,953 - $41,603 $45,658 - $45,486 

2% Annual Increase 2010 2008 $7,566 - $10,115 $4,677 - $5,557 $7,483 - $9,171 $11,549 - $12,740 $16,408 - $17,496 $20,157 - $20,737 $22,452 - $23,530 $25,841 - $27,112 3% Annual Increase 2010 2008 $20,829 - $21,766 $7,942 - $7,573 $11,670 - $13,438 $18,135 - $19,002 $24,641 - $26,500 $28,397 - $30,408 $32,005 - $34,866 $37,166 - $38,115 4% Annual Increase 2010 2008 $30,318 - $30,571 $11,136 - $10,695 $15,657 - $17,693 $24,012 - $23,968 $32,048 - $32,435 $39,147 - $38,150 $43,137 - $43,036 $48,184 - $47,472 5% Annual Increase 2010 2008 $23,134 - $25,489 $13,908 - $12,850 $19,458 - $20,338 $29,536 - $27,425 $37,857 - $37,576 $44,307 - $44,735 $48,820 - $49,299 $54,476 - $53,930 6% Annual Increase 2010 2008 $26,046 - $30,698 $16,132 - $15,675 $22,076 - $23,527 $33,519 - $30,413 $40,234 - $40,453 $48,036 - $47,588 $52,251 - $54,856 $59,027 - $60,173 7% Annual Increase 2010 2008 $33,356 - $36,910 $19,324 - $18,543 $25,675 - $26,712 $36,384 - $34,102 $42,890 - $43,579 $49,291 - $50,549 $56,369 - $58,878 $62,145 - $63,596 Max Net Benefits 2010 2008 $39,548 - $49,680 $21,104 - $22,376 $24,397 - $25,644 $33,058 - $30,088 $39,268 - $36,256 $44,064 - $41,354 $46,782 - $44,370 $50,172 - $47,796 Total Cost = Total Benefit 2010 2008 $43,413 - $58,900 $22,925 - $27,356 $26,145 - $30,685 $36,061 - $34,701 $42,096 - $42,336 $47,221 - $47,746 $51,475 - $52,197 $57,373 - $56,534 

16 These benefits are considered from a “societal perspective” because they include externalities. They are distinguished from a consum

consumers generally would not think about the value of carbon dioxide, energy security, etc. Table 10 includes only social benefits; soTable 9. 
38 

Table 10b 

Present Value of Lifetime Societal Benefits, by Alternative

Light Trucks, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $5,746 - $2,113 $3,483 - $2,717 $4,659 - $6,323 $11,863 - $11,755 $15,773 - $17,051 $21,876 - $23,171 $24,263 - $26,462 $27,545 - $28,570 

2% Annual Increase 2010 2008 $16,681 - $10,301 $7,876 - $5,967 $8,501 - $8,333 $12,207 - $11,826 $13,804 - $15,180 $15,354 - $18,036 $16,871 - $20,097 $18,816 - $21,262 3% Annual Increase 2010 2008 $19,781 - $12,554 $9,501 - $8,089 $10,548 - $11,181 $15,614 - $16,944 $19,514 - $22,022 $23,555 - $26,195 $25,865 - $28,604 $29,058 - $30,552 4% Annual Increase 2010 2008 $20,079 - $14,774 $9,850 - $10,355 $11,957 - $14,306 $18,008 - $21,512 $22,990 - $27,389 $28,231 - $32,172 $30,635 - $34,792 $33,899 - $37,484 5% Annual Increase 2010 2008 $20,436 - $17,115 $10,773 - $11,800 $12,916 - $16,752 $20,389 - $25,134 $26,022 - $32,680 $31,743 - $37,282 $34,487 - $40,369 $39,018 - $42,905 6% Annual Increase 2010 2008 $24,199 - $23,773 $12,305 - $13,754 $14,527 - $18,729 $21,451 - $27,027 $27,401 - $35,466 $33,690 - $40,400 $36,683 - $43,836 $41,065 - $45,533 7% Annual Increase 2010 2008 $25,108 - $26,203 $13,224 - $14,883 $15,715 - $20,771 $23,066 - $28,680 $29,545 - $36,017 $35,540 - $41,993 $38,063 - $45,194 $42,203 - $47,828 Max Net Benefits 2010 2008 $26,435 - $41,963 $13,506 - $20,101 $15,190 - $23,201 $21,984 - $28,917 $27,071 - $34,022 $32,702 - $38,482 $34,834 - $40,591 $38,712 - $41,985 Total Cost = Total Benefit 2010 2008 $28,084 - $43,815 $13,867 - $21,281 $15,647 - $24,269 $21,490 - $29,835 $27,642 - $35,953 $33,617 - $40,412 $35,347 - $42,504 $39,097 - $44,555 
39 

Table 10c 

Present Value of Lifetime Societal Benefits, by Alternative 

Passenger Cars and Light Trucks Combined, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $23,194 - $17,894 $13,817 - $11,373 $19,671 - $21,280 $34,996 - $34,025 $44,601 - $47,821 $57,847 - $59,408 $64,216 - $68,065 $73,203 - $74,056 

2% Annual Increase 2010 2008 $24,247 - $20,416 $12,553 - $11,524 $15,984 - $17,504 $23,755 - $24,567 $30,212 - $32,676 $35,511 - $38,773 $39,322 - $43,626 $44,657 - $48,374 3% Annual Increase 2010 2008 $40,611 - $34,320 $17,443 - $15,662 $22,218 - $24,619 $33,750 - $35,946 $44,155 - $48,523 $51,951 - $56,603 $57,870 - $63,470 $66,224 - $68,667 4% Annual Increase 2010 2008 $50,397 - $45,345 $20,986 - $21,050 $27,614 - $31,998 $42,020 - $45,481 $55,037 - $59,824 $67,378 - $70,322 $73,771 - $77,828 $82,083 - $84,956 5% Annual Increase 2010 2008 $43,571 - $42,604 $24,681 - $24,651 $32,374 - $37,090 $49,924 - $52,559 $63,879 - $70,256 $76,051 - $82,017 $83,307 - $89,667 $93,494 - $96,836 6% Annual Increase 2010 2008 $50,245 - $54,471 $28,436 - $29,429 $36,602 - $42,256 $54,970 - $57,440 $67,635 - $75,919 $81,725 - $87,988 $88,934 - $98,691 $100,092 - $105,706 7% Annual Increase 2010 2008 $58,464 - $63,113 $32,549 - $33,426 $41,389 - $47,483 $59,450 - $62,782 $72,435 - $79,596 $84,831 - $92,542 $94,433 - $104,072 $104,348 - $111,424 Max Net Benefits 2010 2008 $65,983 - $91,643 $34,610 - $42,476 $39,587 - $48,846 $55,042 - $59,005 $66,339 - $70,278 $76,766 - $79,836 $81,616 - $84,960 $88,883 - $89,780 Total Cost = Total Benefit 2010 2008 $71,496 - $102,715 $36,793 - $48,637 $41,792 - $54,954 $57,552 - $64,537 $69,738 - $78,290 $80,838 - $88,158 $86,822 - $94,701 $96,469 - $101,089 
40 

Table 11a 

Present Value of Net Total Benefits17 by Alternative 

Passenger Cars, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $11,949 - $11,737 $6,980 - $6,178 $10,047 - $10,510 $15,852 - $15,365 $19,660 - $20,481 $24,458 - $23,581 $27,200 - $27,008 $31,335 - $29,635 

2% Annual Increase 2010 2008 $5,323 - $7,471 $3,137 - $4,041 $4,786 - $6,468 $7,486 - $8,746 $10,905 - $11,814 $13,301 - $13,976 $14,849 - $15,900 $17,314 - $18,507 3% Annual Increase 2010 2008 $14,352 - $16,247 $5,442 - $5,511 $7,938 - $9,494 $12,353 - $13,423 $17,127 - $18,279 $19,956 - $20,787 $22,388 - $23,764 $26,209 - $26,401 4% Annual Increase 2010 2008 $19,731 - $22,651 $7,120 - $7,700 $10,106 - $12,370 $15,815 - $16,573 $21,362 - $21,701 $26,217 - $25,121 $29,001 - $28,125 $32,570 - $30,798 5% Annual Increase 2010 2008 $15,664 - $19,016 $9,081 - $9,186 $12,656 - $13,999 $18,589 - $18,703 $23,758 - $23,571 $27,641 - $26,715 $30,006 - $28,800 $32,603 - $30,659 6% Annual Increase 2010 2008 $18,003 - $21,204 $10,816 - $10,528 $14,354 - $15,276 $20,802 - $19,789 $24,050 - $24,518 $26,700 - $25,992 $28,817 - $26,647 $28,671 - $27,340 7% Annual Increase 2010 2008 $20,241 - $24,315 $11,733 - $11,986 $15,033 - $15,978 $20,071 - $20,255 $23,871 - $24,164 $25,717 - $23,182 $23,045 - $21,304 $21,657 - $22,062 Max Net Benefits 2010 2008 $24,764 - $32,845 $13,320 - $13,675 $15,368 - $15,848 $21,168 - $18,165 $24,603 - $21,813 $27,428 - $25,060 $29,321 - $27,258 $31,633 - $29,550 Total Cost = Total Benefit 2010 2008 $26,362 - $35,926 $14,103 - $12,958 $15,923 - $15,556 $19,641 - $17,938 $23,744 - $22,408 $26,161 - $25,555 $28,689 - $27,949 $29,937 - $30,132 

17 This table is from a societal perspective, thus, civil penalties are deleted from the costs because they are a transfer payment. 
41 

Table 11b 

Present Value of Net Total Benefits by Alternative 

Light Trucks, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $3,948 - $1,641 $2,464 - $2,105 $3,453 - $5,025 $9,105 - $9,374 $11,956 - $13,671 $16,342 - $18,531 $18,323 - $21,076 $20,986 - $22,796 

2% Annual Increase 2010 2008 $11,048 - $8,662 $5,482 - $4,975 $6,095 - $6,816 $9,217 - $9,771 $10,521 - $12,396 $11,753 - $14,705 $12,963 - $16,306 $14,598 - $17,384 3% Annual Increase 2010 2008 $13,340 - $10,725 $6,718 - $6,800 $7,702 - $9,267 $11,927 - $13,987 $14,753 - $17,861 $17,906 - $21,158 $19,829 - $23,011 $22,393 - $24,647 4% Annual Increase 2010 2008 $13,285 - $12,327 $6,872 - $8,360 $8,617 - $11,474 $13,664 - $17,123 $17,166 - $21,453 $21,371 - $24,832 $23,243 - $26,856 $25,781 - $28,974 5% Annual Increase 2010 2008 $13,771 - $13,734 $7,646 - $9,281 $9,315 - $13,083 $14,952 - $19,414 $17,857 - $24,117 $21,574 - $27,002 $23,405 - $28,664 $26,572 - $30,536 6% Annual Increase 2010 2008 $16,719 - $17,665 $8,833 - $10,344 $10,490 - $14,043 $15,268 - $20,129 $18,355 - $24,205 $21,980 - $27,294 $24,016 - $29,000 $26,996 - $29,946 7% Annual Increase 2010 2008 $16,695 - $19,752 $9,023 - $11,270 $10,790 - $15,471 $15,901 - $20,707 $18,880 - $23,977 $22,787 - $27,172 $24,435 - $28,397 $27,306 - $29,071 Max Net Benefits 2010 2008 $15,931 - $26,414 $8,896 - $13,589 $10,305 - $16,072 $15,296 - $20,667 $18,402 - $23,400 $22,360 - $26,590 $23,916 - $28,294 $26,723 - $29,552 Total Cost = Total Benefit 2010 2008 $17,355 - $26,935 $9,082 - $14,130 $10,540 - $16,551 $14,920 - $20,951 $18,273 - $23,081 $22,666 - $26,195 $23,970 - $27,707 $26,616 - $29,056 
42 

Table 11c 

Present Value of Net Total Benefits by Alternative 

Passenger Cars and Light Trucks Combined, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $15,897 - $13,379 $9,444 - $8,284 $13,500 - $15,535 $24,957 - $24,739 $31,616 - $34,152 $40,800 - $42,112 $45,523 - $48,085 $52,320 - $52,431 

2% Annual Increase 2010 2008 $16,372 - $16,133 $8,620 - $9,016 $10,881 - $13,285 $16,703 - $18,517 $21,426 - $24,211 $25,054 - $28,681 $27,812 - $32,206 $31,912 - $35,892 3% Annual Increase 2010 2008 $27,692 - $26,972 $12,160 - $12,311 $15,640 - $18,761 $24,279 - $27,411 $31,880 - $36,140 $37,862 - $41,945 $42,217 - $46,776 $48,602 - $51,047 4% Annual Increase 2010 2008 $33,016 - $34,978 $13,992 - $16,060 $18,723 - $23,844 $29,479 - $33,696 $38,528 - $43,154 $47,588 - $49,952 $52,244 - $54,981 $58,351 - $59,772 5% Annual Increase 2010 2008 $29,435 - $32,750 $16,727 - $18,467 $21,971 - $27,081 $33,541 - $38,117 $41,615 - $47,688 $49,215 - $53,718 $53,411 - $57,464 $59,175 - $61,195 6% Annual Increase 2010 2008 $34,722 - $38,869 $19,649 - $20,872 $24,845 - $29,319 $36,071 - $39,917 $42,405 - $48,723 $48,680 - $53,287 $52,833 - $55,647 $55,667 - $57,286 7% Annual Increase 2010 2008 $36,936 - $44,067 $20,756 - $23,256 $25,823 - $31,449 $35,973 - $40,962 $42,752 - $48,141 $48,504 - $50,355 $47,480 - $49,701 $48,963 - $51,133 Max Net Benefits 2010 2008 $40,695 - $59,259 $22,216 - $27,264 $25,673 - $31,920 $36,464 - $38,832 $43,005 - $45,212 $49,788 - $51,650 $53,237 - $55,552 $58,356 - $59,101 Total Cost = Total Benefit 2010 2008 $43,718 - $62,861 $23,185 - $27,089 $26,463 - $32,107 $34,561 - $38,889 $42,017 - $45,489 $48,827 - $51,749 $52,659 - $55,657 $56,553 - $59,188 
43 

Table 12a 

Millions of Gallons of Liquid Fuel Saved18

Passenger Cars, Undiscounted Over the Lifetime of the Model Year 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 6,093 - 5,501 3,547 - 2,949 5,106 - 5,073 7,826 - 7,524 9,672 - 10,365 11,993 - 12,117 13,215 - 13,828 14,983 - 15,005 

2% Annual Increase 2010 2008 2,632 - 3,538 1,596 - 1,896 2,531 - 3,111 3,886 - 4,361 5,489 - 5,931 6,711 - 6,968 7,417 - 7,861 8,456 - 8,980 3% Annual Increase 2010 2008 4,498 - 4,954 2,725 - 2,581 3,964 - 4,560 6,127 - 6,407 8,257 - 8,898 9,452 - 10,139 10,568 - 11,560 12,166 - 12,533 4% Annual Increase 2010 2008 6,695 - 6,939 3,817 - 3,649 5,324 - 6,006 8,167 - 8,096 10,802 - 10,921 13,100 - 12,758 14,328 - 14,304 15,867 - 15,716 5% Annual Increase 2010 2008 8,073 - 8,891 4,764 - 4,382 6,615 - 6,904 10,126 - 9,275 12,905 - 12,903 15,011 - 15,323 16,585 - 16,889 18,437 - 18,451 6% Annual Increase 2010 2008 9,064 - 10,716 5,519 - 5,353 7,504 - 8,000 11,503 - 10,273 13,922 - 13,811 16,769 - 16,711 18,150 - 19,655 20,834 - 21,685 7% Annual Increase 2010 2008 11,633 - 12,885 6,618 - 6,337 8,751 - 9,174 12,632 - 11,686 14,967 - 15,211 17,207 - 18,453 20,381 - 22,239 22,867 - 23,933 Max Net Benefits (3% Discount Rate) 

2010 2008 

14,530 -

17,484 

7,627 -

7,963 

8,737 -

9,379 

12,615 -

11,480 

14,642 -

14,063 

16,186 -

15,872 

17,307 -

16,854 

18,649 -

17,819 

Max Net Benefits (7% Discount Rate) 

2010 2008 

13,815 -

17,387 

7,226 -

7,811 

8,296 -

8,889 

11,286 -

10,522 

13,605 -

12,702 

15,221 -

14,334 

16,022 -

15,266 

17,014 -

16,293 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

15,169 -

20,614 

7,851 -

9,965 

8,895 -

11,053 

12,896 -

12,455 

14,937 -

15,193 

16,720 -

16,982 

18,078 -

18,446 

20,255 -

19,837 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

15,169 -

20,614 

7,851 -

9,965 

8,895 -

11,053 

12,896 -

12,455 

14,937 -

15,193 

16,720 -

16,982 

18,078 -

18,446 

20,255 -

19,837 

18 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios. The results of all other scenario

discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both Max Net Benefits and Total Cost = Total Benefit scenarios. 
44 

Table 12b 

Millions of Gallons of Liquid Fuel Saved 

Light Trucks, Undiscounted Over the Lifetime of the Model Year

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 2,041 - 750 1,219 - 954 1,640 - 2,211 4,215 - 4,084 5,575 - 5,864 7,697 - 7,929 8,444 - 8,986 9,482 - 9,616 

2% Annual Increase 2010 2008 6,151 - 3,689 2,828 - 2,095 3,045 - 2,911 4,359 - 4,102 4,886 - 5,214 5,376 - 6,155 5,849 - 6,800 6,455 - 7,127 3% Annual Increase 2010 2008 7,259 - 4,510 3,408 - 2,847 3,766 - 3,910 5,541 - 5,890 6,889 - 7,591 8,229 - 8,971 8,955 - 9,715 9,959 - 10,280 4% Annual Increase 2010 2008 7,376 - 5,326 3,530 - 3,660 4,265 - 5,017 6,381 - 7,496 8,099 - 9,459 9,851 - 11,049 10,588 - 11,846 11,622 - 12,654 5% Annual Increase 2010 2008 7,493 - 6,168 3,857 - 4,177 4,602 - 5,881 7,238 - 8,776 9,318 - 11,391 11,304 - 12,900 12,215 - 13,950 13,707 - 14,701 6% Annual Increase 2010 2008 8,851 - 8,561 4,397 - 4,864 5,164 - 6,588 7,605 - 9,448 9,799 - 12,727 12,017 - 14,353 12,971 - 15,550 14,422 - 16,049 7% Annual Increase 2010 2008 9,181 - 9,475 4,730 - 5,273 5,616 - 7,322 8,216 - 10,050 10,808 - 12,723 12,926 - 14,802 13,724 - 15,992 15,102 - 16,936 Max Net Benefits (3% Discount Rate) 

2010 2008 

9,805 -

15,617 

4,762 -

7,393 

5,399 -

8,432 

7,848 -

10,280 

9,758 -

12,991 

11,735 -

14,531 

12,448 -

15,153 

13,673 -

15,681 

Max Net Benefits (7% Discount Rate) 

2010 2008 

9,673 -

15,206 

4,828 -

7,180 

5,404 -

8,227 

7,843 -

10,161 

9,694 -

12,048 

11,589 -

13,521 

12,230 -

14,134 

13,475 -

14,481 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

10,271 -

15,875 

4,953 -

7,592 

5,561 -

8,598 

7,660 -

10,479 

9,937 -

13,211 

11,936 -

14,679 

12,463 -

15,302 

13,664 -

15,902 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

10,271 -

15,875 

4,953 -

7,592 

5,561 -

8,598 

7,660 -

10,479 

9,937 -

13,211 

11,936 -

14,679 

12,463 -

15,302 

13,664 -

15,902 
45 

Table 12c 

Millions of Gallons of Liquid Fuel Saved 

Passenger Cars and Light Trucks Combined 

Undiscounted Over the Lifetime of the Model Year 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 8,134 - 6,251 4,766 - 3,904 6,746 - 7,285 12,041 - 11,608 15,247 - 16,230 19,690 - 20,045 21,659 - 22,815 24,466 - 24,621 

2% Annual Increase 2010 2008 8,784 - 7,227 4,424 - 3,992 5,576 - 6,022 8,244 - 8,463 10,375 - 11,145 12,086 - 13,123 13,266 - 14,661 14,911 - 16,107 3% Annual Increase 2010 2008 11,757 - 9,464 6,132 - 5,428 7,730 - 8,470 11,668 - 12,297 15,146 - 16,489 17,681 - 19,110 19,523 - 21,275 22,125 - 22,813 4% Annual Increase 2010 2008 14,070 - 12,265 7,347 - 7,309 9,588 - 11,023 14,548 - 15,592 18,901 - 20,380 22,951 - 23,807 24,916 - 26,150 27,489 - 28,370 5% Annual Increase 2010 2008 15,566 - 15,059 8,621 - 8,560 11,217 - 12,785 17,365 - 18,051 22,223 - 24,294 26,314 - 28,223 28,801 - 30,839 32,144 - 33,152 6% Annual Increase 2010 2008 17,914 - 19,278 9,916 - 10,217 12,668 - 14,589 19,108 - 19,721 23,721 - 26,538 28,786 - 31,064 31,121 - 35,205 35,256 - 37,734 7% Annual Increase 2010 2008 20,814 - 22,360 11,348 - 11,610 14,367 - 16,496 20,848 - 21,736 25,775 - 27,934 30,133 - 33,255 34,105 - 38,231 37,969 - 40,869 Max Net Benefits (3% Discount Rate) 

2010 2008 

24,335 -

33,102 

12,389 -

15,356 

14,136 -

17,811 

20,463 -

21,760 

24,401 -

27,054 

27,921 -

30,403 

29,755 -

32,007 

32,322 -

33,500 

Max Net Benefits (7% Discount Rate) 

2010 2008 

23,487 -

32,593 

12,054 -

14,991 

13,700 -

17,116 

19,129 -

20,683 

23,299 -

24,750 

26,810 -

27,856 

28,253 -

29,399 

30,489 -

30,774 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

25,440 -

36,489 

12,804 -

17,557 

14,456 -

19,650 

20,557 -

22,935 

24,874 -

28,405 

28,656 -

31,661 

30,540 -

33,747 

33,918 -

35,739 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

25,440 -

36,489 

12,804 -

17,557 

14,456 -

19,650 

20,557 -

22,935 

24,874 -

28,405 

28,656 -

31,661 

30,540 -

33,747 

33,918 -

35,739 
46 

Table 12d 

Change in Electricity Consumption (in GW-h) 

Passenger Cars

Undiscounted Over the Lifetime of the Model Year 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,949.6 272.1 - 2,310.8 349.5 - 3,100.3 366.6 - 3,747.2 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 2,120.8 0.0 - 2,667.7 272.1 - 2,959.9 349.5 - 3,725.6 354.8 - 4,180.1 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,442.0 272.1 - 1,800.5 349.5 - 2,563.3 366.6 - 3,012.2 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 73.5 - 1,562.7 347.6 - 1,926.5 638.8 - 2,694.9 692.1 - 4,778.0 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 2,061.4 - 542.3 2,720.8 - 7,208.8 3,691.9 - 10,168.0 5,601.8 - 10,687.4 7,261.1 - 13,416.6 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 460.9 2,043.7 - 722.7 3,285.9 - 4,885.1 10,267.7 - 18,022.2 10,568.1 - 35,074.0 24,997.5 - 48,022.8 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 2,478.3 6,390.9 - 4,364.5 8,121.4 - 9,222.4 10,992.8 - 26,094.0 33,649.0 - 57,940.9 48,359.2 - 66,198.7 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

32.0 -

 1,806.7 

11,498.8 -

 10,940.9 

14,406.0 -

 15,351.4 

14,865.4 -

 16,358.0 

16,048.4 -

 17,690.9 

17,136.1 -

 19,094.8 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

35.9 -

 1,813.9 

2,069.5 -

 6,478.5 

8,503.8 -

 10,208.3 

9,583.3 -

 10,730.2 

9,927.1 -

 11,684.2 

10,135.5 -

 12,398.6 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,274.3 

35.9 -

 14,822.4 

12,875.2 -

 17,142.9 

13,844.7 -

 22,018.9 

16,294.3 -

 23,290.6 

17,533.1 -

 26,328.6 

27,801.7 -

 29,438.9 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,274.3 

35.9 -

 14,822.4 

12,875.2 -

 17,142.9 

13,844.7 -

 22,018.9 

16,294.3 -

 23,290.6 

17,533.1 -

 26,328.6 

27,801.7 -

 29,438.9 
47 

Table 12e 

Change in Electricity Consumption (in GW-h) 

Light Trucks 

Undiscounted Over the Lifetime of the Model Year 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.2 - 0.0 0.2 - 0.0 0.2 - 0.0 0.2 - 206.5 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 487.2 - 1,160.2 485.4 - 1,151.8 497.8 - 1,159.1 532.7 - 1,362.6 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 540.4 - 7,952.7 538.1 - 8,220.3 551.4 - 9,244.6 585.1 - 9,425.2 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 33.0 - 239.8 32.8 - 230.5 4,341.9 - 1,399.0 4,325.8 - 1,713.8 4,435.7 - 3,719.9 5,299.1 - 6,955.8 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 0.0 

35.7 -

 250.5 

35.6 -

 241.1 

592.9 -

 12,967.5 

671.4 -

 12,932.8 

689.1 -

 13,068.0 

690.8 -

 13,076.7 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 0.0 

35.7 -

 250.5 

35.6 -

 241.1 

35.5 -

 5,338.1 

35.4 -

 5,342.0 

36.3 -

 5,412.8 

35.9 -

 5,427.5 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 45.8 

35.7 -

 299.2 

35.6 -

 288.3 

519.8 -

 13,443.1 

517.6 -

 13,387.7 

1,253.5 -

 13,468.4 

1,254.9 -

 13,461.2 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 45.8 

35.7 -

 299.2 

35.6 -

 288.3 

519.8 -

 13,443.1 

517.6 -

 13,387.7 

1,253.5 -

 13,468.4 

1,254.9 -

 13,461.2 
48 

Table 12f 

Change in Electricity Consumption (in GW-h) 

Passenger Cars and Light Trucks Combined 

Undiscounted Over the Lifetime of the Model Year 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,949.6 272.1 - 2,310.8 349.5 - 3,100.3 366.6 - 3,747.2 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 2,120.8 0.0 - 2,667.7 272.1 - 2,959.9 349.5 - 3,725.6 354.8 - 4,180.1 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,442.0 272.1 - 1,800.5 349.5 - 2,563.3 366.6 - 3,012.2 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 73.7 - 1,562.7 347.8 - 1,926.5 639.0 - 2,694.9 692.3 - 4,984.5 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 2,061.4 - 542.3 3,208.0 - 8,369.0 4,177.3 - 11,319.7 6,099.6 - 11,846.5 7,793.9 - 14,779.2 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 460.9 2,043.7 - 722.7 3,826.2 - 12,837.8 10,805.8 - 26,242.5 11,119.6 - 44,318.6 25,582.6 - 57,448.0 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 65.0 - 2,718.1 6,423.7 - 4,595.0 12,463.4 - 10,621.4 15,318.7 - 27,807.8 38,084.7 - 61,660.8 53,658.3 - 73,154.5 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

67.8 -

 2,057.2 

11,534.4 -

 11,182.0 

14,999.0 -

 28,318.9 

15,536.9 -

 29,290.8 

16,737.6 -

 30,759.0 

17,826.8 -

 32,171.5 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

71.6 -

 2,064.5 

2,105.1 -

 6,719.6 

8,539.3 -

 15,546.4 

9,618.7 -

 16,072.2 

9,963.4 -

 17,097.0 

10,171.4 -

 17,826.0 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,320.1 

71.6 -

 15,121.7 

12,910.8 -

 17,431.2 

14,364.5 -

 35,462.0 

16,811.9 -

 36,678.3 

18,786.6 -

 39,797.0 

29,056.6 -

 42,900.2 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,320.1 

71.6 -

 15,121.7 

12,910.8 -

 17,431.2 

14,364.5 -

 35,462.0 

16,811.9 -

 36,678.3 

18,786.6 -

 39,797.0 

29,056.6 -

 42,900.2 
49 

Breakdown of Costs and Benefits for the Preferred Alternative 

Tables 13 and 14 provide breakdowns of the costs and benefits for the preferred alternative using a 3 percent and rate, respectively. 

Table 13 

Preferred Alternative

Cost and Benefit Estimates, 3% Discount Rate 

Passenger Cars and Light Trucks Combined 

(Millions of 2010 Dollars) 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Social Costs Technology Costs 2010 2008 ($6,172) ­ ($3,654) ($3,722) ­ ($2,499) ($5,227) ­ ($4,589) ($8,256) ­ ($7,349) ($10,809) ­ ($11,059) ($14,033) ­ ($14,236) ($15,262) ­ ($16,447) ($16,883) ­ ($17,767) ($19,7

($20,5

Maintenance Costs 2010 2008 ($21) - ($0) ($13) - ($78) ($12) - ($228) ($237) ­ ($488) ($210) ­ ($592) ($551) ­ ($540) ($730) ­ ($689) ($946) ­ ($755) ($1,20

($80

Congestion Costs 2010 2008 ($917) ­ ($736) ($539) ­ ($447) ($779) ­ ($823) ($1,323) ­ ($1,291) ($1,669) ­ ($1,789) ($2,153) ­ ($2,198) ($2,390) ­ ($2,514) ($2,727) ­ ($2,743) ($3,09

($3,1

Accident Costs 2010 2008 ($419) ­ ($329) ($248) ­ ($204) ($355) ­ ($380) ($619) ­ ($602) ($785) ­ ($839) ($1,014) ­ ($1,036) ($1,125) ­ ($1,185) ($1,282) ­ ($1,291) ($1,45

($1,4

Noise Costs 2010 2008 ($17) - ($13) ($10) - ($8) ($14) - ($15) ($25) - ($24) ($31) - ($33) ($40) - ($41) ($44) - ($47) ($51) - ($51) ($58

($5

Relative Value Loss (EVs) 

2010 2008 

$0 -

$0 

($0) - 

($1) 

($0) - 

($5) 

($0) - 

($12) 

($0) - 

($40) 

($4) - 

($50) 

($6) - 

($59) 

($7) - 

($71) 

($32

($11

Total Social Costs 2010 2008 ($7,545) ­ ($4,732) ($4,532) ­ ($3,239) ($6,388) ­ ($6,039) ($10,460) ­ ($9,765) ($13,504) ­ ($14,353) ($17,795) ­ ($18,100) ($19,558) ­ ($20,942) ($21,896) ­ ($22,677) ($25,5

($26,0

 Social Benefits Lifetime Fuel Expenditures (Pretax) 

2010 2008 

$22,020 -

$16,856 

$13,145 -

$10,780 

$18,750 -

$20,246 

$33,571 -

$32,477 

$42,751 -

$45,654 

$55,429 -

$56,795 

$61,476 -

$65,088 

$70,033 -

$70,797 

$79,5

$79,9

Consumer Surplus from Additional Driving 

2010 2008 

$2,169 -

$1,746 

$1,255 -

$1,037 

$1,735 -

$1,903 

$3,063 -

$2,995 

$3,913 -

$4,186 

$5,083 -

$5,141 

$5,645 -

$5,860 

$6,484 -

$6,429 

$7,31

$7,2
50 

Refueling Time Value 

2010 2008 

$810 -

$679 

$472 -

$421 

$640 -

$726 

$1,045 -

$1,105 

$1,303 -

$1,563 

$1,625 -

$1,936 

$1,824 -

$2,227 

$2,055 -

$2,384 

$2,35

$2,6

Petroleum Market Externalities 

2010 2008 

$1,227 -

$938 

$716 -

$590 

$1,010 -

$1,099 

$1,781 -

$1,753 

$2,242 -

$2,449 

$2,895 -

$3,023 

$3,193 -

$3,442 

$3,607 -

$3,714 

$4,07

$4,1

Value of Reduced Fatalities 

2010 2008 

($10) - 

$41 

$9 -

$14 

$12 -

$39 

($68) - 

$15 

($39) - 

$81 

$0 -

$67 

$5 -

$86 

$5 -

$77 

$38 

$10

CO2 2010 2008 $2,062 - $1,574 $1,257 - $1,030 $1,816 - $1,957 $3,298 - $3,176 $4,257 - $4,515 $5,585 - $5,694 $6,274 - $6,607 $7,233 - $7,267 $8,29

$8,2

CO 2010 2008 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 

$0 

VOC 2010 2008 $27 - $21 $16 - $13 $22 - $25 $40 - $40 $50 - $56 $68 - $69 $75 - $78 $84 - $85 $94 

$9

NOX 2010 2008 $60 - $47 $35 - $29 $50 - $53 $88 - $81 $110 - $111 $126 - $137 $140 - $156 $160 - $167 $180 

$18

PM 2010 2008 $344 - $265 $201 - $165 $284 - $306 $501 - $492 $632 - $681 $847 - $839 $929 - $952 $1,043 - $1,026 $1,16

$1,1

SOX 2010 2008 $302 - $232 $177 - $146 $249 - $261 $441 - $413 $556 - $537 $710 - $666 $781 - $742 $883 - $787 $929 

$78

Total Social Benefits 

2010 2008 

$29,011 -

$22,398 

$17,281 -

$14,224 

$24,569 -

$26,616 

$43,759 -

$42,546 

$55,775 -

$59,832 

$72,369 -

$74,366 

$80,343 -

$85,237 

$91,587 -

$92,733 

$104,0

$104,

Net Total Benefits 2010 2008 $21,466 - $17,666 $12,748 - $10,986 $18,181 - $20,576 $33,299 - $32,781 $42,271 - $45,479 $54,574 - $56,266 $60,785 - $64,295 $69,691 - $70,056 $78,4

$78,5
51 

Table 14 

Preferred Alternative

Cost and Benefit Estimates, 7% Discount Rate 

Passenger Cars and Light Trucks Combined 

(Millions of 2010 Dollars) 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Social Costs Technology Costs 2010 2008 ($6,172) ­ ($3,654) ($3,722) ­ ($2,499) ($5,227) ­ ($4,589) ($8,256) ­ ($7,349) ($10,809) ­ ($11,059) ($14,033) ­ ($14,236) ($15,262) ­ ($16,447) ($16,883) ­ ($17,767) ($19,7

($20,5

Maintenance Costs 2010 2008 ($15) - ($0) ($10) - ($58) ($9) - ($170) ($177) ­ ($365) ($156) ­ ($441) ($410) ­ ($402) ($543) ­ ($513) ($704) ­ ($562) ($894

($59

Congestion Costs 2010 2008 ($724) ­ ($581) ($426) ­ ($353) ($615) ­ ($650) ($1,044) ­ ($1,019) ($1,317) ­ ($1,412) ($1,698) ­ ($1,734) ($1,884) ­ ($1,983) ($2,149) ­ ($2,162) ($2,44

($2,4

Accident Costs 2010 2008 ($330) ­ ($260) ($196) ­ ($161) ($281) ­ ($300) ($489) ­ ($475) ($619) ­ ($662) ($799) ­ ($817) ($886) ­ ($934) ($1,010) ­ ($1,017) ($1,14

($1,1

Noise Costs 2010 2008 ($13) - ($11) ($8) - ($6) ($11) - ($12) ($19) - ($19) ($25) - ($26) ($32) - ($32) ($35) - ($37) ($40) - ($40) ($45

($4

Relative Value Loss (EVs) 

2010 2008 

$0 -

$0 

($0) - 

($1) 

($0) - 

($2) 

($0) - 

($5) 

($0) - 

($18) 

($2) - 

($22) 

($3) - 

($26) 

($3) - 

($31) 

($14

($4

Total Social Costs 2010 2008 ($7,255) ­ ($4,505) ($4,361) ­ ($3,080) ($6,144) ­ ($5,723) ($9,986) ­ ($9,232) ($12,926) ­ ($13,618) ($16,974) ­ ($17,242) ($18,614) ­ ($19,939) ($20,789) ­ ($21,578) ($24,2

($24,8

 Social Benefits Lifetime Fuel Expenditures (Pretax) 

2010 2008 

$17,208 -

$13,183 

$10,280 -

$8,431 

$14,672 -

$15,825 

$26,221 -

$25,369 

$33,386 -

$35,651 

$43,261 -

$44,319 

$47,965 -

$50,770 

$54,624 -

$55,213 

$62,0

$62,3

Consumer Surplus from Additional Driving 

2010 2008 

$1,696 -

$1,367 

$983 -

$812 

$1,361 -

$1,491 

$2,396 -

$2,344 

$3,060 -

$3,275 

$3,970 -

$4,017 

$4,405 -

$4,574 

$5,057 -

$5,015 

$5,70

$5,6

Refueling Time Value 

2010 2008 

$640 -

$537 

$373 -

$333 

$506 -

$573 

$825 -

$872 

$1,028 -

$1,233 

$1,283 -

$1,527 

$1,440 -

$1,757 

$1,622 -

$1,881 

$1,85

$2,1

Petroleum Market Externalities 

2010 2008 

$968 -

$741 

$565 -

$465 

$798 -

$867 

$1,404 -

$1,382 

$1,767 -

$1,930 

$2,282 -

$2,383 

$2,517 -

$2,713 

$2,843 -

$2,928 

$3,21

$3,2

Value of Reduced Fatalities 

2010 2008 

($9) - 

$32 

$7 -

$10 

$9 -

$30 

($54) - 

$11 

($32) - 

$63 

($1) - 

$52 

$3 -

$66 

$2 -

$60 

$28 

$7
52 

CO2 2010 2008 $2,062 - $1,574 $1,257 - $1,030 $1,816 - $1,957 $3,298 - $3,176 $4,257 - $4,515 $5,585 - $5,694 $6,274 - $6,607 $7,233 - $7,267 $8,29

$8,2

CO 2010 2008 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 - $0 $0 

$0 

VOC 2010 2008 $22 - $17 $13 - $11 $18 - $20 $32 - $32 $40 - $45 $54 - $55 $60 - $63 $67 - $68 $76 

$7

NOX 2010 2008 $49 - $38 $29 - $24 $41 - $43 $72 - $66 $90 - $90 $104 - $112 $115 - $127 $132 - $136 $148 

$14

PM 2010 2008 $276 - $212 $161 - $132 $228 - $245 $401 - $394 $507 - $546 $676 - $672 $742 - $763 $833 - $822 $934 

$91

SOX 2010 2008 $239 - $183 $139 - $115 $197 - $206 $348 - $326 $439 - $423 $560 - $524 $616 - $584 $696 - $620 $732 

$61

Total Social Benefits 

2010 2008 

$23,152 -

$17,884 

$13,805 -

$11,363 

$19,643 -

$21,258 

$34,942 -

$33,970 

$44,542 -

$47,770 

$57,774 -

$59,354 

$64,137 -

$68,024 

$73,110 -

$74,009 

$83,0

$83,5

Net Total Benefits 2010 2008 $15,897 - $13,379 $9,444 - $8,284 $13,500 - $15,535 $24,957 - $24,739 $31,616 - $34,152 $40,800 - $42,112 $45,523 - $48,085 $52,320 - $52,431 $58,7

$58,6
 

53 

Cumulative Impacts 

Table 15 shows the cumulative impacts of the fuel economy rules from MY 2011 through MY 

2025 compared to a MY 2010 baseline. The baseline is assumed to be the MY 2010 standards of 

27.5 mpg for passenger cars and 23.5 mpg for light trucks. We did not add the estimates from 

previous analyses of MY 2011 and MY 2012 - 2016 rulemakings to this FRIA analysis for 2017­

2025. These estimates are all from the most up-to-date current analysis using the 2010 baseline 

fleet. The costs and benefits are not the same as shown throughout the rest of the analysis, since 

the baseline assumes that the 2010 standards would continue, whereas the rest of the analysis 

starts with the MY 2016 standards. 
 

 

 

 

 

 

 

                                                      

 

54 

Table 15 

Cumulative Impacts of All Fuel Economy Standards 

From MY 2011-2025 

Passenger Cars Light Trucks Combined 

Baseline Required mpg in 

MY 2010 

27.5 23.5 25.9 

Achieved mpg with AC in 

MY 2025 

52.1 37.6 46.2 

Consumer Cost19 - MY 2025 vs. 

MY 2010 vehicle 

(per vehicle) 

($1,885) ($1,903) ($1,891) 

Lifetime Fuel Savings - MY 

2025 vs. MY 2010 vehicle 

(per vehicle) 

Discounted at 3% 

$8,906 $12,341 $10,033 

Lifetime Fuel Savings - MY 

2025 vs. MY 2010 vehicle 

(per vehicle) 

Discounted at 7% 

$6,986 $9,558 $7,830 

Net Consumer Savings 

(per vehicle) Discounted at 3% 

$7,021 $10,438 $8,142 

Net Consumer Savings 

(per vehicle) Discounted at 3% 

$5,101 $7,655 $5,939 

Total technology costs – All ($151.4) ($93.2) ($244.6) 

19 Includes technology costs and fines 
 

 

 

 

 

55 

model years 2011 through 2025 

(Billions of 2010 dollars) 

Total fuel savings – Over the 

lifetime of All model years 

2011 through 2025 

(Billions of Gallons) 

251 186 437 

Total CO2 savings – Over the 

lifetime of All model years 

2011 through 2025 

(Billions of Metric Tons) 

2.7 2.0 4.7 

Net savings – All model years 

2011 through 2025 

(Billions of 2010 dollars) 

Discounted at 3% 

733 558 1,291 

Net savings – All model years 

2011 through 2025 

(Billions of 2010 dollars) 

Discounted at 7% 

558 424 982 
                                                       

 

 

 

 

56 

I. INTRODUCTION 

The purpose of this study is to analyze the effects of extending the National Program of Federal 

and corporate average fuel economy (CAFE) standards to model years (MYs) 2017 and beyond 

for passenger cars and light trucks. This study includes a discussion of the technologies that can 

improve fuel economy, the potential impacts on retail prices, safety, the discounted lifetime net 

benefits of fuel savings, and the potential gallons of fuel saved, among other things. 

EPA and NHTSA, on behalf of the Department of Transportation, are issuing final rules to 

further reduce greenhouse gas emissions and improve fuel economy for light-duty vehicles for 

model years 2017 and beyond. On May 21, 2010, President Obama issued a Presidential 

Memorandum requesting that NHTSA and EPA develop through notice and comment 

rulemaking a coordinated National Program to improve fuel economy and reduce greenhouse gas 

emissions of light-duty vehicles for model years 2017-2025, building on the success of the first 

phase of the National Program for these vehicles for model years 2012-201620. This Final Rule, 

consistent with the President’s request, responds to the country’s critical need to address global 

climate change and to reduce oil consumption. NHTSA is finalizing Corporate Average Fuel 

Economy standards for model years 2017-2021 and issuing augural21 standards for model years 

2022-2025 under the Energy Policy and Conservation Act, as amended by the Energy 

Independence and Security Act. EPA is finalizing greenhouse gas emissions standards for model 

years 2017-2025 under the Clean Air Act. These standards apply to passenger cars, light-duty 

trucks, and medium-duty passenger vehicles, and represent the continuation of a harmonized and 

consistent National Program. Under the National Program automobile manufacturers will be 

20 Final Rule published in the Federal Register on May 7, 2010 (75FR 25324). 

21 For the NPRM/PRIA/Draft EIS, NHTSA described the proposed standards for MYs 2022-2025 as 

“conditional.” “Conditional” was understood and objected to by some readers as implying that the future 

proceeding would consist merely of a confirmation of the conclusions and analysis of the current rulemaking, which 

would be incorrect and inconsistent with the agency’s obligations under both EPCA/EISA and the Administrative 

Procedures Act. The agency must conduct a de novo rulemaking for model years 2022-2025. To avoid creating an 

incorrect impression, the agency is changing the descriptor for the 2022-2025 standards that are presented and 

discussed in these documents. The descriptor must convey that the standards we are now presenting for MYs 2022­

2025 reflect the agency’s current estimate of what we would have set at this time had we the authority to do so, but 

also avoid suggesting that the future process for establishing final standards for 2022-2025 would be anything other 

than a rulemaking based on a totally white-sheet-of-paper evaluation looking at all of the freshly gathered and 

solicited information before the agency at that future time and reflecting a fresh balancing of all statutorily relevant 

factors, in light of the considerations existing at the time of the evaluation. The agency deliberated extensively, 

considering many alternative descriptors, and concluded that the best descriptor was “augural,” from the verb “to 

augur,” meaning to foretell future events based on current information (as in, “these standards may augur well for 

what the agency might establish in the future”). This is precisely what the MYs 2022-2025 standards presented in 

these documents are – our best estimate of what we would set, based on the information before us today, but 

knowing that future information and thus our future decision may just as well be different as not. 
 

                                                      

 

 

 

57 

able to continue building a single light-duty national fleet that satisfies all requirements under 

both programs while ensuring that consumers still have the full range of vehicle choices that are 

available today. 

Continuing the National Program would ensure that all manufacturers can build a single fleet of 

U.S. vehicles that would satisfy all requirements under both programs as well as under 

California’s program, helping to reduce costs and regulatory complexity while providing 

significant energy security and environmental benefits. President Obama announced plans for 

these rules on July 29, 2011 and NHTSA and EPA issued a Supplemental Notice of Intent (NOI) 

outlining the agencies’ plans for proposing the MY 2017-2025 standards and program.22 The 

State of California and thirteen auto manufacturers representing over 90 percent of U.S. vehicle 

sales provided letters of support for the program concurrent with the Supplemental NOI.23 The 

United Auto Workers (UAW) also supported the announcement.24 

In a notice of proposed rulemaking (NPRM)25, NHTSA proposed CAFE standards and EPA 

Proposed greenhouse gas (GHG) emissions standards for MYs 2017-2025. Supporting that 

NPRM was a Preliminary Regulatory Impact Analysis.26 These standards take into consideration 

significant public input that was received in response to the NPRM from the regulated industry, 

consumer groups, labor unions, states, environmental organizations, a military security nonprofit organization, industry suppliers and dealers, as well as other organizations and by 

thousands of U.S. citizens. 

One aspect of this phase of the National Program that is unique for NHTSA, however, is that the 

passenger car and light truck CAFE standards for MYs 2022-2025 are augural, while EPA’s (and 

also California’s) standards for those model years will be legally binding. Consistent with its 

statutory authority, NHTSA is establishing two phases of passenger car and light truck standards 

for MYs 2017-2025 in this rulemaking action. The first phase, from MYs 2017-2021, includes 

final standards that are required. The second phase of the CAFE program, from MYs 2022­

2025, includes standards that are not final due to the statutory provision that NHTSA shall issue 

regulations prescribing average fuel economy standards for at least 1 but not more than 5 model 

years at a time. The MYs 2022-2025 CAFE standards, then, are not final based on this 

rulemaking, but rather are augural, meaning that they represent the agency’s current best 

estimate, based on the information available to the agency today, of what levels of stringency 

might be maximum feasible in those model years. NHTSA notes that these estimated combined 

22 76 FR 48758 (August 9, 2011). 

23 Commitment letters are available at http://www.nhtsa.gov/fuel-economy (last accessed Aug. 24, 2011). 24 The UAW’s support was expressed in a statement on July 29, 2011, which can be found at 

http://www.uaw.org/articles/uaw-supports-administration-proposal-light-duty-vehicle-cafe-and-greenhouse-gasemissions-r (last accessed September 19, 2011) 

25 76 FR 74854, December 1, 2011, also in NHTSA Docket No. 2010 -0131-0183. 26 “Preliminary Regulatory Impact Analysis, Corporate Average Fuel Economy for MY 2017-2025 Passenger Cars
 

and Light Trucks”, November 2011, NHTSA Docket No. 2010-0131-0167
 
58 

fleet average mpg levels are projections and, in fact NHTSA establishes separate standards for 

passenger cars and trucks, based on a vehicle’s size or “footprint,” and the actual average 

achieved fuel economy and GHG emissions levels are determined by the actual footprints and 

production volumes of the vehicle models that are produced. 

NHTSA will undertake a de novo rulemaking at a later date to set legally binding standards for 

MYs 2022-2025. Concurrent with that de novo rulemaking, the agencies intend to conduct a 

comprehensive mid-term evaluation and agency decision-making process for the MYs 2022­

2025 standards. The mid-term evaluation reflects the rules’ long time frame and, for NHTSA, 

the agency’s statutory obligation to conduct a separate rulemaking in order to establish final 

standards for vehicles for those model years. 

NHTSA examined regulatory alternatives in two ways. First, we examined these alternatives 

considering how maximum feasible standards can be set within the limitations of EPCA/EISA. 

In conducting this “estimated required” or “standard setting” analysis, NHTSA assumes 

manufacturers do not use dedicated alternative fuel vehicles, electric vehicles, plug-in electric 

vehicles, dual-fueled alternative fuel vehicles (through MY 2020), or credits earned for overcompliance to meet the required mpg levels, as directed by 49 U.S.C. 32902(h). 

Second, we conducted more of a real-world analysis of what manufacturers are likely to do under 

CAFE standards and taking advantage of flexibilities and adjustments offered under CAFE 

standards, as actually provided by EPCA/EISA. In conducting this “projected achieved” or “real 

world under EPCA/EISA” analysis, NHTSA assumes manufacturers will use dedicated 

alternative fuel vehicles, electric vehicles, plug-in electric vehicles, dual-fueled alternative fuel 

vehicles (for all model years), and flexibilities allowed in the final rule and credits earned for 

over-compliance to meet the required mpg levels. 

Under both types of analysis, NHTSA assumes some manufacturers will continue, as they have 

done historically, not to meet the standards and instead pay civil penalties for non-compliance, as 

permitted by EPCA. NHTSA also assumes manufacturers will apply A/C efficiency 

improvements and off-cycle technology improvements to meet the standards. 

The analysis contained in this document reflects the impacts that NHTSA believes would result 

from manufacturers increasing the fuel economy of their vehicles in order to meet the stringency 

levels required or projected to be achieved under the different regulatory alternatives. When the 

agency was examining issues that relate to standard setting, then the analysis is based on the 

“estimated required” mpg levels. Thus, analyses in Chapter V on technology relate to the 

amount of technology needed to get to the “estimated required” mpg level. Analyses in Chapter 

X relating to Sensitivity Analyses and Chapter XI on probabilistic uncertainties relate to the 

“estimated required” mpg level. However, estimates of the levels to be achieved by 

manufacturers (Chapter VI), costs and sales (Chapter VII), benefits and fuel savings (Chapter 

VIII), impact of weight reduction on safety (Chapter IX),and net benefits (Chapter X) are based 
59 

on the more real world “projected achieved” mpg levels that are more likely to be achieved by 

the manufacturers. 
 

                                                       

 

 

 

 

60 

II. NEED OF THE NATION TO CONSERVE ENERGY 

The Energy Policy and Conservation Act (EPCA) states that: 

“When deciding maximum feasible average fuel economy ... the Secretary of 

Transportation shall consider technological feasibility, economic practicability, the effect 

of other motor vehicle standards of the Government on fuel economy, and the need of the 

United States to conserve energy.”27 

Thus, EPCA specifically directs the Department to balance the technological and economic 

challenges related to fuel economy with the Nation’s need to conserve energy. The concerns 

about energy security and the effects of energy prices and supply on National economic wellbeing that led to the enactment of EPCA persist today. The demand for petroleum grew in the 

U.S. up through the year 2005, peaking at 20.8 million barrels per day, and has since declined to 

an average of 19.2 million barrels per day in 2010.28 World demand, however, is expected to 

continue to rise until 2035.29 

Since 1970, there have been a series of events that suggest that the behavior of petroleum
 

markets is a matter for public concern. 

	 Average annual crude oil prices rose from $68 per barrel in 2007 to $95 per barrel in 

2008, having peaked at $129 per barrel in July 2008. Prices declined to $37 per barrel in 

January 2009, but then rose to $113 per barrel in April 2011.30 As recently as 1998, 

crude prices averaged about $13 per barrel.31 Gasoline prices more than tripled during 

this ten-year period, from an annual average of $1.07 in 1998 to $3.30 in 2008. As the 

price of oil fluctuates, the price of gasoline also rises and falls, hitting an average of 

$3.96 in April of 2012.32 

27 49 U.S.C. § 32902(f) 28 U.S. Department of Energy, Energy Information Administration, International Energy Statistics, Total Petroleum 

Consumption. See http://www.eia.gov/cfapps/ipdbproject/IEDIndex3.cfm?tid=5&pid=5&aid=2 (last accessed, May 

16, 2012).

29 U.S Department of Energy, Energy Information Administration, International Energy Outlook 2011. See 

http://www.eia.gov/oiaf/ieo/highlights.html (last accessed May 16, 2012). 30 U.S. Department of Energy, Energy Information Administration, Short-Term Energy Outlook, U.S. Refiner 

Average Acquisition Cost per Barrel of Crude Oil. See http://www.eia.gov/emeu/steo/pub/cf_query/index.cfm (last 

accessed May 16, 2012). 

31 Ibid.
 32 U.S. Department of Energy, Energy Information Administration, Weekly Retail and Gasoline Diesel Prices. See
 

http://www.eia.gov/dnav/pet/pet_pri_gnd_dcus_nus_m.htm (last accessed, May 16, 2012). 
 

                                                      

 

 

 

 

 

 

 

61 

	 U.S. domestic petroleum production stood at 10 million barrels per day in 1975, rose 

slightly to 10.6 million barrels per day in 1985, and by 2009 had declined to 7.3 million 

barrels per day.33 Domestic production is predicted to increase through 2020, after which 

it is projected to decrease through 2035, although remaining above current levels.34 

Between 1975 and 2005, U.S. petroleum consumption increased from 16.3 million 

barrels per day to 20.8 million barrels per day.35 In 2009, vehicle miles traveled and 

consumption fell compared to the 2005 levels. Net petroleum imports accounted for 51.5 

percent of U.S. domestic petroleum consumption in 2009.36 Worldwide oil demand is 

fairly inelastic: declining prices do not induce large increases in consumption, while 

higher prices do not significantly restrain consumption. For example, the price of 

unleaded regular gasoline rose from an average of $2.57 in 2006 to $3.25 in 2008 (a 26.5 

percent increase)37 and vehicle miles traveled decreased by 1.3 percent.38 Within the 

United States, demand for gasoline, diesel, and jet fuel within the transportation sector is 

particularly inelastic. 

	 Demand for oil is projected to increase significantly worldwide in the next several 

decades, resulting in upward oil cost pressure. Between 2007 and 2035, total world 

petroleum consumption is expected to grow from 85.9 to 112.2 million barrels per day.39 

	 Foreign oil production facilities, refineries, and supply chains have been disrupted from 

time to time, either by wars, political action by oil producers, civil unrest, or natural 

disasters. 

	 High oil prices, sometimes induced by disruptions in oil markets, have often coincided 

with rising inflation and subsequent economic recessions. 

	 Greenhouse gas emissions from the consumption of petroleum have become a subject of 

increasing public policy concern, both in the United States and internationally. 

Greenhouse gases in general and carbon dioxide were first regulated in the United States 

in the joint EPA and NHTSA greenhouse gas emissions and improve fuel economy 

rulemaking for model years 2012-2016 light-duty vehicles.40 In addition, EPA and 

NHTSA have finalized rules for greenhouse gas emissions and fuel efficiency of model 

years 2014-2018 medium- and heavy-duty engines and vehicles.41 Studies by multiple 

sources suggest that rising atmospheric concentrations of greenhouse gases will damage 

33 U.S. Department of Energy, Energy Information Administration, Monthly Energy Review, April 2012. See 

http://www.eia.gov/totalenergy/data/monthly/pdf/sec3_3.pdf (last accessed May 16, 2012). 34 U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook 2012 Early Release, 

Table A11. Available at http://www.eia.gov/forecasts/aeo/er/pdf/tbla11.pdf (last accessed May 16, 2012). 35 U.S. Department of Energy, Energy Information Administration, Monthly Energy Review, April 2012. See 

http://www.eia.gov/totalenergy/data/monthly/pdf/sec3_7.pdf (last accessed May 16, 2012). 36 Ibid. 37 U.S. Department of Energy, Energy Information Administration, Weekly Retail and Gasoline Diesel Prices. See 

http://www.eia.gov/dnav/pet/pet_pri_gnd_dcus_nus_m.htm (last accessed, May 16, 2012). 38 U.S. Department of Transportation, Federal Highway Administration, Office of Highway Policy Information, 

Quick Find: Vehicle Miles of Travel, Table VM-2 (2006 and 2008). Available at 

http://www.fhwa.dot.gov/policyinformation/quickfinddata/qftravel.cfm (last accessed May 16, 2012). 39 U.S. Department of Energy, Energy Information Administration, International Energy Outlook 2011, Table A5. 

Available at http://www.eia.gov/forecasts/ieo/pdf/ieoreftab_5.pdf (last accessed May 16, 2012). 40 Final Rule published in the Federal Register on May 7, 2010 (75FR 25324). 

41 Final Rule published in the Federal Register on September 15, 2011 (76FR 57106). 
 

                                                      

 

62 

human health and welfare.42 There is a direct linkage between the consumption of fossil 

energy and emissions of the greenhouse gas carbon dioxide, as essentially all of the 

carbon in hydrocarbon fuels is oxidized into carbon dioxide when the fuel is combusted. 

Reducing U.S. fossil petroleum consumption will generally induce a proportional 

reduction in carbon dioxide emissions. 

Energy is an essential input to the U.S. economy, and having a strong economy is essential to 

maintaining and strengthening our National security. Secure, reliable, and affordable energy 

sources are fundamental to economic stability and development. Rising energy demand poses a 

challenge to energy security, given increased reliance on global energy markets. As noted 

above, approximately half of the petroleum consumed in the U.S. is imported. 

Conserving energy, especially reducing the Nation’s dependence on petroleum, benefits the U.S. 

in several ways. Improving energy efficiency has benefits for economic growth and the 

environment, as well as other benefits, such as reducing pollution and improving security of 

energy supply. More specifically, reducing total petroleum use decreases our economy’s 

vulnerability to oil price shocks. Reducing dependence on oil imports from regions with 

uncertain conditions enhances our energy security and can reduce the flow of oil profits to 

certain states now hostile to the U.S. 

These final CAFE standard for MYs 2017-2021 and augural standards for MYs 2022-2025 

encourage conservation of petroleum for transportation by the application of broader use of fuel 

saving technologies, resulting in more fuel-efficient vehicles, i.e., vehicles requiring less fuel 

consumption per unit mile. 

Table II-1 presents historical trend data and projections of the production and consumption of 

petroleum. Increases in domestic petroleum production are expected through 2025 as 

technological advances further the economic recoverability of oil from conventional and 

unconventional resources. Despite the projected increase in domestic production, by 2035 the 

U.S. is expected to remain reliant on foreign sources for over 36 percent of its oil needs. 

Although not shown in Table II-1, the U.S. petroleum consumption is equivalent to U.S. 

petroleum supply. The Energy Information Administration’s measure of U.S. petroleum supply 

exceeds the sum of domestic production and net imports because the EIA’s measure of total 

supply includes renewable fuel and oxygenate plant net production, refinery and blender net 

production, changes in suppliers’ reserve stocks, and adjustments for crude oil, fuel ethanol, 

42 IPCC 2007: Climate Change 2007: Synthesis Report: Contributions of Working Groups I, II, and III to the Fourth 

Assessment Report of the Intergovernmental Panel on Climate Change, [Core writing team, Pachauri, R.K. and 

Reisinger, A. 9eds.)] (Published by the Intergovernmental Panel on Climate Change, 2008). Available at 

http://www.ipcc.ch/pdf/assessment-report/ar4/syr/ar4_syr.pdf (last accessed May 16, 2012). 
 

 

                                                      

 

 

 

 

 

 

 

63 

motor gasoline blending components, and distillate fuel oil. 

Table II-1
 

Petroleum Production and Supply 

(Million Barrels per Day) 

Domestic 

Petroleum 

Production 

43 

Net 

Petroleum 

Imports44 

U.S. 

Petroleum 

Consumption 

45 

World 

Petroleum 

Consumption 

46 

Net Imports 

as a Share of 

U.S. 

Consumption 

47 

1975 10.0 5.8 16.3 56.2 35.8% 

1985 10.6 4.3 15.7 60.1 27.3% 

1995 8.3 7.9 17.7 70.1 44.5% 

2005 6.9 12.5 20.8 84.1 60.3% 

2010 7.5 9.4 19.2 85.7 49.2% 

DOE 

Predictions48, 

49 

2015 8.8 8.2 19.2 93.3 42.7% 

2025 9.2 7.4 19.5 103.2 37.9% 

2035 8.9 7.3 20.1 112.2 36.3% 

43 U.S. Department of Energy, Energy Information Administration, Monthly Energy Review, April 2012. See 

http://www.eia.gov/totalenergy/data/monthly/pdf/sec3_3.pdf (last accessed May 16, 2012). 44 Ibid. 45 Ibid. 46 U.S. Department of Energy, Energy Information Administration, International Energy Statistics, Total Petroleum 

Consumption. See http://www.eia.gov/cfapps/ipdbproject/IEDIndex3.cfm?tid=5&pid=5&aid=2 (last accessed, May 

16, 2012).

47 U.S. Department of Energy, Energy Information Administration, Monthly Energy Review, April 2012. See 

http://www.eia.gov/totalenergy/data/monthly/pdf/sec3_7.pdf (last accessed May 16, 2012). 48 Source of Predictions of Domestic Petroleum Production, Net Petroleum Imports, and U.S. Petroleum 

Consumption: U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook 2012 Early 

Release, Table A11. Available at http://www.eia.gov/forecasts/aeo/er/pdf/tbla11.pdf (last accessed May 16, 2012). 49 Source of Predictions of World Petroleum Consumption: U.S. Department of Energy, Energy Information 

Administration, International Energy Outlook 2011, Table A5. Available at 

http://www.eia.gov/forecasts/ieo/pdf/ieoreftab_5.pdf (last accessed May 16, 2012). 
 

                                                      

64 

Table II-2 shows that light vehicle petroleum consumption made up 74.1 percent of all 

transportation petroleum consumption in 2009. Therefore, reductions in light vehicle petroleum 

consumption resulting from increases in CAFE fuel economy standards will substantively 

support the Nation’s efforts to conserve energy. 

Table II-2 

Petroleum 

Transportation Consumption by Mode 

(Thousand Barrels per Day)50 

Passenger 

Cars 

Light 

Trucks 

Total Light 

Vehicles 

Total 

Transportation 

Light 

Vehicles 

as % of 

Trans. 

1975 4,836 1,245 6,081 8,472 71.8% 

1985 4,665 1,785 6,450 9,536 67.6% 

1995 4,440 2,975 7,415 11,346 65.4% 

2005 5,050 3,840 8,890 14,020 63.4% 

2009 4,662 4,019 8,681 11,708 74.1% 

50 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Transportation Energy Data 

Book, Table 1.13. Available at http://cta.ornl.gov/data/chapter1.shtml (last accessed May 16, 2012). 
 

                                                       

 

65 

III. BASELINE AND ALTERNATIVES
 

A. The Baseline Vehicle Fleet 

1. Why establish a baseline vehicle fleet? 

In order to calculate the impacts of the final rule, it is necessary to estimate the composition of 

the future vehicle fleet absent the new standards. EPA and NHTSA have developed a 

baseline/reference fleet in three steps. The first step was to develop a “baseline” fleet. The 

agencies create a baseline fleet in order to track the volumes and types of fuel economyimproving and CO2-reducing technologies that are already present in the existing vehicle fleet. 

Creating a baseline fleet helps to keep, to some extent, the agencies’ models from adding 

technologies to vehicles that already have these technologies, which would result in “double 

counting” of technologies’ costs and benefits. The second step was to project the baseline fleet 

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

volumes (but, until later steps, not additional levels of technology) that the agencies believe 

would exist in MYs 2017-2025 absent any change due to regulation in 2017-2025. The third 

step was to add technologies to that fleet such that each manufacturer’s average car and truck 

CO2 levels are in compliance with MY 2016 CAFE standards, assuming that manufacturers 

would not make fuel economy improvements beyond what is required by the MY 2016 

standards. This final “reference case” is the light duty fleet estimated to exist in MYs 2017-2025 

without the final CAFE standards. All of the agency’s estimates of fuel economy improvements, 

costs, and societal impacts are developed in relation to the respective reference cases. 

2. Why did the agencies develop two fleet projections for the final rule? 

Although much of the discussion in this and following sections describes the methodology for 

creating a single baseline and reference fleet, for this final rule the agencies actually developed 

two baseline and reference fleets. In the NPRM, the agencies used 2008 MY CAFE certification 

data to establish the “2008-based fleet projection.” 51 The agencies noted that MY 2009 CAFE 

51 2008 based fleet projection is a new term that is the same as the reference fleet. The term is added to clarify when 

we are using the 2008 baseline and reference fleet vs. the 2010 baseline and reference fleet. 
                                                      

66 

certification data was not likely to be representative since it was so dramatically influenced by 

the economic recession (Joint Draft TSD section 1.2.1). The agencies further noted that MY 

2010 CAFE certification data might be available for use in the final rulemaking for purposes of 

developing a baseline fleet (id.). The agencies also stated that a copy of the MY 2010 CAFE 

certification data would be put in the public docket if it became available during the comment 

period. The MY 2010 data was reported by the manufacturers throughout calendar year 2011 as 

the final sales figures were compiled and submitted to the EPA database. Due to the lateness of 

the CAFE data submissions52, it was not possible to submit the new 2010 data into the docket 

during the public comment period. As explained below, however, consistent with the agencies’ 

expectations at proposal, and with the agencies’ standard practice of updating relevant 

information as practicable between proposals and final rules, the agencies are using these data in 

one of the two fleet-based projections we are using to estimate the impacts of the final rules. 

For analysis supporting the NPRM, the agencies developed a forecast of the light vehicle market 

through MY 2025 based on (a) the vehicle models in the MY 2008 CAFE certification data, (b) 

the AEO2011 interim projection of future fleet sales volumes, and (c) the future fleet forecast 

conducted by CSM in 2009. In the proposal, the agencies stated we planned to use MY 2010 

CAFE certification data, if available, for analysis supporting the final rule (Joint Draft TSD, p. 1­

2). The agencies also indicated our intention to, for analysis supporting the final rule, use the 

most recent version of EIA’s AEO, and a market forecast updated relative to that purchased from 

CSM (Joint Draft TSD section 1.3.5). 

For this final rulemaking, the agencies have analyzed the costs and benefits of the standards 

using two different forecasts of the light vehicle fleet through MY 2025. The agencies have 

concluded that the significant uncertainty associated with forecasting sales volumes, vehicle 

technologies, fuel prices, consumer demand, and so forth out to MY 2025, makes it reasonable 

and appropriate to evaluate the impacts of the final CAFE and GHG standards using two 

baselines. One market forecast, similar to the one used for the NPRM, uses corrected data 

regarding the MY2008 fleet, information from AEO 2011, and information purchased from 

CSM. The agencies received comments regarding the market forecast used in the NPRM 

suggesting that updates in several respects could be helpful to the agencies’ analysis of final 

standards; given those comments and since the agencies were already planning to produce an 

updated market forecast, the final rule also contains another market forecast using MY 2010 

CAFE certification data, information from AEO 2012, and information purchased from LMC 

Automotive (formerly JD Powers Forecasting). 

52 Partly due to the earthquake and tsunami in Japan and the significant impact this had on their facilities, some 

manufacturers requested and were granted an extension on the deadline to submit their CAFE data. 
 

67 

Thus, given the volume of information that goes into creating a baseline forecast and given the 

significant uncertainty in any projection out to MY 2025, the agencies think that a reasonable 

way to illustrate the possible impacts of that uncertainty for purposes of this rulemaking is the 

approach taken here of analyzing the effects of the final standards under both the MY 2008­

based baseline and the MY 2010-based baseline. 

3. How was the 2008-based vehicle fleet developed? 

The baseline that EPA developed in consultation with NHTSA for the 2012-2016 final rule was 

comprised of model year 2008 CAFE compliance data (specifically, individual vehicles with 

sales volumes disaggregated at the level of specific engine/transmission combinations) submitted 

by manufacturers to EPA, in part because full MY 2009 data was not available at the time. For 

this NPRM, the agencies chose again to use MY 2008 vehicle data as the basis of the baseline 

fleet, but for different reasons than in the 2012-2016 final rule. First, when the NPRM was 

issued, MY 2008 was the most recent model year for which the industry had what the agencies 

would consider “normal” sales levels. Complete MY 2009 data was available for the industry, 

but in the agencies’ judgment, that model year was disrupted by the economic downturn and the 

bankruptcies of both General Motors and Chrysler. CAFE compliance data shows that there was 

a significant reduction in the number of vehicles sold by both companies and by the industry as a 

whole. These abnormalities led the agencies to conclude that MY 2009 data was likely not 

representative for projecting the future fleet for purposes of this analysis. And second, while 

MY 2010 data is likely more representative for projecting the future fleet, it was not complete 

and available in time for it to be used for the NPRM analysis. Therefore, for purposes of the 

NPRM analysis, the agencies chose to use MY 2008 CAFE compliance data for the baseline 

since it was the latest, most representative transparent data set that we had available. More 

details about how the agencies constructed this baseline fleet can be found in Chapter 1.3 of the 

Joint TSD. 

Between the NPRM and the final rule, the agencies found discrepancies in footprint values for a 

number of vehicles in the MY 2008 CAFE certification data. Specifically, contractors to DOT 

employed to develop a market share model for incorporation into the CAFE model noted that out 

of 1,302 vehicles in the MY 2008-based input file used in the agencies’ NPRM analysis, in 554 

cases, the wheelbase value in the CAFE certification data did not match wheelbase data from 

Ward’s Automotive that the contractor had obtained separately. While wheelbase is not a direct 
 

68 

input to the models used in developing the standards, it is a component of footprint, which is a 

key input in the modeling process. 

Of the reported differences, 287 (51.8%) were less than or equal to 0.1 inch, and 115 (20.8%) 

were greater than 0.1 inch but less than or equal to 0.5 inch. The former set of differences is 

most likely attributable to differences in the number of significant digits in the reported raw data. 

The latter set of differences may also be due to reporting differences or actual measurement 

differences, but would not have a significant impact on the computed footprint value, all other 

things being equal. These differences were not considered further. 

 Of the remaining differences, 14 (2.5%) were greater than 0.5 inch but less than 1 inch. Most 

significantly, 138 (24.9%) of the differences were greater than 1 inch, ranging in value from 1.1 

inch to 23.8 inches. 

To verify these findings, the Ward’s data used by the contractor on wheelbase for the 152 

vehicles with a discrepancy greater than 0.5 inches were compared to wheelbase data from 

Edmunds, cars.com, Motor Trend, and product plans where available, and values reflecting the 

agencies’ best judgment about actual average values was selected. 

As discussed further in the joint TSD, footprint for the 152 vehicles was thus recalculated based 

on corrected wheelbase. In the process of validating the wheelbase data, the agencies noted that 

there were many discrepancies in the track width values, which the agencies also corrected in the 

calculation of the corrected footprints. 

The baseline vehicle fleet for the analysis informing these final rules is the same except for the 

footprint changes to the baseline vehicle fleet used in the MYs 2012-2016 rulemaking, and like 

that baseline, is comprised of publicly-available data to the largest extent possible. Some of the 

technology data included in the MYs 2012-2016 analysis’ baseline fleet was based on 

confidential product plan information about MY 2008 vehicles, specifically, data about which 

vehicles already have low friction lubricants, electric power steering, improved accessories, and 

low rolling resistance tires applied, the agencies no longer consider that information as needing 

to be withheld, because by now all MY 2008 vehicle models are already in the on-road fleet. As 

a result, the agencies are able to make public the exact baseline used in this rulemaking analysis. 
 

                                                      

 

69 

4. How was the projected MY 2017-2025 fleet (the MY2008-based reference 

fleet) developed? 

EPA and NHTSA have based the projection of total car and total light truck sales for MYs 2017­

2025 on projections made by the Department of Energy’s Energy Information Administration 

(EIA). EIA publishes a mid-term projection of national energy use called the Annual Energy 

Outlook (AEO). This projection utilizes a number of technical and econometric models which 

are designed to reflect both economic and regulatory conditions expected to exist in the future. 

In support of its projection of fuel use by light-duty vehicles, EIA projects sales of new cars and 

light trucks. 

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

available made by the Energy Information Administration (EIA). EIA publishes a projection of 

national energy use annually called the Annual Energy Outlook (AEO).53 EIA published its 

Early Annual Energy Outlook for 2011 in December 2010. EIA released updated data to 

NHTSA in February (Interim AEO). The final release of AEO for 2011 came out in April 2011, 

but by that time EPA/NHTSA had already prepared modeling runs for the 2017-2025 NPRM 

using the interim data release to NHTSA. Today’s analysis continues to apply the AEO2011 

early release to the MY2008-based fleet. For the MY2010-based fleet, we have applied the 

AEO2012 early release, which EIA published January 2012. Although EIA has since published 

the final version of AEO2012, it did so in June, after we had already completed our analysis 

supporting today’s final rule. 

Similar to the analyses supporting the MYs 2012-2016 rulemaking, the agencies have used the 

Energy Information Administration’s (EIA’s) National Energy Modeling System (NEMS) to 

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

methodology includes shifting vehicle sales volume, starting after 2007, away from fleets with 

lower fuel economy (the light-truck fleet) towards vehicles with higher fuel economies (the 

passenger car fleet) in order to facilitate compliance with CAFE and GHG MYs 2012-2016 

standards. 

53 Department of Energy, Energy Information Administration, Annual Energy Outlook (AEO) 2011, Early Release. 

Available at http://www.eia.gov/forecasts/aeo/ (last accessed Aug. 15, 2011). 
70 

Because we use our market projections as baselines relative to which we measure the effects of 

new standards, and we attempt to estimate the industry’s ability to comply with new standards 

without changing product mix (i.e., we analyze the effects of potential new standards assuming 

manufacturers will not change fleet composition as a compliance strategy, as opposed to changes 

that might happen due to market forces), the Interim AEO 2011-projected shifts in passenger car 

market share as a result of required fuel economy improvements creates a circularity. Therefore, 

for the current analysis, the agencies developed new projections of passenger car and light truck 

sales shares by running scenarios from the Interim AEO 2011 reference case that first deactivate 

the above-mentioned sales-volume shifting methodology and then hold post-2017 CAFE 

standards constant at MY 2016 levels. This is referred to as the Unforced Reference Case. 

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

by an average of about 5% during 2017-2025. 

In 2017, car and light truck sales are projected to be 10.0 and 5.8 million units, respectively, in 

the MY2008-based fleet. While the total level of sales of 15.8 million units is similar to pre2008 levels, the forecast fractions of car sales in 2017 and beyond are projected to be higher than 

in the 2000-2007 timeframe. Note that EIA’s definition of cars and trucks follows that used by 

NHTSA prior to the MY 2011 CAFE final rule. The MY 2011 CAFE final rule reclassified 

approximately 1 million 2-wheel drive sport utility vehicles from the truck fleet to the car fleet 

and car and truck sales shown above reflect this reclassification. 

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

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

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

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

in fleet makeup shown in the MY2008-based forecast used for the NPRM, EPA and NHTSA 

used a custom long range forecast purchased from CSM Worldwide (CSM). CSM is a wellknown industry analyst, that provided the forecast used by the agencies for the 2012-2016 final 

rule. 

As part of the basis for the market forecast we used in the 2017-2025 NPRM, NHTSA and EPA 

decided to use the forecast from CSM for several reasons. One, CSM uses a ground up approach 

(e.g., looking at the number of plants and capacity for specific engines, transmissions, and 

vehicles) for their forecast, which the agencies believe is a robust forecasting approach. Two, 

CSM agreed to allow us to publish their high level data, on which the forecast is based, in the 

public domain. Three, the CSM forecast covered all the timeframe of greatest relevance to this 

analysis (2017-2025 model years). Four, it provided projections of vehicle sales both by 
 

71 

manufacturer and by market segment. And five, it utilized market segments similar to those used 

in the EPA emission certification program and fuel economy guide, such that the agencies could 

include only the vehicle types covered by the new standards. 

The agencies combined the CSM forecast with data from other sources to create the reference 

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

the baseline fleet with the projection data. This was a complex multistep procedure, which is 

described in more detail in Chapter 1 of the Joint TSD. This procedure was the same as that used 

for the 2012-2016 rule. 

We then projected the CSM forecasts for relative sales of cars and trucks by manufacturer and by 

market segment onto the total sales estimates of AEO 2011. Tables III.A.3-1 and III.A.3-2 

show the resulting projections for the reference 2025 model year and compare these to actual 

sales that occurred in baseline 2008 model year. Both tables show sales using the traditional 

definition of cars and light trucks. 
 

 

 

 

72 

Table III-1 

Annual Sales of Light-Duty Vehicles by Manufacturer in 2008 and Estimated for 2025 – 

MY2008-Based Market Forecast 

Cars Light Trucks Total 

2008 MY 2025 MY 2008 MY 2025 MY 2008 MY 2025 MY 

Aston Martin 1,370 1,182 1,370 1,182 

BMW 291,796 405,256 61,324 145,409 353,120 550,665 

Daimler 208,195 340,719 79,135 101,067 287,330 441,786 

Fiat/Chrysler 542,003 381,829 1,119,397 394,070 1,661,400 775,899 

Ford 654,539 989,401 1,116,354 1,235,185 1,770,893 2,224,586 

Geely/Volvo 55,600 88,039 42,797 55,657 98,397 143,696 

General Motors 1,659,086 1,737,321 1,436,102 1,460,623 3,095,188 3,197,943 

Honda 899,498 1,233,439 612,281 664,579 1,511,779 1,898,018 

Hyundai 270,293 479,443 120,734 365,943 391,027 845,386 

Kia 145,863 260,649 135,589 199,787 281,452 460,436 

Lotus 252 316 252 316 

Mazda 191,326 250,553 111,220 117,619 302,546 368,172 

Mitsubishi 76,701 54,092 24,028 55,600 100,729 109,692 

Nissan 653,121 895,341 370,294 545,889 1,023,415 1,441,229 

Porsche 18,909 40,696 18,797 11,219 37,706 51,915 
 

 

73 

Spyker/Saab 21,706 23,130 4,250 3,475 25,956 26,605 

Subaru 85,629 230,101 112,952 101,592 198,581 331,692 

Suzuki 68,720 96,728 45,938 27,800 114,658 124,528 

Tata 9,596 65,418 55,584 56,805 65,180 122,223 

Tesla 800 31,974 800 31,974 

Toyota 1,143,696 1,942,012 1,067,804 1,376,057 2,211,500 3,318,069 

Volkswagen 291,483 630,163 26,999 154,284 318,482 784,447 

Total 6,981,307 9,836,330 6,870,454 7,414,129 13,851,761 17,250,459 
 

 

 

 

 

 

 

 

74 

Table III-2

 Annual Sales of Light-Duty Vehicles by Market Segment in 2008 and Estimated for 2025 – 

MY2008-Based Market Forecast 

Cars Light Trucks 

2008 MY 2025 MY 2008 MY 2025 MY 

Full-Size Car 829,896 245,355 Full-Size Pickup 1,332,335 1,002,806 

Luxury Car 1,048,341 1,637,410 Mid-Size Pickup 452,013 431,272 

Mid-Size Car 2,103,108 2,713,078 Full-Size Van 33,384 88,572 

Mini Car 617,902 1,606,114 Mid-Size Van 719,529 839,452 

Small Car 1,912,736 2,826,190 Mid-Size MAV* 110,353 548,457 

Specialty Car 469,324 808,183 Small MAV 231,265 239,065 

Full-Size SUV* 559,160 46,978 

Mid-Size SUV 436,080 338,849 

Small SUV 196,424 71,827 

Full-Size CUV* 264,717 671,665 

Mid-Size CUV 923,165 1,259,483 

Small CUV 1,612,029 1,875,703 

Total Sales** 6,981,307 9,836,330 6,870,454 7,414,129 

* MAV – Multi-Activity Vehicle, SUV – Sport Utility Vehicle, CUV – Crossover Utility 

Vehicle 

**Total Sales are based on the classic Car/Truck definition. 

Determining which traditionally-defined trucks will be defined as cars for purposes of this 

analysis using the revised definition established by NHTSA for MYs 2011 and beyond requires 
 

75 

more detailed information about each vehicle model. This is described in greater detail in 

Chapter 1 of the TSD. 

The forecasts obtained from CSM provided estimates of car and truck sales by segment and by 

manufacturer, but not by manufacturer for each market segment. Therefore, NHTSA and EPA 

needed other information on which to base these more detailed projected market splits. For this 

task, the agencies used as a starting point each manufacturer’s sales by market segment from 

model year 2008, which is the baseline fleet. Because of the larger number of segments in the 

truck market, the agencies used slightly different methodologies for cars and trucks. 

The first step for both cars and trucks was to break down each manufacturer’s 2008 sales 

according to the market segment definitions used by CSM. For example, the agencies found that 

Ford’s cars sales in 2008 were broken down as shown in Table III-3: 
76 

Table III-3
 

Breakdown of Ford’s 2008 Car Sales – MY2008 - Based Market Forecast 

Full-size cars 160,857 units 

Mid-size Cars 170,399 units 

Small/Compact Cars 180,249 units 

Subcompact/Mini Cars None 

Luxury cars 87,272 units 

Specialty cars 110,805 units 

EPA and NHTSA then adjusted each manufacturer’s sales of each of its car segments (and truck 

segments, separately) so that the manufacturer’s total sales of cars (and trucks) matched the total 

estimated for each future model year based on AEO and CSM forecasts. For example, as 

indicated in Table III-3, Ford’s total car sales in 2008 were 709,583 units, while the agencies 

project that they will increase to 1,222,532 units by 2025. This represents an increase of 72.3 

percent. Thus, the agencies increased the 2008 sales of each Ford car segment by 72.3 percent. 

This produced estimates of future sales which matched total car and truck sales per AEO and the 

manufacturer breakdowns per CSM. However, the sales splits by market segment would not 

necessarily match those of CSM (shown for 2025 in Table III-1). 

In order to adjust the market segment mix for cars, the agencies first adjusted sales of luxury, 

specialty and other cars. Since the total sales of cars for each manufacturer were already set, any 

changes in the sales of one car segment had to be compensated by the opposite change in another 

segment. For the luxury, specialty and other car segments, it is not clear how changes in sales 

would be compensated. For example, if luxury car sales decreased, would sales of full-size cars 

increase, mid-size cars, and so on? The agencies have assumed that any changes in the sales of 

cars within these three segments were compensated for by proportional changes in the sales of 

the other four car segments. For example, for 2025, the figures in Table III-2 indicate that luxury 

car sales in 2025 are 1,633,410 units. Luxury car sales are 1,048,341 units in 2008. However, 

after adjusting 2008 car sales by the change in total car sales for 2025 projected by EIA and a 
 

77 

change in manufacturer market share per CSM, luxury car sales decreased to 1,539,165 units. 

Thus, overall for 2025, luxury car sales had to increase by 98,245 units or 6 percent. The 

agencies accordingly increased the luxury car sales by each manufacturer by this percentage. 

The absolute decrease in luxury car sales was spread across sales of full-size, mid-size, compact 

and subcompact cars in proportion to each manufacturer’s sales in these segments in 2008. The 

same adjustment process was used for specialty cars and the “other cars” segment defined by 

CSM. 

The agencies used a slightly different approach to adjust for changing sales of the remaining four 

car segments. Starting with full-size cars, the agencies again determined the overall percentage 

change that needed to occur in future year full-size car sales after 1) adjusting for total sales per 

AEO 2010, 2) adjusting for manufacturer sales mix per CSM and 3) adjusting the luxury, 

specialty and other car segments, in order to meet the segment sales mix per CSM. Sales of each 

manufacturer’s large cars were adjusted by this percentage. However, instead of spreading this 

change over the remaining three segments, the agencies assigned the entire change to mid-size 

vehicles. The agencies did so because the CSM data followed the trend of increasing volumes of 

smaller cars while reducing volumes of larger cars. If a consumer had previously purchased a 

full-size car, we thought it unlikely that their next purchase would decrease by two size 

categories, down to a subcompact. It seemed more reasonable to project that they would drop 

one vehicle size category smaller. Thus, the change in each manufacturer’s sales of full-size cars 

was matched by an opposite change (in absolute units sold) in mid-size cars. 

The same process was then applied to mid-size cars, with the change in mid-size car sales being 

matched by an opposite change in compact car sales. This process was repeated one more time 

for compact car sales, with changes in sales in this segment being matched by the opposite 

change in the sales of subcompacts. The overall result was a projection of car sales for model 

years 2017-2025--the reference fleet--which matched the total sales projections of the AEO 

forecast and the manufacturer and segment splits of the CSM forecast. 

As mentioned above, the agencies applied a slightly different process to truck sales, because the 

agencies could not confidently project how the change in sales from one segment preferentially 

went to or came from another particular segment. Some trend from larger vehicles to smaller 

vehicles would have been possible. However, the CSM forecasts indicated large changes in total 

sport utility vehicle, multi-activity vehicle and cross-over sales which could not be connected. 

Thus, the agencies applied an iterative, but straightforward process for adjusting 2008 truck sales 

to match the AEO and CSM forecasts. The first three steps were exactly the same as for cars. 

EPA and NHTSA broke down each manufacturer’s truck sales into the truck segments as defined 
78 

by CSM. The agencies then adjusted all manufacturers’ truck segment sales by the same factor 

so that total truck sales in each model year matched AEO projections for truck sales by model 

year. The agencies then adjusted each manufacturer’s truck sales by segment proportionally so 

that each manufacturer’s percentage of total truck sales matched that forecast by CSM. This 

again left the need to adjust truck sales by segment to match the CSM forecast for each model 

year. 

In the fourth step, the agencies adjusted the sales of each truck segment by a common factor so 

that total sales for that segment matched the combination of the AEO and CSM forecasts. For 

example, projected sales of large pickups across all manufacturers were 932,610 units in 2025 

after adjusting total sales to match AEO’s forecast and adjusting each manufacturer’s truck sales 

to match CSM’s forecast for the breakdown of sales by manufacturer. Applying CSM’s forecast 

of the large pickup segment of truck sales to AEO’s total sales forecast indicated total large 

pickup sales of 1,002,086 units. Thus, we increased each manufacturer’s sales of large pickups 

by 7 percent. The agencies applied the same type of adjustment to all the other truck segments at 

the same time. The result was a set of sales projections which matched AEO’s total truck sales 

projection and CSM’s market segment forecast. However, after this step, sales by manufacturer 

no longer met CSM’s forecast. Thus, we repeated step three and adjusted each manufacturer’s 

truck sales so that they met CSM’s forecast. The sales of each truck segment (by manufacturer) 

were adjusted by the same factor. The resulting sales projection matched AEO’s total truck sales 

projection and CSM’s manufacturer forecast, but sales by market segment no longer met CSM’s 

forecast. However, the difference between the sales projections after this fifth step was closer to 

CSM’s market segment forecast than it was after step three. In other words, the sales projection 

was converging to the desired result. The agencies repeated these adjustments, matching 

manufacturer sales mix in one step and then market segment in the next a total of 19 times. At 

this point, we were able to match the market segment splits exactly and the manufacturer splits 

were within 0.1 percent of our goal, which is well within the needs of this analysis. 

The next step in developing the reference fleets was to characterize the vehicles within each 

manufacturer-segment combination. In large part, this was based on the characterization of the 

specific vehicle models sold in 2008 -- i.e., the vehicles comprising the baseline fleet. EPA and 

NHTSA chose to base our estimates of detailed vehicle characteristics on 2008 sales for several 

reasons. One, these vehicle characteristics are not confidential and can thus be published here 

for careful review by interested parties. Two, because it is constructed beginning with actual 

sales data, this vehicle fleet is limited to vehicle models known to satisfy consumer demands in 

light of price, utility, performance, safety, and other vehicle attributes. 
 

 

                                                      

79 

As noted above, the agencies gathered most of the information about the 2008 baseline vehicle 

fleet from EPA’s emission certification and fuel economy database. The data obtained from this 

source included vehicle production volume, fuel economy, engine size, number of engine 

cylinders, transmission type, fuel type, etc. EPA’s certification database does not include a 

detailed description of the types of fuel economy-improving/CO2-reducing technologies 

considered in this final rule. Thus, the agencies augmented this description with publicly 

available data which includes more complete technology descriptions from Ward’s Automotive 

Group.54 In a few instances when required vehicle information (such as vehicle footprint) was 

not available from these two sources, the agencies obtained this information from publicly 

accessible internet sites such as Motortrend.com and Edmunds.com.55 

The projections of future car and truck sales described above apply to each manufacturer’s sales 

by market segment. The EPA emissions certification sales data are available at a much finer 

level of detail, essentially vehicle configuration. As mentioned above, the agencies placed each 

vehicle in the EPA certification database into one of the CSM market segments. The agencies 

then totaled the sales by each manufacturer for each market segment. If the combination of AEO 

and CSM forecasts indicated an increase in a given manufacturer’s sales of a particular market 

segment, then the sales of all the individual vehicle configurations were adjusted by the same 

factor. For example, if the Prius represented 30 percent of Toyota’s sales of compact cars in 

2008 and Toyota’s sales of compact cars in 2025 was projected to double by 2025, then the sales 

of the Prius were doubled, and the Prius sales in 2025 remained 30 percent of Toyota’s compact 

car sales. 

54 Note that WardsAuto.com is a fee-based service, but all information is public to subscribers. 55 Motortrend.com and Edmunds.com are free, no-fee internet sites. 
 

 

 

 

                                                      

 

80 

5. How was the 2010-based vehicle fleet developed? 

Before the agencies began conducting analysis in support of today’s final rule, CAFE 

certification data for the MY2010 fleet became available. Judging this fleet, though somewhat 

impacted by the recession, to provide a reasonable foundation for the construction of a forecast 

of the future light vehicle market, the agencies developed such a forecast. In doing so, the 

agencies followed the same basic approach, and relied on the same types of supplementing 

publicly- and commercially-available information as applied in developing the MY2008-based 

market forecast. 

As discussed above, similar to the MY2008-based market forecast, most of the information about 

the vehicles that make up the MY2010-based market forecast was gathered from EPA’s emission 

certification and fuel economy database, most of which is available to the public. These data 

included, by individual vehicle model produced in MY 2010, vehicle production volume, fuel 

economy rating for CAFE certification, carbon dioxide emissions, fuel type, fuel injection type, 

EGR, number of engine cylinders, displacement, intake valves per cylinder, exhaust valves per 

cylinder, variable valve timing, variable valve lift, engine cycle, cylinder deactivation, 

transmission type, drive (rear-wheel, all-wheel, etc.), hybrid type (if applicable), and aspiration 

(naturally-aspirated, turbocharged, etc.). In addition to this information about each vehicle 

model produced in MY 2010, the agencies augmented this description with publicly-available 

data which includes more complete technology descriptions from Ward’s Automotive Group.56,57 

As with the 2008 baseline, the agencies also used Edmunds.com and Motortrend.com58,59,60 

Like the MY 2008 baseline fleet and the baseline vehicle fleet used in the MYs 2012-2016 

rulemaking, the MY 2010 baseline vehicle fleet is developed using publicly-available data to the 

largest extent possible. 

The process for creating the 2010 baseline fleet Excel file was streamlined when compared with 

the past rulemaking. EPA and NHTSA worked together to create the baseline using 2010 CAFE 

58 Motortrend.com and Edmunds.com: Used as a source for footprint and vehicle weight data. 

59 Motortrend.com and Edmunds.com are free, no-fee internet sites. 60 A small amount of footprint data from manufacturers’ MY 2008 product plans submitted to the agencies was used
 

in the development of the baseline. 
 

                                                      

 

81 

certification data from EPA’s Verify database. EPA contracted LMC Automotive (formerly JD 

Powers Forecasting) to produce an up to date long range forecast of volumes for the future fleet. 

Using information sources discussed below, NHTSA identified technology and footprint 

information for every vehicle model in the 2010 CAFE certification data. EPA used the forecast 

from LMC Automotive to project the future fleet’s volume projections (a detailed discussion of 

the method used to project the future fleet volumes is in section 1.4.2 of the joint TSD.) 

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

projections available made by the Energy Information Administration (EIA). EIA’s Annual 

Energy Outlook (AEO) projects future energy production, consumption and prices.61 EIA issued 

an “early release” version of AEO 2012 in January 2012. The complete final version of AEO 

2012 was released June 25, 2012, but by that time EPA/NHTSA had already completed analyses 

supporting the final 2017-2025 standards using the interim data release. Similar to the analyses 

supporting the MYs 2012-2016 rulemaking and for the 2008 based fleet projection, the agencies 

have used the Energy Information Administration’s (EIA’s) National Energy Modeling System 

(NEMS) to estimate the future relative market shares of passenger cars and light trucks. 

However, as explained above, NEMS shifts the market toward passenger cars in order to ensure 

compliance with EISA’s requirement that CAFE standards cause the fleet to achieve 35 mpg by 

2020. Because we use our market projection as a baseline relative to which we measure the 

effects of new standards, and we attempt to estimate the industry’s ability to comply with new 

standards without changing product mix (i.e., we analyze the effects of the final rules assuming 

manufacturers will not change fleet composition as a compliance strategy), using the Interim 

AEO 2012-projected shift in passenger car market share as provided by EIA would cause the 

agencies to understate the cost of achieving compliance through additional technology, alone. 

Therefore, for the current analysis, the agencies developed a new projection of passenger car and 

light truck sales shares by using NEMS to run scenarios from the Interim AEO 2012 reference 

case, after first deactivating the above-mentioned sales-volume shifting methodology and 

holding post-2017 CAFE standards constant at MY 2016 levels. Incorporating these changes 

reduced the projected passenger car share of the light vehicle market by an average of about 5% 

during 2017-2025. 

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

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

61 Department of Energy, Energy Information Administration, Annual Energy Outlook (AEO) 2011 2012, Early 

Release. Available at http://www.eia.gov/forecasts/aeo/ (last accessed Aug. 15, 2011April 9, 2012). 
 

82 

agencies also wanted to use the most updated information on Chrysler projections, as the older 

NPRM projection conducted by CSM showed Chrysler sales to be very low in 2025. The 

agencies agree with the Chrysler comments that the NPRM projections are most likely outdated 

and too low with respect to Chrysler’s market share. In order to reflect these changes in fleet 

makeup, EPA and NHTSA used a custom long range forecast purchased from LMC Automotive 

(formerly J.D. Powers Forecasting). . J.D. Powers is a well-known industry analyst. NHTSA and 

EPA decided to use the forecast from LMC Automotive (J.D. Powers Forecasting) for MY2010­

based market forecast for several reasons. First, Like CSM, LMC Automotive uses a ground up 

approach (e.g., looking at the number of plants and capacity for specific engines, transmissions, 

and vehicles) for their forecast, which the agencies believe is a robust forecasting approach. 

Second, LMC Automotive allows us to publish their entire forecast in the public domain. Third, 

the LMC Automotive forecast covered all the timeframe of greatest relevance to this analysis 

(2017-2025 model years). Fourth, it provided projections of vehicle sales both by manufacturer 

and by market segment. Fifth, it utilized market segments similar to those used in the EPA 

emission certification program and fuel economy guide, such that the agencies could include 

only the vehicle types covered by the final standards. And finally, it had a more updated 

projection of Chrysler sales. 

LMC Automotive created a forecast that covered model years 2010-2025. Since the agencies 

used this forecast to generate the reference fleet (i.e., the fleet expected to be sold absent any 

increases in the stringency regulations after the 2016 model year), it is important for the forecast 

to be independent of increases during 2017-2025 in the stringency of CAFE/ GHG standards. 

LMC Automotive does not use the CAFE or GHG standard as an input to their model, and 

specifically had no assumption of increase in stringency in the 2017-2025 time frame. 

The agencies combined the LMC Automotive forecast with data from other sources to create the 

2010 baseline reference fleet projections. 

6. How was the projected MY 2017-2025 fleet (the MY2010-based reference 

fleet) developed? 

The process of producing the MY 2010 baseline 2017-2025 reference fleet involved combining 

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

procedure, which is described in this section. The procedure is new and some of the steps are 

different than those used with the MY2008 baseline fleet projection. 
 

83 

EPA and NHTSA employed a different method from the method used in the NPRM for mapping 

certification vehicles to LMC Automotive (LMC) vehicles. Merging the 2010 baseline data with 

the 2017-2025 LMC data required a thorough mapping of certification vehicles to LMC vehicles 

by individual make and model. One challenge that the agencies faced when determining a 

reference case fleet was that the sales data projected by LMC had different market segmentation 

than the data contained in EPA’s internal database. The joint TSD explains the side-by-side 

comparison of each vehicle model to map the two datasets. 

In the combined EPA certification and LMC data, all 2010 vehicle models were assumed to 

continue out to 2025, though their volumes changed in proportion to LMC projections. Also, 

any new models expected to be introduced within the 2011-2025 timeframe are not included in 

the data. These volumes are reassigned to the existing models to keep the overall fleet volume 

the same. All MYs 2017-2025 vehicles are mapped to the existing vehicles by a process of 

mapping to manufacturer’s future segment volumes. 

As with the comparable step in the MY 2008 baseline 2017-2025 reference fleet process, the 

next step in the agencies’ generation of the reference fleet is one of the more complicated steps 

to explain. First, the 2010 CAFE data was mapped to the LMC segments. Second, the 

breakdown of segment volumes by manufacturer was compared between the LMC and CAFE 

data sets. Third, a correction was applied for Class 2B vehicles (Large Pickup Trucks) in the 

LMC data. Fourth, the individual manufacturer segment multipliers were created by year. And 

finally, the absolute volumes of cars and trucks were normalized (set equal) to the total sales 

estimates of the Early Release of the 2012 Annual Energy Outlook (AEO). The process and 

results are presented in detail in the joint TSD. 

2.	 How are the baselines for today’s final rule different quantitatively 

from the baselines that NHTSA used for the NPRM? 

As discussed above, the current baseline was developed from adjusted MY 2008 compliance data 

and covers MY 2017-2025. This section describes, for the reader’s comparison, some of the 

differences between the current baseline and the MY 2012-2016 CAFE rule baseline. This 

comparison provides a basis for understanding general characteristics and measures of the 

difference between the two baselines. The current baseline, while developed using the same 
 

84 

methods as the baseline used for MY 2012-2016 rulemaking, reflects updates to the underlying 

commercially-available forecast of manufacturer and market segment shares of the future light 

vehicle market. The differences are in input assumptions rather than the basic approach and 

methodology. It also includes changes in various macro economic assumptions underlying the 

AEO forecasts and the use of the AEO Unforced Reference Case. Another change in the market 

input data from the last rulemaking involved our redefinition of the list of manufacturers to 

account for realignment taking place within the industry. 

Estimated vehicle sales: 

The sales forecasts, based on the Energy Information Administration’s (EIA’s) Early Annual 

Energy Outlook for 2011 (Interim AEO 2011) and 2012 (Interim AEO 2012), used in the current 

baselines indicate that the total number of light vehicles expected to be sold during MYs 2012­

2016 is 74.3-79.0 million, or 14.9-15.8 million vehicles annually. NHTSA’s MY 2012-2016 final 

rule forecast, based on AEO 2010, of the total number of light vehicles likely to be sold during 

MY 2012 through MY 2016 was 80 million, or about 16 million vehicles annually. Light trucks 

are expected to make up 36-37 percent of the MY 2016 baseline market forecast in the current 

baseline, compared to 34 percent of the baseline market forecast in the MY 2012-2016 final rule. 

These changes in both the overall size of the light vehicle market and the relative market shares 

of passenger cars and light trucks reflect changes in the economic forecast underlying AEO, 

changes in AEO’s forecast of future fuel prices, and use of the Unforced Reference Case. 

Estimated manufacturer market shares: 

These changes are reflected below in Table III-4, which shows the agency’s sales forecasts for 

passenger cars and light trucks under the current baseline and the MY 2012-2016 final rule. 

There has been a general decrease in MY 2016 forecast overall sales and for all manufacturers, 

with the exception of Chrysler, when the current baseline is compared to that used in the MY 

2012-2016 rulemaking. There were no significant shifts in manufacturers’ market shares 

between the baseline applied for the 2012-2016 final rule and the MY2008-based baseline 

applied for today’s final rule. However, compared to these MY2008-based baselines, the 

MY2010-based baseline applied for today’s final rule shows significantly different market shares 

for some manufacturers (e.g., Fiat/Chrysler). The effect of including the low volume specialty 

manufacturers and accounting for known corporate realignments in the current baseline appear to 

be negligible. There has been a shift in the shares of passenger and non passenger vehicles as 
 

85 

would be expected given that the agency is relying on different underlying assumptions as 

discussed above and in Chapter 1 of the joint TSD. 
86 

Table III-4
 

Sales Forecasts (Production for U.S. Sale in MY 2016, Thousand Units) 
Fleet Passenger Cars Light Trucks 

MY 

Manufacturer Basis NPRM Final NPRM Final 

2008 1 ­ ­ Aston Martin 1 - 2010 1 

2008 383 ­ 184 ­ BMW 383 184 2010 317 107 

2008 245 ­ 136 ­ Daimler 245 136 2010 250 97 

2008 394 ­ 495 ­ Fiat/Chrysler 392 498 2010 725 794 

2008 1,393 ­ 930 ­ Ford 1,393 930 2010 1,354 1,039 

2008 94 ­ 50 ­ Geely 94 50 2010 58 34 

2008 1,444 ­ 1,391 ­ General Motors 1,391 1,444 2010 1,672 1,222 

2008 862 ­ 588 ­ Honda 862 588 2010 1,127 531 

2008 489 ­ 99 ­ Hyundai 489 99 2010 847 136 

2008 512 ­ 124 ­ KIA 512 124 2010 333 46 

2008 ­ ­ Lotus 0 - 2010 

2008 378 ­ 93 ­ Mazda 393 78 2010 258 60 

2008 98 ­ 42 ­ Mitsubishi 80 60 2010 57 13 

2008 869 ­ 410 ­ Nissan 869 410 2010 907 310 

2008 30 ­ 18 ­ Porsche 30 18 2010 19 20 

2008 18 ­ 2 ­ Spyker 18 2 2010 

2008 236 ­ 74 ­ Subaru 236 74 2010 213 94 

2008 94 ­ 21 ­ Suzuki 94 21 2010 43 3 

2008 59 ­ 46 ­ Tata 59 46 2010 29 53 

2008 27 ­ ­ Tesla 27 - 2010 

2008 2,043 ­ 1,159 ­ Toyota 2,043 1,159 2010 1,532 970 

2008 528 ­ 134 ­ Volkswagen 528 134 2010 486 104 

2008 10,198 - 5,997 - Total 10,140 6,055 2010 10,227 5,635

87 
 

88 

Estimated achieved fuel economy levels: 

The corrected MY2008-based market forecast shows an industry-wide combined (passenger car 

and light truck) average fuel economy level of 27.03 mpg, as for the NPRM. Because 

corrections included changes to the regulatory classification of a small number of General 

Motors vehicle models, the industry-wide passenger car average fuel economy decreased slightly 

(from 30.65 mpg to 30.60 mpg), and the industry-wide light truck average fuel economy 

increased slightly (from 22.55 mpg to 22.56 mpg). For nearly all manufacturers’ fleets, the new 

MY2010-based market forecast shows higher baseline CAFE levels than under the corrected 

MY2008-based market forecast, consistent with progress in manufacturers’ application of 

technology to improve fuel economy between MY2008 and MY2010. As a result, the MY2010­

based market forecast shows higher industry-wide average fuel economy levels of 31.6 mpg for 

passenger cars, 23.1 mpg for light trucks, and 27.9 mpg for the combined fleet. These fuel 

economy levels are shown in detail below in Table III-5, which shows manufacturer-specific 

CAFE levels (not counting FFV credits that some manufacturers expect to earn) from the current 

baselines versus the baseline applied for the NPRM. 
89 

Table III-5 

Current Baseline CAFE Levels in MY 2016 versus MY 2012-2016 Rule Making CAFE Levels 

(Passenger Car and Light Truck) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

90 

NPRM Final Rule 

 Passenger 

Car

 Light 

Truck Combined

 Passenger 

Car

 Light 

Truck Combined 

Aston Martin 

18.83 18.83 

19.03 ­

18.83 

.00 ­

.00 

19.03 ­

18.83 

BMW 

27.19 23.03 25.68 

27.39 ­

27.19 

24.07 ­

23.01 

26.46 ­

25.68 

Daimler 

25.50 21.13 23.75 

24.71 ­

25.50 

21.03 ­

21.12 

23.56 ­

23.75 

Fiat/Chrysler 27.74 22.19 24.33 

28.20 ­

27.69 

21.70 ­

22.20 

24.38 ­

24.34 

Ford 

28.24 21.32 24.99 

30.26 ­

28.23 

22.17 ­

21.33 

26.12 ­

24.99 

Geely/Volvo 25.89 21.08 23.99 

28.20 ­

25.89 

22.80 ­

21.07 

25.91 ­

23.98 

General Motors 

28.38 21.45 24.37 

30.35 ­

28.16 

22.47 ­

21.38 

26.43 ­

24.37 

Honda 

33.83 25.02 29.61 

34.54 ­

33.83 

25.12 ­

25.03 

30.84 ­

29.61 

Hyundai 31.74 24.29 30.18 

32.90 ­

31.75 

28.19 ­

24.28 

32.15 ­

30.18 

Kia 

32.70 23.74 30.46 

35.15 ­

32.72 

25.00 ­

23.76 

33.51 ­

30.48 

Lotus 

29.66 29.66 

26.72 ­

29.66 

.00 ­

.00 

26.72 ­

29.66 

Mazda 

30.77 26.40 29.95 

32.04 ­

31.27 

25.20 ­

25.59 

30.48 ­

29.96 

Mitsubishi 

28.86 23.57 26.33 

32.47 ­

27.52 

28.15 ­

23.91 

31.58 ­

26.33 

Nissan 

31.98 22.10 27.97 

32.57 ­

31.98 

23.57 ­

22.09 

29.68 ­

27.96 

Porsche 

26.22 19.98 23.48 

25.40 ­

26.21 

20.51 ­

19.99 

22.63 ­

23.49 

Spyker/Saab 26.54 19.79 25.70 

.00 ­

26.57 

.00 ­

19.81 

.00 ­

25.73 

Subaru 

29.59 27.37 29.03 

29.66 ­

29.57 

30.69 ­

27.34 

29.97 ­

29.00 

Suzuki 

30.77 23.29 29.04 

33.14 ­

30.78 

26.15 ­

23.32 

32.52 ­

29.06 

Tata 

24.58 19.71 22.19 

23.33 ­

24.58 

18.94 ­

19.71 

20.28 ­

22.19 

Tesla 

244.00 244.00 

.00 ­

244.00 

.00 ­

.00 

.00 ­

244.00 

Toyota 35.22 24.26 30.27 

35.39 ­

35.22 

24.13 ­

24.25 

29.97 ­

30.27 

Volkswagen 28.90 20.24 26.60 

31.82 ­

28.91 

24.05 ­

20.22 

30.10 ­

26.60 

Average 30.65 22.56 27.03 

31.58 ­

30.60 

23.12 ­

22.55 

27.94 ­

27.03 
 

                                                      

91 

3. How else has NHTSA looked at the baseline for the final rule? 

NHTSA has also developed an alternative “market-driven” baseline which assumes that 

manufacturers may adopt some fuel-saving measures beyond what is required by the MY 2016 

rule. This baseline, discussed in Section X, below, assumes that manufacturers will compare the 

cost of fuel-saving technologies to consumers to the fuel savings in the first year of operation and 

decide to voluntarily apply those technologies to their vehicles when benefits for the first year 

exceeded costs for the consumer. 

NHTSA sought comment on whether this baseline more accurately predicts the likely state of the 

market in MY 2017 to 2025 than the flat baseline assumption, or whether even more fuel 

technologies would be likely to be adopted in the absence of the proposed rule. Several 

environmental organizations submitted comments on NHTSA’s analysis. The Center for 

Biological Diversity (CBD) commented that the agency’s baseline “suggests a much lower fuel 

efficiency increase driven solely by market forces than actual experience demonstrates occurs.”62 

The Natural Resources Defense Council (NRDC) commented that manufacturers might add 

more technology than required by standards, but that such decisions are too uncertain to be 

included in NHTSA’s baseline projection. The Environmental Defense Fund (EDF) commented 

that, given relatively stable future fuel prices, and given provisions allowing credit transfers 

between manufacturers, manufacturers will not likely overcomply with MY2016 standards, on 

average, after MY2016. The American Council for an Energy-Efficient Economy (ACEEE) 

commented that the historical record contains little evidence of sustained fuel economy increases 

absent sustained increases in fuel economy standards. ACEEE also commented that an 

alternative “non-flat” baseline would reduce NHTSA’s estimates of the benefits (and costs) of 

the new standards, the net effect being a reduction in the cost-effectiveness of the standards, 

because the most cost-effective technologies are the ones that will appear in the alternative 

baseline scenario, leaving the more expensive technologies for the rule to bring into the market. 

In addition, several stakeholders on the “payback period” NHTSA should apply in its analysis. 

EDF indicated that any payback period shorter than five years would not accurately reflect the 

current and forecasted buying trends of consumers. The Sierra Club also submitted comments 

suggesting a five-year payback period. Volkswagen commented that buyers’ preferences will 

suggest payback periods of less than four years. The International Council on Clean 

Transportation (ICCT) commented that analysis in 2010 by David Greene supported an average 

payback period of three years.63 NADA commented that analysis based on a payback period 

62 CBD, p. 6.
 63 Greene, David 2010. “Uncertainty, loss aversion, and markets for energy efficiency”, Energy Economics. 
92 

oversimplifies the calculation of consumer benefits, but did not comment on the payback period 

as basis to estimate the potential that manufacturers might add technology beyond that required 

by regulation. 

NHTSA recognizes the uncertainty inherent in forecasting whether and to what extent the 

average fuel economy level of light-duty vehicles will continue to increase beyond the level 

necessary to meet regulatory standards. However, because market forces could independently 

result in changes to the future light-duty vehicle fleet even in the absence of agency action, to the 

extent they can be estimated, those changes should be incorporated into the baseline. As a result, 

today’s final rule continues to present impacts in terms of two sets of analyses: one assuming 

that the average fleetwide fuel economy for light-duty vehicles will not exceed the minimum 

level necessary to comply with CAFE standards, and one assuming continued improvement in 

average fleetwide fuel economy for light-duty vehicles due to higher market demand for fuelefficient vehicles. 

NHTSA also considered developing and using a vehicle choice model to estimate the extent to 

which sales volumes would shift in response to changes in vehicle prices and fuel economy 

levels. As discussed Chapter V, the agency is currently sponsoring research directed toward 

developing such a model. However, that effort has not yet yielded a choice model ready for 

integration into NHTSA’s analysis. If that effort is successful in the future, the agency will 

consider integrating the model into the CAFE modeling system and using the integrated system 

for future analysis of potential CAFE standards. If the agency does so, we expect that the 

vehicle choice model would impact estimated fleet composition not just under new CAFE 

standards, but also under baseline CAFE standards. 

B. Alternatives examined by the agency, and why NHTSA is proposing the 

Preferred Alternative 

1. What regulatory alternatives has NHTSA considered in this analysis, 

and why? 

In developing today’s MY 2017-25 standards, the agency developed and examined a wide 

variety of alternatives. The No-Action Alternative assumes continuation of MY 2016 standards. 

All other alternatives begin with curves resulting from the agency’s updated curve fitting 
                                                      

93 

analysis (discussed in Chapter V). Curves defining all regulatory alternatives have the same 

constrained linear form (linear on a fuel consumption basis), and define fuel economy targets 

applicable to each vehicle model, based on the vehicle’s footprint: 

1

൨ݐ ܽܶ݊݅ݎ݁݃ ൬ ܰܫܯ൤ ܯܺܣ ൌ ݐ݃݁ݎܶܽ ݐ݌ܿ݁ݎ݁ݐ݊ܫ ൅ ܨݐ݅݊ݎ݌ݐ݋݋ ൈ ݁݌݋݈ܵ ܯ , ൰ݐ ܽܶݎ݁݃ ݔ ܯ ܽ,

Required CAFE level depends not only on the footprints of specific vehicle models, but also on 

the numbers of units produced for sale in the U.S.: 

ൌ ܧܨܣܥ݁݀ݎ݅ݑݍܴ݁ ௜ܱܰܫܶܥܷܦܴܱܲ ௜∑

௜ܱܰܫܶܥܷܦܴܱܲ ∑

௜ݕ݉݋݊݋ܿܧ݈݁ݑܨ

௜

The curves defining fuel economy targets do not depend on fleet mix, and are therefore not 

subject to uncertainty because NHTSA cannot predict with certainty what mix of vehicle 

manufacturers will sell through MY 2025. However, future average required fuel economy 

levels cannot be predicted with certainty, because average fuel economy levels depend on fleet 

mix. 

The agency selected a range of candidate curves that increased in stringency by 2% to 7% 

annually.64 Thus, the majority of the alternatives considered in this rulemaking are defined as 

annual increases in curve stringency—2 percent per year, 3 percent per year, 4 percent per year, 

and so on. NHTSA believes that this approach clearly communicates the requirements of each 

alternative and allows us to identify alternatives that represent different ways to balance 

NHTSA’s statutory requirements under EPCA/EISA. NHTSA has also estimated average 

required fuel economy levels under each alternative, but notes that these estimates are based on 

fleet mix projections that are subject to uncertainty. 

64 The fitted curves from NHTSA’s analysis reflect the maximum application of most technologies, in order to 

adjust for differences in technologies in the MY 2008 fleet. Before applying these annual stringency increases, 

NHTSA adjusted these curves to levels that would produce the same average required fuel economy levels in MY 

2016 as would the actual MY 2016 standards the agency recently promulgated. 
                                                      

 

94 

Each of the listed alternatives represents, in part, a different way in which NHTSA could 

conceivably balance different policies and considerations in setting the standards. The agency 

needs to weigh and balance many factors, such as technological feasibility, economic 

practicability, including lead time considerations for the introduction of technologies and impacts 

on the auto industry, the impacts of the standards on fuel savings and CO2 emissions, and fuel 

savings by consumers, as well as other relevant factors such as safety. For example, the 7% 

Alternative weighs energy conservation and climate change considerations more heavily and 

technological feasibility and economic practicability less heavily. In contrast, the 2% 

Alternative, the least stringent alternative (aside from the No-Action Alternative), places more 

weight on technological feasibility and economic practicability. The “feasibility” of the 

alternatives also may reflect differences and uncertainties in the way in which key economic 

(e.g., the price of fuel and the social cost of carbon) and technological inputs could be assessed 

and estimated or valued. Some technologies will not be available for more than limited 

commercial use in earlier model years, and that even those technologies that could be more 

widely commercialized through MY 2025 cannot all be deployed on every vehicle model in MY 

2017 but require a realistic schedule for more widespread commercialization to be within the 

realm of economically practicability. The preferred alternative, discussed below in Section B.2, 

represents the agency’s tentative conclusion as to how these factors should be balanced to 

produce the maximum feasible standards for MYs 2017-2025. 

In addition to the alternatives defined by curves with stringency that increases evenly at annual 

rates ranging from 2% to 7%, NHTSA is also considering alternatives developed using benefitcost criteria. The agency emphasized benefit-cost-related alternatives in its rulemakings for MY 

2008-2011 and, subsequently, MY 2011 standards. By including such alternatives in its analysis, 

the agency is providing a degree of analytical continuity between the two approaches to defining 

alternatives in an effort to illustrate the similarities and dissimilarities. To that end, we have 

included and analyzed two additional alternatives, one that sets standards at the point where net 

benefits are maximized (labeled “MNB” in the table below), and another that sets standards at 

the point at which total costs are most nearly equal to total benefits (labeled “TCTB” in the table 

below).65 With respect to the first of those alternatives, we note that Executive Order 12866 

65 The stringency indicated by each of these alternatives depends on the value of inputs to NHTSA’s analysis. 

Results presented here for these two alternatives are based on NHTSA’s reference case inputs, which underlie the 

central analysis of the proposed standards. In the accompanying FRIA, the agency presents the results of that 

analysis to explore the sensitivity of results to changes in key economic inputs. Because of numerous changes in 

model inputs (e.g., discount rate, rebound effect, CO2 value, technology cost estimates), our analysis often exhausts 

all available technologies before reaching the point at which total costs equal total benefits. In these cases, the 

stringency that exhausts all available technologies is considered. Also, because the agency’s analysis “carries 

forward” technologies applied in one model year, and also simulates “multiyear planning” (manufacturers’ early 

application of technology to facilitate compliance in later model years), the agency’s estimates of the net benefit 

maximizing and “TCTB” stringencies are subject to interactions between model years. 
95 

focuses attention on an approach that maximizes net benefits. Further, since NHTSA has 

previously set attribute-based CAFE standards at the point at which net benefits are maximized, 

we believe it will be useful and informative to consider the potential impacts of that approach as 

compared to the new approach, which the agency also applied in 2010 for MYs 2012-2016. 

All of the above alternatives were developed in terms of the 2-cycle test that has, to date, 

provided the basis for determining fuel economy levels used to calculate manufacturers’ CAFE 

levels. EPA is responsible for determining these test procedures and calculation methods, and is 

today promulgating changes to fuel economy calculation methods to include adjustments 

reflecting any increases in the efficiency of automotive air conditioners. NHTSA and EPA have 

estimated the average extent to which manufacturers will apply such improvements, and NHTSA 

has adjusted all regulatory alternatives accordingly. 

Table III-6
 

Estimated Average Adjustments (g/mi CO2) Reflecting Air Conditioner Efficiency Increases
 

Model Years Passenger Cars Light Trucks 

2017 5.0 5.0 

2018 5.0 6.5 

2019-2025 5.0 7.2 

NHTSA applied these adjustments as follows: 

1

ݐ݃݁ݎܶܽ ൅ ݐ݉݁݊ݐݏݑ݆݀ܣ ܥܣ

1 ൌ஺஼ ݐ݃݁ݎܶܽ

݈݈݊݃ܽ݋ 	8887 ଶ ܥܱ ݏܽ݉ݎ݃

Where TargetAC is the fuel economy target reflecting AC adjustments, and the 8,887 grams of 

CO2 per gallon reflects the characteristics of indolene, the test fuel used to certify the fuel 

economy of gasoline vehicles. In terms of coefficients defining CAFE standards, NHTSA 

applied the additive adjustment to the Intercept, MinTarget, and MaxTarget terms as follows: 
96 

ଶܱ ൅ ݐ݌ܿ݁ݎ݁ݐ݊ܫ ൌ஺஼ ݐ݌ܿ݁ݎ݁ݐ݊ܫ ݐ݉݁݊ݐݏݑ݆݀ܣ ܥܣ

݊݋݈݈݃ܽ

	8887 ܥ ݏܽ݉ݎ݃

1

ݐ݃݁ݎ݅݊ܶܽܯ ൅ ݐ݉݁݊ݐݏݑ݆݀ܣ ܥܣ

ൌ஺஼ ݐ݃݁ݎ݅݊ܶܽܯ

ܱଶ

݊݋݈݈݃ܽ

ܥ ݏܽ݉ݎ݃

1

8887	

1

ݐ݃݁ݎܶܽݔܽܯ ൅ ݐ݉݁݊ݐݏݑ݆݀ܣ ܥܣ

ൌ஺஼ ݐ݃݁ݎܶܽݔܽܯ

ܱଶ

݊݋݈݈݃ܽ

ܥ ݏܽ݉ݎ݃

1

8887	

For purposes of estimating the incremental effects of new CAFE standards, NHTSA defined a 

No-Action Alternative that assumed MY 2016 standards would remain in effect through MY 

2025, and adjusted these standards based on the assumption that, on average, manufacturers 

would implement AC efficiency improvements reflecting a 4.8 g/mi adjustment. The following 

table presents the range of targets spanned by the resultant curves, as well as NHTSA’s estimates 

of the resultant average required fuel economy levels. As discussed above, while curves are 

fixed, average required fuel economy levels depend on fleet composition, and are therefore 

subject to change. For example, the No-Action Alternative for light trucks is a curve 

(unchanging during MY 2017-2025) specifying a maximum fuel economy target (for the 

smallest light trucks) of 35.07 mpg, a minimum fuel economy target (for the largest light trucks) 

of 25.08 mpg, with targets decreasing between these limits as footprint increases. Based on the 

market agency’s market forecast discussed above, NHTSA estimates that this curve would result 

in average required fuel economy levels that increase gradually from 28.93-29.25 mpg in MY 

2017 to 28.91-29.43 mpg in MY2025, as the light truck fleet mix shifts among models with 

different footprints. 

This table and the ten ensuing tables show the maximum range spanned by the target curve 

defining the standard applicable to each fleet in each model year (e.g., 31.49-42.03 for the 

baseline passenger car standard), as well as the range between results under the two baseline 

market forecasts examined by the agency (e.g., for the MY2017 passenger car fleet, 34.61 under 

the MY2008-based market forecast, and 34.30 under the MY2010-based market forecast, 

resulting in a range of 34.61-34.30 between the two forecasts). 
97 

The standards themselves are not uncertain (except insofar as the MY2022-2025 standards must 

be put in place through a de novo rulemaking, and the MY2017-2021 standards could 

conceivably be revised through rulemaking between now and early MY2015), because, as 

required by EISA/EPCA, they are expressed as mathematical functions defined in terms of an 

attribute related to fuel economy. However, the resultant average required fuel economy levels 

are uncertain, because the average required fuel economy levels will depend on the future 

composition of the new light vehicle market, and the future composition of the new light vehicle 

market is uncertain. While the ranges in average required fuel economy levels shown in the 

following eleven tables show the range between the two baseline market forecasts examined in 

detail by NHTSA, these ranges do not show the full range of uncertainty. In NHTSA’s 

judgment, the composition of the light vehicle market is much more uncertain than reflected by 

the range between the MY2008-based and MY2010-based baseline market forecasts. NHTSA’s 

probabilistic uncertainty analysis, presented below in Chapter XII, accounts for one aspect of 

uncertainty regarding the future fleet’s composition—the relative overall market shares of 

passenger cars and light trucks. 

Table III-7
 

No-Action Alternative
 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 31.49 - 42.03 (38.19 ­ 38.68 ) 25.08 - 35.07 (28.93 ­ 29.25 ) 25.08 - 42.03 (34.30 ­ 34.61 ) 

2018 2010 

2008 31.49 - 42.03 (38.17 ­

 38.69 ) 25.08 - 35.07 (28.91 ­

 29.29 ) 25.08 - 42.03 (34.29 ­

 34.68 ) 

2019 2010 

2008 31.49 - 42.03 (38.15 ­ 38.70 ) 25.08 - 35.07 (28.91 ­ 29.32 ) 25.08 - 42.03 (34.29 ­ 34.76 ) 

2020 2010 

2008 31.49 - 42.03 (38.15 ­

 38.67 ) 25.08 - 35.07 (28.91 ­ 29.30 ) 25.08 - 42.03 (34.33 ­

 34.79 ) 

2021 2010 

2008 31.49 - 42.03 (38.12 ­

 38.70 ) 25.08 - 35.07 (28.90 ­ 29.30 ) 25.08 - 42.03 (34.35 ­ 34.82 ) 

2022 2010 

2008 31.49 - 42.03 (38.15 ­

 38.71 ) 25.08 - 35.07 (28.90 ­

 29.31 ) 25.08 - 42.03 (34.39 ­

 34.86 ) 

2023 2010 

2008 31.49 - 42.03 (38.11 ­ 38.67 ) 25.08 - 35.07 (28.90 ­ 29.36 ) 25.08 - 42.03 (34.40 ­ 34.92 ) 

2024 2010 

2008 31.49 - 42.03 (38.15 ­ 38.70 ) 25.08 - 35.07 (28.92 ­ 29.40 ) 25.08 - 42.03 (34.47 ­ 35.02 ) 

2025 2010 

2008 31.49 - 42.03 (38.12 ­

 38.71 ) 25.08 - 35.07 (28.91 ­

 29.43 ) 25.08 - 42.03 (34.47 ­

 35.08 ) 

This table also shows that although there is no CAFE standard for the combined (passenger car 

and light truck) fleet, the lowest possible requirement would be 25.08 mpg (if the market shifted 
98 

entirely to the very largest light trucks), the highest possible requirement would be 42.08 (if the 

market shifted entirely to the very smallest passenger cars), and NHTSA estimates that the 

overall average fuel economy required of the industry under the No Action Alternative increases 

gradually from 34.53 mpg in MY 2017 to 34.98 mpg in MY 2025, as the market gradually shifts 

toward away from light trucks and toward passenger cars. 

The remaining tables in this section present equivalent information for the other regulatory 

alternatives. For each regulatory alternative, the first table presents the alternative as actually 

examined by the agency, and the second table presents the underlying alternative absent 

adjustments for improvements to automotive air conditioner efficiency for the reader’s easier 

comparison to the CAFE increases analyzed in the MY 2012-2016 rulemaking. As above, for 

each fleet and model year, the fuel economy targets specified by the target curve are presented as 

a range, and the estimated average required fuel economy is presented in parentheses (and 

subject to uncertainty and change related to uncertainty in the agency’s market forecast). 

The “preferred alternative” represents the rates of increase which the agency has tentatively 

concluded are maximum feasible under EPCA/EISA for passenger cars and light trucks 

manufactured in MYs 2017-2025. Section B.2 below discusses why the agency has tentatively 

concluded that the preferred alternative standards are maximum feasible. 
99 

Table III-8
 

Preferred Alternative
 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 32.65 - 43.61 (39.61 ­ 40.10 ) 25.09 - 36.26 (29.08 ­ 29.44 ) 25.09 - 43.61 (35.11 ­ 35.42 ) 

2018 2010 

2008 33.84 - 45.21 (41.05 ­

 41.59 ) 25.20 - 37.36 (29.57 ­

 30.02 ) 25.20 - 45.21 (36.10 ­

 36.52 ) 

2019 2010 

2008 35.07 - 46.87 (42.53 ­ 43.12 ) 25.25 - 38.16 (30.03 ­ 30.60 ) 25.25 - 46.87 (37.08 ­ 37.66 ) 

2020 2010 

2008 36.47 - 48.74 (44.18 ­ 44.82 ) 25.25 - 39.11 (30.65 ­

 31.19 ) 25.25 - 48.74 (38.30 ­ 38.89 ) 

2021 2010 

2008 38.02 - 50.83 (46.05 ­

 46.76 ) 25.25 - 41.80 (32.64 ­ 33.31 ) 25.25 - 50.83 (40.34 ­ 41.00 ) 

2022 2010 

2008 39.79 - 53.21 (48.24 ­ 48.96 ) 26.29 - 43.79 (34.22 ­ 34.90 ) 26.29 - 53.21 (42.32 ­

 43.00 ) 

2023 2010 

2008 41.64 - 55.71 (50.47 ­ 51.24 ) 27.53 - 45.89 (35.82 ­ 36.62 ) 27.53 - 55.71 (44.34 ­ 45.14 ) 

2024 2010 

2008 43.58 - 58.32 (52.86 ­ 53.65 ) 28.83 - 48.09 (37.53 ­ 38.45 ) 28.83 - 58.32 (46.51 ­ 47.42 ) 

2025 2010 

2008 45.61 - 61.07 (55.32 ­

 56.18 ) 30.19 - 50.39 (39.34 ­

 40.28 ) 30.19 - 61.07 (48.74 ­

 49.74 ) 

NHTSA also considered alternatives under which the mathematical functions (i.e., curves) 

defining fuel economy targets were advanced in stringency at constant annual rates ranging from 

2% to 7%, which we believed represented a reasonable range of possible alternative ways the 

agency could balance the required statutory factors to determine the maximum feasible levels of 

improvement in fuel economy that manufacturers could achieve during MYs 2017-2025. 

Because NHTSA developed these curves mathematically (i.e., calculating the gpm-based 

coefficients defining a given model year’s curve by multiplying the coefficients applicable to the 

prior model year by one minus the rate of increase), yet average required fuel economy levels 

depend also on fleet composition, the resultant average required fuel economy levels do not 

progress at precisely the same rates of increase as do the underlying mathematical functions – 

that is, a reader will not be able to calculate the same fuel economy levels by multiplying the 

initial mpg number times 1.03, 1.04, etc., as the agency calculates based on multiplying the curve 

coefficients. While NHTSA recognizes that alternatives based on multiplying mpg levels may 

be easier for some readers to understand, we considered alternatives in terms of multiplying 

curve coefficients instead because it is the actual target curves that are the standards with which 

industry has to comply, and not the estimated mpg levels that result from those target curves in 
100 

the agency’s analysis. Characteristics of these alternatives are summarized in the twelve tables 

appearing below: 

Table III-9
 

2% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 32.16 - 42.95 (39.00 ­ 39.51 ) 25.09 - 37.52 (29.67 ­ 30.10 ) 25.09 - 42.95 (35.09 ­ 35.47 ) 

2018 2010 

2008 32.83 - 43.85 (39.83 ­

 40.35 ) 25.20 - 38.55 (30.31 ­

 30.79 ) 25.20 - 43.85 (35.85 ­

 36.29 ) 

2019 2010 

2008 33.51 - 44.76 (40.61 ­ 41.18 ) 25.25 - 39.48 (30.94 ­ 31.54 ) 25.25 - 44.76 (36.58 ­ 37.16 ) 

2020 2010 

2008 34.21 - 45.70 (41.45 ­

 42.04 ) 25.25 - 40.32 (31.54 ­ 32.12 ) 25.25 - 45.70 (37.36 ­

 37.95 ) 

2021 2010 

2008 34.92 - 46.66 (42.30 ­

 42.94 ) 25.25 - 41.17 (32.20 ­ 32.80 ) 25.25 - 46.66 (38.17 ­ 38.77 ) 

2022 2010 

2008 35.65 - 47.64 (43.19 ­ 43.85 ) 25.25 - 42.03 (32.84 ­ 33.51 ) 25.25 - 47.64 (38.99 ­

 39.64 ) 

2023 2010 

2008 36.39 - 48.63 (44.09 ­ 44.72 ) 25.77 - 42.92 (33.53 ­ 34.25 ) 25.77 - 48.63 (39.84 ­ 40.53 ) 

2024 2010 

2008 37.15 - 49.65 (45.04 ­ 45.69 ) 26.31 - 43.83 (34.27 ­ 35.06 ) 26.31 - 49.65 (40.75 ­ 41.51 ) 

2025 2010 

2008 37.92 - 50.70 (45.96 ­

 46.68 ) 26.86 - 44.76 (34.96 ­

 35.81 ) 26.86 - 50.70 (41.60 ­

 42.45 ) 
101 

Table III-10
 

3% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 32.50 - 43.40 (39.43 ­ 39.93 ) 25.09 - 37.92 (29.90 ­ 30.34 ) 25.09 - 43.40 (35.43 ­ 35.80 ) 

2018 2010 

2008 33.52 - 44.78 (40.67 ­

 41.19 ) 25.20 - 39.37 (30.92 ­

 31.41 ) 25.20 - 44.78 (36.59 ­

 37.04 ) 

2019 2010 

2008 34.58 - 46.20 (41.91 ­ 42.52 ) 25.25 - 40.76 (31.90 ­ 32.51 ) 25.25 - 46.20 (37.73 ­ 38.34 ) 

2020 2010 

2008 35.67 - 47.67 (43.24 ­

 43.83 ) 25.26 - 42.06 (32.86 ­ 33.47 ) 25.26 - 47.67 (38.96 ­ 39.56 ) 

2021 2010 

2008 36.79 - 49.18 (44.58 ­

 45.23 ) 26.06 - 43.41 (33.90 ­ 34.58 ) 26.06 - 49.18 (40.21 ­ 40.86 ) 

2022 2010 

2008 37.96 - 50.75 (46.02 ­ 46.70 ) 26.88 - 44.80 (34.99 ­ 35.70 ) 26.88 - 50.75 (41.54 ­

 42.22 ) 

2023 2010 

2008 39.16 - 52.36 (47.45 ­ 48.16 ) 27.73 - 46.24 (36.09 ­ 36.88 ) 27.73 - 52.36 (42.88 ­ 43.64 ) 

2024 2010 

2008 40.40 - 54.03 (48.99 ­ 49.70 ) 28.61 - 47.72 (37.25 ­ 38.15 ) 28.61 - 54.03 (44.32 ­ 45.16 ) 

2025 2010 

2008 41.67 - 55.75 (50.55 ­

 51.33 ) 29.52 - 49.26 (38.45 ­

 39.39 ) 29.52 - 55.75 (45.76 ­

 46.69 ) 
102 

Table III-11
 

4% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 32.84 - 43.87 (39.87 ­ 40.38 ) 25.09 - 38.32 (30.16 ­ 30.61 ) 25.09 - 43.87 (35.79 ­ 36.17 ) 

2018 2010 

2008 34.24 - 45.74 (41.54 ­

 42.09 ) 25.20 - 40.22 (31.56 ­

 32.07 ) 25.20 - 45.74 (37.37 ­

 37.83 ) 

2019 2010 

2008 35.69 - 47.70 (43.24 ­ 43.89 ) 25.28 - 42.09 (32.89 ­ 33.57 ) 25.28 - 47.70 (38.92 ­ 39.58 ) 

2020 2010 

2008 37.21 - 49.74 (45.11 ­

 45.74 ) 26.36 - 43.91 (34.31 ­ 34.94 ) 26.36 - 49.74 (40.66 ­ 41.29 ) 

2021 2010 

2008 38.79 - 51.87 (47.03 ­

 47.72 ) 27.48 - 45.80 (35.76 ­ 36.47 ) 27.48 - 51.87 (42.42 ­ 43.09 ) 

2022 2010 

2008 40.45 - 54.10 (49.05 ­ 49.77 ) 28.65 - 47.78 (37.31 ­ 38.05 ) 28.65 - 54.10 (44.28 ­

 45.01 ) 

2023 2010 

2008 42.17 - 56.43 (51.15 ­ 51.90 ) 29.87 - 49.86 (38.91 ­ 39.77 ) 29.87 - 56.43 (46.23 ­ 47.04 ) 

2024 2010 

2008 43.97 - 58.85 (53.36 ­ 54.14 ) 31.15 - 52.02 (40.60 ­ 41.57 ) 31.15 - 58.85 (48.28 ­ 49.20 ) 

2025 2010 

2008 45.85 - 61.39 (55.61 ­

 56.48 ) 32.48 - 54.28 (42.33 ­

 43.39 ) 32.48 - 61.39 (50.36 ­

 51.39 ) 
103 

Table III-12
 

5% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 33.19 - 44.34 (40.28 ­ 40.79 ) 25.09 - 38.73 (30.47 ­ 30.92 ) 25.09 - 44.34 (36.16 ­ 36.53 ) 

2018 2010 

2008 34.98 - 46.73 (42.43 ­

 43.00 ) 25.20 - 41.10 (32.19 ­

 32.77 ) 25.20 - 46.73 (38.14 ­

 38.65 ) 

2019 2010 

2008 36.85 - 49.26 (44.66 ­ 45.32 ) 26.10 - 43.48 (33.96 ­ 34.66 ) 26.10 - 49.26 (40.20 ­ 40.87 ) 

2020 2010 

2008 38.84 - 51.93 (47.06 ­

 47.75 ) 27.51 - 45.85 (35.79 ­ 36.45 ) 27.51 - 51.93 (42.42 ­ 43.09 ) 

2021 2010 

2008 40.93 - 54.75 (49.64 ­

 50.36 ) 28.99 - 48.36 (37.73 ­ 38.47 ) 28.99 - 54.75 (44.77 ­ 45.47 ) 

2022 2010 

2008 43.13 - 57.72 (52.33 ­ 53.10 ) 30.55 - 51.01 (39.80 ­ 40.58 ) 30.55 - 57.72 (47.24 ­

 48.01 ) 

2023 2010 

2008 45.46 - 60.86 (55.14 ­ 55.95 ) 32.20 - 53.81 (41.96 ­ 42.88 ) 32.20 - 60.86 (49.84 ­ 50.72 ) 

2024 2010 

2008 47.92 - 64.18 (58.17 ­ 59.03 ) 33.94 - 56.78 (44.28 ­ 45.34 ) 33.94 - 64.18 (52.64 ­ 53.65 ) 

2025 2010 

2008 50.51 - 67.69 (61.32 ­

 62.26 ) 35.78 - 59.91 (46.69 ­

 47.86 ) 35.78 - 67.69 (55.53 ­

 56.66 ) 
104 

Table III-13
 

6% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 33.55 - 44.82 (40.70 ­ 41.23 ) 25.09 - 39.15 (30.78 ­ 31.24 ) 25.09 - 44.82 (36.54 ­ 36.92 ) 

2018 2010 

2008 35.74 - 47.76 (43.37 ­

 43.96 ) 25.26 - 42.01 (32.88 ­

 33.44 ) 25.26 - 47.76 (38.98 ­

 39.48 ) 

2019 2010 

2008 38.07 - 50.90 (46.14 ­ 46.83 ) 26.96 - 44.93 (35.08 ­ 35.79 ) 26.96 - 50.90 (41.53 ­ 42.22 ) 

2020 2010 

2008 40.55 - 54.24 (49.16 ­

 49.87 ) 28.72 - 47.91 (37.37 ­ 38.11 ) 28.72 - 54.24 (44.30 ­ 45.02 ) 

2021 2010 

2008 43.21 - 57.82 (52.38 ­

 53.19 ) 30.60 - 51.10 (39.85 ­ 40.65 ) 30.60 - 57.82 (47.26 ­ 48.03 ) 

2022 2010 

2008 46.03 - 61.64 (55.83 ­ 56.69 ) 32.61 - 54.50 (42.50 ­ 43.35 ) 32.61 - 61.64 (50.42 ­

 51.26 ) 

2023 2010 

2008 49.05 - 65.72 (59.52 ­ 60.41 ) 34.75 - 58.15 (45.30 ­ 46.31 ) 34.75 - 65.72 (53.81 ­ 54.76 ) 

2024 2010 

2008 52.28 - 70.08 (63.48 ­ 64.45 ) 37.03 - 62.04 (48.32 ­ 49.48 ) 37.03 - 70.08 (57.45 ­ 58.56 ) 

2025 2010 

2008 55.72 - 74.74 (67.68 ­

 68.71 ) 39.47 - 66.22 (51.54 ­

 52.83 ) 39.47 - 74.74 (61.29 ­

 62.55 ) 
105 

Table III-14
 

7% Annual Increase Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 33.92 - 45.32 (41.17 ­ 41.70 ) 25.09 - 39.58 (31.13 ­ 31.58 ) 25.09 - 45.32 (36.95 ­ 37.33 ) 

2018 2010 

2008 36.53 - 48.82 (44.33 ­

 44.90 ) 25.82 - 42.94 (33.62 ­

 34.20 ) 25.82 - 48.82 (39.84 ­

 40.35 ) 

2019 2010 

2008 39.34 - 52.60 (47.70 ­ 48.39 ) 27.86 - 46.45 (36.26 ­ 37.00 ) 27.86 - 52.60 (42.93 ­ 43.63 ) 

2020 2010 

2008 42.37 - 56.69 (51.37 ­

 52.11 ) 30.01 - 50.09 (39.06 ­ 39.80 ) 30.01 - 56.69 (46.30 ­ 47.04 ) 

2021 2010 

2008 45.64 - 61.10 (55.36 ­

 56.19 ) 32.33 - 54.03 (42.12 ­ 42.97 ) 32.33 - 61.10 (49.95 ­ 50.76 ) 

2022 2010 

2008 49.17 - 65.87 (59.67 ­ 60.58 ) 34.83 - 58.29 (45.41 ­ 46.34 ) 34.83 - 65.87 (53.88 ­

 54.79 ) 

2023 2010 

2008 52.98 - 71.03 (64.31 ­ 65.26 ) 37.53 - 62.90 (48.97 ­ 50.06 ) 37.53 - 71.03 (58.15 ­ 59.18 ) 

2024 2010 

2008 57.10 - 76.61 (69.38 ­ 70.41 ) 40.45 - 67.89 (52.83 ­ 54.11 ) 40.45 - 76.61 (62.80 ­ 64.01 ) 

2025 2010 

2008 61.54 - 82.64 (74.79 ­

 75.97 ) 43.60 - 73.30 (57.00 ­

 58.42 ) 43.60 - 82.64 (67.75 ­

 69.15 ) 

NHTSA also considered a regulatory alternative under which the stringency in each model year 

was set at a level estimated to maximize net benefits. Executive Order 12866 states that in 

choosing among regulatory alternatives in rulemakings, agencies should select the approach that 

maximizes net benefits (including potential economic, environmental, public health and safety, 

and other advantages; distributive impacts; and equity), unless a statute requires another 

approach. Executive Order 13563, signed by President Obama on January 18, 2011, reiterates 

that agencies should focus on approaches that maximize net benefits, to the extent consistent 

with applicable law. 

In the context of CAFE rulemakings, NHTSA has long considered regulatory alternatives that 

approximate the levels at which net benefits are maximized. Because EPCA/EISA requires that 

CAFE standards be set separately for cars and trucks in each model year, finding the precise 

level at which net benefits are maximized for each fleet, for each year, taking into account all of 

the considerations enumerated by EOs 12866 and 13563, is challenging to say the least. While 

NHTSA accounts for many costs and benefits associated with setting CAFE standards through 

its modeling analysis, we are careful to emphasize that the modeling analysis does not, and 

indeed, cannot capture all possible impacts – some impacts, such as lifecycle maintenance and 
106 

repair costs, for example, are currently too uncertain to quantify and include in the 

analysis. That uncertainty affects our ability to determine the absolute single level of stringency 

for each fleet, for each model year, which reflects perfect maximization of net benefits. 

We have, nevertheless, done our best over multiple rulemakings to approximate in our modeling 

analysis a regulatory alternative that maximizes net benefits. In the rulemaking to establish the 

MY 2011 standards for cars and trucks, for example, NHTSA used the CAFE model to test a 

wide range of potential stringencies for cars and trucks separately, calculating the net benefits 

(i.e., social benefits of standards minus total costs of standards) at each stringency, and then 

identifying the stringency that yielded the highest level of net benefits for that fleet, for that 

single model year and using that as the regulatory alternative that maximized net benefits. 

Because the CAFE model has evolved since that rulemaking, the agency’s ability to use it to 

determine the regulatory alternative that maximizes net benefits has also had to evolve. As the 

CAFE model exists today, it includes the ability to simulate multiyear planning effects—that is, 

the potential that a manufacturer might apply “extra” technology in earlier model years if doing 

so would facilitate compliance with standards in later model years. As discussed below, 

consideration of these effects reveals interdependencies the net benefit maximizing stringencies 

in different model years. 

Thus, for this rulemaking, as for the MYs 2012-2016 rulemaking, the maximum net benefit and 

“total cost = total benefit” regulatory alternatives were developed using the CAFE model to 

perform corresponding optimizations on a year-by-year basis. For example, when estimating 

stringencies at which net benefits are maximized, the model begins by examining MY 2017, 

seeking the car and truck stringencies that would maximize net benefits in MY 2017, without any 

information regarding post-MY 2017 standards. The model then performs a compliance 

simulation for MY 2017; carries resultant technology forward into MY 2018; seeks car and truck 

stringencies that would maximize net benefits in MY 2018; and continues the sequence through 

MY 2025. However, once standards throughout MYs 2017-2025 are “known” at the end of that 

sequence, the compliance simulation in earlier model years is revisited and influenced by 

standards in later model years. For example, the model might add “extra” technology in MY 

2015 to facilitate compliance with expected MY 2019 standards, and carry that technology 

forward to MY 2016 and MY 2017. This extra carried-forward technology could increase the 

net benefits attributed to the MY 2017 standards that had previously been estimated to maximize 

net benefits, absent information regarding post-MY 2017 standards. As a result, standards 

estimated to maximize net benefits on a year-by-year basis do not necessarily produce maximum 

net benefits—in any specific model year or over a series of model years—when standards in all 
 

                                                      

 

 

107 

model years are defined.66 Given economic and technology-related inputs to the agency’s 

analysis, opportunities to add fuel-saving technologies are sometimes “exhausted” before total 

costs reach the level of total benefits; when this occurs in a given model year, this regulatory 

alternative is defined by the stringency leading to this exhaustion of available technology. We 

believe, nevertheless, that this is an appropriate approach given that manufacturers seeking to 

comply with CAFE standards do not consider each model year in isolation, but rather within the 

context of a product plans spanning multiple model years—in other words, manufacturers 

engage in multiyear planning. For example, if a manufacturer is redesigning a vehicle model in 

MY 2012, and does not plan to redesign the vehicle again until MY 2019, the manufacturer is 

likely to consider what standards will be in place between MY 2012 and MY 2019, and factor 

that information into decisions about what technologies to apply to that vehicle. Insofar as 

manufacturers actually engage in such planning, the costs and benefits of new standards over 

time will be affected, and the net benefit maximizing stringencies will also be affected. 

66 As a potential means to address these interactions between model years when standards are defined and multiyear 

planning effects are simulated, Volpe Center staff has experimented with techniques to optimize a steady rate of 

increase. Under this approach, when a given level of stringency in MY 2017 is tested, the post-MY 2017 standards 

are also defined, because they are set at levels reflecting a constant rate of increase in stringency. However, EISA’s 

requirement that the standards be set at the maximum feasible levels in each specific model year precludes the 

presumption that the stringency of standards would increase at a constant rate. On the other hand, testing a wide 

range of both profiles and levels of increases over nine model years poses a technical challenge the agency has not 

determined how best to address for purposes of maximizing net benefits. In the agency’s judgment, further 

conceptual work may be required regarding the maximization of net benefits in each model year when net benefits 

in any given model year depend on the stringency of standards in earlier and later model years. 
                                                      

108 

Table III-15
 

Maximum Net Benefit Alternative
 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 36.95 - 49.33 (44.60 ­ 45.39 ) 27.00 - 44.91 (31.97 ­ 35.72 ) 27.00 - 49.33 (39.12 ­ 41.31 ) 

2018 2010 

2008 38.62 - 51.66 (46.93 ­

 47.52 ) 28.27 - 47.17 (32.90 ­

 37.51 ) 28.27 - 51.66 (40.78 ­

 43.35 ) 

2019 2010 

2008 40.50 - 54.10 (49.10 ­ 49.80 ) 29.59 - 49.29 (35.25 ­ 39.26 ) 29.59 - 54.10 (43.13 ­ 45.47 ) 

2020 2010 

2008 41.76 - 55.90 (50.64 ­ 51.35 ) 30.75 - 51.46 (37.48 ­

 40.86 ) 30.75 - 55.90 (45.13 ­ 47.13 ) 

2021 2010 

2008 42.60 - 57.08 (51.95 ­

 52.46 ) 31.80 - 53.09 (40.94 ­ 42.18 ) 31.80 - 57.08 (47.55 ­ 48.36 ) 

2022 2010 

2008 43.54 - 58.25 (52.75 ­ 53.55 ) 32.54 - 54.51 (41.61 ­ 43.31 ) 32.54 - 58.25 (48.32 ­

 49.52 ) 

2023 2010 

2008 44.38 - 59.42 (53.85 ­ 54.64 ) 32.96 - 55.05 (42.47 ­ 43.85 ) 32.96 - 59.42 (49.37 ­ 50.44 ) 

2024 2010 

2008 45.33 - 60.70 (56.14 ­ 55.80 ) 33.59 - 56.14 (43.36 ­ 44.87 ) 33.59 - 60.70 (51.10 ­ 51.62 ) 

2025 2010 

2008 46.27 - 61.99 (58.20 ­

 56.99 ) 34.86 - 58.33 (44.49 ­

 46.55 ) 34.86 - 61.99 (52.79 ­

 53.08 ) 

Finally, and as mentioned above, NHTSA considered a regulatory alternative under which the 

stringency in each model year was set at a level estimated to produce incremental costs most 

closely equal to incremental benefits. The agency also used the CAFE model to progressively 

estimate stringencies defining this “Total Cost = Total Benefit” or “Zero Net Benefit” 

alternative.67 As above, when technologies are exhausted before total costs reach the level of 

total benefits, this regulatory alternative is defined by the stringency leading to this exhaustion of 

available technology. 

67 The optimization procedures used to develop this regulatory alternative are also subject to the uncertainties and 

inter-MY dependencies discussed in the preceding footnote. 
109 

Table III-16
 

Total Cost = Total Benefit Alternative 

Model Year 

Fleet MY 

Basis 

Passenger Cars Light Trucks Fleet 

Max. Range Est. Range Max. Range Est. Range Max. Range Est. Range 

2017 2010 

2008 38.10 - 50.92 (45.30 ­ 46.83 ) 27.31 - 45.33 (32.26 ­ 36.12 ) 27.31 - 50.92 (39.63 ­ 42.26 ) 

2018 2010 

2008 39.67 - 53.04 (47.17 ­

 48.78 ) 28.48 - 47.39 (33.26 ­

 37.71 ) 28.48 - 53.04 (41.10 ­

 44.12 ) 

2019 2010 

2008 40.92 - 54.74 (49.10 ­ 50.33 ) 29.70 - 49.62 (35.25 ­ 39.46 ) 29.70 - 54.74 (43.13 ­ 45.86 ) 

2020 2010 

2008 42.39 - 56.76 (50.64 ­

 52.14 ) 31.06 - 52.00 (37.48 ­ 41.27 ) 31.06 - 56.76 (45.13 ­ 47.75 ) 

2021 2010 

2008 43.23 - 57.93 (52.47 ­

 53.28 ) 32.11 - 53.63 (41.16 ­ 42.63 ) 32.11 - 57.93 (47.93 ­ 49.02 ) 

2022 2010 

2008 45.12 - 60.38 (54.14 ­ 55.53 ) 32.43 - 54.18 (41.81 ­ 43.09 ) 32.43 - 60.38 (49.18 ­

 50.51 ) 

2023 2010 

2008 46.48 - 62.31 (55.54 ­ 57.26 ) 33.06 - 55.27 (42.69 ­ 44.08 ) 33.06 - 62.31 (50.41 ­ 51.99 ) 

2024 2010 

2008 47.96 - 64.24 (58.53 ­ 59.09 ) 34.12 - 57.13 (43.36 ­ 45.58 ) 34.12 - 64.24 (52.40 ­ 53.79 ) 

2025 2010 

2008 48.91 - 65.64 (60.67 ­

 60.34 ) 34.96 - 58.55 (44.72 ­

 46.81 ) 34.96 - 65.64 (54.23 ­

 55.12 ) 
 

110 

IV. IMPACT OF OTHER GOVERNMENTAL VEHICLE STANDARDS 

ON FUEL ECONOMY 

Introduction 

The Energy Policy and Conservation Act (EPCA or the Act) requires that fuel economy 

standards for passenger cars and light trucks be set at the maximum feasible level after 

considering the following criteria: (1) technological feasibility, (2) economic practicability, (3) 

the impact of other Government standards on fuel economy, and (4) the need of the Nation to 

conserve energy. This section discusses the effects of other government regulations on model 

year (MY) 2017-2025 passenger car and light truck weight, using both MYs 2008 and 2010 as a 

baseline. These effects have not been included in the agency’s analysis of potential 

manufacturer compliance pathways under different regulatory alternatives, because the agency is 

assuming that the manufacturers will be able to reduce overall weight by different amounts 

depending upon the alternative being analyzed. If weight is added to meet the requirements 

imposed by the regulations discussed here, we assume that manufacturers will nevertheless 

remove enough weight from vehicles in order to reach the assumed net weight reduction. This 

assumption was made in the analysis for the NPRM, and no comments were received on it. 

The Impact on Weight of Safety Standards and Voluntary Safety Improvements 

To the extent that safety improvements affect a manufacturer’s ability to improve fuel economy, 

they will typically occur because of adding the necessary technologies to improve safety. The 

necessary technologies to improve safety typically increase vehicle weight, which reduces the 

fuel economy of the vehicle – a heavier vehicle has to do more work (and consume more fuel) to 

travel the same distance as a lighter vehicle. The agency’s estimates of how much weight 

various safety improvements might add are based on cost and weight tear-down studies of a few 

vehicles and are not meant to represent all the variations in all the manufacturers’ fleets, but 

instead represent rough averages of potential per-vehicle weights that could be incurred. 

Consistent with prior analyses, we have broken down our analysis of the impact of safety 

standards that might affect the MY 2017-25 fleets into two parts: 1) those NHTSA final rules 

with known effective dates between 2008 and 2017 (or 2010 and 2017) depending upon the 

baseline fleet, and 2) proposed rules or potential rules in NHTSA’s priority plan that could 

become effective before MY 2025, but do not have effective dates at this time. 
 

 

111 

Weight Impacts of Required Safety Standards (Final Rules with Known Effective Dates) 

NHTSA has issued several safety standards that become effective for passenger cars and light 

trucks between MY 2008 and MY 2018. We will examine the potential impact on passenger car 

and light truck weights for these final rules using MY 2008 as a baseline and using MY 2010 as 

a baseline. 

1. FMVSS 126, Electronic Stability Control 

2. FMVSS 202a, Head Restraints 

3. FMVSS 206, Door Locks 

4. FMVSS 208, 5th Female 35 mph Tests 

5. FMVSS 214, Side Impact Oblique Pole Test 

6. FMVSS 216, Roof Crush 

7. FMVSS 226, Ejection Mitigation 

8. FMVSS 301, Fuel System Integrity 

FMVSS 126, Electronic Stability Control 

The phase-in schedule for vehicle manufacturers is: 

Table IV-1 

Electronic Stability Control Effective Dates Phase-in Schedule 

Model Year Production Beginning Date Requirement 

2009 September 1, 2008 55% with carryover credit 

2010 September 1, 2009 75% with carryover credit 

2011 September 1, 2010 95% with carryover credit 

2012 September 1, 2011 All light vehicles 

The final rule requires all light vehicles to meet the ESC requirements by MY 2012. In 

comparison, the MY 2008 voluntary compliance was estimated as shown in Table IV-2. 
                                                      

 

112 

Table IV-2
 

MY 2008 Voluntary Compliance 

Passenger Cars Light Trucks 

ABS and ESC 36% 64% 

ABS alone 46% 35% 

No systems 18% 1% 

The agency’s analysis68 of weight impacts found that ABS adds 10.7 lb. and ESC adds 1.8 lb. per 

vehicle for a total of 12.5 lb. Based on confidential manufacturers’ plans for voluntary 

installation of ESC in MY 2008, 82 percent of passenger cars would have ABS and 36 percent 

would have ESC. Thus, the MY 2008 weight added by the manufacturers’ plans for passenger 

cars would be 9.42 lb. (0.82*10.7 + 0.36*1.8) and for light trucks would be 11.75 lb. (0.99*0.7 + 

0.64*1.8). 

The incremental weight for the period of MY 2017-2025 compared to the MY 2008 baseline is 

3.08 lb. for passenger cars (12.5 – 9.42 lb.) and 0.75 lb. for light trucks (12.5 – 11.75 lb.) for the 

ESC requirements. 

For the MY 2010 baseline, ESC was required in 95 percent of all light vehicles for MY 2010, so 

that left 5 percent of the fleet that might need ESC. Thus, the weight increase in MY 2010 

would have been 12.0 pounds for passenger cars (12.5 lb.*.95) and 12.3 pounds for light trucks 

(0.99*10.7 + 0.95*1.8). Thus, the incremental weight for the period of MY 2017-2025 

compared to the MY 2010 baseline is 0.5 lb. for passenger cars (12.5 – 12.0 lb.) and 0.2 lb. for 

light trucks (12.5 – 12.3 lb.) for the ESC requirements. 

68 “Final Regulatory Impact Analysis, FMVSS 126, Electronic Stability Control Systems”, March 2007, NHTSA, 

Docket No. 2007-27662-2. 
 

113 

FMVSS 202a, Head Restraints 

An amendment to the head restraints rule increased the height of head restraint by an estimated 

1.3 inches and reduced backset, which brought the head restraint closer to the back of the head. 

The phase-in starts with MY 2010 when 80 percent of the passenger cars and light trucks must 

comply. The average weight increase is estimated by NHTSA to be about 3 pounds for both 

passenger cars and light trucks. Thus, an increase of 3 pounds is assumed for the MY 2008 

baseline (since none of the MY 2008 vehicles would have had this change applied) and 0.6 

pounds for the MY 2010 baseline for both passenger cars and light trucks (3 lb. * (1-0.8)). 

FMVSS 206, Door locks 

A new door lock test for sliding doors took effect in MY 2009. This test was expected to require 

those sliding doors that used a latch/pin mechanism to change to two latches to help keep sliding 

doors closed during crashes. The increase in weight is estimated to be 1.0 lb. Several van 

models had two sliding doors, which would require 2 lb. for two doors. Out of 1.4 million MY 

2003 vans, an estimated 1.2 million doors would be required to change to the two latch system. 

Given that vans were 13.2 percent of light truck sales in MY 2007, it is estimated that in MY 

2009, average light truck weight would be increased by 0.11 lb. for sliding door latches (1.2/1.4 

million * 0.132 * 1 lb.). No increase in weight is anticipated for passenger cars, since no known 

vehicle design that has sliding doors would qualify as a passenger car for CAFE purposes. For 

the MY 2010 baseline, in contrast, there would be no increase in weight resulting from this 

requirement, because the latches were required to be on all vehicles already by MY 2009. 

FMVSS 208, Occupant Crash Protection – 35 mph belted 50th percentile male and 5th percentile 

female testing 

The agency phase-in requirements for 35 mph belted testing with the 50th percentile male were 

35 percent for MY 2008, 65 percent for MY 2009, and 100 percent for MY 2010. The agency 

phase-in requirements for 35 mph belted testing with the 5th percentile female were 35 percent 

for MY 2010, 65 percent for MY 2011, and 100 percent for MY 2012. Several different 

technologies could be used to pass this test, but the agency’s analysis of these countermeasures 

showed no increase in weight was needed, which means that we did not estimate any effect of 

this safety standard on fuel economy for purposes of this analysis. 
                                                      

 

 

 

 

114 

FMVSS 214, Oblique Pole Side Impact Test 

Based on the phase-in requirements for the side impact oblique pole test, all vehicles must meet 

the test by MY 2017. A teardown study of five thorax air bags resulted in an average weight 

increase per vehicle of 4.77 pounds (2.17 kg).69 A second study70 performed teardowns of 5 

window curtain systems. One of the window curtain systems was very heavy (23.45 pounds). 

The other four window curtain systems had an average weight increase per vehicle of 6.78 

pounds (3.08 kg), a figure which we assumed to be average for all vehicles in the future. 

Based on MY 2008 confidential information supplied by manufacturers to NHTSA, most 

vehicles already currently provide head and thorax protection. The estimated percentage of 

vehicles with side air bags with head protection was 99.5 percent of passenger cars and 97.2 

percent of light trucks and torso protection was estimated at 93.0 percent of passenger cars and 

82.5 percent of light trucks. This information indicates that the weight increases for the head and 

thorax air bag countermeasures for the FMVSS 214 oblique pole test for the MY 2017 and later 

vehicles compared to a MY 2008 baseline are 0.37 lb. for passenger cars and 1.02 lb. for light 

trucks. 

During make/model testing, the agency noted that some vehicles did not pass the chest deflection 

criteria even with thorax air bags. This means that additional structure may have to be added for 

some vehicles. Based on confidential information provided in the last fuel economy rulemaking 

from several manufacturers, the side structure of many vehicles has been increased due to the 

side oblique pole test. Based on the confidential information, an average estimate of the weight 

added per vehicle is 12.85 pounds for both passenger cars and light trucks. Based on MY 2008 

certification data, an estimated 6.1 percent of passenger cars and 17.9 percent of light trucks 

certified compliance to the oblique pole test requirements. Because the relative percent of sales 

of certifying models decreased in MY 2010 compared to MY 2008, MY 2010 certification data 

showed slightly less but essentially the same percent of vehicles certified compliance as in MY 

2008 (MY 2010 certification data showed 5.9 percent for passenger cars and 17.6 percent for 

light trucks). Thus, an estimate of the increased structural weight that will be added between 

MY 2008 or MY 2010 and MY 2017 is 12.07 pounds for passenger cars and 10.55 pounds for 

light trucks {(1 - .061)*12.85 pounds and (1 - .179)*12.85 pounds}. 

Combined, the total weight added for FMVSS 214 oblique pole test between MY 2008 or MY 

2010 and MY 2017 is estimated to be 12.43 pounds (0.37 + 10.05) for passenger cars and 11.57 

pounds (1.02 + 10.55) for light trucks. 

FMVSS 216, Roof Crush 

On May 12, 2009, NHTSA issued a final rule amending the roof crush standard from 1.5 times 

the vehicle weight to 3.0 times the vehicle weight for passenger cars and light trucks of 6,000 lb. 

69 Khadilkar, et al. “Teardown Cost Estimates of Automotive Equipment Manufactured to Comply with Motor 

Vehicle Standard – FMVSS 214(D) – Side Impact Protection, Side Air Bag Features”, April 2003, DOT HS 809 

809.
 70 Ludtke & Associates, “Perform Cost and Weight Analysis, Head Protection Air Bag Systems, FMVSS 201”, page 

4-3 to 4-5, DOT HS 809 842.
 
                                                      

 

115 

GVWR or less.71 Vehicles over 6,000 lb. and less than 10,000 lb. GVWR will be required to 

meet the same test, but at 1.5 times the vehicle weight. This rule will apply to all passenger cars 

and light trucks by MY 2017. In the FRIA for that rulemaking, the average passenger car and 

light truck weight was estimated to increase weight by 7.9 to 15.4 lb. The average weight of 

11.65 lb. will be used in this analysis for both the MY 2008 and MY 2010 baselines. 

FMVSS 226 Ejection Mitigation 

On January 19, 2011, the agency published a final rule on ejection mitigation.72 The final rule 

will result in larger window curtain side air bags and for a rollover sensor to be installed. Based 

on cost/weight tear down studies, the agency estimates that there will be an incremental weight 

increase of 0.73 pounds for air bag material and 1.27 pounds for a larger inflator for a total of 2.0 

pounds for passenger cars compared to the side air bags needed for the oblique side pole test. 

The rollover sensor has a very minor weight. For light trucks, of which about 72 percent will 

have 3 rows of curtain coverage instead of 2 rows in most passenger cars, this estimate is 

increased by 25 percent to 2.5 pounds. Thus, for the average light truck the estimate is 2.36 

pounds (0.72*2.5 + 0.28* 2.0) for both the MY 2008 and MY 2010 baselines. 

FMVSS 301 Fuel System Integrity 

NHTSA issued a final rule changing the rear impact test procedure to a 50 mph offset test. The 

phase-in effective dates are 40 percent for MY 2007, 70 percent for MY 2008, and 100 percent 

for MY 2009. Thus, an incremental 30 percent of the fleet needs to meet the standard in 

comparison to the MY 2008 baseline, while all of the MY 2010 vehicles must comply. Several 

different countermeasures could be used to meet the standard. Averaging the most likely two 

countermeasures in the analysis for that rulemaking resulted73 in an estimated 3.7 lb. to 

passenger cars and light trucks. Assuming an incremental 30 percent of the fleet for MY 2009 at 

3.7 lb., results in an increase of 1.11 lb. for the average vehicle under the MY 2008 baseline. 

Weight Impacts of proposed or potential rules that might affect MY 2017 and later vehicles 

Based on NPRMs that the agency has issued, and based on projects in the priority plan, the 

agency has selected a list of rulemakings that might also affect weight in the rulemaking time 

71 Final Regulatory Impact Analysis, FMVSS 216 Upgrade Roof Crush Resistance, (Docket No. NHTSA-2009­

0093-0004) (May 12, 2009) (74 FR 22347) 

72 76 FR 3212, January 19, 2011, The Final Regulatory Impact Analysis is in Docket No. NHTSA-2011-0004-0003.
 73 Improvements in the fuel filler neck and redesigning areas around the fuel tank shield, for example a deformed 

gusset plate punctured the fuel tank wall.
 
                                                      

116 

frame. However, we note that there is no guarantee that these projects will become final rules, 

and therefore estimates of additional weight that might be due to these potential rules are 

included in order to be conservative as to the impacts of other standards on fuel economy. 

Additionally, unless an NPRM has been issued, the weight estimates for these projects remain 

even more uncertain, since we would not have an actual proposed alternative to determine the 

stringency of the proposal. 

1. FMVSS 111, Rear Visibility (Cameras) 

2. Pedestrian Protection 

3. Forward Collision Warning and Crash Imminent Braking 

4. Lane Departure Warning 

5. Oblique/Low Offset Frontal Collision 

6. Event Data Recorders (EDR) 

FMVSS 111, Rear Visibility 

On December 7, 2008, the agency issued a notice of proposed rulemaking (NPRM) on rear 

visibility for passenger cars and light trucks. At this point it appears that cameras are the only 

countermeasure that could meet all the criteria of the proposal. Based on the results of a tear 

down study74, we estimate the weight of a camera assembly with the display in the mirror at 0.68 

lb., and a camera assembly with the display on the dash at 0.26 lb. Assuming a 50-50 split in 

these two display methods, the average weight increase would be 0.47 lb. Based on sales 

information, only a small percent of passenger cars had cameras for MY 2008 and about 5 

percent of the light trucks had cameras. While a larger percent of the fleet has cameras as an 

option in MY 2008, the agency does not have sales figures or take rates on those optional 

systems to update those percentages. Thus, the incremental weights are estimated to be 0.47 lb. 

for passenger cars and 0.45 lb. for light trucks for MY 2008. 

For MY 2010, an estimated 10.5 percent of passenger cars have cameras and 30.1 percent of 

light trucks have cameras, thus, the incremental weights are estimated to be 0.42 lb. for 

passenger cars and 0.33 lb. for light trucks. 

Pedestrian Protection 

74 Will be added to Docket No. NHTSA-2011-0066. 
117 

The agency currently expects to propose the Global Technical Regulation on pedestrian 

protection. The effective dates have not been decided. Potential weight increases for pedestrian 

head and leg protection have not yet been identified, but the leg protection part of the standard 

has the potential to add an unknown amount of weight to the front of the vehicle by changing the 

material used on front end to a softer material. 

Forward Collision Warning and Crash Imminent Braking 

This is a research project in the priority plan that examines forward collision warning, dynamic 

brake support and crash imminent braking. The agency has underway a cost tear down study of 

a variety of these systems. Preliminary information from this cost tear down study shows that 

the forward collision warning system has a camera and adds 0.64 lb., the forward collision 

warning with dynamic brake support systems have radar and add 2.61 to 3.27 lb., and the 

forward collision warning with dynamic brake support and crash imminent braking have radar 

and a camera and add 4.09 to 6.00 lb. Not knowing where the technology might go voluntarily 

or what rulemakings the agency might consider in the future, we put the range of weights into the 

analysis at 0.64 lb. to 6.00 lb. for both MY 2008 and MY 2010 baselines. 

Lane Departure Warning 

This is another research project that could add 0.64 pounds to each vehicle. It could use the 

same camera behind the mirror that might be used for a forward collision warning system 

discussed above. But not all systems discussed above used a camera, some only used radar. 

However, all systems that made up the range of weights in the 0.64 to 6.00 lb. above used 

cameras, thus this weight would not be additive to the weight assumed for forward collision 

warning. 

Oblique or Small Offset Frontal Collision 

The agency has made no decisions on this research project yet, but it does have the potential to 

add many pounds to the front of the vehicle (20-40 lb.) to have structure on the corners of the 

vehicle. 

Part 563 Event Data Recorders 

The agency anticipates about 1.0 pound of additional wiring or modules will be required by some 

manufacturers to meet future potential standards in this area. At this time, this only includes 

requiring the current voluntary standard and does not include other potential updates which have 

not been proposed. Since 92 percent of the current new vehicle fleet has event data recorders, 

the average incremental weight for the fleet is estimated at 0.08 lb. 

Voluntary Measures that could affect weight 

There are other voluntary measures that some manufacturers have identified as potentially 

increasing weight substantially. These include: 

New NCAP tests – these have yet to be proposed, so their impact is not known. 
 

 

118 

IIHS testing of a narrow frontal pole test – how much overlap there is between meeting this test 

and the oblique/low offset frontal collision is not known. Potentially the same countermeasures 

could be designed to meet both projects. 

Summary – Overview of Anticipated Weight Increases 

Table IV-3a summarizes estimates made by NHTSA regarding the weight added by the above 

discussed standards or potential rulemakings with a MY 2008 baseline and Table IV-3b 

summarizes the same for a MY 2010 baseline. NHTSA currently estimates that weight additions 

required by final rules will add 32.31 pounds for passenger cars and 30.09 pounds for light 

trucks. With more uncertainty, we have estimated weight impacts of potential NHTSA 

regulations that would be effective by MY 2025, compared to the MY 2008 fleet, would increase 

weight by 21.19 to 46.55 pounds for passenger cars and 21.17 to 46.53 pounds for light trucks. 

The combined weight increase of these safety standards are estimated at 53.50 to 78.86 pounds 

for passenger cars and 51.26 to 76.62 pounds for light trucks. 

With a MY 2010 baseline, the estimated weight increases required by final rules will add 27.18 

pounds for passenger cars and 26.38 pounds for light trucks. With more uncertainty, we have 

estimated weight impacts of potential NHTSA regulations that would be effective by MY 2025, 

compared to the MY 2010 fleet, would increase weight by 21.14 to 46.50 pounds for passenger 

cars and 21.05 to 46.41 pounds for light trucks. The combined weight increase of these safety 

standards are estimated at 48.32 to 73.68 pounds for passenger cars and 47.43 to 72.79 pounds 

for light trucks. 
 

119 

Table IV-3a
 

NHTSA ESTIMATES 

Weight Additions Due to Final Rules or Potential NHTSA Regulations 

Comparing MY 2025 to the MY 2008 Baseline fleet 

Final Rules by 

FMVSS No. 

Passenger Cars 

Added Weight 

(pounds) 

Passenger Cars 

Added Weight 

(kilograms) 

Light Trucks 

Added Weight 

(pounds) 

Light Trucks 

Added Weight 

(kilograms) 

126 ESC 2.12 0.96 0.29 0.13 

202a Head 

Restraints 

3.00 1.36 3.00 1.36 

206 Door Locks 0.00 0.00 0.11 0.05 

208 5th Female 

35 mph Test 

0.00 0.00 0.00 0.00 

214 Side Pole 

Test 

12.43 5.64 11.57 5.25 

216 Roof Crush 11.65 5.28 11.65 5.28 

226 Ejection 

Mitigation 

2.00 0.91 2.36 1.07 

301 Fuel Tank 1.11 0.50 1.11 0.50 

Final Rules 

Subtotal 

32.31 14.66 30.09 13.64 
 

 

 

120 

Potential Rules 

111 Rear 

Cameras 

0.47 0.21 0.45 0.20 

Pedestrian 

Protection 

? ? ? ? 

Forward 

Collision 

Warning 

0.64 to 6.00 0.29 to 2.72 0.64 to 6.00 0.29 to 2.72 

Lane Departure 

Warning 

Included above Included above Included above Included above 

Oblique/Offset 

Frontal 

20.00 - 40.00 9.07 - 18.14 20.00 - 40.00 9.07 - 18.14 

Part 563 EDR 0.08 0.04 0.08 0.04 

Potential Rules 

Subtotal 

21.19 – 46.55 9.61 – 21.11 21.17 – 46.53 9.60 – 21.10 

Total 53.50 – 78.86 24.27 – 35.77 51.26 – 76.62 23.24 – 34.74 
 

121 

Table IV-3b
 

NHTSA ESTIMATES 

Weight Additions Due to Final Rules or Potential NHTSA Regulations 

Comparing MY 2025 to the MY 2010 Baseline fleet 

Final Rules by 

FMVSS No. 

Passenger Cars 

Added Weight 

(pounds) 

Passenger Cars 

Added Weight 

(kilograms) 

Light Trucks 

Added Weight 

(pounds) 

Light Trucks 

Added Weight 

(kilograms) 

126 ESC 0.50 0.23 0.20 0.09 

202a Head 

Restraints 

0.60 0.27 0.60 0.27 

206 Door Locks 0.00 0.00 0.00 0.00 

208 5th Female 

35 mph Test 

0.00 0.00 0.00 0.00 

214 Side Pole 

Test 

12.43 5.64 11.57 5.25 

216 Roof Crush 11.65 5.28 11.65 5.28 

226 Ejection 

Mitigation 

2.00 0.91 2.36 1.07 

301 Fuel Tank 0 0 0 0 

Final Rules 

Subtotal 

27.18 12.33 26.38 11.96 
 

 

                            

122 

Potential Rules 

111 Rear 

Cameras 

0.42 0.19 0.33 0.15 

Pedestrian 

Protection 

? ? ? ? 

Forward 

Collision 

Warning 

0.64 to 6.00 0.29 to 2.72 0.64 to 6.00 0.29 to 2.72 

Lane Departure 

Warning 

Included above Included above Included above Included above 

Oblique/Offset 

Frontal 

20.00 - 40.00 9.07 - 18.14 20.00 - 40.00 9.07 - 18.14 

Part 563 EDR 0.08 0.04 0.08 0.04 

Potential Rules 

Subtotal 

21.14 – 46.50 9.59 – 21.09 21.05 – 46.41 9.55 – 21.05 

Total 48.32 – 73.68 21.92 – 33.42 47.43 – 72.79 21.51 – 33.01 

[CONFIDENTIAL

Table IV‐4 provides a comparison of NHTSA estimates to those provided confidentially by ].
                                                       

 

123 

V.	 FUEL ECONOMY ENHANCING TECHNOLOGIES AND THE CAFE 

MODEL 

What attribute and mathematical function do the agencies use, and why? 

As in the MYs 2012-2016 CAFE rule, and as NHTSA did in the MY 2011 CAFE rule, NHTSA 

is proposing to set attribute-based CAFE standards that are defined by a mathematical function. 

EPCA, as amended by EISA, expressly requires that CAFE standards for passenger cars and 

light trucks be based on one or more vehicle attributes related to fuel economy, and be expressed 

in the form of a mathematical function.75 Public comments on the MYs 2012-2016 rulemaking 

widely supported attribute-based standards. 

Under an attribute-based standard, every vehicle model has a fuel economy target, the level of 

which depends on the vehicle’s attribute (for this final rule, footprint, as discussed below). The 

manufacturers’ fleet average performance is determined by the harmonic production-weighted76 

average of those targets. 

NHTSA believes an attribute-based standard is preferable to a single-industry-wide average 

standard in the context of CAFE standards for several reasons. First, if the shape is chosen 

properly, every manufacturer is more likely to be required to continue adding more fuel efficient 

technology each year across their fleet, because the stringency of the compliance obligation will 

depend on the particular product mix of each manufacturer. Therefore a maximum feasible 

attribute-based standard will tend to require greater fuel savings and CO2 emissions reductions 

overall than would a maximum feasible flat standard (that is, a single mpg level applicable to 

every manufacturer). 

Second, depending on the attribute, attribute-based standards reduce the incentive for 

manufacturers to respond to CAFE standards in ways harmful to safety.77 Because each vehicle 

model has its own target (based on the attribute chosen), properly fitted attribute-based standards 

provide little, if any, incentive to build smaller vehicles simply to meet a fleet-wide average, 

because the smaller vehicles will be subject to more stringent compliance targets.78 

75 49 U.S.C. 32902(a)(3)(A). 76 Production for sale in the United States. 

77 The 2002 NAS Report described at length and quantified the potential safety problem with average fuel economy 

standards that specify a single numerical requirement for the entire industry. See 2002 NAS Report at 5, finding 12. 

Ensuing analyses, including by NHTSA, support the fundamental conclusion that standards structured to minimize 

incentives to downsize all but the largest vehicles will tend to produce better safety outcomes than flat standards.

78 Assuming that the attribute is related to vehicle size. 
                                                      

124 

Third, attribute-based standards provide a more equitable regulatory framework for different 

vehicle manufacturers.79 A single industry-wide average standard imposes disproportionate cost 

burdens and compliance difficulties on the manufacturers that need to change their product plans 

to meet the standards, and puts no obligation on those manufacturers that have no need to change 

their plans. As discussed above, attribute-based standards help to spread the regulatory cost 

burden for fuel economy more broadly across all of the vehicle manufacturers within the 

industry. 

Fourth, attribute-based standards better respect economic conditions and consumer choice, as 

compared to single-value standards. A flat, or single-value standard, encourages a certain 

vehicle size fleet mix by creating incentives for manufacturers to use vehicle downsizing as a 

compliance strategy. Under a footprint-based standard, manufacturers are required to invest in 

technologies that improve the fuel economy of the vehicles they sell rather than shifting the 

product mix, because reducing the size of the vehicle is generally a less viable compliance 

strategy given that smaller vehicles have more stringent regulatory targets. 

As in the MYs 2012-2016 CAFE rules, and as NHTSA did in the MY 2011 CAFE rule, NHTSA 

is setting CAFE standards that are based on vehicle footprint, which has an observable 

correlation to fuel economy and emissions. There are several policy and technical reasons why 

NHTSA believes that footprint is the most appropriate attribute on which to base the standards, 

even though some other vehicle attributes (notably curb weight) are better correlated to fuel 

economy and emissions. 

First, in the agency’s judgment, from the standpoint of vehicle safety, it is important that the 

CAFE and CO2 standards be set in a way that does not encourage manufacturers to respond by 

selling vehicles that are in any way less safe. While NHTSA’s research of historical crash data 

also indicates that reductions in vehicle mass that are accompanied by reductions in vehicle 

footprint tend to compromise vehicle safety, footprint-based standards provide an incentive to 

use advanced lightweight materials and structures that would be discouraged by weight-based 

standards, because manufacturers can use them to improve a vehicle’s fuel economy and CO2 

emissions without their use necessarily resulting in a change in the vehicle’s fuel economy and 

emissions targets. 

Further, although we recognize that weight is better correlated with fuel economy than is 

footprint, we continue to believe that there is less risk of “gaming” (changing the attribute(s) to 

achieve a more favorable target) by increasing footprint under footprint-based standards than by 

increasing vehicle mass under weight-based standards—it is relatively easy for a manufacturer to 

add enough weight to a vehicle to decrease its applicable fuel economy target a significant 

amount, as compared to increasing vehicle footprint. We also continue to agree with concerns 

79 Id. at 4-5, finding 10. 
                                                      

 

125 

raised in 2008 by some commenters on the MY 2011 CAFE rulemaking that there would be 

greater potential for gaming under multi-attribute standards, such as those that also depend on 

weight, torque, power, towing capability, and/or off-road capability. As presented in NHTSA’s 

MY 2011 CAFE final rule,80 we anticipate that the possibility of gaming is lowest with footprintbased standards, as opposed to weight-based or multi-attribute-based standards. Specifically, 

standards that incorporate weight, torque, power, towing capability, and/or off-road capability in 

addition to footprint would not only be more complex, but by providing degrees of freedom with 

respect to more easily-adjusted attributes, they could make it less certain that the future fleet 

would actually achieve the average fuel economy levels projected by the agency. 

NHTSA recognizes that based on economic and consumer demand factors that are external to 

this rule, the distribution of footprints in the future may be different (either smaller or larger) 

than what is projected in this rule. However, NHTSA continues to believe that there will not be 

significant shifts in this distribution as a direct consequence of this proposed rule. The agency 

also recognizes that some international attribute-based standards use attributes other than 

footprint and that there could be benefits for a number of manufacturers if there was greater 

international harmonization of fuel economy and GHG standards for light-duty vehicles, but this 

is largely a question of how stringent standards are and how they are tested and enforced. It is 

entirely possible that footprint-based and weight-based systems can coexist internationally and 

not present an undue burden for manufacturers if they are carefully crafted. Different countries 

or regions may find different attributes appropriate for basing standards, depending on the 

particular challenges they face—from fuel prices, to family size and land use, to safety concerns, 

to fleet composition and consumer preference, to other environmental challenges besides climate 

change. NHTSA anticipates working more closely with other countries and regions in the future 

to consider how to address these issues in a way that least burdens manufacturers while 

respecting each country’s need to meet its own particular challenges. 

NHTSA continues to find that footprint is the most appropriate attribute upon which to base the 

proposed standards, but recognizing strong public interest in this issue, for the proposal we 

sought comment on whether the agency should consider setting standards for the final rule based 

on another attribute or another combination of attributes. If commenters suggested that the 

agency should consider another attribute or another combination of attributes, we specifically 

requested that commenters address the concerns raised in the paragraphs above regarding the use 

of other attributes, and explain how standards should be developed using the other attribute(s) in 

a way that contributes more to fuel savings and CO2 reductions than the footprint-based 

standards, without compromising safety Comments on the choice of attribute (or attributes) are 

summarized and discussed below and in Section IV of the preamble to today’s rule. 

80 See 74 FR at 14359 (Mar. 30, 2009). 
 

 

                                                      

 

 

 

 

126 

For the MY 2011 CAFE rule, NHTSA estimated fuel economy levels after normalization for 

differences in technology.81 Starting with the technology adjusted passenger car and light truck 

fleets, NHTSA used minimum absolute deviation (MAD) regression without sales weighting to 

fit a logistic form as a starting point to develop mathematical functions defining the standards. 

NHTSA then identified footprints at which to apply minimum and maximum values (rather than 

letting the standards extend without limit) and transposed these functions vertically (i.e., on a 

gpm basis, uniformly downward) to produce the promulgated standards. In the preceding rule, 

for MYs 2008-2011 light truck standards, NHTSA examined a range of potential functional 

forms, and concluded that, compared to other considered forms, the constrained logistic form 

provided the expected and appropriate trend (decreasing fuel economy as footprint increases), 

but avoided creating “kinks” the agency was concerned would provide distortional incentives for 

vehicles with neighboring footprints.82 

For the MYs 2012-2016 rules, NHTSA and EPA re-evaluated potential methods for specifying 

mathematical functions to define fuel economy and GHG standards. The agencies concluded 

that the constrained logistic form, if applied to post-MY 2011 standards, would likely contain a 

steep mid-section that would provide undue incentive to increase the footprint of midsize 

passenger cars.83 The agencies judged that a range of methods to fit the curves would be 

reasonable, and used a minimum absolute deviation (MAD) regression without sales weighting 

on a technology-adjusted car and light truck fleet to fit a linear equation. This equation was used 

as a starting point to develop mathematical functions defining the standards as discussed above. 

The agencies then identified footprints at which to apply minimum and maximum values (rather 

than letting the standards extend without limit) and transposed these constrained/piecewise linear 

functions vertically (i.e., on a gpm or CO2 basis, uniformly downward) to produce the fleet-wide 

fuel economy and CO2 emission levels for cars and light trucks described in the final rule.84 

By requiring NHTSA to set CAFE standards that are attribute-based and defined by a 

mathematical function, Congress appears to have wanted the post-EISA standards to be datadriven – a mathematical function defining the standards, in order to be “attribute-based,” should 

reflect the observed relationship in the data between the attribute chosen and fuel economy.85 

The relationship between fuel economy and footprint, though directionally clear (i.e., fuel 

81 See 74 FR 14196, 14363-14370 (Mar. 30, 2009) for NHTSA discussion of curve fitting in the MY 2011 CAFE 

final rule. 

82 See 71 FR 17556, 17609-17613 (Apr. 6, 2006) for NHTSA discussion of “kinks” in the MYs 2008-2011 light 

truck CAFE final rule (there described as “edge effects”). A “kink,” as used here, is a portion of the curve where a 

small change in footprint results in a disproportionally large change in stringency. 

83 75 FR at 25362 

84 See generally 74 FR at 49491-96; 75 FR at 25357-62. 85 A mathematical function can be defined, of course, that has nothing to do with the relationship between fuel 

economy and the chosen attribute – the most basic example is an industry-wide standard defined as the mathematical 

function average required fuel economy = X, where X is the single mpg level set by the agency. Yet a standard that 

is simply defined as a mathematical function that is not tied to the attribute(s) would not meet the requirement of 

EISA. 
                                                      

 

 

127 

economy tends to decrease with increasing footprint), is theoretically vague and quantitatively 

uncertain; in other words, not so precise as to a priori yield only a single possible curve.86 There 

is thus a range of legitimate options open to NHTSA in developing curve shapes. The agency 

may of course consider statutory objectives in choosing among the many reasonable alternatives. 

For example, curve shapes that might have some theoretical basis could lead to perverse 

outcomes contrary to the intent of the statute to conserve energy.87 Thus, the decision of how to 

set the target curves cannot always be just about most “clearly” using a mathematical function to 

define the relationship between fuel economy and the attribute; it often has to have a normative 

aspect, where the agency adjusts the function that would define the relationship in order to avoid 

perverse results, improve equity of burden across manufacturers, preserve consumer choice, etc. 

This is true both for the decisions that guide the mathematical function defining the sloped 

portion of the target curves, and for the separate decisions that guide our choice of “cut-points” 

(if any) that define the fuel economy and footprints at each end of the curves where the curves 

become flat. Data informs these decisions, but how the agency defines and interprets the 

relevant data, and then the choice of methodology for fitting a curve to the data, must include a 

consideration of both technical concerns and policy goals. 

Each of the CAFE standards that NHTSA is setting today for passenger cars and light trucks is 

expressed as a mathematical function that defines a fuel economy target applicable to each 

vehicle model and, for each fleet, establishes a required CAFE level determined by computing 

the sales-weighted harmonic average of those targets. We emphasize that whenever NHTSA 

shows required CAFE mpg levels, they are estimated required levels based on NHTSA’s current 

projection of manufacturers’ vehicle fleets in MYs 2017–2025. Actual required levels are not 

determined until the end of each model year, when all of the vehicles produced by a 

manufacturer in that model year are known and their compliance obligation can be determined 

with certainty. The target curves, as defined by the constrained linear function, and as embedded 

in the function for the sales-weighted harmonic average, are the real “standards.” 

NHTSA has determined passenger car fuel economy targets using a constrained linear function 

defined according to the following formula: 

86 In fact, numerous manufacturers have confidentially shared with the agencies what they described as “physics 

based” curves, with each OEM showing significantly different shapes, and footprint relationships. The sheer variety 

of curves shown to the agencies further confirm the lack of an underlying principle of “fundamental physics” driving 

the relationship between CO2 emission or fuel consumption and footprint, and the lack of an underlying principle to 

dictate any outcome of the agencies’ establishment of footprint-based standards. 87 For example, if the agencies set weight-based standards defined by a steep function, the standards might 

encourage manufacturers to keep adding weight to their vehicles to obtain less stringent targets. 
128 

1 TARGET    1 1   MIN MAX c  FOOTPRINT  d, ,     a b    

Here, TARGET is the fuel economy target (in mpg) applicable to vehicles of a given footprint 

(FOOTPRINT, in square feet), b and a are the function’s lower and upper asymptotes (also in 

mpg), respectively, c is the slope (in gallons per mile per square foot) of the sloped portion of the 

function, and d is the intercept (in gallons per mile) of the sloped portion of the function (that is, 

the value the sloped portion would take if extended to a footprint of 0 square feet. The MIN and 

MAX functions take the minimum and maximum, respectively of the included values. 

NHTSA is finalizing for this rule, consistent with the proposal and the standards for MYs 2011­

2016, that the CAFE level required of any given manufacturer be determined by calculating the 

production-weighted harmonic average of the fuel economy targets applicable to each vehicle 

model: 

ܱܰܫܶܥܷܦܴܱܲ ∑

ܧܨܣܥ௤௘௥௨௜௥௘ௗ ൌ ௜ ௜

௜ ∑ ܱܰܫܶܥܷܦܴܱܲ

௜ܶܧܩܴܣܶ

௜

PRODUCTIONi is the number of units produced for sale in the United States of each i

th unique 

footprint within each model type, produced for sale in the United States, and TARGETi is the 

corresponding fuel economy target (according to the equation shown above and based on the 

corresponding footprint), and the summations in the numerator and denominator are both 

performed over all unique footprint and model type combinations in the fleet in question. 

The proposed standards for passenger cars are, therefore, specified by the four coefficients 

defining fuel economy targets: 

a = upper limit (mpg) 

b = lower limit (mpg) 

c = slope (gallon per mile per square foot) 

d = intercept (gallon per mile) 

For light trucks, NHTSA is proposing to define fuel economy targets in terms of a mathematical 

function under which the target is the maximum of values determined under each of two 

constrained linear functions. The second of these establishes a “floor” reflecting the MY 2016 

standard, after accounting for estimated adjustments reflecting increased air conditioner 

efficiency. This prevents the target at any footprint from declining between model years. The 
                                                      

129 

resultant mathematical function is as follows: 

ܶܧܩܴܣܶ

ൌ ܯ ܺܣ ൮ 1 1 , ൲

൨

1

݂ ቁ , 1

1 ݄, ൅ ܰܶܫܱܱܴܶܲܨ ൈ ݃ቀ ܺܣܯ൤ ܰܫܯ ቃ ݁

ܾ ቁ , 1

ܽ

݀, ൅ ܰܶܫܱܱܴܶܲܨ ൈ ܿቀ ܺܣܯቂ ܰܫܯ

The proposed standards for light trucks are, therefore, specified by the eight coefficients defining 

fuel economy targets: 

a = upper limit (mpg) 

b = lower limit (mpg) 

c = slope (gallon per mile per square foot) 

d = intercept (gallon per mile) 

e = upper limit (mpg) of “floor” 

f = lower limit (mpg) of “floor” 

g = slope (gallon per mile per square foot) of “floor” 

h = intercept (gallon per mile) of “floor” 

Why are standards attribute-based and defined by a mathematical function? 

As in the MYs 2012-2016 CAFE/GHG rules, and as NHTSA did in the MY 2011 CAFE rule, 

NHTSA is promulgating attribute-based CAFE standards that are defined by a mathematical 

function. EPCA, as amended by EISA, expressly requires that CAFE standards for passenger 

cars and light trucks be based on one or more vehicle attributes related to fuel economy, and be 

expressed in the form of a mathematical function.88 Public comments on the MYs 2012-2016 

rulemaking widely supported attribute-based standards for NHTSA’s standards. Comments 

received on the MY 2017 and later proposal also generally supported an attribute-based standard, 

as further discussed in sections II.C and IV of the preamble to today’s final rule. 

Under an attribute-based standard, every vehicle model has a performance target (fuel economy 

and CO2 emissions for CAFE standards, respectively), the level of which depends on the 

vehicle’s attribute (for this rule, footprint, as discussed below). The manufacturers’ fleet average 

88 49 U.S.C. 32902(a)(3)(A). 
                                                      

 

130 

performance is determined by the production-weighted89 average (for CAFE, harmonic average) 

of those targets. 

NHTSA believes that an attribute-based standard is preferable to a single-industry-wide average 

standard in the context of CAFE standards for several reasons. First, if the shape is chosen 

properly, every manufacturer is more likely to be required to continue adding more fuel efficient 

technology each year across their fleet, because the stringency of the compliance obligation will 

depend on the particular product mix of each manufacturer. Therefore a maximum feasible 

attribute-based standard will tend to require greater fuel savings and CO2 emissions reductions 

overall than would a maximum feasible flat standard (that is, a single mpg or CO2 level 

applicable to every manufacturer). 

Second, depending on the attribute, attribute-based standards reduce the incentive for 

manufacturers to respond to CAFE standards in ways harmful to safety.

90 Because each vehicle 

model has its own target (based on the attribute chosen), properly fitted attribute-based standards 

provide little, if any, incentive to build smaller vehicles simply to meet a fleet-wide average, 

because the smaller vehicles will be subject to more stringent compliance targets.91 

Third, attribute-based standards provide a more equitable regulatory framework for different 

vehicle manufacturers.92 A single industry-wide average standard imposes disproportionate cost 

burdens and compliance difficulties on the manufacturers that need to change their product plans 

to meet the standards, and puts no obligation on those manufacturers that have no need to change 

their plans. As discussed above, attribute-based standards help to spread the regulatory cost 

burden for fuel economy more broadly across all of the vehicle manufacturers within the 

industry. 

Fourth, attribute-based standards better respect economic conditions and consumer choice, as 

compared to single-value standards. A flat, or single value, standard encourages a certain 

vehicle size fleet mix by creating incentives for manufacturers to use vehicle downsizing as a 

compliance strategy. Under a footprint-based standard, manufacturers have greater incentive 

(compared to under a flat standard) to invest in technologies that improve the fuel economy of 

the vehicles they sell rather than shifting product mix, because reducing the size of the vehicle is 

generally a less viable compliance strategy given that smaller vehicles have more stringent 

regulatory targets. 

89 Production for sale in the United States. 

90 The 2002 NAS Report described at length and quantified the potential safety problem with average fuel economy 

standards that specify a single numerical requirement for the entire industry. See 2002 NAS Report at 5, finding 12.
 

Ensuing analyses, including by NHTSA, support the fundamental conclusion that standards structured to minimize 

incentives to downsize all but the largest vehicles will tend to produce better safety outcomes than flat standards.

91 Assuming that the attribute is related to vehicle size. 

92 Id. at 4-5, finding 10.
 
 

                                                      

 

131 

What attribute is NHTSA adopting, and why? 

As in the MYs 2012-2016 CAFE/GHG rules, and as NHTSA did in the MY 2011 CAFE rule, 

NHTSA is promulgating CAFE standards that are based on vehicle footprint, which has an 

observable correlation to fuel economy and emissions. There are several policy and technical 

reasons why NHTSA believes that footprint is the most appropriate attribute on which to base 

the standards for the vehicles covered by this rulemaking, even though some other light-duty 

vehicle attributes (notably curb weight) are better correlated to fuel economy and emissions. 

First, in NHTSA’s judgment, from the standpoint of vehicle safety, it is important that the CAFE 

standards be set in a way that does not encourage manufacturers to respond by selling vehicles 

that are less safe. NHTSA’s research of historical crash data has found that reductions in vehicle 

size and reductions in the mass of lighter vehicles tend to compromise overall highway safety, 

while reductions in the mass of heavier vehicles tend to improve overall highway safety. If 

footprint-based standards are defined in a way that creates relatively uniform burden for 

compliance for vehicles of all sizes, then footprint-based standards will not incentivize 

manufacturers to downsize their fleets as a strategy for compliance, which could compromise 

societal safety, or to upsize their fleets which might reduce the program’s fuel savings and GHG 

emission reduction benefits. Footprint-based standards also enable manufacturers to apply 

weight-efficient materials and designs to their vehicles while maintaining footprint, as an 

effective means to improve fuel economy and reduce GHG emissions. On the other hand, 

depending on their design, weight-based standards can create disincentives for manufacturers to 

apply weight-efficient materials and designs. This is because weight-based standards would 

become more stringent as vehicle mass is reduced. NHTSA discusses mass reduction and its 

relation to safety in more detail in Preamble section II.G. 

Further, although we recognize that weight is better correlated with fuel economy and CO2 

emissions than is footprint, we continue to believe that there is less risk of “gaming” (changing 

the attribute(s) to achieve a more favorable target) by increasing footprint under footprint-based 

standards than by increasing vehicle mass under weight-based standards—it is relatively easy for 

a manufacturer to add enough weight to a vehicle to decrease its applicable fuel economy target a 

significant amount, as compared to increasing vehicle footprint. We also continue to agree with 

concerns raised in 2008 by some commenters on the MY 2011 CAFE rulemaking that there 

would be greater potential for gaming under multi-attribute standards, such as those that also 

depend on weight, torque, power, towing capability, and/or off-road capability. NHTSA agrees 

with the assessment first presented in NHTSA’s MY 2011 CAFE final rule93 that the possibility 

93 See 74 FR at 14359 (Mar. 30, 2009). 
                                                      

 

 

 

132 

of gaming an attribute-based standard is lowest with footprint-based standards, as opposed to 

weight-based or multi-attribute-based standards. Specifically, standards that incorporate weight, 

torque, power, towing capability, and/or off-road capability in addition to footprint would not 

only be more complex, but by providing degrees of freedom with respect to more easily-adjusted 

attributes, they could make it less certain that the future fleet would actually achieve the average 

fuel economy and CO2 reduction levels projected by NHTSA.94 This is not to say that a 

footprint-based system will eliminate gaming, or that a footprint-based system will eliminate the 

possibility that manufacturers will change vehicles in ways that compromise occupant protection. 

In NHTSA’s judgment, footprint-based standards achieved the best balance among affected 

considerations. 

NHTSA recognizes that based on economic and consumer demand factors that are external to 

this rule, the distribution of footprints in the future may be different (either smaller or larger) 

than what is projected in this rule. However, NHTSA continues to believe that there will not be 

significant shifts in this distribution as a direct consequence of this rule. We note that comments 

by CBD, ACEEE, and NACAA referenced a 2011 study by Whitefoot and Skerlos, “Design 

incentives to increase vehicle size created from the U.S. footprint-based fuel economy 

standards.”95 This study concluded that the proposed MY 2014 standards “create an incentive to 

increase vehicle size except when consumer preference for vehicle size is near its lower bound 

and preference for acceleration is near its upper bound.”96 The commenters who cited this study 

generally did so as part of arguments in favor of flatter standards (i.e., curves that are flatter 

across the range of footprints) for MYs 2017-2025. While NHTSA considers the concept of the 

Whitefoot and Skerlos analysis to have some potential merits, it is also important to note that, 

among other things, the authors assumed different inputs than NHTSA actually used in the MYs 

2012-2016 rules regarding the baseline fleet, the cost and efficacy of potential future 

technologies, and the relationship between vehicle footprint and fuel economy. Were NHTSA to 

use the Whitefoot and Skerlos methodology (e.g., methods to simulate manufacturers’ potential 

decisions to increase vehicle footprint) with the actual inputs to the MYs 2012-2016 rules, 

NHTSA would likely obtain different findings. Underlining the potential uncertainty, 

considering a range of scenarios, the authors obtained a wide range of results in their analyses. 

NHTSA discusses this study more fully in the Section II of the preamble and in this RIA. 

NHTSA also recognizes that some international attribute-based standards use attributes other 

than footprint and that there could be benefits for a number of manufacturers if there was greater 

94However, for heavy-duty pickups and vans not covered by today’s standards, the agencies determined that use of 

footprint and work factor as attributes for heavy duty pickup and van GHG and fuel consumption standards could 

reasonably avoid excessive risk of gaming. See 76 FR 57106, 57161-62 (Sept. 15, 2011) 

95 Whitefoot, K.S. and Skerlos, S.J., “Design Incentives to Increase Vehicle Size Created from the U.S. Footprintbased Fuel Economy Standards,” Energy Policy, Vol. 41, Issue 1, 2012, DOI: 10.1016/j.enpol.2011.10.062. 

Prepublication version available at: http://designscience.umich.edu/alumni/katie/Whitefoot_Skerlos_Footprint.pdf 96 Id., see Abstract, p. 1. 
                                                      

133 

international harmonization of fuel economy and GHG standards for light-duty vehicles, but this 

is largely a question of how stringent standards are and how they are tested and enforced. It is 

entirely possible that footprint-based and weight-based systems can coexist internationally and 

not present an undue burden for manufacturers if they are carefully crafted. Different countries 

or regions may find different attributes appropriate for basing standards, depending on the 

particular challenges they face—from fuel prices, to family size and land use, to safety concerns, 

to fleet composition and consumer preference, to other environmental challenges besides climate 

change. NHTSA anticipates working more closely with other countries and regions in the future 

to consider how to address these issues in a way that least burdens manufacturers while 

respecting each country’s need to meet its own particular challenges. 

In the proposal, NHTSA found that footprint was the most appropriate attribute upon which to 

base the proposed standards. Recognizing strong public interest in this issue, NHTSA sought 

comment on whether a different attribute or combination of attributes should be considered in 

setting standards for the final rule. NHTSA specifically requested that the commenters address 

the concerns raised in the proposal regarding the use of other attributes, and explain how 

standards should be developed using the other attribute(s) in a way that contributes more to fuel 

savings and CO2 reductions than the footprint-based standards, without compromising safety. 

NHTSA received several comments regarding the attribute(s) upon which new CAFE standards 

should be based. NADA97 and the Consumer Federation of America (CFA)98 expressed support 

for attribute-based standards, generally, indicating that such standards accommodate consumer 

preferences, level the playing field between manufacturers, and remove the incentive to push 

consumers into smaller vehicles. Many commenters, including automobile manufacturers, 

NGOs, trade associations and parts suppliers (e.g., General Motors,99 Ford,100 American 

Chemistry Council,101 Alliance of Automobile Manufacturers,102 International Council on Clean 

Transportation,103 Insurance Institute for Highway Safety,104 Society of the Plastics Industry,105 

Aluminum Association,106 Motor and Equipment Manufacturers Association,107 and others) 

expressed support for the continued use of vehicle footprint as the attribute upon which to base 

CAFE standards, citing advantages similar to those mentioned by NADA and CFA. Conversely, 

the Institute for Policy Integrity (IPI) at the New York University School of Law questioned 

97 NADA, Docket No. NHTSA-2010-0131-0261, at 11. 

98 CFA, Docket No. EPA-HQ-OAR-2010-0799-9419, at 8, 44. 

99 GM, Docket No. NHTSA-2010-0131-0236, at 2. 100 Ford, Docket No. NHTSA-2010-0131-0235, at 8.
 101 ACC, Docket No. NHTSA-2010-0131-0095, at 2.
 102 Alliance, Docket No. NHTSA-2010-0131-0262, at 85. 103 ICCT, Docket No. NHTSA-2010-0131-0258, at 48. 104 IIHS, Docket No. NHTSA-2010-0131-0222, at 1.
 105 SPI, Docket No. EPA-HQ-OAR-2010-0799-9492, at 4.
 106 Aluminum Association, Docket No. NHTSA-2010-0131-0226, at 1.
 107 MEMA, Docket No. EPA-HQ-OAR-2010-0799-9478, at 1.
 
 

                                                      

 

 

134 

whether non-attribute-based (flat) or an alternative attribute basis would be preferable to 

footprint-based standards as a means to increase benefits, improve safety, reduce “gaming,” 

and/or equitably distribute compliance obligations.108 IPI argued that, even under flat standards, 

credit trading provisions would serve to level the playing field between manufacturers. IPI 

acknowledged that NHTSA, unlike EPA, is required to promulgate attribute-based standards, and 

agreed that a footprint-based system could have much less risk of gaming than a weight-based 

system. IPI suggested that NHTSA consider a range of options, including a fuel-based system, 

and select the approach that maximizes net benefits. Ferrari and BMW suggested that NHTSA 

consider weight-based standards, citing the closer correlation between fuel economy and 

footprint, and BMW further suggested that weight-based standards might facilitate international 

harmonization (i.e., between U.S. standards and related standards in other countries).109 Porsche 

commented that the footprint attribute is not well suited for manufacturers of high performance 

vehicles with small footprints.110 

Regarding the comments from IPI, as IPI appears to acknowledge, EPCA/EISA expressly 

requires that CAFE standards be attribute-based and defined in terms of mathematical functions. 

Also, NHTSA has, in fact, considered and reconsidered options other than footprint, over the 

course of multiple CAFE rulemakings conducted throughout the past decade. When first 

contemplating attribute-based systems, NHTSA considered attributes such as weight, “shadow” 

(overall area), footprint, power, torque, and towing capacity. NHTSA also considered 

approaches that would combine two or potentially more than two such attributes. To date, every 

time NHTSA has reconsidered options, the agency has concluded that a properly designed 

footprint-based approach provides the best means of achieving the basic policy goals (i.e., better 

balancing compliance burdens among full-line and limited-line manufacturers and reducing 

incentives for manufacturers to respond to standards by reducing vehicle size in ways that could 

compromise overall highway safety) involved in applying an attribute-based standards, and at the 

same time structuring footprint-based standards in a way that furthers the energy and 

environmental policy goals of EPCA and the CAA by controlling incentives to increase vehicle 

size in ways that could increase fuel consumption and GHG emissions.111 In response to IPI’s 

suggestion to use fuel-based standards as a type of attribute, although NHTSA has not presented 

quantitative analysis of standards that differentiate between fuel type for light-duty vehicles, 

such standards would effectively use fuel type to identify different subclasses of vehicles, thus 

requiring mathematical functions—not addressed by IPI’s comments—to recombine these fuel 

types into regulated classes.112 Insofar as EPCA/EISA already specifies how different fuel types 

108 IPI, Docket No. EPA-HQ-OAR-2010-0799-9480, at 13-15. 109 BMW, Docket No. NHTSA-2010-0131-0250, at 3.
 110 Porsche, Docket No. NHTSA-2010-0131-0224, at 7.
 111 See 71 FR 17566, at17595-17596 (April 6, 2006); 74 FR 14196, at14359 (March 30, 2009); 75 FR 25324 at 

25333 (May 7, 2010). 

112 The agencies did adopt separate standards for gasoline and diesel heavy-duty pickups and vans based on
 

technological differences between gasoline and diesel engines. See 76 FR at 57163-65. However, the agencies
 
                                                                                                                                                                              

 

 

 

135 

are to be treated for purposes of calculating fuel economy and CAFE levels, and moreover, 

insofar as the EISA revisions to EPCA removed NHTSA’s previously-clear authority to set 

separate CAFE standards for different classes of light trucks, using fuel type to further 

differentiate subclasses of vehicles could conflict with the intent, and possibly the letter, of 

NHTSA’s governing statute. Finally, in NHTSA’s judgment, while regarding IPI’s suggestion 

that NHTSA select the attribute-based approach that maximizes net benefits may have merit, net 

benefits are but one of many considerations which lead to the setting of the standard. Also, such 

an undertaking would be impracticable at this time, considering that the mathematical forms 

applied under each attribute-based approach would also need to be specified, and that NHTSA 

lacks methods to reliably quantify the relative potential for induced changes in vehicle attributes. 

Regarding Ferrari’s and BMW’s comments, as stated previously, in NHTSA’s judgment, 

footprint-based standards (a) discourage vehicle downsizing that might compromise occupant 

protection, (b) encourage the application of technology, including weight-efficient materials 

(e.g., high-strength steel, aluminum, magnesium, composites, etc.), and (c) are less susceptible 

than standards based on other attributes to “gaming” that could lead to less-than-projected energy 

and environmental benefits. It is also important to note that there are many differences between 

both the standards and the on-road light-duty vehicle fleets in Europe and the United States. The 

stringency of standards, independent of the attribute used, is another factor that influences 

harmonization. While NHTSA agrees that international harmonization of test procedures, 

calculation methods, and/or standards could be a laudable goal, again, harmonization is not 

simply a function of the attribute upon which the standards are based. Given the differences in 

the on-road fleet (including vehicle classification and use), in fuel composition and availability, 

in regional consumer preferences for different vehicle characteristics, in other vehicle regulations 

besides for fuel economy/CO2 emissions, it would not necessarily be expected that the CAFE 

and GHG emission standards would align with standards of other countries. Thus, NHTSA 

continues to judge vehicle footprint to be a preferable attribute for the same reasons enumerated 

in the proposal and reiterated above. 

What mathematical functions has NHTSA previously used, and why? 

stated that “standards that do not distinguish between fuel types are generally preferable where technological and 

market-based reasons do not strongly argue otherwise. These technological differences exist presently between 

gasoline and diesel engines for GHGs ... The agencies emphasize, however, that they are not committed to 

perpetuating separate GHG standards for gasoline and diesel heavy-duty vehicles and engines, and expect to 

reexamine the need for separate gasoline/diesel standards in the next rulemaking.” 76 FR at 57165. IPI did not 

suggest that there were any such technological distinctions justifying separate fuel-based attributes for light duty 

vehicles, and the agencies note that EPCA/EISA already specifies how different fuels are to be treated for pruposes 

of CAFE 
 

                                                      

 

 

 

136 

NHTSA in MY 2008 and MY 2011 CAFE (constrained logistic) 

For the MY 2011 CAFE rule, NHTSA estimated fuel economy levels after normalization for 

differences in technology, but did not make adjustments to reflect other vehicle attributes (e.g., 

power-to-weight ratios).113 Starting with the technology adjusted passenger car and light truck 

fleets, NHTSA used minimum absolute deviation (MAD) regression without sales weighting to 

fit a logistic form as a starting point to develop mathematical functions defining the standards. 

NHTSA then identified footprints at which to apply minimum and maximum values (rather than 

letting the standards extend without limit) and transposed these functions vertically (i.e., on a 

gallons-per-mile basis, uniformly downward) to produce the promulgated standards. In the 

preceding rule, for MYs 2008-2011 light truck standards, NHTSA examined a range of potential 

functional forms, and concluded that, compared to other considered forms, the constrained 

logistic form provided the expected and appropriate trend (decreasing fuel economy as footprint 

increases), but avoided creating “kinks” the agency was concerned would provide distortionary 

incentives for vehicles with neighboring footprints.114 

MYs 2012-2016 Light Duty GHG/CAFE (constrained/piecewise linear) 

For the MYs 2012-2016 rules, NHTSA reevaluated potential methods for specifying 

mathematical functions to define fuel economy and GHG standards. NHTSA concluded that the 

constrained logistic form, if applied to post-MY 2011 standards, would likely contain a steep 

mid-section that would provide undue incentive to increase the footprint of midsize passenger 

cars.115 NHTSA judged that a range of methods to fit the curves would be reasonable, and used a 

minimum absolute deviation (MAD) regression without sales weighting on a technologyadjusted car and light truck fleet to fit a linear equation. This equation was used as a starting 

point to develop mathematical functions defining the standards as discussed above. NHTSA 

then identified footprints at which to apply minimum and maximum values (rather than letting 

the standards extend without limit) and transposed these constrained/piecewise linear functions 

vertically (i.e., on a gpm or CO2 basis, uniformly downward) to produce the fleet wide fuel 

economy and CO2 emission levels for cars and light trucks described in the final rule.116 

113 See 74 FR 14196, 14363-14370 (Mar. 30, 2009) for NHTSA discussion of curve fitting in the MY 2011 CAFE 

final rule. 

114 See 71 FR 17556, 17609-17613 (Apr. 6, 2006) for NHTSA discussion of “kinks” in the MYs 2008-2011 light
 

truck CAFE final rule (there described as “edge effects”). A “kink,” as used here, is a portion of the curve where a
 

small change in footprint results in a disproportionally large change in stringency. 

115 75 FR at 25362. 116 See generally 74 FR at 49491-96; 75 FR at 25357-62. 
 

                                                      

 

 

 

137 

How has NHTSA defined the mathematical functions for the MYs 2017-2025 standards, 

and why? 

By requiring NHTSA to set CAFE standards that are attribute-based and defined by a 

mathematical function, NHTSA interprets Congress as intending that the post-EISA standards to 

be data-driven – a mathematical function defining the standards, in order to be “attribute-based,” 

should reflect the observed relationship in the data between the attribute chosen and fuel 

117 economy.

The relationship between fuel economy (and GHG emissions) and footprint, though directionally 

clear (i.e., fuel economy tends to decrease and CO2 emissions tend to increase with increasing 

footprint), is theoretically vague and quantitatively uncertain; in other words, not so precise as to 

a priori yield only a single possible curve.118 There is thus a range of legitimate options open to 

NHTSA in developing curve shapes. NHTSA may of course consider statutory objectives in 

choosing among the many reasonable alternatives since the statutes do not dictate a particular 

mathematical function for curve shape. For example, curve shapes that might have some 

theoretical basis could lead to perverse outcomes contrary to the intent of the statutes to conserve 

energy and reduce GHG emissions.119 Thus, the decision of how to set the target curves cannot 

always be just about most “clearly” using a mathematical function to define the relationship 

between fuel economy and the attribute; it often has to have reflect legitimate policy judgments, 

where NHTSA adjusts the function that would define the relationship in order to achieve 

environmental goals, reduce petroleum consumption, encourage application of fuel-saving 

technologies, not adversely affect highway safety, reduce disparities of manufacturers’ 

compliance burdens (thereby increasing the likelihood of improved fuel economy and reduced 

GHG emissions across the entire spectrum of footprint targets), preserve consumer choice, etc. 

This is true both for the decisions that guide the mathematical function defining the sloped 

portion of the target curves, and for the separate decisions that guide NHTSA’s choice of 

“cutpoints” (if any) that define the fuel economy/CO2 levels and footprints at each end of the 

curves where the curves become flat. Data informs these decisions, but how NHTSA defines 

117 A mathematical function can be defined, of course, that has nothing to do with the relationship between fuel 

economy and the chosen attribute – the most basic example is an industry-wide standard defined as the mathematical 

function average required fuel economy = X, where X is the single mpg level set by the agency. Yet a standard that 

is simply defined as a mathematical function that is not tied to the attribute(s) would not meet the requirement of 

EISA. 

118 In fact, numerous manufacturers have confidentially shared with the agencies what they describe as “physics 

based” curves, with each OEM showing significantly different shapes, and footprint relationships. The sheer variety 

of curves shown to the agencies further confirm the lack of an underlying principle of “fundamental physics” driving 

the relationship between CO2 emission or fuel consumption and footprint, and the lack of an underlying principle to 

dictate any outcome of the agencies’ establishment of footprint-based standards. 119 For example, if the agencies set weight-based standards defined by a steep function, the standards might 

encourage manufacturers to keep adding weight to their vehicles to obtain less stringent targets. 
 

                                                      

 

 

138 

and interprets the relevant data, and then the choice of methodology for fitting a curve to the 

data, must include a consideration of both technical data and policy goals. Supporting the 

consideration and selection of mathematical functions upon which to base new CAFE standards, 

NHTSA conducted a broad-ranging analysis spanning different techniques for adjusting data and 

fitting linear functions. The next sections examine the policy concerns that NHTSA considered 

in developing the target curves that define the MYs 2017-2025 CAFE standards, technical work 

(expanding on similar analyses performed by NHTSA when the agency proposed MY 2011-2015 

standards, and by both agencies during consideration of options for MY 2012-2016 CAFE 

standards) that was completed in the process of reexamining potential mathematical functions for 

this rulemaking, how NHTSA has defined the data, and how NHTSA explored statistical curvefitting methodologies in order to arrive at proposed and final curves. Because NHTSA is 

finalizing the target curves for MYs 2017-2025 as proposed, the following discussion largely 

mirrors the discussion in the version of the TSD that accompanied the proposal; it is repeated 

here for the reader’s convenience. 

What did NHTSA propose for the MYs 2017-2025 curves? 

The mathematical functions for the proposed MYs 2017-2025 standards were somewhat changed 

from the functions for the MYs 2012-2016 standards, in response to comments received from 

stakeholders both pre-proposal and during the public comment period and in order to address 

technical concerns and policy goals that NHTSA judged more significant in this nine-model year 

rulemaking than in the prior one, which only included five model years.120 This section 

discusses the methodology NHTSA selected as best addressing those technical concerns and 

policy goals for this rulemaking, given the various technical inputs to NHTSA’s current 

analyses. The section titled “Once NHTSA determined the appropriate slope for the sloped part, 

how did NHTSA determine the rest of the mathematical function?”, below, discusses how 

NHTSA determined the cutpoints and the flat portions of the MYs 2017-2025 target curves. We 

note that both of these sections address only how the target curves were fit to fuel consumption 

and CO2 emission values determined using the city and highway test procedures, and that in 

determining respective regulatory alternatives, NHTSA made further adjustments to the resultant 

curves in order to account for adjustments for improvements to mobile air conditioners. 

120 We note that although, due to statutory constraints, NHTSA is finalizing standards for only MYs 2017-2021 and 

presenting augural standards for MYs 2022-2025, NHTSA’s analysis was conducted with respect to shapes of target 

curves for all nine model years because NHTSA’s augural standards for MYs 2022-2025 represent the agency’s best 

estimate, based on the information currently before it, of the standards that the agency would finalize had it the 

authority to do so. NHTSA will fully revisit all aspects of the MYs 2022-2025 standards as part of the later 

rulemaking concurrent with the planned mid-term evaluation. 
 

                                                      

139 

Thus, recognizing that there are many reasonable statistical methods for fitting curves to data 

points that define vehicles in terms of footprint and fuel economy, NHTSA chose for the 

proposed rule to fit curves using an ordinary least-squares formulation, on sales-weighted data, 

using a fleet that has had technology applied, and after adjusting the data for the effects of 

weight-to-footprint, as described below. This represents a departure from the statistical approach 

for fitting the curves in the MYs 2012-2016 rules, as explained in the next section. NHTSA 

considered a wide variety of reasonable statistical methods in order to better understand the 

range of uncertainty regarding the relationship between fuel consumption (the inverse of fuel 

economy), CO2 emission rates, and footprint, thereby providing a range within which decisions 

about standards would be potentially supportable. 

What concerns were NHTSA looking to address that led them to change from the approach 

used for the MYs 2012-2016 curves? 

Before the MY 2017 and later proposal was issued, NHTSA received a number of comments 

from stakeholders on how curves should be fitted to the passenger car and light truck fleets.121 

Some limited-line manufacturers argued that curves should generally be flatter in order to avoid 

discouraging production of small vehicles, because steeper curves tend to result in more stringent 

targets for smaller vehicles. Most full-line manufacturers argued that a passenger car curve 

similar in slope to the MY 2016 passenger car curve would be appropriate for future model 

years, but that the light truck curve should be revised to be less stringent for manufacturers 

selling the largest full-size pickup trucks. These manufacturers argued that the MY 2016 light 

truck curve was not “physics-based,” and that in order for future tightening of standards to be 

feasible for full-line manufacturers, the truck curve for later model years should be steeper and 

extended further (i.e., made less stringent) into the larger footprints. As stated in the TSD 

accompanying the proposal, NHTSA does not agree that the MY 2016 light truck curve was 

somehow deficient in lacking a “physics basis,” or that it was somehow overly stringent for 

manufacturers selling large pickups—manufacturers making these arguments presented no 

“physics-based” model to explain how fuel economy should depend on footprint.122 The same 

manufacturers indicated that they believed that the light truck standard should be somewhat 

steeper after MY 2016, primarily because, after more than ten years of progressive increases in 

the stringency of applicable CAFE standards, large pickups would be less capable of achieving 

further improvements without compromising load carrying and towing capacity. 

In developing the curve shapes for the proposed rule, NHTSA was aware of the current and prior 

technical concerns raised by OEMs concerning the effects of the stringency on individual 

manufacturers and their ability to meet the standards with available technologies, while 

121 See 75 FR at 76341 for a general summary. 122 See footnote 85. 
                                                      

 

140 

producing vehicles at a cost that allowed them to recover the additional costs of the technologies 

being applied. Although we continue to believe that the methodology for fitting curves for the 

MYs 2012-2016 standards was technically sound, we recognize manufacturers’ technical 

concerns regarding their abilities to comply with a similarly shallow curve after MY 2016 given 

the anticipated mix of light trucks in MYs 2017-2025. As in the MYs 2012-2016 rules, NHTSA 

considered these concerns in the analysis of potential curve shapes for the MYs 2017-2025 

proposal. NHTSA also considered safety concerns which could be raised by curve shapes 

creating an incentive for vehicle downsizing, as well as the potential loss to consumer welfare 

should vehicle upsizing be unduly disincentivized. In addition, NHTSA sought to improve the 

balance of compliance burdens among manufacturers, and thereby increase the likelihood of 

improved fuel economy and reduced GHG emissions across the entire spectrum of footprint 

targets. Among the technical concerns and resultant policy trade-offs NHTSA considered were 

the following: 

 Flatter standards (i.e., curves) increase the risk that both the weight and size of vehicles 

will be reduced, potentially compromising highway safety. 

 Flatter standards potentially impact the utility of vehicles by providing an incentive for 

vehicle downsizing. 

	 Steeper footprint-based standards may create incentives to upsize vehicles, thus 

increasing the possibility that fuel economy and greenhouse gas reduction benefits will be 

less than expected. 

	 Given the same industry-wide average required fuel economy or CO2 standard, flatter 

standards tend to place greater compliance burdens on full-line manufacturers 

	 Given the same industry-wide average required fuel economy or CO2 standard, steeper 

standards tend to place greater compliance burdens on limited-line manufacturers 

(depending of course, on which vehicles are being produced). 

	 If cutpoints are adopted, given the same industry-wide average required fuel economy, 

moving small-vehicle cutpoints to the left (i.e., up in terms of fuel economy, down in 

terms of CO2 emissions) discourages the introduction of small vehicles, and reduces the 

incentive to downsize small vehicles in ways that could compromise overall highway 

safety. 

	 If cutpoints are adopted, given the same industry-wide average required fuel economy, 

moving large-vehicle cutpoints to the right (i.e., down in terms of fuel economy, up in 

terms of CO2 emissions) better accommodates the design requirements of larger 

vehicles—especially large pickups—and extends the size range over which downsizing is 

discouraged. 

All of these were policy goals that required weighing and consideration. Ultimately, NHTSA 

rejected the argument that the MY 2017 target curves for the proposal, on a relative basis, should 

be made significantly flatter than the MY 2016 curve,123 as we believed that this would undo 

123 While “significantly” flatter is subjective qualitative description, the year over year change in curve shapes is 

discussed in greater detail in Section 0. 
141 

some of the safety-related incentives and balancing of compliance burdens among 

manufacturers—effects that attribute-based standards are intended to provide. 

Nonetheless, NHTSA recognized full-line OEM concerns and tentatively concluded that further 

increases in the stringency of the light truck standards would be more feasible if the light truck 

curve is made steeper than the MY 2016 truck curve and the right (large footprint) cut-point is 

extended over time to larger footprints. This conclusion was supported by NHTSA’s technical 

analyses of regulatory alternatives defined using the curves developed in the manner described 

below. 

What methodologies and data did NHTSA consider in developing the 2017-2025 curves 

presented in the proposal? 

In considering how to address the various policy concerns discussed in the previous sections, 

NHTSA revisited the data and performed a number of analyses using different combinations of 

the various statistical methods, weighting schemes, adjustments to the data and the addition of 

technologies to make the fleets less technologically heterogeneous. As discussed below, in 

NHTSA’s judgment, there is no single “correct” way to estimate the relationship between CO2 or 

fuel consumption and footprint – rather, each statistical result is based on the underlying 

assumptions about the particular functional form, weightings and error structures embodied in 

the representational approach. These assumptions are the subject of the following discussion. 

This process of performing many analyses using combinations of statistical methods generated 

many possible outcomes, each embodying different potentially reasonable combinations of 

assumptions and each thus reflective of the data as viewed through a particular lens. The choice 

of a standard developed by a given combination of these statistical methods was consequently a 

decision based upon NHTSA’s determination of how, given the policy objectives for this 

rulemaking and NHTSA’s MY 2008-based forecast of the market through MY 2025, to 

appropriately reflect the current understanding of the evolution of automotive technology and 

costs, the future prospects for the vehicle market, and thereby establish curves (i.e., standards) 

for cars and light trucks. 

For the MYs 2017-2025 standards, what information did NHTSA use to estimate a 

relationship between fuel economy, CO2 and footprint? 

For each fleet, NHTSA began with the MY 2008-based market forecast developed to support the 

proposal (i.e., the baseline fleet), with vehicles’ fuel economy levels and technological 
                                                      

142 

characteristics at MY 2008 levels.124 The development, scope, and content of this market 

forecast are discussed in detail in Chapter 1 of the joint Technical Support Document supporting 

the proposed rulemaking. 

Figure V-1 shows the MY 2008 CO2 by car and truck class as it existed in the NHTSA CAFE 

NPRM model data files (for a gasoline-only fleet, fuel consumption—the inverse of fuel 

economy—is directly proportional to CO2). This fleet was the starting point for all analysis in 

the proposal. 

Figure V-1 2008 CO2 vs. Footprint by Car and Truck 

Although NHTSA is finalizing the target curves as proposed, NHTSA has also revisited and 

updated their analyses for this final rule, and found that the proposed curves are well within the 

ranges spanned by the final rule analyses. As discussed above, NHTSA has used two different 

market forecasts to conduct additional analyses supporting this final rule. The first, referred to 

here as the “MY 2008-Based Fleet Projection,” is largely identical to that used for analysis 

supporting the NPRM, but includes some corrections to the footprint of some vehicle models 

discussed in section III of this RIA, as well as other minor changes. The second, referred to here 

as the “MY 2010-Based Fleet Projection,” is a post-proposal market forecast based on the MY 

124 While the agencies jointly conducted this analysis, the coefficients ultimately used in the slope setting analysis 

are from the CAFE model. 
                                                      

143 

2010 fleet of vehicles. Using both of these projected fleets, NHTSA repeated the analyses 

described below, and obtained broadly similar results, details of which are presented in a 

memorandum available in NHTSA’s docket.125 Because NHTSA is promulgating target curve 

standards identical to those proposed in the NPRM, the remainder of this chapter reviews results 

supporting the development of those proposed standards. This chapter concludes with a 

summary of results of NHTSA’s updated analysis, and discussion of the consideration that 

analysis was given in selecting mathematical functions upon which to base the standards in the 

final rules. 

What adjustments did NHTSA evaluate? 

As indicated in the joint TSD supporting the NPRM, one possible approach is to fit curves to the 

minimally adjusted data shown above (the approach still includes sales mix adjustments, which 

influence results of sales-weighted regressions), much as DOT did when it first began evaluating 

potential attribute-based standards in 2003.126 However, NHTSA found, as in prior rulemakings, 

that the data are so widely spread (i.e., when graphed, they fall in a loose “cloud” rather than 

tightly around an obvious line) that they indicate a relationship between footprint and CO2 and 

fuel consumption that is real but not particularly strong (Figure V-1). Therefore, as discussed 

below, NHTSA also explored possible adjustments that could help to explain and/or reduce the 

ambiguity of this relationship, or could help to produce policy outcomes NHTSA judged to be 

more desirable. 

Adjustment to reflect differences in technology 

As in prior rulemakings, NHTSA considered technology differences between vehicle models to 

be a significant factor producing uncertainty regarding the relationship between CO2/fuel 

consumption and footprint. Noting that attribute-based standards are intended to encourage the 

application of additional technology to improve fuel efficiency and reduce CO2 emissions, 

NHTSA, in addition to considering approaches based on the unadjusted engineering 

characteristics of MY 2008 vehicle models, therefore also considered approaches in which, as for 

previous rulemakings, technology is added to vehicles for purposes of the curve fitting analysis 

in order to produce fleets that are less varied in technology content. This approach helps to 

reduce “noise” (i.e., dispersion) in the plot of vehicle footprints and fuel consumption levels and 

to identify a more technology-neutral relationship between footprint and fuel economy / CO2 

emissions. 

125 Docket No. NHTSA-2010-0131. 126 68 FR 74920-74926. 
                                                      

 

144 

For the analysis supporting the NPRM, NHTSA adjusted the NPRM baseline fleet for 

technology by adding all technologies considered, except for, diesel engines, integrated starter 

generators, strong HEVs, PHEVs, EVs, FCVs, and the most advanced high-BMEP (brake mean 

effective pressure) gasoline engines.127 NHTSA included 15 percent mass reduction on all 

vehicles. Figure V-2 shows the same fleet, with technology adjustment and 2021 sales applied, 

and the baseline diesel fueled vehicles, HEV and EVs removed from the fleet. Of note, the fleet 

is now more closely clustered128 (and lower in emissions), but the same basic pattern emerges; in 

both figures, the CO2 emission rate (which, as mentioned above, is directly proportional to fuel 

consumption for a gasoline-only fleet) increases with increasing footprint, although the 

relationship is less pronounced for larger light trucks. 

Figure V-2 2008 CO2 vs. Footprint by Car and Truck, after Adjustment Reflecting
 

Technology Differences, and removing diesel fueled vehicles, HEVs and EVs
 

127 As described in the preceding paragraph, applying technology in this manner serves to reduce the effect of 

technology differences across the vehicle fleet. The particular technologies used for the normalization were chosen 

as a reasonable selection of technologies which could potentially be used by manufacturer over this time period.

128 For cars, the standard deviation of the CO2 data is reduced from 81 to 54 through the technology normalization. 

For trucks, the standard deviation is reduced from 62 to 36. 
 

                                                      

 

 

145 

Updating this analysis using the current MY2008- and MY2010-based fleet projection yielded 

results generally similar to those shown above. Detailed results of the analyses with the final 

rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.129

Adjustments reflecting differences in performance and “density” 

As discussed previously, during stakeholder meetings NHTSA held while developing the 

NPRM,130 some manufacturers indicated that they believed that the light truck standard should 

be somewhat steeper after MY 2016. As a means to produce a steeper light truck curve, NHTSA 

considered adjustments for other differences between vehicle models (i.e., inflating or deflating 

the fuel economy of each vehicle model based on the extent to which one of the vehicle’s 

attributes, such as power, is higher or lower than average). Previously, NHTSA had rejected 

such adjustments because they imply that a multi-attribute standard may be necessary, and as 

explained above, NHTSA judged most multi-attribute standards to be more subject to gaming 

than a footprint-only standard.131,132 Having considered this issue again for purposes of this 

rulemaking, NHTSA concluded the need to accommodate in the target curves the challenges 

faced by manufacturers of large pickups currently outweighs these prior concerns (comments on 

this topic are discussed in Chapter 2 of the joint TSD and in Section II.C of the preamble). 

Therefore, NHTSA also evaluated curve fitting approaches through which fuel consumption and 

CO2 levels were adjusted with respect to weight-to-footprint alone, and in combination with 

power-to-weight. While NHTSA examined these adjustments for purposes of fitting curves, 

NHTSA did not propose a multi-attribute standard; the proposed fuel economy and CO2 targets 

for each vehicle were still functions of footprint alone. NHTSA is not promulgating a multiattribute standard, and no adjustment will be used in the compliance process. 

NHTSA also examined some differences between the technology-adjusted car and truck fleets in 

order to better understand the relationship between footprint and CO2/fuel consumption in 

NHTSA’s MY 2008 based forecast. More direct measures (such as coefficients of drag and 

rolling resistance), while useful for vehicle simulation, were not practical or readily available at 

the fleet level. Given this issue, and based on analysis published in the MYs 2012-2016 rule,133 

129 Docket No. NHTSA-2010-0131. 130 See Preamble I.A.2 for a discussion of the stakeholder meetings before the NPRM. 131 For example, in comments on NHTSA’s 2008 NPRM regarding MY 2011-2015 CAFE standards, Porsche 

recommended that standards be defined in terms of a “Summed Weighted Attribute”, wherein the fuel economy 

target would calculated as follows: target = f(SWA), where target is the fuel economy target applicable to a given 

vehicle model and SWA = footprint + torque1/1.5 + weight1/2.5. (NHTSA-2008-0089-0174). While the standards the 

agencies proposed for MY 2017-2025 are not multi-attribute standards-- that is, the target is only a function of 

footprint--we proposed curve shapes that were developed considering more than one attribute.

132 74 FR 14359. 133 See 75 FR at 25458 
 

 

 

 

                                                      

 

 

 

146 

NHTSA investigated a sales-weighted (i.e., treating every vehicle unit sold as a separate 

observation) regression equation involving power to weight ratio and vehicle weight (Equation 

V-1).134 This equation provides for a strong correlation between HP/WT, weight and CO2 

emissions (R2

=0.78, Table V-1) after accounting for technology adjustments.135 

Equation V-1 – Relationship between vehicle attributes and emissions or fuel consumption

CO2i	or	GPMi ൌ β୦୮/୵୲ ൬

Horsepower൰ ൅ β୵ୣ୧୥୦୲Weight୧ ൅ 	C Weight ୧

Where: 

HP/Weight= the rated horsepower of the vehicle divided by the curb weight 

Weight = the curb weight of the vehicle in pounds 

C = a constant. 

Table V-1 – Physical Regression Coefficients against Technology Adjusted CO

 Cars Light Trucks 

R2 0.78 0.78

F-test p <0.01 <0.01

β୦୮/୵୲ 1.09*103 1.13*103 

β୵ୣ୧୥୦୲ 3.29*10-2 3.45*10-2

C -3.29 2.73 

2

* 

*In this gasoline only fleet, these coefficients can be divided by 8887 (the amount of CO2 

produced by the combustion of a gallon of the fuel used to certify the fuel economy and 

emissions of gasoline vehicles) to yield the corresponding fuel consumption coefficients. 

Updating this analysis using the MY 2008- and MY 2010-based fleet projections yielded results 

generally similar to those shown above. Detailed results of the analyses with the final 

rulemaking fleet projections are presented a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.136

The coefficients above show, for NHTSA’s MY 2008-based market forecast as developed for the 

NPRM, strong correlation between these vehicle attributes and the fuel consumption and 

emissions of the vehicle, as well as strong similarity between car and truck coefficients. (As 

explained in below, our analysis using the corrected version of the MY 2008 based market 

forecast used for the final rule, as well as the alternative 2010 based market forecast, is 

134 These parameters directly relate to the amount of energy required to move the vehicle. As compared to a lighter 

vehicle, more energy is required to move a heavier vehicle the same distance. Similarly, a more powerful engine, 

when technology adjusted, is less efficient than a less powerful engine. 

135 As R2

 does not equal 1, there are remaining unaccounted for differences beyond technology, power and weight. 

These may include gear ratios, axle ratios, aerodynamics, and other vehicle features not captured in this equation.

136 Docket No. NHTSA-2010-0131. 
 

                                                      

 

 

147 

consistent with these results.) Given these very similar parameters, similar distributions of 

power and weight would be expected to produce similarly arrayed plots of CO2 (or equivalently, 

fuel consumption) by footprint, regardless of car or truck class. Based on the differences seen in 

the technology-adjusted plot (Figure V-2), NHTSA further investigated these particular attributes 

and their relationship to footprint in NHTSA’s MY 2008-based market forecast developed for 

the NPRM, to examine the differences across the footprint distribution. 

Figure V-3 shows vehicle curb weight charted against footprint, with sales weighted ordinary 

least squares sales fit (blue) and sales-weighted LOESS fit (red) imposed. For cars, the LOESS 

fit, which weights nearby points more heavily, 137 is nearly identical to the linear fit in the data 

filled region between about 40 and 56 square feet (with the gray bar showing standard error on 

the LOESS fit). For this market forecast, average car curb weight is linearly proportional to car 

footprint between 40 and 56 square feet, or in other words, cars progress in weight in a regular 

fashion as they get larger ( 

Figure V-3). By contrast, a linear fit does not overlap with the LOESS fit on the truck side, 

which indicates that for this market forecast, truck curb weight does not linearly increase with 

footprint, at least not across the entire truck fleet. The LOESS fit shows that larger trucks (those 

on the right side of the data bend in Figure V-2) have a different trend than smaller trucks, and 

after about 55 square feet, no longer proportionally increases in weight. The same pattern is seen 

in Figure V-1 and Figure V-2 above. 

137: In a LOESS regression, “fitting is done locally. That is, for the fit at point x, the fit is made using points in a 

neighborhood of x, weighted by their distance from x (with differences in ‘parametric’ variables being ignored when 

computing the distance). The size of the neighborhood is controlled by α For α < 1, the neighborhood includes 

proportion α of the points, and these have tricubic weighting (proportional to (1 - (dist/maxdist)^3)^3. For α > 1, all 

points are used, with the ‘maximum distance’ assumed to be α^1/p times the actual maximum distance for p 

explanatory variables.” 

A span of 1 was used in these images. http://cran.r-project.org/doc/manuals/fullrefman.pdf, p. 1406. 
                                                      

148 

Figure V-3 Relationship between Weight and Footprint in Agencies’ MY2008-Based 

Market Forecast 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.138

To further pursue this topic, weight divided by footprint (WT/FP) can be thought of as a 

“density” of a vehicle (although dimensionally it has units of pressure). As seen in Figure V-4, 

the trend in WT/FP in NHTSA’s MY2008-based market forecast is different in trucks than in 

cars. The linear trend on cars is an increase in WT/FP as footprint increases (Figure V-4). In 

contrast, light trucks do not consistently increase in WT/FP ratio as the vehicles grow larger, but 

WT/FP actually decreases (Figure V-4). 

138 Docket No. NHTSA-2010-0131. 
                                                      

149 

Figure V-4 Relationship between Weight/FP and Footprint in Agencies’ MY2008-Based 

Market Forecast 

Updating this analysis using the current MY 2008- and MY 2010-based fleet projection yielded 

results generally similar to those shown above. Detailed results of the analyses with the final 

rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.139

The heterogeneity of the truck fleet explains part of the WT/FP trend, where the pickup truck 

fleet is largest in footprint, but is also relatively light for its size due to the flat bed (Figure V-5). 

Note that the two light truck classes with the smallest WT/FP ratios are small and large pickups. 

Further, as the only vehicle class with a sales-weighted average footprint above 60 square feet, 

the large pickup trucks have a strong influence on the slope of the truck curve. As the 

correlation between weight and CO2 is strong (Table V-1), having proportionally lighter vehicles 

at one extreme of the footprint distribution can bias a curve fit to these vehicles. If no 

adjustment is made to the curve fitted to the truck fleet, and no other compensating flexibilities 

or adjustments are made available, manufacturers selling significant numbers of vehicles at the 

large end of the truck distribution will face compliance burdens that are comparatively more 

challenging that those faced by manufacturers not serving this part of the light truck market. As 

139 Docket No. NHTSA-2010-0131. 
 

                                                      

150 

noted further below, this consideration provided the basis for NHTSA’s proposal to change the 

cutpoint for larger light trucks from 66 feet to 74 feet, and to steepen the slope of the light truck 

curve for larger light trucks. 

Figure V-5 Class and the WT/FP distribution 

Updating this analysis using the revised MY 2008- and the MY 2010-based market forecasts 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.140

NHTSA also investigated the relationship between HP/WT and footprint in NHTSA’s MY 2008­

based market forecast developed for the NPRM (Figure V-6). On a sales weighted basis, cars 

tend to become proportionally more powerful as they get larger. In contrast, there is a minimally 

positive relationship between HP/WT and footprint for light trucks, indicating that light trucks 

become only slightly more powerful as they get larger, but that the trend is not especially 

pronounced. 

140 Docket No. NHTSA-2010-0131. 
                                                      

151 

Figure V-6 HP/WT v. FP 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.141 

One factor influencing results of this analysis is the non-homogenous nature of the truck fleet; 

some vehicles at the smaller end of the footprint curve are different in design and utility from 

others at the larger end (leading to the observed bend in the LOESS fit, Figure V-6). There are 

many high volume four-wheel drive vehicles with smaller footprint in the truck fleet (such as the 

Chevrolet Equinox, Dodge Nitro, Ford Escape, Honda CR-V, Hyundai Santa Fe, Jeep Liberty, 

Nissan Rogue, Toyota RAV4, and others) exhibit only select truck characteristics.142 By 

contrast, the largest pickup trucks in the light truck fleet have unique aerodynamic and power 

characteristics that tend to increase CO2 emissions and fuel consumption. These disparities 

contribute to the slopes of lines fitted to the light truck fleet. 

141 Docket No. NHTSA-2010-0131.
 142 In most cases, these vehicles have four-wheel drive, but no significant towing capability, and no open-bed. Many
 

of these vehicles are also offered without four-wheel drive, and these two-wheel drive versions are classified as 

passenger cars, not light trucks. 
                                                      

 

152 

Several comments, such as those by CBD and ACEEE, were submitted with regard to the nonhomogenous nature of the truck fleet, and the “unique” attributes of pickup trucks. Ford Motor 

Company described the attributes of these vehicles, noting that “towing capability generally 

requires increased aerodynamic drag caused by a modified frontal area, increased rolling 

resistance, and a heavier frame and suspension to support this additional capability.”143 Ford 

further noted that these vehicles further require auxiliary transmission oil coolers, upgraded 

radiators, trailer hitch connectors and wiring harness equipment, different steering ratios, 

upgraded rear bumpers and different springs for heavier tongue load (for upgraded towing 

packages), body-on-frame (vs. unibody) construction (also known as ladder frame construction) 

to support this capability and an aggressive duty cycle, and lower axle ratios for better pulling 

power/capability. In NHTSA’s judgment, the curves and cutpoints defining the light truck 

standards appropriately account for engineering differences between different types of vehicles. 

For example, NHTSA’s estimates of the applicability, cost, and efficacy of different fuel-saving 

technologies differentiate between small, medium, and large light trucks. Further discussion on 

this topic is contained in Section II.C of the preamble to this final rule. 

NHTSA’s technical analyses of regulatory alternatives developed using curves fitted as 

described below supported OEM comments that there would be significant compliance 

challenges for the manufacturers of large pickup trucks, and led toward NHTSA’s policy goal of 

a steeper slope for the light truck curve relative to MY 2016. Three primary drivers were as 

follows: (a) the largest trucks have unique equipment and design, as described in the Ford 

comment referenced above; (b) NHTSA agree with those large truck manufacturers who 

indicated in discussions prior to the proposal that they believed that the light truck standard 

should be somewhat steeper after MY 2016, primarily because, after more than ten recent years 

of progressive increases in the stringency of applicable CAFE standards (after nearly ten years 

during which Congress did not allow NHTSA to increase light truck CAFE standards), 

manufacturers of large pickups would have limited options to comply with more stringent 

standards without resorting to compromising large truck load carrying and towing capacity; and 

(c) given the relatively few platforms which comprise the majority of the sales at the largest 

truck footprints, NHTSA was concerned about requiring levels of average light truck 

performance that might lead to overly aggressive advanced technology penetration rates in this 

important segment of the work fleet. Specifically, NHTSA was concerned at proposal, and 

remain concerned, about issues of lead time and cost with regard to manufacturers of these work 

vehicles. As noted later in this chapter, while the largest trucks are a small segment of the 

overall truck fleet, and an even smaller segment of the overall fleet, 144 these changes to the truck 

143 Ford comments, Docket No. NHTSA-2010-0131-0235, at 6. 144 The agencies’ market forecast used at proposal includes about 24 vehicle configurations above 74 square feet 

with a total volume of about 50,000 vehicles or less during any MY in the 2017-2025 time frame, In the MY2010 

based market forecast, there are 14 vehicle configurations with a total volume of 130,000 vehicles or less during any 
                                                                                                                                                                              

153 

slope have been made in order to provide a clearer path toward compliance for manufacturers of 

these vehicles, and reduce the potential that new standards would lead these manufacturers to 

choose to downpower, modify the structure, or otherwise reduce the utility of these work 

vehicles. 

Some commenters disagreed with these policy goals concerning the largest light trucks and 

argued that higher fuel economy for the largest light trucks is fully compatible with maintaining 

towing and hauling capacity. These comments, which largely deal with stringency, are 

addressed Section IV.F of the preamble to today’s final rule, as well as in Section II.C, which 

addresses the shapes of the target curves. Consequently, NHTSA considered options including 

fitting curves developed using results of the analysis described above. Specifically, NHTSA 

notes that the WT/FP ratio of the light duty fleet potentially has a large impact on a salesweighted regression.145 The increasing trend in WT/FP versus footprint for cars in the 2008 MY 

baseline would steepen the slope of the car curve, while the decreasing trend in WT/FP would 

flatten the truck slope, as compared to a WT/FP adjusted fleet. This result was reflected in the 

MYs 2012-2016 final rulemaking,146 where NHTSA noted the steep car curves resulting from a 

weighted least-squares analysis. 

Based on the above analysis, NHTSA also considered adjustments for other differences between 

vehicle models. Therefore, utilizing the coefficients derived in Equation V-1, NHTSA also 

evaluated curve fitting approaches through which fuel consumption and CO2 levels were 

adjusted with respect to weight-to-footprint alone, and in combination with power-to-weight. 

This adjustment procedure inflates or deflates the fuel economy or CO2 emissions of each 

vehicle model based on the extent to which one of the vehicle’s attributes, such as power, is 

higher or lower than average. As mentioned above, while NHTSA considered this technique for 

purposes of fitting curves, NHTSA did not propose a multi-attribute standard, as the proposed 

fuel economy and CO2 targets for each vehicle were still functions of footprint alone. NHTSA is 

not promulgating a multi-attribute standard, and no adjustment would be used in the compliance 

process. 

The basis for the gallon-per-mile (GPM) adjustments is the sales-weighted linear regression 

discussed previously (Equation V-1, Table V-1). The coefficients to this equation give the 

impact of the various car attributes on CO2 emissions and fuel consumption in NHTSA’s MY 

2008-based market forecast used in the NPRM. For example, β୵ୣ୧୥୦୲ gives the impact of weight 

while holding the ratio horsepower to weight constant. Importantly, this means that as weight 

MY in the 2017-2025 time frame. This is a similarly small portion of the overall number of vehicle models or 

vehicle sales. 

145 As mentioned above, the agencies also performed the same analysis without sales-weighting, and found that the 

WT/FP ratio also had a directionally similar effect on the fitted car and truck curves. 146 75 FR at 25363 
154 

changes, horsepower must change as well to keep the power/weight ratio constant. Similarly, 

β୦୮/୵୲ gives the CO2 impact of changing the performance of the vehicle while keeping the 

weight constant. These coefficients were used to perform an adjustment of the gallons per mile 

measure for each vehicle to the respective car or truck—i.e., in the case of a HP/WT adjustment, 

to deflate or inflate the fuel consumption of each vehicle model based on the extent to which the 

vehicle’s power-to-weight ratio is above or below the regression-based value at that footprint. 

NHTSA performed this normalization to adjust for differences in vehicle weight per square foot 

observations in the data discussed in Section 2.4 of the Joint TSD. This adjustment process 

requires two pieces of information: the weight coefficient from Equation V-1 and the average 

weight per footprint (i.e., pounds per square foot) for that vehicle’s group. Two groups, 

passenger cars and light trucks, were used. For each group, the average weight per footprint was 

calculated as a weighted average with the weight being the same as in the above regression 

(projected sales by vehicle in 2021). The equation below indicates how this adjustment was 

carried out. 

Equation V-2 WT/FP adjustment 

െ

തWeıght തതതതതതതതതതത Weight	per	Footprint	Adjusted	GPM୧	or	CO2i ൌ GPM୧ െ ቆWeight୧ ൈ Footprint୧ቇൈβ୵ୣ୧୥୦୲ Footprınt

The term in parentheses represents the vehicle’s deviation from an “expected weight.” That is, 

multiplying the average weight per footprint for a group of vehicles (cars or trucks) by a specific 

vehicle’s footprint gives an estimate of the weight of that specific vehicle if its density were 

“average,” based on the analyzed fleet. Put another way, this factor represents what the weight is 

“expected” to be, given the vehicle’s footprint, and based on the analyzed fleet. This “expected 

weight” is then subtracted from the vehicle’s actual weight. Vehicles that are heavier than their 

“expected weight” will receive a positive value (i.e., a deflated fuel economy value) here, while 

vehicles that are lighter than their “expected weight” will receive a negative number (i.e., an 

inflated fuel economy value). 

This deviation from “expected weight” is then converted to a gallon value by the regression 

coefficient. The units on this coefficient are gallons per mile per pound, as can be deduced from 

Equation V-1. This value is then subtracted from the vehicle’s actual gallons per mile measure. 

Note that the adjusted truck data no longer exhibits the bend seen in Figure V-1 and Figure V-2. 
Car Truck 

GPM

.01 .02 .03 .04 .05

40 50 60 70 80 40 50 60 70 80 

Footprint 

155 

Figure V-7 WT/FP Adjusted Fuel Consumption vs. Footprint 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.147

This adjustment serves to reduce the variation in gallons per mile measures caused by variation 

in weight in NHTSA’s MY 2008-based market forecast used in the NPRM. Importantly, this 

adjustment serves to reduce the fuel consumption (i.e., inflate fuel economy) for those vehicles 

which are heavier than their footprint would suggest while increasing the gallons per mile 

measure (i.e., deflating fuel economy) for those vehicles which are lighter. For trucks, a linear 

trend is more evident in the data cloud. The following table shows the degree of adjustment for 

several vehicle models: 

Table V-2 - Sample Adjustments for Weight to Footprint, Cars 

    147 Docket No. NHTSA-2010-0131. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

156 

Manufacturer Model Name Plate Weight / 

Footprint Footprint GPM MPG Adjusted GPM 

Adjusted 

MPG 

GPM % 

Adjustment 

HONDA HONDA FIT FIT 64.4 39.5 0.01 69.40 0.0157 63.73 8.9% 

TOYOTA TOYOTA 

COROLLA COROLLA 61.3 42.5 0.01 69.94 0.0164 60.80 15.0% 

FORD FORD 

FOCUS FOCUS FWD 62.9 41.7 0.02 61.94 0.0177 56.34 9.9% 

GENERAL 

MOTORS 

CHEVROLET 

MALIBU MALIBU 73.5 46.9 0.02 53.70 0.0185 54.08 -0.7% 

HONDA HONDA 

ACCORD 

ACCORD 

4DR SEDAN 69.6 46.6 0.02 57.57 0.0179 55.73 3.3% 

NISSAN INFINITI G37 G37 COUPE 76.7 47.6 0.02 47.83 0.0200 50.08 -4.5% 

GENERAL 

MOTORS 

CHEVROLET 

CORVETTE CORVETTE 69.3 46.3 0.02 40.84 0.0251 39.83 2.5% 

FORD FORD 

MUSTANG MUSTANG 74.7 46.7 0.03 31.32 0.0316 31.67 -1.1% 

TOYOTA TOYOTA 

CAMRY 

CAMRY 

SOLARA 

CONVERTIB 

LE 

75.6 46.9 0.02 50.87 0.0191 52.27 -2.7% 

VOLKSWAG 

EN 

VOLKSWAG 

EN JETTA JETTA 78.0 42.4 0.02 46.77 0.0211 47.47 -1.5% 

FORD FORD 

FUSION 

FUSION 

FWD 72.2 46.1 0.02 59.96 0.0168 59.61 0.6% 

HONDA HONDA 

ACCORD 

ACCORD 

2DR COUPE 71.6 46.6 0.02 56.92 0.0178 56.26 1.2% 

HYUNDAI HYUNDAI 

SONATA SONATA 70.7 46.0 0.02 61.72 0.0166 60.34 2.3% 

HONDA HONDA 

CIVIC CIVIC 59.9 43.2 0.02 64.25 0.0177 56.38 14.0% 
 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

157 

Table V-3 – Sample Adjustments for Weight to Footprint, Trucks 

Manufacture 

r Model Name Plate Weight / Footprint Footprint GPM MPG Adjusted GPM 

Adjusted 

MPG 

GPM % 

Adjustment 

FORD FORD 

ESCAPE 

ESCAPE 

FWD 80.1 65.2 0.02 51.00 0.0181 55.11 -7.5% 

GENERAL 

MOTORS 

CHEVROLET 

C15 

C15 

SILVERAD 

O 2WD 

119WB 

85.9 55.9 0.03 39.76 0.0248 40.29 -1.3% 

FIAT JEEP GRAND 

CHEROKEE 

GRAND 

CHEROKE 

E 4WD 

103.7 47.1 0.02 41.45 0.0222 44.98 -7.9% 

HONDA HONDA 

PILOT 

PILOT 

4WD 85.2 51.3 0.02 40.95 0.0243 41.22 -0.6% 

TOYOTA 

TOYOTA 

HIGHLANDE 

R 

HIGHLAN 

DER 4WD 79.6 49.0 0.02 45.90 0.0227 44.05 4.2% 

FORD FORD F150 

F150 FFV 

4WD 145 

WB 

73.8 67.4 0.03 32.70 0.0334 29.97 9.1% 

FIAT DODGE RAM 

RAM 1500 

PICKUP 

4WD 140 

WB 

78.1 66.3 0.03 33.75 0.0316 31.65 6.6% 

TOYOTA TUNDRA 

TOYOTA 

TUNDRA 

4WD 145 

WB 

79.3 68.7 0.03 32.07 0.0325 30.73 4.3% 

TATA 

LAND 

ROVER 

RANGE 

ROVER 

SPORT 

RANGE 

ROVER 

SPORT 

118.6 47.5 0.03 33.17 0.0239 41.92 -20.9% 

GENERAL 

MOTORS 

CHEVROLET 

UPLANDER 

UPLANDE 

R FWD 114.4 49.2 0.02 45.46 0.0163 61.34 -25.9% 

GENERAL 

MOTORS HUMMER H3 H3 4WD 99.9 50.7 0.03 36.71 0.0242 41.30 -11.1% 

GENERAL 

MOTORS 

PONTIAC 

TORRENT 

TORRENT 

FWD 84.2 48.2 0.02 46.64 0.0215 46.56 0.2% 

TOYOTA TACOMA 

TOYOTA 

TACOMA 

4WD 

74.8 53.4 0.02 43.01 0.0252 39.63 8.5% 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.148

Based on Equation V-1, NHTSA also evaluated an adjustment of GPM and CO2 based on 

HP/WT. 

Equation V-3 –Adjustment based on HP/WT 

തതതതത

WT adjusted	GPM୧	or	CO2୧ ൌ GPM୧ ሻ ൈ βୌ୔/୛୘

HP

െ ሺ

HP୧ െ HP

WT୧ WT

148 Docket No. NHTSA-2010-0131. 
158 

Figure V-8 shows the adjusted data and the estimated relationship between the adjusted GPM 

values and footprint. 
159 

Table V-4 shows the degree of adjustment for several vehicle models. Those vehicles which 

have more power than average for their actual curb weight are adjusted downward (i.e., fuel 

economy ratings are inflated), while those that have less power than average are adjusted upward 

(i.e., fuel economy ratings are deflated).

Car Truck 

GPM 

.01 .02 .03 .04 

40 50 60 70 80 40 

Footprint 

50 60 70 80 

Figure V-8 HP/WT Adjusted Fuel Consumption v. Footprint 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

160 

Table V-4 - Sample Adjustments for Horsepower to Weight, Cars 

Manufacturer Model Name Plate Horsepower Footprint GPM MPG Adjusted GPM 

Adjusted 

MPG 

GPM % 

Adjustment 

HONDA HONDA FIT FIT 109 39.5 0.01 69.40 0.0157 63.73 8.9% 

TOYOTA 

TOYOTA 

COROLLA COROLLA 126 42.5 0.01 69.94 0.0164 60.80 15.0% 

FORD 

FORD 

FOCUS FOCUS FWD 140 41.7 0.02 61.94 0.0177 56.34 9.9% 

GENERAL 

MOTORS 

CHEVROLET 

MALIBU MALIBU 169 46.9 0.02 53.70 0.0185 54.08 -0.7% 

HONDA 

HONDA 

ACCORD 

ACCORD 4DR 

SEDAN 190 46.6 0.02 57.57 0.0179 55.73 3.3% 

NISSAN INFINITI G37 G37 COUPE 330 47.6 0.02 47.83 0.0200 50.08 -4.5% 

GENERAL 

MOTORS 

CHEVROLET 

CORVETTE CORVETTE 400 46.3 0.02 40.84 0.0251 39.83 2.5% 

FORD 

FORD 

MUSTANG MUSTANG 500 46.7 0.03 31.32 0.0316 31.67 -1.1% 

TOYOTA 

TOYOTA 

CAMRY 

CAMRY 

SOLARA 

CONVERTIBL 

E 

225 46.9 0.02 50.87 0.0191 52.27 -2.7% 

VOLKSWAG 

EN 

VOLKSWAG 

EN JETTA JETTA 170 42.4 0.02 46.77 0.0211 47.47 -1.5% 

FORD 

FORD 

FUSION FUSION FWD 160 46.1 0.02 59.96 0.0168 59.61 0.6% 

HONDA 

HONDA 

ACCORD 

ACCORD 2DR 

COUPE 190 46.6 0.02 56.92 0.0178 56.26 1.2% 

HYUNDAI 

HYUNDAI 

SONATA SONATA 162 46.0 0.02 61.72 0.0166 60.34 2.3% 

HONDA 

HONDA 

CIVIC CIVIC 140 43.2 0.02 64.25 0.0177 56.38 14.0% 

Table V-5 - Sample Adjustments for Horsepower to Weight, Trucks 

Manufacturer Model Name Plate Horsepower Footprint GPM MPG 

Adjuste 

d GPM 

Adjusted 

MPG 

GPM % 

Adjustmen 

t 

FORD 

FORD 

ESCAPE ESCAPE FWD 153 65.2 0.02 51.00 0.0181 55.11 -7.5% 

GENERAL 

MOTORS 

CHEVROLET 

C15 

C15 SILVERADO 

2WD 119WB 195 55.9 0.03 39.76 0.0248 40.29 -1.3% 

FIAT 

JEEP 

GRAND 

CHEROKEE 

GRAND 

CHEROKEE 

4WD 

210 47.1 0.02 41.45 0.0222 44.98 -7.9% 

HONDA 

HONDA 

PILOT PILOT 4WD 244 51.3 0.02 40.95 0.0243 41.22 -0.6% 

TOYOTA 

TOYOTA 

HIGHLANDE 

R 

HIGHLANDER 

4WD 

270 49.0 0.02 45.90 0.0227 44.05 4.2% 

FORD FORD F150 

F150 FFV 4WD 

145 WB 300 67.4 0.03 32.70 0.0334 29.97 9.1% 

FIAT 

DODGE 

RAM 

RAM 1500 

PICKUP 4WD 

140 WB 

345 66.3 0.03 33.75 0.0316 31.65 6.6% 

TOYOTA TUNDRA 

TOYOTA 

TUNDRA 4WD 

145 WB 

381 68.7 0.03 32.07 0.0325 30.73 4.3% 

TATA 

LAND 

ROVER 

RANGE 

ROVER 

SPORT 

RANGE ROVER 

SPORT 

300 47.5 0.03 33.17 0.0239 41.92 -20.9% 

GENERAL 

MOTORS 

CHEVROLET 

UPLANDER 

UPLANDER 

FWD 240 49.2 0.02 45.46 0.0163 61.34 -25.9% 
 

       

                                                      

 

161 

GENERAL 

MOTORS 

HUMMER 

H3 H3 4WD 242 50.7 0.03 36.71 0.0242 41.30 -11.1% 

GENERAL 

MOTORS 

PONTIAC 

TORRENT TORRENT FWD 185 48.2 0.02 46.64 0.0215 46.56 0.2% 

TOYOTA TACOMA 

TOYOTA 

TACOMA 4WD 236 53.4 0.02 43.01 0.0252 39.63 8.5% 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses are with 

the final rulemaking fleet projections presented in a memorandum available in NHTSA’s

docket.149

The above approaches resulted in three data sets each for (a) vehicles without added technology 

and (b) vehicles with technology added to reduce technology differences, any of which may 

provide a reasonable basis for fitting mathematical functions upon which to base the slope of the 

standard curves: (1) vehicles without any further adjustments; (2) vehicles with adjustments 

reflecting differences in “density” (weight/footprint); and (3) vehicles with adjustments 

reflecting differences in “density,” and adjustments reflecting differences in performance 

(power/weight). Further, these sets were developed for both the revised MY 2008-based fleet 

projection and the post-proposal MY 2010-based fleet projection. Detailed results using these 

market forecasts are presented in a memorandum titled “Curve Fitting Analysis: Regression 

Results,” available in NHTSA’s docket.150

What statistical methods did NHTSA evaluate? 

Using these data sets, NHTSA tested a range of regression methodologies, each judged to be 

possibly reasonable for application to at least some of these data sets. 

Regression Approach 

In the MYs 2012-2016 final rules, NHTSA employed a robust regression approach (minimum 

absolute deviation, or MAD), rather than an ordinary least squares (OLS) regression.151 MAD is 

generally applied to mitigate the effect of outliers in a dataset, and thus was employed in that 

rulemaking as part of our interest in attempting to best represent the underlying technology. 

NHTSA had used OLS in early development of attribute-based CAFE standards, but NHTSA 

subsequently chose MAD instead of OLS for both the MY 2011 and the MYs 2012-2016 

rulemakings. These decisions on regression technique were made both because OLS gives 

149 Docket No. NHTSA-2010-0131. 150 Docket No. NHTSA-2010-0131. 151 See 75 FR at 25359. 
                                                      

 

162 

additional emphasis to outliers152 and because the MAD approach helped achieve NHTSA’s 

policy goals with regard to curve slope in those rulemakings.153 In the interest of taking a fresh 

look at appropriate regression methodologies as promised in the 2012-2016 light duty 

rulemaking, in developing this proposal, NHTSA gave full consideration to both OLS and MAD. 

The OLS representation, as described, uses squared errors, while MAD employs absolute errors 

and thus weights outliers less. 

As noted, one of the reasons stated for choosing MAD over least square regression in the MYs 

2012-2016 rulemaking was that MAD reduced the weight placed on outliers in the data. As seen 

in Figure 2-1, there clearly are some outliers in the data, mostly to the high CO2 and fuel 

consumption side. However, NHTSA has further considered whether it is appropriate to classify 

these vehicles as outliers. Unlike in traditional datasets, these vehicles’ performance is not 

mischaracterized due to errors in their measurement, a common reason for outlier classification. 

Being certification data, the chances of large measurement errors should be near zero, 

particularly towards high CO2 or fuel consumption. Thus, they can only be outliers in the sense 

that the vehicle designs are unlike those of other vehicles. These outlier vehicles may include 

performance vehicles, vehicles with high ground clearance, 4WD, or boxy designs. Given that 

these are equally legitimate on-road vehicle designs, NHTSA concluded that it would 

appropriate to reconsider the treatment of these vehicles in the regression techniques. 

Based on these considerations as well as on the adjustments discussed above, NHTSA concluded 

it was not meaningful to run MAD regressions on gpm data that had already been adjusted in the 

manner described above. Normalizing already reduced the variation in the data, and brought 

outliers towards average values. This was the intended effect, so NHTSA deemed it unnecessary 

to apply an additional remedy to resolve an issue that had already been addressed, but we sought 

comment on the use of robust regression techniques under such circumstances. One commenter, 

ACEEE, addressed this question in this rulemaking, indicating (consistent with NHTSA’s views) 

that MAD and OLS are both technically sound methods for fitting functions. 

Sales Weighting 

Likewise, in the proposal, NHTSA reconsidered the application of sales-weighting to represent 

the data. As explained below, the decision to sales weight or not is ultimately based upon a 

choice about how to represent the data, and not by an underlying statistical concern. Sales 

weighting is used if the decision is made to treat each (mass produced) unit sold as a unique 

physical observation. Doing so thereby changes the extent to which different vehicle model 

types are emphasized as compared to a non-sales weighted regression. For example, while total 

152 Id. at 25362-63. 153 Id. at 25363. 
 

                                                      

163 

General Motors Silverado (332,000) and Ford F-150 (322,000) sales differed by less than 10,000 

in MY 2021 market forecast used for the NPRM, 62 F-150s models and 38 Silverado models 

were reported in NHTSA baselines. Without sales-weighting, the F-150 models, because there 

were more of them, were given 63 percent more weight in the regression despite comprising a 

similar portion of the marketplace and a relatively homogenous set of vehicle technologies. 

NHTSA did not use sales weighting in the MYs 2012-2016 rulemaking analysis of the curve 

shapes. A decision to not perform sales weighting reflects judgment that each vehicle model 

provides an equal amount of information concerning the underlying relationship between 

footprint and fuel economy. Sales-weighted regression gives the highest sales vehicle model 

types vastly more emphasis than the lowest-sales vehicle model types thus driving the regression 

toward the sales-weighted fleet norm. For unweighted regression, vehicle sales do not matter. 

NHTSA notes that the light truck market forecast shows MY 2025 sales of 218,000 units for 

Toyota’s 2WD Sienna, and shows 66 model configurations with MY 2025 sales of fewer than 

100 units. Similarly, NHTSA’s market forecast shows MY 2025 sales of 267,000 for the Toyota 

Prius, and shows 40 model configurations with MY2025 sales of fewer than 100 units. Salesweighted analysis would give the Toyota Sienna and Prius more than a thousand times the 

consideration of many vehicle model configurations. Sales-weighted analysis would, therefore, 

cause a large number of vehicle model configurations to be virtually ignored in the 

regressions.154 

However, NHTSA did note in the MYs 2012-2016 final rules that, “sales weighted regression 

would allow the difference between other vehicle attributes to be reflected in the analysis, and 

also would reflect consumer demand.” 155 In reexamining the sales-weighting for this analysis, 

NHTSA notes that there are low-volume model types that account for many of the passenger car 

model types (50 percent of passenger car model types account for 3.3 percent of sales), and it is 

unclear whether the engineering characteristics of these model types should equally determine 

the standard for the remainder of the market. 

In the interest of taking a fresh look at appropriate methodologies as promised in the last final 

rule, in developing proposed and final standards for MYs 2017-2025, NHTSA gave full 

consideration to both sales-weighted and unweighted regressions. 

Analyses Performed 

We performed regressions describing the relationship between a vehicle’s CO2/fuel consumption 

and its footprint, in terms of various combinations of factors: initial (raw) fleets with no 

154 75 FR at 25362 and n. 64 155 75 FR at 25632/3. 
 

164 

technology, versus after technology is applied; sales-weighted versus non-sales weighted; and 

with and without two sets of normalizing factors applied to the observations. NHTSA excluded 

diesels and dedicated AFVs because NHTSA anticipates that advanced gasoline-fueled vehicles 

are likely to be dominant through MY2025. Results supporting development of the proposed and 

finalized standards are depicted graphically in Figure V-9 through Figure V-16, below. 

Thus, the basic OLS regression on the initial data (with no technology applied) and no salesweighting represents one perspective on the relation between footprint and fuel economy. 

Adding sales weighting changes the interpretation to include the influence of sales volumes, and 

thus steps away from representing vehicle technology alone. Likewise, MAD is an attempt to 

reduce the impact of outliers, but reducing the impact of outliers might perhaps be less 

representative of technical relationships between the variables, although that relationship may 

change over time in reality. Each combination of methods and data reflects a perspective, and 

the regression results reflect that perspective in a simple quantifiable manner, expressed as the 

coefficients determining the line through the average (for OLS) or the median (for MAD) of the 

data. It is left to policy makers to determine an appropriate perspective and to interpret the 

consequences of the various alternatives. 

NHTSA sought comment on the application of the weights as described above, and the 

implications for interpreting the relationship between fuel efficiency and footprint. ACEEE 

questioned adjustment of the light truck data based on differences in weight/footprint, indicating 

that, in their view, the adjustment produces too steep a slope and potentially implies 

overstatement of the efficacy of some technologies as applied to pickup trucks. ACEEE also 

suggested that adjustment based on differences in power/weight would yield flatter curves and be 

more consistent with how the EU constructed related CO2 targets. The Alliance, in contrast, 

supported the weightings applied by NHTSA, and the resultant relationships between fuel 

efficiency and footprint. Both ACEEE and the Alliance commented that NHTSA should revisit 

the application of weights—and broader aspects of analysis to develop mathematical functions— 

in the future. Moreover, although ACEEE expressed concern regarding the outcomes of the 

application of the weight/footprint adjustment, NHTSA maintains that the adjustments (including 

no adjustments) considered in the NPRM are all potentially reasonable to apply for purposes of 

developing fuel economy and GHG target curves. This issue is discussed in greater detail in 

Section II.C of the preamble, and related issues–the slope and stringency of the light truck 

standards—are addressed further in Sections III and IV of the preamble. 

What results did NHTSA obtain? 

Both agencies employed the same statistical approaches. For regressions against data including 

technology normalization, NHTSA used the CAFE modeling system. 
                                                      

165 

For illustrative purposes, the set of figures below show the range of curves determined by the 

possible combinations of regression techniques, with and without sales weighting, with and 

without the application of technology, and with various adjustments to the gpm variable prior to 

running a regression. Again, from a statistical perspective, each of these regressions simply 

represents the assumptions employed. Since they are all univariate linear regressions, they 

describe the line that will result from minimizing the sum of the residuals (for MAD) or sum of 

squared residuals (for OLS). Figures show the results for passenger cars, then light trucks, for 

ordinary least squares (OLS) then similar results for MAD regressions for cars and light trucks, 

respectively. The various equations are represented by the string of attributes used to define the 

regression. See the table, Regression Descriptors, below, for the legend. Thus, for example, the 

line representing “ols_LT_wt_ft_adj_init_w” should be read as follows: an OLS regression, for 

light trucks, using data adjusted according to weight to footprint, no technology added, and 

weighted by sales. 

Table V-6 Regression Descriptors 

Notation Description 

ols or mad Ordinary least squares or mean absolute deviation 

PC or LT Passenger car or light truck 

hp_wt_adj Adjustment for horsepower to weight 

wt_ft_adj Adjustment for weight to footprint 

wt_ft_hp_wt_adj Adjustment for both horsepower to weight and weight to footprint 

init or final Vehicles with no technology (initial) or with technology added (final) 

u or w Unweighted or weighted by sales 

Thus, the next figures, for example, represent a family of curves (lines) fit using ordinary least 

squares on data for passenger cars, not modified for technology, and which therefore permits 

comparisons of results in terms of the factors that change in each regression. These factors are 

whether the data are sales-weighted (denoted “w”) or unweighted (denoted “u”), as well as the 

adjustments described above. Each of these adjustments has an influence on the regressions 

results, depicted in the figures below. 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analysis with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.156

156 Docket No. NHTSA-2010-0131. 
0.1
 

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Gallons Per Mile

0.05
 

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25 35 45 55 65 75 85

Footprint

olsPC__init_w olsPC__init_u

olsPC_hp_wt_adj__init_w olsPC_hp_wt_adj__init_u

olsPC_wt_ft_hp_wt_adj__init_w olsPC_wt_ft_hp_wt_adj__init_u

olsPC_wt_ft_adj__init_w olsPC_wt_ft_adj__init_u

No Technology Fleet Technology Fleet

166 

Figure V-9 Best Fit Results for Various Regressions: Cars, No Added Technology, OLS 

Figure V-10, below, shows comparable results, this time with data representing the additional 

technology that has been added to reduce technological heterogeneity. Note that the data now 

pass through the relevant data “cloud” for the fleet with the technology adjustment applied. The 
0.1
 

0.09
 

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Gallons Per Mile0.06
 

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olsPC__final_w Footprint olsPC__final_u

olsPC_hp_wt_adj__final_w olsPC_hp_wt_adj__final_u

olsPC_wt_ft_hp_wt_adj__final_w olsPC_wt_ft_hp_wt_adj__final_u

olsPC_wt_ft_adj__final_w olsPC_wt_ft_adj__final_u

No Technology Fleet Technology Fleet

167 

slopes of the lines are somewhat more clustered (less divergent) in the chart depicting added 

technology (as discussed in footnote 128). 

Figure V-10 Best Fit Results for Various Regressions: Cars, with Added Technology, OLS 

Similar to the figures displaying the results for passenger cars, the figures below display 

regression lines for trucks, first with no technology added, then subsequently, for the case where 

technology has been added. Slopes appear more similar to each other here than of passenger 

cars. 
Gallons per Mile

0.1

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0.08

0.07

0.06

0.05

0.04

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25 35 45 55 65 75 85

olsLT__init_w Footprint olsLT__init_u

olsLT_hp_wt_adj__init_w olsLT_hp_wt_adj__init_u

olsLT_wt_ft_hp_wt_adj__init_w olsLT_wt_ft_hp_wt_adj__init_u

olsLT_wt_ft_adj__init_w olsLT_wt_ft_adj__init_u

No Technology Fleet Technology Fleet

168 

Figure V-11 Best Fit Results for Various Regressions: Trucks, No Added Technology, OLS 

. 
Gallons per Mile

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25 35 45 55 65 75 85

olsLT__final_w Footprint olsLT__final_u

olsLT_hp_wt_adj__final_w olsLT_hp_wt_adj__final_u

olsLT_wt_ft_hp_wt_adj__final_w olsLT_wt_ft_hp_wt_adj__final_u

olsLT_wt_ft_adj__final_w olsLT_wt_ft_adj__final_u

No Technology Fleet Technology Fleet

169 

Figure V-12 Best Fit Results for Various Regressions: Trucks, With Added Technology, 

OLS 
0.1
 

0.09
 

0.08
 

0.07
 

Gallons Per Mile0.06
 

0.05
 

0.04
 

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0

25 35 45 55 65 75 85

madPC_init_w Footprint madPC_init_u

madPC_hp_wt_adj_init_w madPC_hp_wt_adj_init_u

madPC_wt_ft_hp_wt_adj_init_w madPC_wt_ft_hp_wt_adj_init_u

madPC_wt_ft_adj_init_w madPC_wt_ft_adj_init_u

No Technology Fleet Technology Fleet

170 

Figure V-13, below, displays regression results for the passenger car MAD fitted curves. The 

technology adjustment does not have, however, the same degree of impact in reducing the 

difference in the attained slopes (between those with and without the addition of technology) 

evidenced in the OLS regressions. 

Figure V-13 Best Fit Results for Various Regressions: Cars, No Added Technology, MAD 
0.1
 

0.09
 

0.08
 

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Gallons Per Mile0.06
 

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25 35 45 55 65 75 85

Footprint

madPC_final_w madPC_final_u

madPC_hp_wt_adj_final_w madPC_hp_wt_adj_final_u

madPC_wt_ft_hp_wt_adj_final_w madPC_wt_ft_hp_wt_adj_final_u

madPC_wt_ft_adj_final_w madPC_wt_ft_adj_final_u

No Technology Fleet Technology Fleet

171 

Figure V-14 Best Fit Results for Various Regressions: Cars, Added Technology, MAD 

The MAD regression results below in Figure V-15 show a grouping of the fitted lines similar to 

that displayed in the OLS fits for trucks. As expected, an additional reduction in divergence is 

seen in the case where technology has been added, in Figure V-15, which can be ascribed to the 

reduction in heterogeneity of the fleet brought about by the addition of the technology. 
0.1
 

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0.08
 

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Gallons per Mile0.06
 

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25 35 45 55 65 75 85

madLT_init_w Footprint madLT_init_u

madLT_hp_wt_adj_init_w madLT_hp_wt_adj_init_u

madLT_wt_ft_hp_wt_adj_init_w madLT_wt_ft_hp_wt_adj_init_u

madLT_wt_ft_adj_init_w madLT_wt_ft_adj_init_u

No Technology Fleet Technology Fleet

172 

Figure V-15 Best Fit Results for Various Regressions: Trucks, No Added Technology, 

MAD 
0.1
 

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25 35 45 55 65 75 85

madLT_final_w Footprint madLT_final_u

madLT_hp_wt_adj_final_w madLT_hp_wt_adj_final_u

madLT_wt_ft_hp_wt_adj_final_w madLT_wt_ft_hp_wt_adj_final_u

madLT_wt_ft_adj_final_w madLT_wt_ft_adj_final_u

No Technology Fleet Technology Fleet

173 

Figure V-16 Best Fit Results for Various Regressions: Trucks, with Added Technology, 

MAD 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projections 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.157

    157 Docket No. NHTSA-2010-0131. 
                                                      

 

 

174 

Which methodology did NHTSA choose for the proposal, and why was it reasonable? 

For the proposal, the choice among the alternatives presented above was to use the OLS 

formulation, on sales-weighted data, using a fleet that has had technology applied, and after 

adjusting the data for the effect of weight-to-footprint, as described above. NHTSA believes that 

this represented a technically reasonable approach for purposes of developing target curves to 

define the proposed standards, and that it represents a reasonable trade-off among various 

considerations balancing statistical, technical, and policy matters, which include the statistical 

representativeness of the curves considered and the steepness of the curve chosen. NHTSA 

judged the application of technology prior to curve fitting to provide a reasonable means—one 

consistent with the rule’s objective of encouraging manufacturers to add technology in order to 

increase fuel economy and reduce GHG emissions—of reducing variation in the data and thereby 

helping to estimate a relationship between fuel consumption/CO2 and footprint. 

Similarly, for NHTSA’s NPRM MY 2008-based market-forecast and NHTSA’s estimates of 

future technology effectiveness, the inclusion of the weight-to-footprint data adjustment prior to 

running the regression also helped to improve the fit of the curves by reducing the variation in 

the data, and NHTSA believed that the benefits of this adjustment for the proposed rule likely 

outweighed the potential that resultant curves might somehow encourage reduced load carrying 

capability or vehicle performance (note that we were not suggesting that we believed these 

adjustments would reduce load carrying capability or vehicle performance). In addition to 

reducing the variability, the truck curve was also steepened, and the car curve flattened compared 

to curves fitted to sales weighted data that do not include these normalizations. NHTSA agreed 

with manufacturers of full-size pick-up trucks that in order to maintain towing and hauling 

utility, the engines on pick-up trucks must be more powerful, than their low “density” nature 

statistically suggested based on NHTSA’s NPRM MY 2008-based market forecast and 

NHTSA’s estimates of the effectiveness of different fuel-saving technologies. Therefore, 

NHTSA judged that it may be more appropriate (i.e., in terms of relative compliance challenges 

faced by different light truck manufacturers) to adjust the slope of the curves defining fuel 

economy and CO2 targets. 

The results of the normalized regressions are displayed in Table, below.158 

Table V-7 Regression Results 

158 As presented in the draft TSD and PRIA supporting the NPRM, this table erroneously reported coefficients from 

the regression using normalization based on differences in horsepower to weight rather than differences in weight 

per footprint. The differences in this Table as presented in this final RIA reflect this correction. 
                                                      

175 

Vehicle Slope 

(gallons/mile) 

Constant 

(gallons/mile) 

Passenger cars 0.00037782 0.00181033 

Light trucks 0.00038891 0.00401336 

Updating this analysis using the corrected MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.159

As described above, however, other approaches are also technically reasonable, and also 

represent a way of expressing the underlying relationships. NHTSA revisited the analysis for the 

final rule, after correcting the underlying MY 2008 based market forecast, developing a MY 

2010 based market forecast, updating estimates of technology effectiveness and cost, and after 

considering relevant public comments. As presented below, results of these updated analyses 

were generally similar to those supporting the NPRM analysis results, and NHTSA’s balancing 

of considerations led NHTSA to select final curves unchanged from the NPRM curves. 

As shown in the figures below, the line represents the sales-weighted OLS regression fit of 

gallons per mile regressed on footprint, with the proposal data first adjusted by weight to 

footprint, as described above. This introduces weight as an additional consideration into the 

slope of the footprint curve, although in a manner that adjusts the data as described above, and 

thus maintains a simple graphical interpretation of the curve in a two dimensional space (gallons 

per mile and footprint). 

159 Docket No. NHTSA-2010-0131. 
 

   

176 

0

0.01

0.02

0.03

0.04

0.05

0.06

30 35 40 45 50 55 60 65 70 75 80

Weight per Footprint Adjusted GPM

Footprint

GPM vs. Footprint ‐ Cars

Figure V-17 Gallons per Mile versus Footprint, Cars 

(Data adjusted by weight to footprint). 
                                                      

   

177 

0

0.01

0.02

0.03

0.04

0.05

0.06

30 35 40 45 50 55 60 65 70 75 80

Weight per Footprint Adjusted GPM

Footprint

GPM vs. Footprint ‐ Trucks

Figure V-18 Gallons per Mile versus Footprint, Trucks 

(data adjusted by weight to footprint). 

Updating this analysis using the revised MY 2008- and the MY 2010-based fleet projection 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.160

In the preceding two figures, passenger car and light truck data is represented for the 

specification chosen, with the size of the observation scaled to sales. NHTSA notes with regard 

to light trucks that for the MYs 2012-2016 analysis NPRM and final rule analyses, some models 

of pickups are aggregated, when, for example, the same pickup had been available in different 

cab configurations with different wheelbases.161 For the analysis presented above, these models 

have been disaggregated and are represented individually, which leads to a slightly different 

outcome in the regression results than had they remained aggregated. 

Implications of the adopted slopes compared to the slopes in MYs 2012-2016 Rules 

160 Docket No. NHTSA-2010-0131. 161 See 75 FR at 25354 
178 

The slope first proposed, and now adopted by NHTSA has several implications relative to the 

MY 2016 curves, with the majority of changes affecting the truck curve. The selected car curve 

has a slope similar to that finalized in the MYs 2012-2016 rulemaking (4.7 g/mile in MY 2016, 

vs. 4.5 g/mile proposed in MY 2017). By contrast, the truck curve is steeper in MY 2017 than in 

MY 2016 (4.0 g/mile in MY 2016 vs. 4.9 g/mile in MY 2017). As discussed previously, a 

steeper slope relaxes the stringency of targets for larger vehicles relative to those for smaller 

vehicles, thereby shifting relative compliance burdens among manufacturers based on their 

respective product mix. Comments regarding the slope of NHTSA’s proposed curves are 

discussed in Section II.C of the preamble to today’s final rule. 

Once NHTSA determined the appropriate slope for the sloped part, how did NHTSA 

determine the rest of the mathematical function? 

NHTSA continues to believe that without a limit at the smallest footprints, the function— 

whether logistic or linear—can reach values that would be unfairly burdensome for a 

manufacturer that elects to focus on the market for small vehicles; depending on the underlying 

data, an unconstrained form could result in stringency levels that are technologically infeasible 

and/or economically impracticable for those manufacturers that may elect to focus on the 

smallest vehicles. On the other side of the function, without a limit at the largest footprints, the 

function may provide no floor on required fuel economy. Also, the safety considerations that 

support the provision of a disincentive for downsizing as a compliance strategy apply weakly, if 

at all, to the very largest vehicles. Limiting the function’s value for the largest vehicles thus 

leads to a function with an inherent absolute minimum level of performance, while remaining 

consistent with safety considerations. 

Just as for slope, in determining the appropriate footprint and fuel economy values for the 

“cutpoints,” the places along the curve where the sloped portion becomes flat, NHTSA took a 

fresh look for purposes of this rulemaking, taking into account the updated market forecasts and 

new assumptions about the availability of technologies. The next two sections discuss NHTSA’s 

approach to cutpoints for the passenger car and light truck curves separately, as the policy 

considerations for each vary somewhat. 

Cutpoints for Passenger Car curve 

The passenger car fleet upon which NHTSA based the proposed target curves for MYs 2017­

2025 was derived from MY 2008 data, as discussed above. In MY 2008, passenger car 

footprints ranged from 36.7 square feet, the Lotus Exige 5, to 69.3 square feet, the Daimler 

Maybach 62. In that fleet, several manufacturers offer small, sporty coupes below 41 square 
                                                      

179 

feet, such as the BMW Z4 and Mini, Honda S2000, Mazda MX-5 Miata, Porsche Carrera and 

911, and Volkswagen New Beetle. Because such vehicles represent a small portion (less than 10 

percent) of the passenger car market, yet often have performance, utility, and/or structural 

characteristics that could make it technologically infeasible and/or economically impracticable 

for manufacturers focusing on such vehicles to achieve the very challenging average 

requirements that could apply in the absence of a constraint, NHTSA again proposed to cut off 

the sloped portion of the passenger car function at 41 square feet, consistent with the MYs 2012­

2016 rulemaking. NHTSA recognized that for manufacturers who make small vehicles in this 

size range, putting the cutpoint at 41 square feet creates some incentive to downsize (i.e., further 

reduce the size, and/or increase the production of models currently smaller than 41 square feet) 

to make it easier to meet the target. Putting the cutpoint here may also create the incentive for 

manufacturers who do not currently offer such models to do so in the future. However, at the 

same time, NHTSA believes that there is a limit to the market for cars smaller than 41 square 

feet -- most consumers likely have some minimum expectation about interior volume, among 

other things. NHTSA thus believes that the number of consumers who will want vehicles 

smaller than 41 square feet (regardless of how they are priced) is small, and that the incentive to 

downsize to less than 41 square feet in response to this proposal, if present, will be at best 

minimal. On the other hand, NHTSA notes that some manufacturers are introducing mini cars 

not reflected in NHTSA MY 2008-based market forecast, such as the Fiat 500, to the U.S. 

market, and that the footprint at which the curve is limited may affect the incentive for 

manufacturers to do so. 

Above 56 square feet, the only passenger car models present in the MY 2008 fleet were four 

luxury vehicles with extremely low sales volumes—the Bentley Arnage and three versions of the 

Rolls Royce Phantom. As in the MYs 2012-2016 rulemaking, NHTSA therefore proposed again 

to cut off the sloped portion of the passenger car function at 56 square feet.162 

While meeting with manufacturers prior to issuing the proposal, NHTSA received comments 

from some manufacturers that, combined with slope and overall stringency, using 41 square feet 

as the footprint at which to cap the target for small cars would result in unduly challenging 

targets for small cars. NHTSA does not agree. No specific vehicle need meet its target (because 

standards apply to fleet average performance), and maintaining a sloped function toward the 

smaller end of the passenger car market is important to discourage unsafe downsizing, NHTSA 

thus proposed to again “cut off” the passenger car curve at 41 square feet, notwithstanding these 

comments. 

NHTSA discusses the comments that were received for the cutpoints on both passenger car and 

light truck curves in the next section. 

162 The MY 2010 based market forecast has a similarly small number of cars above a footprint of 56 sq ft. These 

nine vehicle models include 5 Rolls Royce models, a Maybach 57-S and three BMW vehicles, with fewer than 

20,000 total projected sales in any model year during this timeframe. 
                                                      

180 

Cutpoints for Light Truck curve 

The light truck fleet upon which NHTSA based the proposed target curves for MYs 2017-2025, 

like the passenger car fleet, was derived from MY 2008 data, as discussed above. In MY 2008, 

light truck footprints ranged from 41.0 square feet, the Jeep Wrangler, to 77.5 square feet, the 

Toyota Tundra. For consistency with the curve for passenger cars, NHTSA proposed to cut off 

the sloped portion of the light truck function at the same footprint, 41 square feet, although we 

recognized that no light trucks are currently offered below 41 square feet. With regard to the 

upper cutpoint, NHTSA heard from a number of manufacturers during the discussions leading up 

to the proposal of the MYs 2017-2025 standards that the location of the cutpoint in the MYs 

2012-2016 rules, 66 square feet, resulted in very challenging targets for the largest light trucks in 

the later years of that rulemaking (although, because CAFE standards are based on average 

performance, manufacturers to not need to ensure that every vehicle model meets its fuel 

economy and GHG targets). See 76 FR at 74864-65. Those manufacturers requested that 

NHTSA extend the cutpoint to a larger footprint, to reduce targets for the largest light trucks 

which represent a significant percentage of those manufacturers’ light truck sales. At the same 

time, in re-examining the light truck fleet data, NHTSA concluded that aggregating pickup truck 

models in the MYs 2012-2016 rule had led NHTSA to underestimate the impact of the different 

pickup truck model configurations above 66 square feet on manufacturers’ fleet average fuel 

economy and CO2 levels (as discussed immediately below). In disaggregating the pickup truck 

model data, the impact of setting the cutpoint at 66 square feet after model year 2016 became 

clearer to NHTSA. 

In NHTSA’s view, these comments have a legitimate basis. NHTSA’s market forecast used at 

proposal includes about 24 vehicle configurations above 74 square feet with a total volume of 

about 50,000 vehicles or less during any MY in the 2017-2025 time frame.163 While a relatively 

small portion of the overall truck fleet, for some manufacturers, these vehicles are a non-trivial 

portion of their sales. As noted above, the very largest light trucks have significant load-carrying 

and towing capabilities that make it particularly challenging for manufacturers to add fuel 

economy-improving/CO2-reducing technologies in a way that maintains the full functionality of 

those capabilities.164 Considering manufacturer CBI and our estimates of the impact of the 66 

square foot cutpoint for future model years, NHTSA determined to adopt curves that transition to 

a different cut point. While noting that no specific vehicle need meet its target (because 

163 In the MY2010 based market forecast, there are 14 vehicle configurations with a total volume of 130,000 

vehicles or less during any MY in the 2017-2025 time frame. This is a similarly small portion of the overall number 

of vehicle models or vehicle sales. 

164 Comments on this issue are discussed in previous section of this FRIA entitled “Adjustments reflecting 

differences in performance and ‘density’.” 
                                                      

181 

standards apply to fleet average performance), we believe that the information provided to us by 

manufacturers (i.e., information provided regarding the accumulated impacts, especially on 

manufacturers’ credit balances, of CAFE standards since MY2005 and GHG standards since 

MY2012) and our own analysis supported the gradual extension of the cutpoint for large light 

trucks in the proposal from 66 square feet in MY 2016 out to a larger footprint square feet before 

MY 2025. NHTSA’s analysis with regard to this topic, and how it relates to the stringency of the 

standards, are presented in preamble IV.F and summarized in preamble section II.C. 

Figure V-19 Footprint Distribution by Car and Truck* 

*Proposed truck cutpoints for MY 2025 shown in red, car cutpoints shown in green 

Updating this analysis using the revised MY 2008- and the MY 2010-based market forecasts 

yielded results generally similar to those shown above. Detailed results of the analyses with the 

final rulemaking fleet projections are presented in a memorandum titled “Curve Fitting Analysis: 

Regression Results,” available in NHTSA’s docket.165, and noted in footnotes 162 and 163.

NHTSA proposed to phase in the higher cutpoint for the truck curve in order to avoid any 

backsliding from the MY 2016 standard. A target that is feasible in one model year should never 

165 Docket No. NHTSA-2010-0131. 
 

                                                      

182 

become less feasible in a subsequent model year since manufacturers should have no reason to 

remove fuel economy-improving/CO2-reducing technology from a vehicle once it has been 

applied. Put another way, NHTSA proposed to not allow “curve crossing” from one model year 

to the next. In proposing MYs 2011-2015 CAFE standards and promulgating MY 2011 

standards, NHTSA proposed and requested comment on avoiding curve crossing, as an “antibacksliding measure.”166 The MY 2016 2-cycle test curves are therefore a floor for the MYs 

2017-2025 curves. For passenger cars, which have minimal change in slope from the MY 2012­

2016 rulemakings and no change in cut points, there were no curve crossing issues in the 

proposed (or final) standards. 

The minimum stringency determination was done using the two-cycle curves. Stringency 

adjustments for air conditioning and other credits were calculated after curves that did not cross 

were determined in two-cycle space. The year over year increase in these adjustments cause 

neither the GHG nor CAFE curves (with A/C) to contact the 2016 curves when charted. 

NHTSA received some comments on the selection of these cutpoints. ACEEE commented that 

the extension of the light truck cutpoint upward from 66 square feet to 74 square feet would 

reduce stringency for large trucks even though there is no safety-related reason to discourage 

downsizing of these trucks. Sierra Club and Volkswagen commented that moving this cutpoint 

could encourage trucks to get larger and may be detrimental to societal fatalities. Global 

Automakers commented that the cutpoint for the smallest light trucks should be set at 

approximately ten percent of sales (as for passenger cars) rather than at 41 square feet. 

Conversely, IIHS commented that, for both passenger cars and light trucks, the 41 square feet 

cutpoint should be moved further to the left (i.e., to even smaller footprints), to reduce the 

incentive for manufacturers to downsize the lightest vehicles. 

NHTSA has considered these comments regarding the cutpoint applied to the high footprint end 

of the target function for light trucks, and we judge there to be minimal risk that manufacturers 

would respond to this upward extension of the cutpoint by deliberately increasing the size of 

light trucks that are already at the upper end of marketable vehicle sizes, particularly as gasoline 

prices may continue to increase in the future. Such vehicles have distinct size, maneuverability, 

fuel consumption, storage, and other characteristics which differ from vehicles between 43 and 

48 square feet, and are likely not be suited for all consumers in all usage scenarios. Further, 

larger vehicles typically also have additional production costs that make it unlikely that the sales 

of these vehicles will increase in response to changes in the cutpoint. Therefore, we remain 

concerned that not to extend this cutpoint to 74 square feet would fail to take into adequate 

consideration the challenges to improving fuel economy and CO2 emissions to the levels 

required by this final rule for vehicles with footprints larger than 66 square feet, given their 

increased utility. As noted above, while manufacturers are not required to ensure that every 

166 74 Fed. Reg. at 14370 (Mar. 30, 2009). 
                                                      

183 

vehicle model meets its target, NHTSA is concerned that standards with more stringent targets 

for large trucks would unduly burden full-line manufacturers active in the market for full-size 

pickups and other large light trucks, as discussed earlier, and evidenced by NHTSA’s estimates 

of differences between compliance burdens faced by OEMs active and not active in the market 

for full-size pickups. While some manufacturers have recently indicated167 that buyers are 

currently willing to pay a premium for fuel economy improvements, NHTSA is concerned that 

disparities in long-term regulatory requirements could lead to future market distortions 

undermining the economic practicability of the standards. Absent an upward extension of the 

cutpoint, such disparities would be even greater. For these reasons, NHTSA does not expect that 

gradually extending the cutpoint to 74 square feet will incentivize the upsizing of large trucks 

and, thus, believe there will be no adverse effects on societal safety. Therefore, we are 

promulgating standards that, as proposed, gradually extend the truck curve cutpoint to 74 square 

feet. We have also considered the above comments by Global Automakers and IIHS on the 

cutpoints for the smallest passenger cars and light trucks. In our judgment, placing these 

cutpoints at 41 square feet continues to strike an appropriate balance between (a) not 

discouraging manufacturers from introducing new small vehicle models in the U.S. and (b) not 

encouraging manufacturers to downsize small vehicles. 

Once NHTSA determined the complete mathematical function shape, how did NHTSA 

adjust the curves to develop the proposed standards and regulatory alternatives? 

The curves discussed above all reflect the addition of technology to individual vehicle models to 

reduce technology differences between vehicle models before fitting curves. This application of 

technology was conducted not to directly determine the proposed standards, but rather for 

purposes of technology adjustments, and set aside considerations regarding potential rates of 

application (i.e., phase-in caps), and considerations regarding economic implications of applying 

specific technologies to specific vehicle models. The following sections describe further 

adjustments to the curves discussed above, that affect both the shape of the curve, and the 

location of the curve, that helped NHTSA determine curves that defined the proposed standards. 

Adjusting for Year over Year Stringency 

As in the MYs 2012-2016 rules, NHTSA developed curves defining regulatory alternatives for 

consideration by “shifting” these curves. For the MYs 2012-2016 rules, NHTSA did so on an 

167 For example, in its June 11, 2012 edition, Automotive News quoted a Ford sales official saying that "fuel 

efficiency continues to be a top purchaser driver.” (“More MPG – ASAP”, Automotive News, Jun 11, 2012.) 
184 

absolute basis, offsetting the fitted curve by the same value (in gpm or g/mi) at all footprints. In 

developing the proposal for MYs 2017-2025, NHTSA reconsidered the use of this approach, and 

concluded that after MY 2016, curves should be offset on a relative basis—that is, by adjusting 

the entire gpm-based curve (and, equivalently, the CO2 curve) by the same percentage rather than 

the same absolute value. NHTSA’s estimates—made jointly with EPA—of the effectiveness of 

these technologies are all expressed in relative terms—that is, each technology (with the 

exception of A/C) is estimated to reduce fuel consumption (the inverse of fuel economy) and 

CO2 emissions by a specific percentage of fuel consumption without the technology. It is, 

therefore, more consistent with the agencies’ estimates of technology effectiveness to develop 

standards and regulatory alternatives by applying a proportional offset to curves expressing fuel 

consumption or emissions as a function of footprint. In addition, extended indefinitely (and 

without other compensating adjustments), an absolute offset would eventually (i.e., at very high 

average stringencies) produce negative (gpm or g/mi) targets. Relative offsets avoid this 

potential outcome. Relative offsets do cause curves to become, on a fuel consumption and CO2 

basis, flatter at greater average stringencies; however, as discussed above, this outcome remains 

consistent with the agencies’ estimates of technology effectiveness. In other words, given a 

relative decrease in average required fuel consumption or CO2 emissions, a curve that is flatter 

by the same relative amount should be equally challenging in terms of the potential to achieve 

compliance through the addition of fuel-saving technology. 

On this basis, and considering that the “flattening” occurs gradually for the regulatory 

alternatives NHTSA has evaluated, NHTSA conclude that this approach to offsetting the curves 

to develop year-by-year regulatory alternatives neither re-creates a situation in which 

manufacturers are likely to respond to standards in ways that compromise highway safety, nor 

undoes the attribute-based standard’s more equitable balancing of compliance burdens among 

disparate manufacturers. NHTSA sought comment on these conclusions, and on any other 

means that might avoid the potential negative outcomes discussed above. As indicated earlier, 

ACEEE and the Alliance both expressed support for the application of relative adjustments in 

order to develop year-over-year increases in the stringency of fuel consumption and CO2 targets, 

although the Alliance also commented that this approach should be revisited as part of the 

planned mid-term evaluation. 

Adjusting for anticipated improvements to mobile air conditioning systems 

The fuel economy values in NHTSA’s market forecasts are based on the 2-cycle (i.e., city and 

highway) fuel economy test and calculation procedures that do not reflect potential 

improvements in air conditioning system efficiency, refrigerant leakage, or refrigerant Global 

Warming Potential (GWP). Recognizing that there are significant and cost effective potential air 

conditioning system improvements available in the rulemaking timeframe (discussed in detail in 

joint TSD Chapter 5), NHTSA is increasing the stringency of the target curves based on 
                                                      

185 

NHTSA’s assessment of the capability of manufacturers to implement these changes. For the 

proposed CAFE standards and alternatives, an offset was included based on air conditioning 

system efficiency improvements, as these improvements are the only improvements that effect 

vehicle fuel economy. For the proposed GHG standards and alternatives, a stringency increase 

was included based on air conditioning system efficiency, leakage and refrigerant improvements. 

As discussed in Chapter 5 of the joint TSD, the air conditioning system improvements affect a 

vehicle’s fuel efficiency or CO2 emissions performance as an additive stringency increase, as 

compared to other fuel efficiency improving technologies which are multiplicative. Therefore, in 

adjusting target curves for improvements in the air conditioning system performance, NHTSA 

adjusted the target curves by additive stringency increases (or vertical shifts) in the curves. 

For the GHG target curves, the offset for air conditioning system performance is being handled 

in the same manner as for the MYs 2012-2016 rules. For the CAFE target curves, NHTSA for 

the first time is accounting for potential improvements in air conditioning system performance. 

Using this methodology, NHTSA first uses a multiplicative stringency adjustment for the sloped 

portion of the curves to reflect the effectiveness on technologies other that air conditioning 

system technologies, creating a series of curve shapes that are “fanned” based on two-cycle 

performance. Then the curves are offset vertically by the air conditioning improvement by an 

equal amount at every point. 

What does NHTSA’s updated analysis indicate? 

As discussed above, NHTSA has used two different market forecasts to conduct analyses 

supporting today’s final rule. The first, referred to here as the “MY 2008-Based Fleet 

Projection,” is largely identical to that used for analysis supporting the NPRM, but includes some 

corrections (in particular, to the footprint of some vehicle models) discussed in Chapter 1 of the 

joint TSD. The second, referred to here as the “MY 2010-Based Fleet Projection,” is a postproposal market forecast based on the MY 2010 fleet of vehicles; the development of this 2010 

based fleet projection is discussed in Chapter 1 of the joint TSD. 

Having made these changes, NHTSA repeated the normalization and statistical analyses describe 

above, following the same approaches as used in the analysis supporting the NPRM. The tables 

and charts that follow compare the results of NHTSA’s updated analysis—documented in a 

memorandum titled “Curve Fitting Analysis: Regression Results,” available in NHTSA’s 

docket.168—to those of NHTSA’s prior analysis, and compare the resultant fitted lines to the 

lines (one each for passenger cars and light trucks) selected for purposes of developing the 

proposed attribute-based standards. The charts below present details of the results in graphical 

form. 

168 Docket No. NHTSA-2010-0131. 
186 

Table V-8 Fitted Coefficients (Slope in gpm/sf, Intercept in gpm), Passenger Cars Normalized for Technology Differences Normalized for Differences in Power/Weight Normalized for Differences in Weight/Footprint Sales‐Weighted Regression Technique Slope ‐ NPRM Analysis Slope ‐ MY2008‐Based Market Forecast Slope ‐ MY2010‐Based Market Forecast Intercept ‐ NPRM Analysis Intercept ‐ MY2008‐Based Market Forecast Intercept ‐ MY2010‐Based Market Forecast

Yes No No Yes OLS 0.000648 0.000510 0.000472 ‐0.01027 ‐0.00450 ‐0.00376

Yes No No No OLS 0.000513 0.000464 0.000502 0.00009 0.00184 ‐0.00076

Yes No No Yes MAD 0.000725 0.000560 0.000427 ‐0.01408 ‐0.00699 ‐0.00210

Yes No No No MAD 0.000359 0.000334 0.000445 0.00610 0.00650 0.00076

Yes Yes No Yes OLS 0.000431 0.000293 0.000248 ‐0.00052 0.00520 0.00643

Yes Yes No No OLS 0.000399 0.000351 0.000398 0.00336 0.00508 0.00221

Yes Yes Yes Yes OLS 0.000161 0.000131 0.000093 0.01155 0.01238 0.01349

Yes Yes Yes No OLS 0.000264 0.000250 0.000268 0.00844 0.00873 0.00736

No No No Yes MAD 0.001486 0.001220 0.001058 ‐0.03401 ‐0.02131 ‐0.01670

No No No No MAD 0.000942 0.000959 0.000995 ‐0.00507 ‐0.00572 ‐0.00944

No No No Yes OLS 0.001345 0.001175 0.001096 ‐0.02766 ‐0.01974 ‐0.01806

No No No No OLS 0.001109 0.001085 0.001099 ‐0.01122 ‐0.00983 ‐0.01259

No Yes No Yes OLS 0.000984 0.000800 0.000737 ‐0.01144 ‐0.00299 ‐0.00176

No Yes No No OLS 0.000920 0.000890 0.000933 ‐0.00579 ‐0.00425 ‐0.00785

No Yes Yes Yes OLS 0.000481 0.000452 0.000403 0.01103 0.01242 0.01336

No Yes Yes No OLS 0.000669 0.000673 0.000654 0.00367 0.00358 0.00319

Yes No Yes Yes OLS 0.000378 0.000348 0.000316 0.00181 0.00268 0.00330

Yes No Yes No OLS 0.000378 0.000362 0.000371 0.00517 0.00550 0.00440

Note 1: Coefficients selected for NPRM shown underlined. 

Note 2: “MY2008-Based Fleet Projection” refers to market forecast developed using (a) MY2008 vehicle models and 

characteristics, (b) AEO2011-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2009 by CSM (now owned by Global Insight). 

Note 3: “MY2010-Based Fleet Projection” refers to market forecast developed using (a) MY2010 vehicle models and 

characteristics, (b) AEO2012-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2011 by J.D. Power (automotive forecasting service now owned by LMC). 
187 

Table V-9 Fitted Coefficients (Slope in gpm/sf, Intercept in gpm), Light Trucks Normalized for Technology Differences Normalized for Differences in Power/Weight Normalized for Differences in Weight/Footprint Sales‐Weighted Regression Technique Slope ‐ NPRM Analysis Slope ‐ MY2008‐Based Market Forecast Slope ‐ MY2010‐Based Market Forecast Intercept ‐ NPRM Analysis Intercept ‐ MY2008‐Based Market Forecast Intercept ‐ MY2010‐Based Market Forecast

Yes No No Yes OLS 0.000269 0.000251 0.000256 0.01036 0.01012 0.00976

Yes No No No OLS 0.000233 0.000229 0.000198 0.01457 0.01376 0.01477

Yes No No Yes MAD 0.000250 0.000245 0.000278 0.01104 0.01060 0.00832

Yes No No No MAD 0.000204 0.000210 0.000231 0.01567 0.01438 0.01248

Yes Yes No Yes OLS 0.000253 0.000239 0.000237 0.01122 0.01078 0.01078

Yes Yes No No OLS 0.000221 0.000220 0.000201 0.01509 0.01414 0.01448

Yes Yes Yes Yes OLS 0.000373 0.000347 0.000340 0.00487 0.00507 0.00526

Yes Yes Yes No OLS 0.000395 0.000374 0.000303 0.00541 0.00558 0.00864

No No No Yes MAD 0.000448 0.000452 0.000481 0.01995 0.01984 0.01654

No No No No MAD 0.000356 0.000349 0.000440 0.02872 0.02914 0.02139

No No No Yes OLS 0.000491 0.000483 0.000470 0.01784 0.01825 0.01756

No No No No OLS 0.000433 0.000432 0.000423 0.02480 0.02486 0.02283

No Yes No Yes OLS 0.000462 0.000453 0.000446 0.01941 0.01988 0.01890

No Yes No No OLS 0.000410 0.000409 0.000426 0.02575 0.02579 0.02245

No Yes Yes Yes OLS 0.000669 0.000662 0.000629 0.00849 0.00881 0.00903

No Yes Yes No OLS 0.000710 0.000708 0.000609 0.00909 0.00919 0.01199

Yes No Yes Yes OLS 0.000389 0.000359 0.000358 0.00401 0.00441 0.00425

Yes No Yes No OLS 0.000407 0.000383 0.000301 0.00489 0.00520 0.00892

Note 1: Coefficients selected for NPRM shown underlined. 

Note 2: “MY2008-Based Market Forecast” refers to market forecast developed using (a) MY2008 vehicle models and 

characteristics, (b) AEO2011-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2009 by CSM (now owned by Global Insight). 

Note 3: “MY2010-Based Fleet Projection” refers to market forecast developed using (a) MY2010 vehicle models and 

characteristics, (b) AEO2012-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2011 by J.D. Power (automotive forecasting service now owned by LMC). 
188 

Figure V-20 Fitted Lines, Passenger Cars, NPRM Analysis 
189 

Figure V-21 Fitted Lines, Passenger Cars, Corrected MY2008-Based Market Forecast 

Note 1: Line based on coefficients selected for NPRM shown for comparison. 

Note 2: “MY2008-Based Fleet Projection” refers to market forecast developed using (a) MY2008 vehicle models and 

characteristics, (b) AEO2011-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2009 by CSM (now owned by Global Insight). 
190 

Figure V-22 Fitted Lines, Passenger Cars, MY2010-Based Market Forecast 

Note 1: Line based on coefficients selected for NPRM shown for comparison. 

Note 2: “MY2010-Based Fleet Projection” refers to market forecast developed using (a) MY2010 vehicle models and 

characteristics, (b) AEO2012-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2011 by J.D. Power (automotive forecasting service now owned by LMC). 
191 

Figure V-23 Fitted Lines, Light Trucks, NPRM Analysis 
192 

Figure V-24 Fitted Lines, Light Trucks, Corrected MY2008-Based Market Forecast 

Note 1: Line based on coefficients selected for NPRM shown for comparison. 

Note 2: “MY2008-Based Fleet Projection” refers to market forecast developed using (a) MY2008 vehicle models and 

characteristics, (b) AEO2011-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2009 by CSM (now owned by Global Insight). 
193 

Figure V-25 Fitted Lines, Light Trucks, MY2010-Based Market Forecast 

Note 1: Line based on coefficients selected for NPRM shown for comparison. 

Note 2: “MY2010-Based Fleet Projection” refers to market forecast developed using (a) MY2010 vehicle models and 

characteristics, (b) AEO2012-based overall passenger car and light truck volumes, and (c) manufacturer- and segment-level 

shares from forecast provided late 2011 by J.D. Power (automotive forecasting service now owned by LMC). 

As discussed above, the selection of a calibrated functional form—in this case, a specific line 

expressing a relationship between fuel consumption and footprint—upon which to base attributebased fuel economy and related GHG standards involves considering not just the apparent range 

of the relevant technical relationship, but also the potential implications for affected policy 

issues. The approaches described above provide a range of reasonable means of estimating 

relationships between observed or adjusted fuel consumption and footprint. 

Having made corrections to the MY 2008-based fleet projection, and having developed a new 

MY 2010-based fleet projection, NHTSA has obtained results generally similar, albeit not 

identical, to those obtained for the NPRM analysis. For any given method of estimating these 

lines, it is unlikely that NHTSA could have obtained identical results after changing inputs. 

Also, there is no reason to expect that the MY 2008- and MY 2010-based fleet projections 

should produce identical results. Still, these differences were mostly small. Using both the 
194 

corrected MY 2008-based passenger car market forecast and the new MY 2010-based forecast, 

three techniques produced fitted passenger car lines very close—in terms of average squared 

differences within the range of footprints between the selected cutpoints discussed above—to 

those selected for the NPRM: sales-weighted OLS without normalizations for differences in 

power/weight or weight/footprint, sales-weighted OLS with normalization for differences 

weight/footprint, and unweighted OLS with normalizations for differences in both power/weight 

and weight/footprint. For light trucks, two techniques did so for both the corrected MY 2008­

based passenger car market forecast and the post-proposal MY 2010-based forecast: unweighted 

OLS with normalizations for differences in both power/weight and weight/footprint, and 

unweighted OLS with normalization for differences weight/footprint. Without any 

normalizations applied to the set of footprint and fuel economy values, unweighted OLS 

produced fitted slopes within 2% of the values obtained through the corresponding unweighted 

OLS analysis conducted in support of the NPRM. Also, as the above charts show, the resultant 

ranges (i.e., areas in fuel consumption – footprint space) spanned by these methods are similar 

across the NPRM analysis and the updated analyses using the MY 2008- and MY 2010-based 

fleet projections. 

Considering that NHTSA has adopted an approach whereby regulatory alternatives are 

developed by shifting fitted curves on a multiplicative basis, results of several of the techniques 

evaluated here thus would produce regulatory alternatives virtually identical to those developed 

for the NPRM. For the method that produced results selected for development of the NPRM, 

relative adjustment of lines fitted to the corrected MY 2008-based market forecast and the MY 

2010-based market forecast produces lines that are, between the footprint cutpoints discussed 

above (41-56 ft2

 and 41-74 ft2 for passenger cars and light trucks, respectively), very close to the 

lines fitted for the NPRM (Figure V-26 and Figure V-27): 
195 

Figure V-26 Sales-Weighted OLS with Normalization for Differences in Weight/Footprint,
 

Passenger Cars, MY2008- and MY2010-Based Fleets Multiplicatively Adjusted 
196 

Figure V-27 Sales-Weighted OLS with Normalization for Differences in Weight/Footprint, 

Light Trucks, MY2008- and MY2010-Based Fleets Multiplicatively Adjusted 

The above figures show, for both for passenger cars and light trucks, that applying the 

techniques selected for the NPRM to either the corrected MY 2008-based fleet projection or the 

MY 2010-based fleet projection would produce regulatory alternatives with highly similar, but 

slightly flatter slopes than those in the NPRM. At any given average stringency, these slightly 

flatter slopes would produce slightly greater incentives for manufacturers to respond to new 

standards by reducing vehicle size. In addition, the slightly flatter slopes would slightly increase 

the stringency of targets for the largest vehicles relative to stringency of targets for the smallest 

vehicles. As discussed in II.C.4.a of the preamble, considering the accumulated effects of light 

truck CAFE standards having increased steadily since MY2004, and GHG standards from MY 

2012, NHTSA is concerned that flatter slopes could induce manufacturers of large light trucks 

toward overly aggressive penetration rates of advanced technologies into the sector, raising 

significant issues of cost, lead time and consumer acceptance which NHTSA regards as 

inappropriate. As discussed above, NHTSA remain concerned that about manufacturer 

incentives to reduce the capability to carry and/or tow heavy loads using full-size light trucks. 
197 

NHTSA has thus looked at a range of analytical techniques for establishing a fitted line including 

using two market forecasts and using different approaches for the normalization for differences 

in technology content, normalization for differences in other vehicle attributes (e.g., 

power/weight or weight/footprint or, plausibly, seating capacity, interior volume, towing 

capacity, etc.), and statistical techniques (e.g., unweighted, sales-weighted, MAD, OLS). 

Considering (a) that the reasonable analytical techniques examined by NHTSA produces a range 

of fitted lines, (b) that the future composition of the light vehicle market is subject to some 

uncertainty, and (c) that other aspects of NHTSA’s analysis are informed by policy implications, 

in NHTSA’s judgment, there is no single analytical method that is the sole “correct” way to 

establish the two fitted lines (one for passenger cars, one for light trucks) NHTSA uses to specify 

final standards. NHTSA’ updated analysis shows newly-fitted lines producing regulatory 

alternatives very close to the corresponding regulatory alternatives considered in the NPRM. 

This confirms that the standards are within the range of technically supportable possibilities. 

While NHTSA’s analysis indicates that slopes spanning relatively wide ranges could be 

technically supportable, NHTSA notes that the final car standard is very similar to the slope of 

the MY 2016 standard, despite being based on a different analytical approach than the previous 

rule. As explained above, NHTSA has selected a truck curve differing from that adopted for the 

previous rule (both slope and upper cut-point); NHTSA expects that doing so will account for the 

future characteristics of the larger (work) trucks, and the manufacturers serving the future market 

for such trucks. The upper size cut-points for cars, and the lower size cut-point for both cars and 

trucks, are the same as in the previous rule. Without these adjustments, NHTSA believes that 

there would either be incentives for manufacturers to reduce the utility of these trucks, or that the 

manufacturer’s compliance costs for reaching the targets would be disproportionately high. 

Thus, in NHTSA’s judgment, the curves strike a reasonable and appropriate balance between the 

affected policy considerations—better reflecting the reasonable penetration rates of the 

technologies needed to achieve the standards and the lead time needed for implementation of 

those technologies, minimizing the incentive for manufacturers to respond to standards in ways 

that may either result in decreased utility or compromise safety (by downsizing vehicles with 

footprints on the sloped portion of mathematical functions defining fuel economy and GHG 

targets), and encouraging widespread penetration of technologies throughout both the car and 

light truck fleets at reasonable cost while achieving very significant energy and environmental 

benefits. Having repeated the analysis documented in the NPRM, and having done so based on 

two fleets (the corrected MY 2008-based market forecast, and the MY 2010-based market 

forecast), NHTSA has demonstrated that, as proposed, the passenger car and light truck curves 

are well within technically supportable ranges. Slightly flatter standards would directionally 

have a potentially compromising effect on the safety-related incentives reflected by the 

promulgated curves, and potentially force more aggressive penetration of advanced technologies 

into work trucks in a way that raises issues of both increased cost and consumer acceptance. 
198 

Conversely, slightly steeper standards would tend to increase the potential that manufacturers 

would respond to the standards by increasing vehicle size beyond levels the market would 

otherwise demand, in lieu of applying some fuel-saving technologies. For these reasons, 

NHTSA is today promulgating standards using lines matching those used to develop proposed 

standards for the NPRM. 

Additional discussion of the feasibility of the final standards is available in Preamble section 

IV.F. 

How does NHTSA use the assumptions in its modeling analysis? 

In developing today’s CAFE standards, NHTSA has made significant use of results produced by 

the CAFE Compliance and Effects Model (commonly referred to as “the CAFE Model” or “the 

Volpe model”), which DOT’s Volpe National Transportation Systems Center developed 

specifically to support NHTSA’s CAFE rulemakings. The model, which has been constructed 

specifically for the purpose of analyzing potential CAFE standards, integrates the following core 

capabilities: 

(1) Estimating how manufacturers could apply technologies in response to new fuel 

economy standards, 

(2) Estimating the costs that would be incurred in applying these technologies, 

(3) Estimating the physical effects resulting from the application of these technologies, 

such as changes in travel demand, fuel consumption, and emissions of carbon dioxide and 

criteria pollutants, and 

(4) Estimating the monetized societal benefits of these physical effects. 

An overview of the model follows below. Separate model documentation provides a detailed 

explanation of the functions the model performs, the calculations it performs in doing so, and 

how to install the model, construct inputs to the model, and interpret the model’s outputs. 

Documentation of the model, along with model installation files, source code, and sample inputs 

are available at NHTSA’s Web site. The model documentation is also available in the docket for 

today’s proposed rule, as are inputs for and outputs from analysis of today’s CAFE standards. 

How does the model operate? 
 

                                                      

 

 

 

199 

As discussed above, the agency uses the CAFE model to estimate how manufacturers could 

attempt to comply with a given CAFE standard by adding technology to fleets that the agency 

anticipates they will produce in future model years. This exercise constitutes a simulation of 

manufacturers’ decisions regarding compliance with CAFE standards. 

This compliance simulation begins with the following inputs: (a) the baseline and reference 

market forecast discussed in Section II.B of the preamble, Chapter III above, and Chapter 1 of 

the joint TSD, (b) technology-related estimates discussed in Section II.D of the preamble, below 

in this Chapter, and Chapter 3 of the joint TSD, (c) economic inputs discussed in Section II.E of 

the preamble, Chapters VII and VIII below, and Chapter 4 of the joint TSD, and (d) inputs 

defining baseline and potential new CAFE standards, discussed in Section II.C of the preamble, 

and Chapter 2 of the joint TSD. For each manufacturer, the model applies technologies in a 

sequence that follows a defined engineering logic (“decision trees,” discussed in the MY 2011 

final rule and in the model documentation) and a cost-minimizing strategy in order to identify a 

set of technologies the manufacturer could apply in response to new CAFE standards.169 The 

model applies technologies to each of the projected individual vehicles in a manufacturer’s fleet, 

considering the combined effect of regulatory and market incentives. Depending on how the 

model is exercised, it will apply technology until one of the following occurs: 

(1) The manufacturer’s fleet achieves compliance170 with the applicable standard, and 

continuing to add technology in the current model year would be attractive neither in 

terms of stand-alone (i.e., absent regulatory need) cost effectiveness nor in terms of 

facilitating compliance in future model years;171 

(2) The manufacturer “exhausts”172 available technologies; or 

169 NHTSA does its best to remain scrupulously neutral in the application of technologies through the modeling 

analysis, to avoid picking technology “winners.” The technology application methodology has been reviewed by the 

agency over the course of several rulemakings, and commenters have been generally supportive of the agency’s 

approach. See, e.g., 74 FR 14238–14246 (Mar. 30, 2009). 170 The model has been modified to provide the ability—as an option—to account for credit mechanisms (i.e., carryforward, carry-back, transfers, and trades) when determining whether compliance has been achieved. For purposes 

of determining maximum feasible CAFE standards, NHTSA cannot consider these mechanisms, and exercises the 

CAFE model without enabling these options. 

171 In preparation for the MY2012-2016 rulemaking, the model was modified in order to apply additional technology 

in early model years if doing so will facilitate compliance in later model years. This is designed to simulate a 

manufacturer’s decision to plan for CAFE obligations several years in advance, which NHTSA believes better 

replicates manufacturers’ actual behavior as compared to the year-by-year evaluation which EPCA would otherwise 

require.

172 In a given model year, the model makes additional technologies available to each vehicle model within several 

constraints, including (a) whether or not the technology is applicable to the vehicle model’s technology class, (b) 

whether the vehicle is undergoing a redesign or freshening in the given model year, (c) whether engineering aspects 

of the vehicle make the technology unavailable (e.g., secondary axle disconnect cannot be applied to two-wheel 

drive vehicles), and (d) whether technology application remains within “phase in caps” constraining the overall 

share of a manufacturer’s fleet to which the technology can be added in a given model year. Once enough 

technology is added to a given manufacturer’s fleet in a given model year that these constraints make further 

technology application unavailable, technologies are “exhausted” for that manufacturer in that model year. 
                                                      

 

 

200 

(3) For manufacturers estimated to be willing to pay civil penalties, the manufacturer reaches 

the point at which doing so would be more cost-effective (from the manufacturer’s 

perspective) than adding further technology.173 

As discussed below, the model has also been modified in order to—as an option—apply more 

technology than may be necessary to achieve compliance in a given model year, or to facilitate 

compliance in later model years. This ability to simulate “voluntary overcompliance,” discussed 

elsewhere in this FRIA as a “market-driven baseline,” reflects the potential that manufacturers 

will apply some technologies to some vehicles if doing so would be sufficiently inexpensive 

compared to the expected reduction in owners’ outlays for fuel. 

The model accounts explicitly for each model year, applying most technologies when vehicles 

are scheduled to be redesigned or freshened, and carrying forward technologies between model 

years. The CAFE model accounts explicitly for each model year because EPCA requires that 

NHTSA make a year-by-year determination of the appropriate level of stringency and then set 

the standard at that level, while ensuring ratable increases in average fuel economy.174 The 

multiyear planning capability and (optional) simulation of “voluntary overcompliance” and 

EPCA credit mechanisms increase the model’s ability to simulate manufacturers’ real-world 

behavior, accounting for the fact that manufacturers will seek out compliance paths for several 

model years at a time, while accommodating the year-by-year requirement. 

The model also calculates the costs, effects, and benefits of technologies that it estimates could 

be added in response to a given CAFE standard.175 It calculates costs by applying the cost 

estimation techniques discussed herein, and by accounting for the number of affected vehicles. It 

173 This possibility was added to the model to account for the fact that under EPCA/EISA, manufacturers must pay 

fines if they do not achieve compliance with applicable CAFE standards. 49 U.S.C. 32912(b). NHTSA recognizes 

that some manufacturers will find it more cost-effective to pay fines than to achieve compliance, and believes that to 

assume these manufacturers would exhaust available technologies before paying fines would cause unrealistically 

high estimates of market penetration of expensive technologies such as diesel engines and strong hybrid electric 

vehicles, as well as correspondingly inflated estimates of both the costs and benefits of any potential CAFE 

standards. NHTSA thus includes the possibility of manufacturers choosing to pay fines in its modeling analysis in 

order to achieve what the agency believes is a more realistic simulation of manufacturer decision-making. Unlike 

flex-fuel and other credits, NHTSA is not barred by statute from considering fine-payment in determining maximum 

feasible standards under EPCA/EISA. 49 U.S.C. 32902(h). 

174 49 U.S.C. 32902(a) states that at least 18 months before the beginning of each model year, the Secretary of 

Transportation shall prescribe by regulation average fuel economy standards for automobiles manufactured by a 

manufacturer in that model year, and that each standard shall be the maximum feasible average fuel economy level 

that the Secretary decides the manufacturers can achieve in that year. NHTSA has long interpreted this statutory 

language to require year-by-year assessment of manufacturer capabilities. 49 U.S.C. 32902(b)(2)(C) also requires 

that standards increase ratably between MY 2011 and MY 2020. 175 As for all of its other rulemakings, NHTSA is required by Executive Order 12866 (as amended by Executive 

Order 13563) and DOT regulations to analyze the costs and benefits of CAFE standards. Executive Order 12866, 58 

FR 51735 (Oct. 4, 1993); DOT Order 2100.5, “Regulatory Policies and Procedures,” 1979, available at 

http://regs.dot.gov/rulemakingrequirements.htm (last accessed November 13, 2011). 
                                                      

201 

accounts for effects such as changes in vehicle travel, changes in fuel consumption, and changes 

in greenhouse gas and criteria pollutant emissions. It does so by applying the fuel consumption 

estimation techniques also discussed herein, and the vehicle survival and mileage accumulation 

forecasts, the rebound effect estimate and the fuel properties and emission factors discussed in 

Chapter VIII below. Considering changes in travel demand and fuel consumption, the model 

estimates the monetized value of accompanying benefits to society, as also discussed in Chapter 

VIII below. The model calculates both the undiscounted and discounted value of benefits that 

accrue over time in the future. 

The CAFE model has other capabilities that facilitate the development of a CAFE standard. The 

integration of (a) compliance simulation and (b) the calculation of costs, effects, and benefits 

facilitates analysis of sensitivity of results to model inputs. The model can also be used to 

evaluate many (e.g., 200 per model year) potential levels of stringency sequentially, and identify 

the stringency at which specific criteria are met. For example, it can identify the stringency at 

which net benefits to society are maximized, the stringency at which a specified total cost is 

reached, or the stringency at which a given average required fuel economy level is attained. This 

allows the agency to compare more easily the impacts in terms of fuel savings, emissions 

reductions, and costs and benefits of achieving different levels of stringency according to 

different criteria. The model can also be used to perform uncertainty analysis (i.e., Monte Carlo 

simulation), in which input estimates are varied randomly according to specified probability 

distributions, such that the uncertainty of key measures (e.g., fuel consumption, costs, benefits) 

can be evaluated. 

Has NHTSA considered other models? 

As discussed in the most recent CAFE rulemaking, while nothing in EPCA requires NHTSA to 

use the CAFE model, and in principle, NHTSA could perform all of these tasks through other 

means, the model’s capabilities have greatly increased the agency’s ability to rapidly, 

systematically, and reproducibly conduct key analyses relevant to the formulation and evaluation 

of new CAFE standards.176 

NHTSA notes that the CAFE model not only has been formally peer-reviewed and tested and 

reviewed through three rulemakings, but also has some features especially important for the 

analysis of CAFE standards under EPCA/EISA. Among these are the ability to perform year-byyear analysis, and the ability to account for engineering differences between specific vehicle 

models. 

176 75 FR 25598-25599. 
                                                      

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EPCA requires that NHTSA set CAFE standards for each model year at the level that would be 

“maximum feasible” for that year.177 Developing maximum feasible CAFE standards requires 

the ability to analyze each model year and, when developing regulations covering multiple model 

years, to account for the interdependency of model years in terms of the appropriate levels of 

stringency for each year modeled. Also, as part of the evaluation of the economic practicability 

of the standards, as required by EPCA, NHTSA has traditionally assessed the annual costs and 

benefits of the standards. In response to comments regarding an early version of the CAFE 

model, DOT modified the CAFE model in order to account for dependencies between model 

years and to better represent manufacturers’ product planning cycles, in a way that still allowed 

NHTSA to comply with the statutory requirement to determine the appropriate level of the 

standards for each model year. 

The CAFE model also accounts for important engineering differences between specific vehicle 

models enabling the capability for the model to reduce the risk of applying technologies that may 

be incompatible with a specific vehicle or that may already be present on a given vehicle model 

Additionally, by combining technologies incrementally and on a model-by-model basis, the 

CAFE model is able to avoid unlikely technology combinations by recognizing these important 

vehicle to vehicle engineering differences. 

The CAFE model also produces a single vehicle-level output file that, for each vehicle model, 

shows which technologies were present at the outset of modeling, which technologies were 

superseded by other technologies, and which technologies were ultimately present at the 

conclusion of modeling. For each vehicle, the same file shows resultant changes in vehicle 

weight, fuel economy, and cost. This provides for efficient identification, analysis, and 

correction of errors, a task with which the public can now assist the agency, since all inputs and 

outputs are public. 

Such considerations, as well as those related to the efficiency with which the CAFE model is 

able to analyze attribute-based CAFE standards and changes in vehicle classification, and to 

perform higher-level analysis such as stringency estimation (to meet predetermined criteria), 

sensitivity analysis, and uncertainty analysis, lead the agency to conclude that the model remains 

the best available to the agency for the purposes of analyzing potential new CAFE standards. 

What changes has DOT made to the model? 

Between promulgation of the MY 2012-2016 CAFE standards and today’s final rule regarding 

MY 2017-2025 standards, the CAFE model has been revised to make some minor 

improvements, and to add some significant new capabilities: (1) accounting for electricity used 

177 49 U.S.C. 32902(a) requires that NHTSA set CAFE standards at the maximum feasible level for each fleet, for 

each model year. 
 

                                                      

203 

to charge electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs), (2) accounting 

for use of ethanol blends in flexible-fuel vehicles (FFVs), (3) accounting for costs (i.e., “stranded 

capital”) related to early replacement of technologies, (4) accounting for previously-applied 

technology when determining the extent to which a manufacturer could expand use of the 

technology, (5) applying technology-specific estimates of changes in consumer value, (6) 

simulating the extent to which manufacturers might utilize EPCA’s provisions regarding 

generation and use of CAFE credits, (7) applying estimates of fuel economy adjustments (and 

accompanying costs) reflecting increases in air conditioner efficiency, (8) reporting privatelyvalued benefits, (9) simulating the extent to which manufacturers might voluntarily apply 

technology beyond levels needed for compliance with CAFE standards, and (10) estimating 

changes in highway fatalities attributable to any applied reductions in vehicle mass. These 

capabilities are described below, and in greater detail in the CAFE model documentation.178 

To support evaluation of the effects electric vehicles (EVs) and plug-in hybrid vehicles (PHEVs) 

could have on energy consumption and associated costs and environmental effects, DOT has 

expanded the CAFE model to estimate the amount of electricity that would be required to charge 

these vehicles (accounting for the potential that PHEVs can also run on gasoline). The model 

calculates the cost of this electricity, as well as the accompanying upstream criteria pollutant and 

greenhouse gas emissions. 

Similar to this expansion to account for the potential the PHEVs can be refueled with gasoline or 

recharged with electricity, DOT has expanded the CAFE model to account for the potential that 

other flexible-fuel vehicles can be operated on multiple fuels. In particular, the model can 

account for ethanol FFVs consuming E85 or gasoline and reports consumption of both fuels as 

well as corresponding costs and upstream emissions. 

Among the concerns raised in the past regarding how technology costs are estimated has been 

one that stranded capital costs be considered. Capital becomes “stranded” when capital 

equipment is retired or its use is discontinued before the equipment has been fully depreciated 

and the equipment still retains some value or usefulness. DOT has modified the CAFE model to, 

if specified for a given technology, when that technology is replaced by a newly applied 

technology, apply a stream of costs representing the stranded capital cost of the replaced 

technology. This cost is in addition to the cost for producing the newly applied technology in the 

first year of production. 

178 http://www.nhtsa.gov/Laws+&+Regulations/CAFE+­

+Fuel+Economy/CAFE+Compliance+and+Effects+Modeling+System:+The+Volpe+Model (last accessed: 

November 14, 2011) 
                                                      

 

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As documented in prior CAFE rulemakings, the CAFE model applies “phase-in caps” to 

constrain technology application at the vehicle manufacturer level. They are intended to reflect 

a manufacturer’s overall resource capacity available for implementing new technologies (such as 

engineering and development personnel and financial resources), thereby ensuring that resource 

capacity is accounted for in the modeling process. This helps to ensure technological feasibility 

and economic practicability in determining the stringency of the standards. When the MY 2012­

2016 rulemaking analysis was completed, the model performed the relevant test by comparing a 

given phase-in cap to the amount (i.e., the share of the manufacturer’s fleet) to which the 

technology had been added by the model. DOT has since modified the CAFE model to take into 

account the extent to which a given manufacturer has already applied the technology (i.e., as 

reflected in the market forecast specified as a model inputs), and to apply the relevant test based 

on the total application of the technology. 

The CAFE model requires inputs defining the technology-specific cost and efficacy (i.e., 

percentage reduction of fuel consumption), and has, to date, effectively assumed that these input 

values reflect application of the technology in a manner that holds vehicle performance and 

utility constant. Considering that some technologies may, nonetheless, offer owners greater or 

lesser value (beyond that related to fuel outlays, which the model calculates internally based on 

vehicle fuel type and fuel economy), DOT has modified the CAFE model to accept and apply 

technology-specific estimates of any value gain realized or loss incurred by vehicle 

purchasers.179 

For the MY 2012-2016 CAFE rulemaking analysis, DOT modified the CAFE model to 

accommodate specification and accounting for credits a manufacturer is assumed to earn by 

producing flexible fuel vehicles (FFVs). Although NHTSA cannot consider such credits when 

determining maximum feasible CAFE standards, the agency presented an analysis that included 

FFV credits, in order to communicate the extent to which use of such credits might cause actual 

costs, effects, and benefits to be lower than estimated in NHTSA’s formal analysis. As DOT 

explained at the time, it was unable to account for other EPCA credit mechanisms, because 

attempts to do so had been limited by complex interactions between those mechanisms and the 

multiyear planning aspects of the CAFE model. DOT has since modified the CAFE model to 

provide the ability to account for any or all of the following flexibilities provided by EPCA: 

FFV credits, credit carry-forward and carry-back (between model years), credit transfers 

(between passenger car and light truck fleets), and credit trades (between manufacturers). The 

model accounts for EPCA-specified limitations applicable to these flexibilities (e.g., limits on the 

amount of credit that can be transferred between passenger car and light truck fleets). These 

capabilities in the model provide a basis for more accurately estimating costs, effects, and 

179 For example, a value gain could be specified for a technology expected to improve ride quality, and a value loss 

could be specified for a technology expected to reduce vehicle range. 
205 

benefits that may actually result from new CAFE standards. Insofar as some manufacturers 

actually do earn and use CAFE credits, this provides NHTSA with the ability to examine 

outcomes more realistically than EPCA allows for purposes of setting new CAFE standards. 

In preparation for today’s analysis, DOT has further modified the CAFE model to provide the 

ability to account for owners’ operating costs including financing, insurance, scheduled 

maintenance, and out-of-warranty repairs. Among these, the model includes only scheduled 

maintenance and out-of-warranty repairs in overall estimates of societal costs. DOT also made 

some further changes to the CAFE modeling system. To facilitate external analysis, the CAFE 

model now produces “flat” text files (comma separated value or “CSV”, format) as model 

output. DOT also corrected some errors DOT staff identified in the version of the model 

supporting the NPRM, the most significant of which include the following: First, the model was 

corrected to ensure that advanced diesel technology is not applied without accounting for 

incremental costs and effects of TURB2, CEGR1, or CEGR2—engine technologies placed 

before diesels on the model’s decision tree for engine technologies. Second, the model was 

corrected to ensure that when fuel-saving technologies are applied to a flexible fuel vehicle 

(FFV), the vehicle’s fuel economy when operating on E85 is increased in parallel with its fuel 

economy when operating on gasoline. Third, the model was corrected to ensure that, when 

calculating the “effective cost” for purposes of deciding among potential technology 

applications, the model refers to fuel prices estimated to prevail after the vehicle’s purchase. 

Further details regarding the model’s design and operation are presented in the model 

documentation available on NHTSA’s web site. 

NHTSA is today setting CAFE standards reflecting EPA’s proposal to change fuel economy 

calculation procedures such that a vehicle’s fuel consumption improvement will be accounted for 

if the vehicle has technologies that reduce the amount of energy needed to power the air 

conditioner. To facilitate analysis of these standards, DOT has modified the CAFE model to 

account for these adjustments, based on inputs specifying the average amount of improvement 

anticipated, and the estimated average cost to apply the underlying technology. 

Considering that past CAFE rulemakings indicate that most of the benefits of CAFE standards 

are realized by vehicle owners, DOT has modified the CAFE model to estimate not just social 

benefits, but also private benefits. The model accommodates separate discount rates for these 

two valuation methods (e.g., a 3% rate for social benefits with a 7% rate for private benefits). 

When calculating private benefits, the model includes changes in outlays for fuel taxes (which, 

as economic transfers, are excluded from social benefits) and excludes changes in economic 

externalities (e.g., monetized criteria pollutant and greenhouse gas emissions). 

Since 2003, the CAFE model (and its predecessors) has provided the ability to estimate the 

extent to which a manufacturer with a history of paying civil penalties allowed under EPCA 
206 

might decide to add some fuel-saving technology, but not enough to comply with CAFE 

standards. In simulating this decision-making, the model considers the cost to add the 

technology, the calculated reduction in civil penalties, and the calculated present value (at the 

time of vehicle purchase) of the change in fuel outlays over a specified “payback period” (e.g., 5 

years). For a manufacturer assumed to be willing to pay civil penalties, the model stops adding 

technology once paying fines becomes more attractive than continuing to add technology, 

considering these three factors. As an extension of this simulation approach, DOT has modified 

the CAFE model to, if specified, simulate the potential that a manufacturer would add more 

technology than required for purposes of compliance with CAFE standards. When set to operate 

in this manner, the model will continue to apply technology to a manufacturer’s CAFEcompliant fleet until applying further technology will incur more in cost than it will yield in 

calculated fuel savings over a specified “payback period” that is set separately from the payback 

period applicable until compliance is achieved. In its analysis supporting MY 2012-2016 

standards adopted in 2010, NHTSA estimated the extent to which reductions in vehicle mass 

might lead to changes in the number of highway fatalities occurring over the useful life of the 

MY 2012-2016 fleet. NHTSA performed these calculations outside the CAFE model (using 

vehicle-specific mass reduction calculations from the model), based on agency analysis of 

relevant highway safety data. DOT has since modified the CAFE model to perform these 

calculations, using an analytical structure indicated by an update to the underlying safety 

analysis. The model also applies an input value indicating the economic value of a statistical 

life, and includes resultant benefits (or disbenefits) in the calculation of total social benefits. 

In comments on recent NHTSA rulemakings, some reviewers have suggested that the CAFE 

model should be modified to estimate the extent to which new CAFE standards would induce 

changes in the prices of vehicles and therefore in the mix of vehicles in the new vehicle 

fleet. NHTSA agrees that a “market share” model, also called a consumer vehicle choice model, 

could provide useful information regarding the possible effects of potential new CAFE 

standards. 

In response, NHTSA has contracted with GRA, Incorporated and the Brookings Institution to 

develop a vehicle choice model estimated at the vehicle configuration level that can be 

implemented as part of DOT’s CAFE model. Also included in this contract are researchers 

based at the University of California – Davis and the University of California – Irvine. The 

Brookings-led researchers are utilizing data found in the National Household Transportation 

Survey to estimate realistic patterns of vehicle substitution and deferral of new vehicle purchases 

in response to changes in vehicle attributes, such as prices and fuel efficiency, which are caused 

by increases or decreases in the CAFE standards. 

In comments on recent NHTSA rulemakings, some reviewers have suggested that the CAFE 

model should be modified to estimate the extent to which new CAFE standards would induce 

changes in the mix of vehicles in the new vehicle fleet. NHTSA agrees that a “market shift” 
207 

model, also called a consumer vehicle choice model, could provide useful information regarding 

the possible effects of potential new CAFE standards. NHTSA has contracted with the 

Brookings Institution (which has subcontracted with researchers at U.C. Davis, U.C. Irvine) to 

develop a vehicle choice model estimated at the vehicle configuration level that can be 

implemented as part of DOT’s CAFE model. As discussed further in Section V of the PRIA, 

past efforts by DOT staff demonstrated that a vehicle could be added to the CAFE model, but did 

not yield credible coefficients specifying such a model. While the NHTSA-sponsored effort is 

still underway, if a suitable and credibly calibrated vehicle choice model becomes available in 

the future, DOT may integrate a vehicle choice model into the CAFE model to support future 

rulemakings. 

NHTSA anticipates this integration of a vehicle choice model would be structurally and 

operationally similar to the integration we implemented previously. As under the version applied 

in support of today’s announcement, the CAFE model would begin with an agency-estimated 

market forecast, estimate to what extent manufacturers might apply additional fuel-saving 

technology to each vehicle model in consideration of future fuel prices and baseline or 

alternative CAFE standards and fuel prices, and calculate resultant changes in the fuel economy 

(and possibly fuel type) and price of individual vehicle models. With an integrated market share 

model, the CAFE model would then estimate how the sales volumes of individual vehicle 

models would change in response to changes in fuel economy levels and prices throughout the 

light vehicle market, possibly taking into account interactions with the used vehicle 

market. Having done so, the model would replace the sales estimates in the original market 

forecast with those reflecting these model-estimated shifts, repeating the entire modeling cycle 

until converging on a stable solution. 

Based on past experience, we anticipate that this recursive simulation will be necessary to ensure 

consistency between sales volumes and modeled fuel economy standards, because achieved 

CAFE levels depend on sales mix and, under attribute-based CAFE standards, required CAFE 

levels also depend on sales mix. NHTSA anticipates, therefore, that application of a market 

share model would impact estimates of all of the following for a given schedule of CAFE 

standards: overall market volume, manufacturer market shares and product mix, required and 

achieved CAFE levels, technology application rates and corresponding incurred costs, fuel 

consumption, greenhouse gas and criteria pollutant emissions, changes in highway fatalities, and 

economic benefits. 

Past testing by DOT/NHTSA staff did not indicate major shifts in broad measures (e.g., in total 

costs or total benefits), but that testing emphasized shorter modeling periods (e.g., 1-5 model 

years) and less stringent standards than reflected in today’s announcement. Especially without 

knowing the characteristics of a future vehicle choice model, it is difficult to anticipate the 

potential degree to which its inclusion would impact analytical outcomes. 
 

 

                                                      

 

 

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NHTSA invited comment on changes made to the CAFE model prior to the NPRM’s release, and 

regarding the above-mentioned prospects for inclusion of a vehicle choice model. The agency 

received comments only regarding the possibility of utilizing a vehicle choice model. Two 

environmental organizations—the National Resources Defense Council (NRDC) and the Union 

of Concerned Scientists (UCS)—urged the agency not to include any vehicle choice model in its 

analysis, citing concerns regarding uncertainties surrounding such models, and in NRDC’s case, 

the potential that use of a choice model would lead NHTSA to adopt less stringent standards than 

if the agency continues to ignore potential market effects.180 On the other hand, the American 

Fuel and Petrochemical Manufacturers (AFPM) indicated serious concern that the proposal was 

based on an analysis that did not incorporate a vehicle choice model, citing this as a serious 

deficiency that must be addressed to properly understand the implications of this proposal.181 

AFPM suggested the proposed standards were not feasible, and indicated that use of a peerreviewed consumer choice model and a new proposal would assist NHTSA’s development of a 

revised proposal that is feasible and coincides with Congress’ mandate in this area.182 The 

Alliance of Automobile Manufacturers indicated that NHTSA should develop a vehicle choice 

model to inform the planned midterm review, and indicated that such a model should use realworld data, be developed in a transparent manner with full peer review, and assess uncertainties 

in its predictions.183 As mentioned above, we do not yet have available a credible consumer 

choice model suitable for integration with our CAFE modeling system. However, we do not 

agree with NRDC and UCS that integration of a vehicle choice model should be rejected out of 

hand, or that application of a vehicle choice model would lead the agency to adopt less stringent 

standards. Nor do we agree with AFPM that the proposed standards were not feasible. We agree 

with the Alliance that NHTSA should continue efforts to develop a vehicle choice model suitable 

for integration with the CAFE modeling system and application toward informing the planned 

midterm review. 

Does the model set the standards? 

Since NHTSA began using the CAFE model in CAFE analysis, some commenters have 

interpreted the agency’s use of the model as the way by which the agency chooses the maximum 

feasible fuel economy standards. As the agency explained in its most recent CAFE rulemaking, 

this is incorrect.184 Although NHTSA currently uses the CAFE model as a tool to inform its 

consideration of potential CAFE standards, the CAFE model does not determine the CAFE 

180 NRDC, EPA Docket: EPA-HQ-OAR-2010-0799-9472, p. 19; UCS, EPA Docket: EPA-HQ-OAR-2010-0799­

9567, p. 14. 

181 AFPM, EPA Docket: EPA-HQ-OAR-2010-0799-9485, p. 4.
 182 Id., p. 8.
 183 Alliance, NHTSA Docket: NHTSA-2010-0131-0262, p. 19. 184 75 FR 25600. 
                                                      

209 

standards that NHTSA proposes or promulgates as final regulations. The results it produces are 

completely dependent on inputs selected by NHTSA, based on the best available information and 

data available in the agency’s estimation at the time standards are set. Ultimately, NHTSA’s 

selection of appropriate CAFE standards is governed and guided by the statutory requirements of 

EPCA, as amended by EISA: NHTSA sets the standard at the maximum feasible average fuel 

economy level that it determines is achievable during a particular model year, considering 

technological feasibility, economic practicability, the effect of other standards of the 

Government on fuel economy, and the need of the nation to conserve energy. 

How does NHTSA make the model available and transparent? 

Model documentation, which is publicly available in the rulemaking docket and on NHTSA’s 

website, explains how the model is installed, how the model inputs (all of which are available to 

the public)185 and outputs are structured, and how the model is used. The model can be used on 

any Windows-based personal computer with Microsoft Office 2003 or 2007 and the Microsoft 

.NET framework installed (the latter available without charge from Microsoft). The executable 

version of the model and the underlying source code are also available at NHTSA’s Web site. 

The input files used to conduct the core analysis documented in this proposed rule are available 

in the public docket. With the model and these input files, anyone is capable of independently 

running the model to repeat, evaluate, and/or modify the agency’s analysis. 

Because the model is available with unrestricted access on NHTSA’s web site, the agency has no 

way of knowing how widely the model has been used. The agency is, however, aware that the 

model has been used by other federal agencies, vehicle manufacturers, private consultants, 

academic researchers, and foreign governments. Some of these individuals have found the 

model complex and challenging to use. Insofar as the model’s sole purpose is to help DOT staff 

efficiently analyze potential CAFE standards, DOT has not expended significant resources trying 

to make the model as “user friendly” as commercial software intended for wide use. However, 

DOT wishes to facilitate informed comment on the proposed standards, and encourages 

reviewers to contact the agency promptly if any difficulties using the model are encountered. 

NHTSA arranged for a formal peer review of an older version of the model, has responded to 

reviewers’ comments, and has considered and responded to model-related comments received 

over the course of four CAFE rulemakings. In the agency’s view, this steady and expanding 

outside review over the course of nearly a decade of model development has helped DOT to 

significantly strengthen the model’s capabilities and technical quality, and has greatly increased 

185 We note, however, that files from any supplemental analysis conducted that relied in part on confidential 

manufacturer product plans cannot be made public, as prohibited under 49 CFR part 512. 
                                                      

 

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transparency, such that all model code is publicly available, and all model inputs and outputs are 

publicly available in a form that should allow reviewers to reproduce the agency’s analysis. 

NHTSA is currently planning a formal peer review of the current CAFE model, pending 

integration of a vehicle choice model (as discussed above), as the agency anticipates that this will 

be a sufficiently major revision to the model to warrant a new peer review. 

How does NHTSA determine a technology path to compliance with alternative CAFE 

standards? 

The agency assumes, in this analysis, that manufacturers will add a variety of technologies to 

each of their vehicle models in order to improve their fuel economy performance. In order to 

evaluate proposed CAFE standards and regulatory alternatives, it is essential to understand what 

is feasible within the timeframe of the final rule. Determining the technological feasibility of the 

2017-2025 standards requires a thorough study of the technologies expected to be available to 

the manufacturers during that timeframe. This chapter includes an assessment of the cost, 

effectiveness, and the availability, development time and manufacturability of the technology 

within either the normal redesign periods of a vehicle line or in the design of a new vehicle. As 

we describe below, when a technology can be applied can affect the cost as well as the 

technology penetration rate (or phase-in caps) that are assumed in the analysis. This chapter will 

also offer a detailed explanation of how NHTSA applies technologies to determine a feasible 

compliance path for the industry for the Preferred Alternative and the other regulatory 

alternatives analyzed by the agency in this rulemaking. 

The agency considered technologies in many categories that manufacturers could use to improve 

the fuel economy of their vehicles during the MYs 2017-2025 timeframe. Many of the 

technologies described in this chapter are available today, are well known, and could be 

incorporated into vehicles once product development decisions are made. These are “nearerterm” technologies and are identical or very similar to those considered in the MYs 2012-2016 

final rule analysis (of course, many of these technologies will likely be applied to the light-duty 

fleet in order to achieve the 2012-2016 CAFE standards; such technologies would be part of the 

baseline fleet for this analysis186). Other technologies considered may not currently be in 

production, but are under development now and are expected to be in production in the next five 

to ten years. Examples of these technologies are downsized and turbocharged engines operating 

at combustion pressures even higher than today’s turbocharged engines, and an emerging hybrid 

architecture mated with an 8 speed transmission—a combination that is not available today. 

These are technologies which the agency believes can, for the most part, be applied both to cars 

and trucks, and which are expected to achieve significant improvements in fuel economy at 

186 The technologies in the baseline fleet, which meets the MY 2016 CAFE standard, are projections made by 

NHTSA’s CAFE model. Some technologies may be significantly represented in this baseline fleet. 
                                                      

211 

reasonable costs in the MYs 2017 to 2025 timeframe. The agency notes that we did not consider 

in our analysis technologies that are currently in an initial stage of research because of the 

uncertainties involved in estimating their costs and effectiveness and in assessing whether the 

technologies will be ready to implement at significant penetration rates during the timeframe of 

the MY2017-2025 standards. Examples of such technologies would be camless valve actuation 

and fuel cell vehicles.187 The agency acknowledges that due to the relatively long period 

between the date of this final rule and the rulemaking timeframe of the MY2017-2025 standards, 

the possibility exists that new and innovative technologies not considered in this analysis will 

make their way into the fleet (perhaps even in significant numbers). The agency plans to assess 

these technologies afresh, along with all of the technologies considered in this final rule, as part 

of our mid-term evaluation. 

How does NHTSA determine what technologies are already in the baseline vehicle fleet? 

As in the MY 2012-2016 final rule, EPA in consultation with NHTSA developed the baseline 

fleet using the 2008 and 2010 CAFE compliance data. The 2008 baseline fleet was used in the 

NPRM analysis, but the final rule will perform its analysis using both the 2008 baseline and the 

new 2010 baseline. The agencies then used EPA’s emission certification and fuel economy 

database and a combination of publicly available data from sources like Ward’s Automotive 

Group, Motortrend.com and Edmunds.com to determine the fuel-economy-improving/CO2­

reducing technologies already present in the individual baseline vehicles. The baseline fleets 

including the technologies already present on each vehicle are contained in the market data file 

model inputs. A more detailed discussion of how the baseline vehicle fleets were constructed 

can be found in Chapter III of this document and Chapter 1 of the joint TSD. 

How does NHTSA determine what technologies can be applied beyond those in the baseline 

vehicle fleet? 

As discussed above, many of the technologies considered for the MY 2017-2025 timeframe are 

the same ones considered for the MY 2012-2026 rulemaking, which are available in varying 

degrees today and which the agency will be able to be incorporated more fully throughout the 

fleet between now and 2025. NHTSA, with EPA, gathered information about these technologies 

for the MYs 2012-2016 rulemaking from a wide variety of sources, discussed at length in the 

FRIA accompanying the MYs 2012-2016 final rule. We refer readers to that document for more 

information. 

187 Fuel cell vehicles may be especially useful in lieu of full battery electric technology for the larger trucks. We 

may consider this possibility for the final rule. 
                                                      

212 

Since the MYs 2012-2016 final rule, EPA has contracted with Ricardo and expanded the 

technology selections available for the agencies’ consideration, based on some of Ricardo’s 

advanced engineering development work for EPA and on some recently-obtained literature 

sources, such as the development of Lotus Sabre188 engine and MAHLE189 engine. Based on this 

research, the agencies are considering significantly more advanced gasoline engines for MYs 

2017-2025 than we have considered for prior rulemakings. Ricardo also performed simulation 

analysis for EPA which the agencies have used to update the effectiveness for a majority of the 

technologies considered in this FRM analysis. Detailed information for Ricardo’s contract and 

body of work supporting this rulemaking can be found in Docket # NHTSA-2010-0131. 

For the reader’s reference, the technologies considered by the NHTSA and EPA models for this 

FRM are briefly described below. For purposes of how NHTSA applies them in our model, the 

technologies fit generally into five broad categories: engine, transmission, vehicle, 

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

technology, and the costs and effectiveness of each, is described in greater detail below in this 

chapter; Chapter 3 of the joint TSD also contains information on the individual technologies. 

Types of engine technologies applied in the analysis for this FRM that improve fuel economy 

include the following: 

	 Low-friction lubricants (LUB1) – low viscosity and advanced low friction lubricants oils 

are now available with improved performance and better lubrication. 

	 Reduction of engine friction losses (EFR1) – can be achieved through low-tension piston 

rings, roller cam followers, improved material coatings, more optimal thermal 

management, piston surface treatments, and other improvements in the design of engine 

components and subsystems that improve engine operation. 

	 Second level of low-friction lubricants and engine friction reduction (LUB2_EFR2) – As 

technologies advance between now and 2017-2025, we expect further developments 

enabling lower viscosity and lower friction lubricants and more engine friction reduction 

technologies to be available. 

	 Cylinder deactivation (DEACS and DEACD) – deactivates the intake and exhaust valves 

and prevents fuel injection of some cylinders during light-load operation. The engine 

runs temporarily as though it were a smaller engine, which substantially reduces pumping 

losses. 

	 Variable valve timing (CCPS, ICP and DCP) – alters the timing or phase of the intake 

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

power, and control residual gases. 

188 Turner, J.W.G., R.J. Pearson, R. Curtis, and B. Holland, Lotus Engineering. “Sabre: a cost-effective engine 

technology combination for high efficiency, high performance and low CO2 emissions.” Available at 

http://www.midlandslotus.co.uk/forum/topic/35578-sabre-a-cost-effective-engine-technology-combination-for-highefficie/ (last accessed Oct. 31, 2011). 

189 Frazer, N., H. Blaxhill, G. Lumsden, and M. Bassett, Mahle Powertrain. “Challenges for Increased Efficiency 

through Gasoline Engine Downsizing,” SAE Paper 2009-01-1053. Available at http://papers.sae.org/2009-01-1053/ 

(last accessed Oct. 31, 2011). 
 

                                                      

 

213 

	 Discrete variable valve lift (DVVLS, DVVLD and VVA) – increases efficiency by 

optimizing air flow over a broader range of engine operation, which reduces pumping 

losses. Accomplished by controlled switching between two or more cam profile lobe 

heights. 

	 Continuous variable valve lift (CVVL) – is an electromechanically controlled system in 

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

range of performance optimization and volumetric efficiency, including enabling the 

engine to be valve throttled. 

	 Stoichiometric gasoline direct-injection technology (SGDI and SGDIO) – injects fuel at 

high pressure directly into the combustion chamber to improve cooling of the air/fuel 

charge within the cylinder, which allows for higher compression ratios and increased 

thermodynamic efficiency. 

	 Turbocharging and downsizing (TRBDS1 and TRBDS2) - increases the available airflow 

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

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

FRM, the agencies considered three levels of boosting (18 bar brake mean effective 

pressure (BMEP), 24 bar BMEP and 27 bar BMEP), as well as four levels of downsizing 

(from I4 to smaller I4 or I3, from V6 to I4 and from V8 to both V6 and I4). 18 bar BMEP 

is applied with 33 percent downsizing, 24 bar BMEP is applied with 50 percent 

downsizing, and 27 bar BMEP is applied with 56 percent downsizing. To achieve the 

same level of torque when downsizing the displacement of an engine by 50 percent, 

approximately double the manifold absolute pressure (2 bar) is required. Accordingly, 

with 56 percent downsizing, the manifold absolute pressure range increases up to 2.3 bar. 

Ricardo states in their 2011 vehicle simulation project report that advanced engines in the 

2020–2025 timeframe can be expected to have advanced boosting systems that increase 

the pressure of the intake charge up to 3 bar.190 

	 Exhaust-gas recirculation boost (CEGR1 and CEGR2) - increases the exhaust-gas 

recirculation used in the combustion process to increase thermal efficiency and reduce 

pumping losses. Levels of exhaust gas recirculation approach 25 percent by volume in 

the highly boosted engines modeled by Ricardo (this, in turn raises the boost requirement 

by approximately 25 percent). This technology is only applied to 24 bar and 27 bar 

BMEP engines in this FRM and considered required for 27 bar BMEP engines. 

	 Diesel engines (ADSL) – have several characteristics that give superior fuel efficiency, 

including reduced pumping losses due to lack of (or greatly reduced) throttling, and a 

combustion cycle that operates at a higher compression ratio, with a very lean air/fuel 

mixture, than an equivalent-performance gasoline engine. This technology requires 

additional enablers, such as NOx trap catalyst after-treatment or selective catalytic 

reduction NOx after-treatment. 

Types of transmission technologies applied in this FRM analysis, consistent with the proposal, 

include: 

190 U.S. EPA, “Project Report: Computer Simulation of Light-Duty Vehicle Technologies for Greenhouse Gas 

Emission Reduction in the 2020-2025 Timeframe”, Contract No. EP-C-11-007, Work Assignment 0-12, November, 

2011, Docket ID NHTSA-2010-0131 
                                                      

 

214 

	 Improved automatic transmission controls (IATC) – optimizes shift schedule to maximize 

fuel efficiency under wide ranging conditions, and minimizes losses associated with 

torque converter slip through lock-up or modulation. 

	 Six- and seven-speed automatic transmissions (NAUTO) – the gear ratio spacing and 

transmission ratio are optimized to enable the engine to operate in a more efficient 

operating range over a broader range of vehicle operating conditions. 

	 Dual clutch transmission (DCT) - are similar to a manual transmission, but the vehicle 

controls shifting and launch functions. A dual-clutch automated shift manual 

transmission uses separate clutches for even-numbered and odd-numbered gears, so the 

next expected gear is pre-selected, which allows for faster, smoother shifting. 

	 Eight-speed automatic transmissions (8SPD) – the transmission gear ratios are optimized 

to enable the engine to operate in a more efficient operating range over a broader range of 

vehicle operating conditions. 

	 High Efficiency Gearbox (automatic, DCT or manual) (HETRANS and HETRANSM) – 

continuous improvement in seals, bearings and clutches, super finishing191 of gearbox 

parts, and development in the area of transmission lubrication, all aimed at reducing 

frictional and other parasitic load in the system for an automatic, DCT or manual type 

transmission. 

	 Shift Optimization (SHFTOPT) – tries to keep the engine operating near its most efficient 

point for a given power demand. The shift controller attempts to emulate a traditional 

continuously-variable transmission (CVT) by selecting the best gear ratio for fuel 

economy at a given required vehicle power level to take full advantage of high BMEP 

engines. 

	 Manual 6-speed transmission (6MAN) – offers an additional gear ratio, often with a 

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

	 High Efficiency Gearbox for manual transmission (HETRANSM) – Similar technologies 

as applied for high efficiency gearbox for automatic and DCT can also be applied to 

manual transmissions to reduce drag in the system. 

Types of vehicle technologies applied in this FRM analysis, consistent with the proposal, 

include: 

	 Low-rolling-resistance tires (ROLL1 and ROLL2) – have characteristics that reduce 

frictional losses associated with the energy dissipated in the deformation of the tires 

under load, thereby reducing the energy needed to move the vehicle. There are two 

levels of rolling resistance reduction considered in this FRM analysis which assume 10 

percent and 20 percent rolling resistance reduction, respectively. The agencies expect 

that tire manufacturers will be able to achieve widespread, production application of the 

20 percent rolling resistance reduction level in time for MY 2017 and later. 

191 “Super finishing” is a metalworking process that improves surface finish and workpiece geometry. Super 

finishing can make pieces more durable and allow for closer tolerances, higher load bearing surfaces, and better 

sealing capabilities, but it can also be more expensive than traditional metal finishing techniques. 
215 

	 Low-drag brakes (LDB) – reduce the sliding friction of disc brake pads on rotors when 

the brakes are not engaged because the brake pads are pulled away from the rotors. 

	 Front or secondary axle disconnect for four-wheel drive systems (SAX) – provides a 

torque distribution disconnect between front and rear axles when torque is not required 

for the non-driving axle, which reduces associated parasitic energy losses. 

	 Aerodynamic drag reduction (AERO1 and AERO2) – is achieved by changing vehicle 

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

aerodynamic side view mirrors. The new, second level of aerodynamic reductions 

involve employing aerodynamic aids which may include such features as active grille 

shutters, rear visors, larger under body panels or low-profile, and possibly dynamic, roof 

racks. There are two levels of aerodynamic drag reduction considered in this FRM 

analysis which assume 10 percent and 20 percent drag reduction, respectively. 

	 Mass reduction (MR1, MR2, MR3, MR4 and MR5)– Mass reduction encompasses a 

variety of techniques to make vehicles lighter, ranging from improved design and better 

component integration to application of lighter and higher-strength materials. A lighter 

vehicle can go further on a gallon of gas, all else equal; mass reduction can also lead to 

collateral fuel economy benefits due to downsized engines and/or ancillary systems 

(transmission, steering, brakes, suspension, etc.). The maximum mass reduction level 

considered in this FRM for any vehicle is 20 percent. 

Types of accessory/hybridization/electrification technologies applied in this FRM analysis: 

	 Electric power steering (EPS) and electro-hydraulic power steering (EHPS) – is an 

electrically-assisted steering system that has advantages over traditional hydraulic power 

steering because it replaces a continuously operated hydraulic pump and only operates 

when needed, thereby reducing parasitic losses from the accessory drive. 

	 Improved accessories (IACC1 and IACC2) –There are two levels of IACC applied in this 

FRM analysis, consistent with the proposal. The first level of IACC includes an electric 

water pump and cooling fans and a high efficiency alternator; the second level of IACC 

includes some mild alternator regenerative braking in addition to what is included in the 

first level of IACC. This excludes other electrical accessories such as electric oil pumps 

and electrically driven air conditioner compressors. 

	 Air Conditioner Systems – For purposes of improvements in fuel economy that can count 

toward CAFE compliance, these technologies include improved compressors, expansion 

valves, heat exchangers and the control of these components for the purposes of 

improving fuel efficiency when the A/C is operating. These technologies are covered 

separately in Chapter 5 of the joint TSD. 

	 12-volt Stop-Start (MHEV) – also known as idle-stop or 12V micro hybrid and commonly 

implemented as a 12-volt belt-driven integrated starter-generator, this is the most basic 

hybrid system that facilitates idle-stop capability. Along with other enablers, this system 

replaces a common alternator with an enhanced power starter-alternator, both belt driven, 

and a revised accessory drive system. 

	 Mild Hybrid/Integrated Starter Generator (ISG) – ISG provides idle-stop capability and 

launch assistance and uses a high voltage battery with increased energy capacity over 

typical automotive batteries. The higher system voltage allows the use of a smaller, more 

powerful electric motor and reduces the weight of the motor, inverter, and battery wiring 

harnesses. This system replaces a standard alternator with an enhanced power, higher 
216 

voltage, higher efficiency belt-driven starter-alternator that can recover braking energy 

while the vehicle slows down (regenerative braking). This technology was not used as an 

enabling technology in the NPRM analysis, because we had incomplete information on 

the technology at that time. Since the proposal, the agencies have obtained better data on 

the costs and effectiveness of this technology (see Section 3.4.3 of the joint TSD). 

Therefore, the agencies have revised their technical analysis on both and found that the 

technology is now competitive with the others in the CAFE model technology decision 

trees and EPA’s technology packages. Further, this technology has been used for “game 

changing” credit for pick-up trucks and can act as a bridge technology for strong hybrid. 

For these reasons, the technology is now included in the analysis. 

	 P2 Hybrid (SHEV1 and SHEV2) –a newly emerging hybrid technology that uses a 

transmission integrated electric motor placed between the engine and a gearbox or CVT, 

much like the IMA system described below except with a wet or dry separation clutch 

which is used to decouple the motor/transmission from the engine. In addition, a P2 

Hybrid would typically be equipped with a larger electric machine, as compared to an 

IMA system. Disengaging the clutch allows all-electric operation and more efficient 

brake-energy recovery. Engaging the clutch allows efficient coupling of the engine and 

electric motor and, when combined with a DCT transmission, provides similar or 

improved fuel efficiency to other strong hybrid systems with reduced cost. 

	 Plug-in hybrid electric vehicles (PHEV1 and PHEV2) – are hybrid electric vehicles with 

the means to charge their battery packs from an outside source of electricity (such as the 

electric grid), as well as a gasoline engine. These vehicles have larger battery packs than 

non-plug-in hybrid electric vehicles with more energy storage and a greater capability to 

be discharged. They also use a control system that allows the battery pack to be 

substantially depleted under electric-only or blended mechanical/electric operation, 

allowing for reduced fuel use during “charge depleting” operation. 

	 Electric vehicles (EV1, EV2, EV3 and EV4) – are vehicles with all-electric drive and with 

vehicle systems powered by energy-optimized batteries charged from grid electricity and 

regenerative braking. EVs with 75 mile and 150 mile ranges have been included in the 

modeling for this FRM and FRIA as potential technologies. 

Types of accessory/hybridization/electrification technologies discussed but not applied in this 

FRM analysis, for a variety of reasons, include: 

	 Integrated Motor Assist (IMA)/Crank integrated starter generator (CISG) – provides 

idle-stop capability and uses a high voltage battery with increased energy capacity over 

typical automotive batteries. The higher system voltage allows the use of a smaller, more 

powerful electric motor and reduces the weight of the wiring harness. This system 

replaces a standard alternator with an enhanced power, higher voltage and higher 

efficiency starter-alternator that is crankshaft mounted and can recover braking energy 

while the vehicle slows down (regenerative braking). The IMA technology is not 

included as an enabling technology in this analysis as the industry trends toward more 

cost effective hybrid configurations, although it is included as a baseline technology 

because it exists in the 2008 and 2010 baseline fleets. 

	 Power-split Hybrid (PSHEV) – is a hybrid electric drive system that replaces the 

traditional transmission with a single planetary gearset and two motor/generators. The 

smaller motor/generator uses the engine to either charge the battery or supply additional 
217 

power to the drive motor. The second, more powerful motor/generator is permanently 

connected to the vehicle’s final drive and always turns with the wheels. The planetary 

gear splits engine power between the first motor/generator and the drive motor to either 

charge the battery or supply power to the wheels. The power-split hybrid technology is 

not included as an enabling technology in this analysis as the industry is expected to trend 

toward more cost-effective hybrid configurations, although it is included as a baseline 

technology because it exists in the 2008 and 2010 baseline fleets. 

	 2-Mode Hybrid (2MHEV) – is a hybrid electric drive system that uses an adaptation of a 

conventional stepped-ratio automatic transmission by replacing some of the transmission 

clutches with two electric motors that control the ratio of engine speed to vehicle speed, 

while clutches allow the motors to be bypassed. This improves both the transmission 

torque capacity for heavy-duty applications and reduces fuel consumption at highway 

speeds relative to other types of hybrid electric drive systems. The 2-mode hybrid 

technology is not included as an enabling technology in this analysis as the industry is 

expected to trend toward more cost effective hybrid configurations, although it is 

included as a baseline technology because it exists in the 2008 and 2010 baseline fleets. 

What does NHTSA then do with those technologies? We apply them to vehicles using the 

CAFE model. 

As in the MYs 2012-2016 final rule, each technology is assigned to one of the five following 

categories based on the system it affects or impacts: engine, transmission, 

electrification/accessory, hybrid or vehicle. Each of these categories has its own decision tree 

that the CAFE model uses to apply technologies sequentially during the compliance analysis. 

The decision trees were designed and configured to allow the CAFE model to apply technologies 

in a cost-effective, logical order that also considers ease of implementation. For example, 

software or control logic changes are implemented before replacing a component or system with 

a completely redesigned one, which is typically a much more expensive option. In some cases, 

and as appropriate, the model may combine the sequential technologies shown on a decision tree 

and apply them simultaneously, effectively developing dynamic technology packages on an asneeded basis. For example, if compliance demands indicate, the model may elect to apply LUB, 

EFR, and ICP on a dual overhead cam engine, if they are not already present, in one single step. 

For this FRM analysis, the decision trees were updated to include additional technologies that the 

agency assumes will be available in the MYs 2017-2025 time frame. 

Each technology within the decision trees has an incremental cost and an incremental 

effectiveness estimate associated with it, and estimates are specific to a particular vehicle 

subclass. Each technology’s incremental estimate takes into account its position in the decision 

tree path, which starts with the most cost-effective/simplest technology options at the top. If a 

technology is located further down the decision tree, the estimates for the costs and effectiveness 

values attributed to that technology are influenced by the incremental estimates of costs and 

effectiveness values for prior technology applications. In essence, this approach accounts for 
218 

“in-path” effectiveness synergies, as well as cost effects that occur between the technologies in 

the same path. When comparing cost and effectiveness estimates from various sources and those 

provided by commenters, it is important that the estimates evaluated are analyzed by the agency 

in the proper context, especially as concerns their likely position in the decision trees and other 

technologies that may be present or missing. Not all estimates available in the public domain or 

offered for the agencies’ consideration can be evaluated in an “apples-to-apples” comparison 

with those used by the CAFE model, since in some cases the order of application, or included 

technology content, is inconsistent with that assumed by NHTSA in the decision tree. 

In the MY 2011 final rule, significant revisions had been made to the sequence of technology 

applications within the decision trees, and in some cases the paths themselves had been modified 

and additional paths had been added. These revisions were maintained for the MYs 2012-2016 

final rule and this FRM analysis. The additional paths allow for a more accurate application of 

technology, insofar as the model now considers the existing configuration of the vehicle when 

applying technology. In this analysis, single overhead camshaft (SOHC), dual overhead 

camshaft (DOHC) and overhead valve (OHV) configured engines have separate paths that allow 

for unique path-dependent versions of certain engine technologies. Thus, the cylinder 

deactivation technology (DEAC) now consists of three unique versions that depend on whether 

the engine being evaluated is an SOHC, DOHC or OHV design; these technologies are 

designated by the abbreviations DEACS, DEACD and DEACO, respectively, to designate which 

engine path they are located on. Similarly the last letter for the Coupled Cam Phasing (CCP) and 

Discrete Variable Valve Lift (DVVL) abbreviations are used to identify which path the 

technology is applicable to. 

Use of separate valvetrain paths and unique path-dependent technology variations also ensures 

that the incremental cost and effectiveness estimates properly account for technology effects so 

as not to “double-count.” For example, in the SOHC path, the incremental effectiveness estimate 

for DVVLS assumes that some pumping loss reductions have already been accomplished by the 

preceding technology, CCPS, which reduces or diminishes the effectiveness estimate for 

DVVLS because part of the efficiency gain associated with the reduction of the pumping loss 

mechanism has already occurred. This accounting approach resolves this potential doublecounting issue. 

In addition to incorporating new technologies for the MYs 2017-2025 time frame, the decision 

trees were also revised to include unique paths, based on engine displacement and cylinder 

configuration, for all turbocharged and downsized, cooled EGR, and diesel engines. This allows 

for more accurate accounting of incurred costs from the application of these advanced engine 

technologies. For each of these advanced engine technologies there are now three unique 

versions that depend on whether or not the engine is more similar to an inline 4-cylinder, a V6, 

or a V8 engine, and are defined by small displacement (“SD”), midsize displacement (“MD”) 
 

                                                      

 

 

219 

and large displacement (“LD”) designations, respectively. For example, the advanced diesel 

technology (ADSL) now consists of three unique versions that are designated by the 

abbreviations ADSL_SD, ADSL_MD and ADSL_LD. 

To address any potential confusion, NHTSA would like to draw attention to the retention of 

previously applied technologies when more advanced technologies (i.e., those further down the 

decision tree) were applied. For this final rule, as in the proposal and previous rulemakings, 

previously-applied technologies are retained in combination with the new technology being 

applied as appropriate and feasible, but not always. For instance, one exception to this would be 

the application of advanced diesel technology, where the entire engine is assumed to be replaced, 

so gasoline engine technologies do not (indeed, cannot) carry over. This exception for advanced 

diesels, along with a few other technologies, is documented below in the detailed discussion of 

each decision tree and corresponding technologies. 

As the CAFE model steps through the decision trees and applies technologies, it accumulates 

total or “NET” cost and effectiveness values. Net costs are accumulated using an additive 

approach while net effectiveness estimates are accumulated multiplicatively. As with the MY 

2012-2016 final rule, the decision trees have been expanded so that NHTSA is better able to 

track the incremental and net/cumulative cost and effectiveness of each technology, which 

substantially improves the “accounting” of costs and effectiveness for this FRM.192 To help 

readers better understand the accumulation process, and in response to comments expressing 

confusion on this subject, the following examples demonstrate how the CAFE model calculates 

net values. 

Accumulation of net cost is explained first, as this is the simpler process. This example uses the 

Transmission decision tree sequentially applying IATC, NAUTO, DCT, 8SPD, HETRANS, 

SHFTOPT technologies to a midsize passenger car using the cost and effectiveness estimates 

from its input sheet. As seen in Table V-10 below, for example, the net cost to apply all the 

192 In addition to the (simplified) decision trees, as published in this document, NHTSA also utilized “expanded” 

decision trees in this final rule analysis. Expanded decision trees graphically represent each unique path, 

considering the branch points available to the CAFE model, which can be utilized for applying fuel saving 

technologies. For instance, the engine decision tree shown in this document has 21 boxes representing engine 

technologies, whereas the expanded engine decision tree requires a total of 90 boxes to accurately represent all 

available application variants. Expanded decision trees presented a significant improvement in the overall 

assessment and tracking of applied technologies since they allowed NHTSA staff to accurately view and assess both 

the incremental and the accumulated, or net cost and effectiveness at any stage of technology application in a 

decision tree. Because of the large format of the expanded decision trees, they could not be included in the Federal 

Register, so NHTSA refers the reader to Docket No. NHTSA-2010-0131. Expanded decision trees for the engine, 

electrification/transmission/hybridization, and the vehicle technologies (three separate decision trees) were 

developed for each of the 12 vehicle technology application classes and have been placed in the docket for the 

reader’s reference. 
                                                      

 

 

 

 

 

220 

transmission technologies would be ($61.88 + -$38.73 + -$73.88 + $255.18 + $248.38 + $1.65 = 

$454.48). Net costs are calculated in a similar manner for all the decision trees. 

Table V-10. Example of CAFE Model Net Cost Calculation 

Example Net Cost (MY2017) Calculation: 

Transmission Path, Midsize Vehicle Subclass 

Tech. Abrev. INCR Cost NET Cost 

IATC $ 61 $ 61 

NAUTO $ (39) $ 22 

DCT $ (74) $ (52) 

8SPD $ 225 $ 173 

HETRANS $ 248 $ 421 

SHFTOPT $ 2 $ 423 

The same decision tree, technologies, and vehicle are used for the example below which 

demonstrates the model’s net effectiveness calculation. Table V-11 below shows average 

incremental effectiveness estimates in column two; this value is calculated in the same manner as 

the cost estimates above (average of lower and upper value taken from the input sheet). To 

calculate the change in fuel consumption due to application of the IATC technology with 

incremental effectiveness of 3.0 percent (or 0.030 in decimal form, column 3), when applied 

multiplicatively, means that the vehicle’s current fuel consumption ‘X’ would be reduced by a 

factor of (1 – 0.030) = 0.970,193 or mathematically 0.970*X. To represent the changed fuel 

consumption in the normal fashion (as a percentage change), this value is subtracted from 1 (or 

100%) to show the net effectiveness in column 5. 

As the NAUTO technology is applied, the vehicle’s fuel consumption is already reduced to 0.970 

of its original value. Therefore the reduction for an additional incremental 2.04 percent results in 

a new fuel consumption value of 0.9502, or a net 4.98 percent effectiveness, as shown in the 

table. Net effectiveness is calculated in a similar manner for the all decision trees. All 

incremental effectiveness estimates were derived with this multiplicative approach in mind; 

calculating the net effectiveness using an additive approach will yield a different and incorrect 

net effectiveness. 

Table V-11. Example of CAFE model Net Effectiveness Calculation 

193 A decrease in fuel consumption (FC) means the fuel economy (FE) will be increased since fuel consumption and 

economy are related by the equation FC = 1/FE. 
221 

Example Net Effectiveness Calculation: 

Transmission Path, Midsize Vehicle Subclass 

Tech. 

Abrev. 

INCR Eff. 

% 

Eff. 

(decimal) 

Multiplicative FC Reduction 

Current FC * (1- INCR) 

NET Eff. 

(1-Red) 

IATC 3.00% 0.0300 1 * (1-0.03) = 0.970 3.00% 

NAUTO 2.04% 0.0204 0.970 * (1 - 0.0204) = 0.9502 4.98% 

DCT 4.06% 0.0406 0.9502 * (1 - 0.0406) = 0.9116 8.84% 

8SPD 4.57% 0.0457 0.9116 * (1 - 0.0457) = 0.8700 13.00% 

HETRANS 2.68% 0.0268 0.8700 * (1- 0.0268) = 0.8467 15.33% 

SHFTOPT 4.08% 0.0408 0.8467 * (1 - 0.0408) = 0.8121 18.79% 

To improve the accuracy of accumulating net cost and effectiveness estimates, “path-dependent 

corrections” were employed in the MYs 2012-2016 final rule and are being utilized in this final 

rule. The previous 2008 analysis for the MYs 2011-2015 NPRM had the potential to either 

overestimate or underestimate net cost and effectiveness depending on which decision tree path 

the CAFE model followed when applying the technologies. For example, if in the 2008 NPRM 

analysis a diesel technology was applied to a vehicle that followed the OHV path, the net cost 

and effectiveness could be different from the net estimates for a vehicle that followed the OHC 

path, even though the intention was to have the same net cost and effectiveness. In order to 

account for this, “in path”-dependent correction tables were added to the input sheets. The 

model uses path-dependent correction factors, found in the synergy tables of the technology 

input sheets, to correct net cost and effectiveness estimate differences that occur when multiple 

paths lead into a single technology that is intended to have the same net cost and effectiveness no 

matter which path was followed. Path-dependent corrections were used when applying cylinder 

deactivation (on the DOHC path) and turbocharging and downsizing. For the cylinder 

deactivation the fuel consumption reduction and cost estimates stated in the following sections 

and the input sheets are for an engine with DVVL. The above-mentioned correction factors are 

then used to adjust the estimates for an engine with CVVL. 

Similarly, the fuel consumption reduction and cost estimates stated in following sections and the 

input sheets for turbocharging and downsizing are for an SOHC engine. Correction factors are 

then used to adjust the estimates for the different paths (i.e., DOHC or OHV). 

What’s new in this rulemaking from the MY 2012-2016 final rule? 

Since the MY 2012-2016 final rule, additional analyses and studies have been initiated to 

improve the technology cost and effectiveness estimates used as inputs for this and future CAFE 

rulemakings. Some of these analyses and studies have been completed already, and their results 
222 

were available for use in this FRM analysis. The following sections briefly describe some of the 

new inputs that NHTSA and EPA have incorporated for this analysis. 

More Vehicle Technologies (LUB2-EFR2, Higher BMEP Engine, P2, Level II of Tire 

Rolling Resistance, Level II of Aerodynamic Drag Reduction) 

The agencies have applied several new technologies and also included a new additional level of 

effectiveness for several technologies in this FRM analysis. The agencies are employing an 

additional level of engine friction reduction (representing engine friction reductions of 20 

percent, compared to the 10 percent reductions previously assumed), an additional level of 

aerodynamic drag reduction (representing drag reductions of 20 percent), and an additional level 

of tire rolling resistance reduction (representing a rolling resistance reduction of 20 percent). 

Other changes to the technologies employed in the modeling include, based on Ricardo’s work 

for EPA, the addition of higher BMEP engines than considered in prior rulemaking analyses, 

such as 24 bar and 27 bar BMEP engines; and two additional technology options which have 

been added to the transmission decision tree, high efficiency gearbox and shift optimization. 

New to this final rule is the ISG mild hybrid, which was not considered in the proposal. The 

strong hybrid technologies used in the MYs 2012-2016 final rule, power split and 2-mode 

hybrid, have been replaced in this FRM analysis by P2 hybrid, which is applied instead of the 

other two technologies due to its lower cost and higher effectiveness. Transmission technologies 

are revised significantly as well, insofar as the “6-, 7- and 8- speed transmission” group is now 

divided into two groups, a “6-speed transmission” group and an “8-speed transmission” group, 

based on information gathered by the agencies. All of these changes reflect the agencies’ 

expectation for technology development before and during MYs 2017-2025 timeframe. The 

agencies believe that these technologies will provide a cost effective path in reducing fuel 

consumption and GHGs. 

Updated Effectiveness Estimates 

EPA contracted with Ricardo Engineering to provide vehicle simulation support for the proposal. 

This simulation work provided the basis for the effectiveness estimates for a number of the 

technologies most heavily relied on in the agencies’ analysis of potential standards for MYs 

2017-2025 and was carried over into this final rule. Some of technology effectiveness estimates 

that were informed by the 2010/2011 Ricardo study were advanced engine friction reductions, 

higher BMEP engines, advanced transmissions, start-stop systems and P2 hybrids. More 
                                                      

 

223 

information about the Ricardo work is available in TSD Chapter 3 or Docket NHTSA-2010­

0131. 

For the final rule, NHTSA conducted a vehicle simulation project with Argonne National 

Laboratory (ANL) that performed additional analyses on mild hybrid technologies and advanced 

transmissions to help NHTSA develop effectiveness values better tailored for the CAFE model’s 

incremental structure. The effectiveness estimates that were developed by ANL for the mild 

hybrid vehicles were applied by both agencies for the final rule. Additionally, NHTSA updated 

the effectiveness estimates of advanced transmissions when coupled with naturally-aspirated 

engines based on ANL’s simulation work for the final rule. 

More Costs from FEV Teardown Study 

Since the MYs 2012-2016 final rule, FEV, contracted by EPA, has completed two more teardown studies that the agencies used for this FRM analysis: a tear-down study comparing the cost 

of an 8-speed automatic transmission to a 6-speed automatic transmission, and a tear-down study 

of a power-split hybrid to determine the incremental costs of converting a conventional gasoline 

powered vehicle (a V6 Ford Fusion) to a power-split hybrid (a Ford Fusion hybrid). The results 

for individual components in power-split hybrid teardown were subsequently used to cost 

another hybrid technology, the P2 hybrid, which employs similar hardware. 

Updates for the Cost of HEV, PHEV, EV 

The agencies have reconsidered the costs for HEVs, PHEVs, EVs, and FCEVs as the result of 

two issues. First, electrified vehicle technologies are developing rapidly: different battery 

materials and different hybrid systems are proliferating, and battery costs are coming down. And 

second, the analysis for the MYs 2012-2016 final rule employed a single $/kWh estimate, and 

did not consider the specific vehicle and technology application for the battery when we 

estimated the cost of the battery.194 Specifically, batteries used in HEVs (high power density 

applications) versus EVs (high energy density applications) need to be considered appropriately 

to reflect the design differences, the chemical material usage differences, and differences in cost 

per kW-hr as the power to energy ratio of the battery changes for different applications. To 

194 However, we believe that this had little impact on the results of the cost analyses in support of the MYs 2012­

2016 final rule, as the agencies projected that the standards could be met with an increase of less than 2 percent 

penetration of hybrid technology, and no increase in plug-in or full electric vehicle technology. 
                                                      

 

224 

address these issues for this final rule, the agencies have used a battery cost model, BatPaC,195 

developed by Argonne National Laboratory (ANL) for the Vehicle Technologies Program of the 

U.S. Department of Energy’s (DOE) Office of Energy Efficiency and Renewable Energy. The 

model developed by ANL allows users to estimate unique battery pack cost using usercustomized input sets for different hybridization applications, such as strong hybrid, PHEV and 

EV. Since the publication of the TAR, ANL’s battery cost model has been peer-reviewed and 

ANL has updated the model to incorporate many suggestions from peer-reviewers. Additionally, 

the model has been updated since the proposal to include certain agency requests, including an 

option to select between liquid or air thermal management and that adequate surface area and 

cell spacing be determined accordingly. Also, the agencies requested a feature to allow battery 

packs to be configured as subpacks in parallel or modules in parallel, as additional options for 

staying within voltage and cell size limits for large packs. EPA staff used this newly updated 

model to derive battery costs for this FRM analysis. The agencies added new configurations of 

HEV, PHEV and EV vehicles to the ANL model for this FRM analysis that include the P2 HEV 

configuration, different mileage ranges for PHEVs and different mileage ranges for EVs. Details 

regarding these vehicle technologies are discussed in Chapter 3 of the joint TSD. 

Updates for the Cost of Mass Reduction and Level of Mass Reduction 

The cost of mass reduction has been updated since to the MYs 2012-2016 final rule. In the last 

rulemaking, a constant cost of $1.32/lb was used. In this FRM analysis, a linear cost curve is 

used at a rate of $4.29/lb/percent of mass reduction. Additionally, the amount of mass reduction 

considered by the agencies as available for purposes of this analysis is generally increased. The 

maximum amount of mass reduction applied to vehicles in NHTSA’s analysis is 20 percent, 

although varying amounts are applied to different types of vehicles in order to ensure that a 

safety neutral path is developed: specifically, less mass reduction is applied to smaller vehicles, 

such as compact cars, and more is allowed to be applied to larger vehicles, such as large pickup 

trucks and SUVs. The mass reduction section below contains detailed descriptions for mass 

reduction costs, available technologies and the agencies’ work plan for refining these estimates 

for the final rule. 

Modification of ICM 

For the analysis in this FRM, NHTSA and EPA have revisited the technologies evaluated by 

EPA staff and relied primarily on the modified Delphi based technologies develop the ICMs. For 

this FRM analysis, the agencies are using the following basis for estimating ICMs: 

195 BatPac Model and peer-review report are in docket NHTSA-2010-0131. 
225 

 All low complexity technologies will be estimated to equal the ICM of the modified 

Delphi based low technology - passive aerodynamic improvements. 

 All medium complexity technologies will be estimated to equal the ICM of the modified 

Delphi based medium technology - engine turbo downsizing. 

 Strong hybrids and non-battery PHEVs will be estimated to equal the ICM of the high 

complexity consensus based high technology – hybrid electric vehicle. 

 PHEVs with battery packs and full electric vehicles will be estimated to equal the ICM 

of the high complexity modified Delphi based high technology – plug-in hybrid electric 

vehicle. 

In addition to shifting the proxy basis for each technology group, the agencies reexamined each 

technology’s complexity designation and adjusted the grouping of technologies. Some new 

technologies are also added to the groupings. Other changes to the ICMs for this rulemaking 

include basing them on the expected long-term average RPE rather than that of any one specific 

year (2007), which involved normalizing them to an average RPE multiplier level of 1.5; and 

distinguishing the ICMs into two parts, one applied to warranty cost and one applied to nonwarranty cost. The latter was done because the agencies believe that learning curves are more 

appropriately applied only to direct costs, with indirect costs established up front based on the 

ICM and then held constant while direct costs are reduced by learning. 

More detailed information about how the agencies applied ICMs in this FRM analysis can be 

found in Chapter VII of this FRIA. 

More and Refined Learning Schedules 

In MYs 2012-2016 rulemaking, the agency applied two types of learning, “time-based” learning 

and “volume-based” learning. For this FRM the agency has, however, adopted new terminology 

to distinguish the two different learning applications. Emerging technologies are adjusted using 

what we now call the “steep “learning schedule, which involves 20% decreases, while mature 

technologies are modified using one of a number of “flat” schedules, involving the smaller 3%, 

2%, or 1% decreases. The “flat” curves assume a learning rate of 3% over the previous years’ 

cost for a number of years, followed by 2% over several more years, followed by 1% 

indefinitely. The “steep” curves assume larger decreases of 20% every 2 years during the initial 

years of production, for a maximum of two learning cycles, before converting to the “flat” 

learning curve rates. For this FRM analysis, the agency has determined where on the learning 

curve each technology lies and then applied learning effects based on those determinations. 

Figure V-28 shows how these determinations impact the level of learning effects applied in our 

analysis. Chapter VII of this FRIA contains a detailed discussion of the changes to the ICM and 

their application to individual technologies. 

Figure V-28. Learning Factors used in the Analysis to accommodate Technologies at 

Different Places on the Learning Curve and Having Costs Based in Different Years 
                                                      

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0.50 

1.00 

1.50 

2.00 

2.50 

3.00 

3.50 

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 

Learning Factor 

Year 

Learning Curves 

6 No learning 11 Flat, 2012 basis 

12 Flat, 2015 basis 16 Steep to flat, 2015 basis 

19 Steep, 2025 basis (for PHEV/EV batteries) 21 Flat, 2017 basis 

24 Steep to flat, 2017 basis (HEV batteries) 25 Steep to flat, 2021 basis 

Inclusion of Stranded Capital Costs 

There is also the potential for stranded capital196 if technologies are introduced too rapidly for 

some indirect costs to be fully recovered. Due to the capital-intensive nature of producing 

automotive components, it is possible for substantial capital investments in manufacturing 

equipment and facilities to become “stranded.” While the FEV tear-down analysis results are 

assumed to be generally valid for the 2017-2025 timeframe for fully mature, high sales volumes, 

FEV perform a supplemental analysis to consider potential stranded capital costs. For a select 

group of technologies NHTSA has included that ability account for stranded capital costs, as 

supplied by FEV, into the analysis. The agency refers readers to Chapter 3 of the joint TSD for a 

more detailed description of how FEV estimated stranded capital costs and later in this chapter 

the agency describes how stranded capital costs were integrated into the analysis. 

What’s new in this final rulemaking from NPRM? 

Inclusion of Mild Hybrid/Belt Integrated Starter Generator (BISG) 

196 The potential for stranded capital occurs when manufacturing equipment and facilities cannot be used in the 

production of a new technology. 
 

227 

Mild hybrid/ISG technology was mentioned but not included in the proposal because the 

agencies had incomplete information at that time. Since the proposal, the agencies have obtained 

better data on the costs and effectiveness of this technology (see the detailed discussion later in 

this chapter). Therefore, the agencies have revised their technical analysis on both the cost and 

effectiveness and found that the technology is now competitive with the others in NHTSA’s 

technology decision trees and EPA’s technology packages. The effectiveness estimates are based 

on full-vehicle simulation modeling by Argonne National Laboratory (ANL) and the cost 

estimates are from the FEV teardown of the Saturn Vue (non-battery components) and ANL’s 

BatPaC model (Li-ion battery). 

 Updated Transmission Effectiveness Estimates 

For the final rule, NHTSA conducted a vehicle simulation project with ANL that performed 

additional analyses on mild hybrid technologies and advanced transmissions to help NHTSA 

develop effectiveness values better tailored for the CAFE model’s incremental structure. The 

effectiveness estimates that were developed by ANL for the mild hybrid vehicles were applied 

by both agencies for the final rule. Additionally, NHTSA updated the effectiveness estimates of 

advanced transmissions when coupled with naturally-aspirated engines based on ANL’s 

simulation work for the final rule. 

Updated allocation of stranded capital costs 

The allocation of stranded capital costs to the different technologies were changed slightly from 

the NPRM to more closely align with how the FEV derived stranded capital costs were meant to 

be applied. The stranded capital costs themselves did not change. The only change was how the 

stranded capital costs were applied to the unique technologies. 

How are technologies applied in the CAFE model? 

As discussed above, the CAFE model uses decision trees to determine the order in which 

technologies are applied to each vehicle in our analysis. The following paragraphs explain, in 

greater detail, the decision tree logic and revisions to the decision trees from the MY 2012-2016 

final rule that have been incorporated for this FRM. 

Engine Technology Decision Tree 

For this FRM, NHTSA modified the engine decision tree and the model’s technology application 

logic that was employed in the MYs 2012-2016 final rule by revising some of the paths and 

adding new technologies that the agencies assume will be available in the MYs 2017-2025 
 

228 

timeframe. Figure V-29 below shows a simplified decision tree for the engine technology 

category. 

As was the case in the MYs 2012-2016 final rule, SOHC, DOHC and OHV engines continue to 

have separate paths to allow the model to apply unique path-dependent valvetrain technologies 

(Variable Valve Timing, Variable Valve Lift, and cylinder deactivation) that are tailored to those 

specific engine types. These path-dependent valvetrain technologies are designated by the letter 

“S” for SOHC, “D” for DOHC and “O” for OHV at the end of each technologies acronym. 

From example, cylinder deactivation (DEAC) on the SOHC is designated as DEACS. This 

approach also improves the accuracy of our accounting for net cost and effectiveness, because 

the unique cost and effectiveness estimates for each engine type can account for the fact that 

SOHC engines only have one camshaft per bank of cylinders, DOHC engines have two 

camshafts per bank of cylinders and OHV engines only have one camshaft regardless of whether 

or not the engine is an inline or V configuration. 

A number of changes have been made to the engine decision tree for the MYs 2017-2025 

analysis in order to reflect changes in our technology assumptions for this rulemaking as 

compared to the MYs 2012-2016 final rule. As explained above, a second step of low-friction 

lubricants and engine friction (LUB2_EFR2) is included in the agencies’ analysis and has thus 

been added to the decision tree, as a single technology following EFR1. On the OHV path, 

coupled cam phasing (CCP) and discrete variable valve lift (DVVL) have been combined into 

one technology, variable valve actuation (VVA). This was done because, and as discussed 

below, cylinder deactivation (DEAC), which utilizes lost motion devices that enable DVVL 

operation, precedes both CCP and DVVL so when applying CCP it seems logical to apply 

DVVL, at no cost due to being enabled by DEAC, to utilize the additional valve control the 

conversion to DOHC has been deleted from the OHV path based on the assumption that 

manufacturers are more likely to proceed to a turbocharged and downsized engine, which has a 

higher potential for fuel consumption reductions, rather than to a naturally aspirated DOHC 

engine in the event that they need to replace the existing OHV engine Additionally, the OHV 

path now has its own unique stoichiometric gasoline direct injection technology (SGDIO). 

The combustion restart (CBRST) technology has been deleted as an enabling engine technology 

based on the assumption that it is likely that manufacturers will accomplish stop-start 

functionality by way of a 12V integrated starter/generator (MHEV). 

The turbocharging and downsizing and cooled EGR technologies are considered to be a 

completely new engines that have been converted to DOHC (if not already a DOHC in the 

baseline vehicle) with LUB, EFR, LUB2_EFR2 (post MY 2016) DCP and SGDI applied. For 

this final rule, the agency has added a second step of turbocharging and downsizing (TRBDS2) 
                                                      

 

 

229 

with a higher Brake Mean Effective Pressure (BMEP197) level. The EGR Boost technology from 

the MYs 2012-2016 technology has been renamed to cooled EGR (CEGR1 and CEGR2) and has 

been expanded to include two steps with the second utilizing higher BMEP levels. For this 

analysis, the conversion to Diesel is now only one technology following CEGR2, and has been 

renamed advanced diesel (ADSL) Similar to the turbocharged and downsized engines, ADSL is 

considered to be a completely new engine that replaces the gasoline engine (although it carries 

over the LUB, EFR and LUB2_EFR2 technologies, which are assumed to still be applicable to 

diesels). We note that because in the TRBDS1 all engines are converted to DOHC engines; there 

are not path-dependent variations of the TRBDS2, CEGR1, CEGR2 and ADSL technologies, 

which means that the same technology state is reached by the modified vehicle regardless of the 

path the model followed to achieve it. Therefore, in conducting the analysis, the net cost and 

effectiveness estimates for the different engine paths are considered to be the same (regardless of 

path), and the incremental cost and effectiveness estimates are adjusted as appropriate to account 

for the path-dependent variations. 

197 BMEP refers to brake mean effective pressure, a common engineering metric which describes the specific torque 

of an engine, as a way of comparing engines of different sizes. It is usually expressed in units of bar, or kPa. 

Current naturally aspirated production engines typically average 10-12 bar BMEP, while modern turbocharged 

engines are now exceeding 20 bar BMEP with regularity. Simply put, a 20 bar BMEP turbocharged engine will 

provide twice the torque of an equivalent sized engine that achieves 10 bar BMEP. 
230 

Figure V-29. Engine Technology (EngMod) Decision Tree 
231 

Electrification/Accessory Technology Decision Tree 

After reviewing this decision tree, NHTSA made some revisions from the version used in the 

MYs 2012-2016 final rule. Specifically, since the agencies are considering a second level of 

Improved Accessories (IACC) after the first level to consider technologies such as mild levels of 

alternator regenerative braking, the decision tree was modified to include that additional 

technology option. Belt Mounted Integrated Starter Generator (BISG) and Crank Mounted ISG 

(CISG) are now combined into one technology, Integrated Starter Generator (ISG). ISG was not 

used in the analysis for the proposal but is included in the final rule analysis. The updated 

decision tree is shown in Figure V-30. 

Electric Power Steering (EPS) is the first technology in this decision tree, since it is a primary 

enabler for stop-start systems and mild and strong hybrids, and is followed by the first level of 

Improved Accessories (IACC1), as in the MY 2012-2016 final rule. IACC1 is then followed by 

a second level of improved accessory (IACC2), which includes a mild level of regenerative 

braking, as stated above. Micro-Hybrid (MHEV), a 12-volt system that offers basic idle 

stop/start functionality only, follows IACC2. An ISG technology block is placed on the decision 

tree to represent the higher voltage system with stop/start and higher level of energy recovery 

through regenerative braking, and some power assist. The ISG mild hybrid system was not 

considered in the proposal and is new for this final rule. All Electrification/Accessory 

technologies can be applied to both automatic and manual transmission vehicles. 

Transmission Technology Decision Tree 

For the NPRM and final rule, NHTSA reviewed the transmission technology decision tree and 

the model’s technology application logic used in the MYs 2012-2016 final rule, and made some 

revisions. This decision tree, shown in Figure V-30, contains two paths: one for automatic/dual 

clutch transmissions and one for manual transmissions. The CVT path used in MYs 2012-2016 

final rule has been removed due to the assumed low market penetration of CVTs in the U.S. in 

the rulemaking timeframe. 

On the automatic/dual clutch path, the decision tree first optimizes the current transmission by 

improving the control system via the Improved Automatic Transmissions Controls and other 

Externals (IATC) technology. After IATC, the decision tree moves to 6-speed automatic 

transmission with improved internals (NAUTO). The NAUTO technology is followed by the 6­

speed Dual Clutch Transmission (DCT) technology. Dual Clutch Transmission (DCT) designs 

do not suffer torque interrupt when shifting; a characteristic associated with automated manual 

transmission (AMT) designs. In response to comments from manufacturers expressing concern 

that torque interrupt will not be acceptable to consumers, AMT designs are not included in this 

analysis. The DCT technology is disabled for vehicles with towing requirements, such as 

Midsize Light Truck (LT), Large LT and Minivan LT vehicle subclasses. After DCT, the 
 

232 

decision tree progresses to an 8-speed transmission (8SPD). For vehicles with towing 

requirements, the 8SPD technology represents an 8-speed automatic. However, for all other 

vehicles the 8SPD technology represents a transition to an 8-speed DCT from a 6-speed DCT. 

Following the 8SPD technology are two new technologies added for this FRM: high efficiency 

gear box (HETRANS) and shift optimization (SHFTOPT). Each of these technologies can be 

applied to both DCT and automatic transmissions. 

As in the 2012-2016 final rule analysis, the manual transmission path has only two technology 

applications: conversion to a 6-Speed Manual with Improved Internals (6MAN), and high 

efficiency gearbox (HETRANSM). NHTSA anticipates limited use of manual transmissions 

with more than 6 speeds within the MYs 2017-2025 timeframe. 

Hybrid Technology Decision Tree 

NHTSA also reviewed the hybrid technology decision tree and the model’s technology 

application logic used in the MY 2012-2016 final rule, and made revisions to this decision tree 

anticipating that more HEV, PHEV and EV vehicles will penetrate the market for the MYs 2017­

2025 rulemaking period. The model continues to apply only strong hybrid technologies when 

both the Electrification/Accessory and Transmission (automatic/dual clutch transmissions only) 

technologies have been fully added to the vehicle, as seen in Figure V-30. When the CAFE 

model applies strong hybrids, it accounts for the fact that some of the fuel consumption 

reductions have already been included when technologies like EPS, IACC, and ISG have been 

previously applied. The decision tree contains two levels of strong hybrid technologies: SHEV1 

and SHEV2. SHEV1 is applied when defining the MYs 2012-2016 baseline and SHEV2 is 

applied in the MYs 2017-2025 analysis. SHEV2 represents a second generation of strong 

hybrids that includes advances in engine and transmission technologies assumed to be available 

in MYs 2017-2025. The model’s logic will allow a vehicle with the SHEV1 technology, either 

as applied by the model or present in the baseline, to be converted to SHEV2 in the MYs 2017­

2025 timeframe. After SHEV2, the decision tree advances to a 30-mile range plug-in hybrid 

(PHEV1). Should the need arise in the future to incorporate another PHEV technology with a 

different range, a placeholder technology, PHEV2, has been added to the decision tree. 

Following SHEV2 in the decision tree are four electric vehicle (EV) technologies: EV1, EV2, 

EV3 and EV4. EV1 is a 75-mile range EV assumed to be marketed to early adopters of the EV 

technology. EV2 and EV3 are not used in this analysis and are reserved for adding different 

versions of EVs with different ranges. EV4 represents a 150-mile range EV that is assumed to 

be marketed as a mass market vehicle. 
 

233 

Figure V-30. Electrification/Accessory, Transmission and Hybrid Technology Decision 

Tree 

Vehicle Technology Decision Tree 

After reviewing this decision tree, NHTSA made some revisions to the vehicle technology tree 

from the version used in the MYs 2012-2016 final rule. The MY 2012-2016 final rule utilized 

three Material Substitution (MS) technologies in a dedicated path in the Vehicle Technology 

Decision tree. For this FRM, Material Substitution has been renamed Mass Reduction (MR) and 
 

234 

has been expanded to five levels as shown in Figure V-15. All have a different definition (in 

terms of the amount of mass reduction that they can represent) than was used in the prior rule 

and the definition for the level of mass reduction differs with each vehicle subclass. For 

example, only MR1 and MR2 are used for midsize passenger cars representing a total of mass 

reduction of 5 percent, while MR1 to MR5 are used for large pickup trucks representing a total 

mass reduction of 20 percent. Section 0 contains detailed description of how mass reductions are 

applied in this analysis. 

Low Drag Brakes (LDB) and Secondary Axle Disconnect (SAX) have the same definition and 

path as used in the MYs 2012-2016 final rule, with SAX still applied to 4WD vehicles only. 

Low Rolling Resistance Tires (ROLL) is separated from LDB and SAX path. There are 3 levels 

of Low Rolling Resistance Tire in the decision tree, ROLL1, ROLL2 and ROLL3. However, 

only ROLL1 and ROLL2 are used in this final rule; the third level is reserved for potential future 

use. 

Aerodynamic Drag Reduction also remains a separate path and there are now two levels of 

aerodynamic drag reduction in this final rule analysis, AERO1 and AERO2. The MYs 2012­

2016 final rule only had one level of AERO. 
235 

Figure V-31. Vehicle Technology Decision Tree 

Is this model year an appropriate time to add the technology? (year of availability; refresh 

and redesign schedule) 

Manufacturers typically plan vehicle changes to coincide with certain stages of a vehicle’s life 

cycle that are appropriate for the change, or in this case the technology being applied. In the 

automobile industry there are two terms that describe when technology changes to vehicles 

occur: redesign and refresh (i.e., freshening). Vehicle redesign usually refers to significant 

changes to a vehicle’s appearance, shape, dimensions, and powertrain. Redesign is traditionally 

associated with the introduction of “new” vehicles into the market, often characterized as the 

“next generation” of a vehicle, or a new vehicle platform. Vehicle refresh usually refers to less 

extensive vehicle modifications, such as minor changes to a vehicle’s appearance, a moderate 

upgrade to a powertrain system, or small changes to the vehicle’s feature or safety equipment 
                                                      

236 

content. Refresh is traditionally associated with mid-cycle cosmetic changes to a vehicle, within 

its current generation, to make it appear “fresh.” Vehicle refresh generally occurs no earlier than 

two years after a vehicle redesign, or at least two years before a scheduled redesign. 

There are many factors that can affect when or how often redesigns occur, such as availability of 

capital and engineering resources and the extent of platform and component sharing between 

vehicle models, or even between manufacturers, if cooperation is involved. Historically highvolume cars have followed roughly a 5-year redesign cycle to remain competitive in the market. 

On the other hand, a few of the niche market or small-volume manufacturer vehicles (i.e. luxury 

and performance vehicles), as well as large trucks and full size vans, have historically followed 

longer 6- to 8-year redesign cycles. Managing product lines and refresh and redesign cycles is a 

complex task undertaken by manufacturers to respond to consumer preference trends and to 

comply with regulations in the most cost- and resource-effective way possible. The agency 

believes that manufacturers can and will accomplish much improvement in fuel economy and 

GHG reductions while applying technology consistent with their redesign schedules. While 

manufacturers look to make common design and technology changes across a vehicle platform, 

consumer preference trends and regulation can sometimes require manufacturers to use 

flexibilities such vehicle-specific designs and technology changes in addition to broader vehicle 

platform level changes at refresh/redesign times in order to stay competitive and ensure 

compliance. As fuel economy standards become more stringent over time, NHTSA believes that 

manufacturers will use every opportunity to improve the fuel economy performance of their 

vehicles. 

For the majority of technologies discussed in this final rule, manufacturers will only be able to 

apply them at a refresh or redesign, because their application would be significant enough to 

involve some level of engineering, testing, and calibration work.198 Some technologies (e.g., 

those that require significant revision) are nearly always applied only when the vehicle is 

expected to be redesigned, like turbocharging and engine downsizing, or conversion to diesel or 

hybridization. Other technologies, like cylinder deactivation, electric power steering, and low 

rolling resistance tires can be applied either when the vehicle is expected to be refreshed or when 

it is expected to be redesigned, while low friction lubricants, can be applied at any time, 

regardless of whether a refresh or redesign event is conducted. Accordingly, the model will only 

apply a technology at the particular point deemed suitable. These constraints are intended to 

produce results consistent with how we assume manufacturers will apply technologies in the 

198 For example, applying material substitution through weight reduction, or even something as simple as low 

rolling-resistance tires, to a vehicle will likely require some level of validation and testing to ensure that the vehicle 

may continue to be certified as compliant with NHTSA’s Federal Motor Vehicle Safety Standards (FMVSS). 

Weight reduction might affect a vehicle’s crashworthiness; low rolling-resistance tires might change a vehicle’s 

braking characteristics or how it performs in crash avoidance tests. 
                                                      

 

 

 

 

 

 

237 

future based on how they have historically implemented new technologies. For each technology 

under consideration, NHTSA specifies whether it can be applied any time, at refresh/redesign, or 

only at redesign. The data forms another input to the CAFE model. 

For this final rule, NHTSA developed redesign and refresh schedules for each of a 

manufacturer’s vehicles included in the analysis, essentially based on the last known redesign 

year for each vehicle, and projected forward using a 4 to 8-year redesign and a 2–3 year refresh 

cycle. NHTSA used publicly-available data to estimate the last known redesign schedule for the 

vehicles produced by the manufacturers.199 The agency also used this public data along with 

engineering judgment to estimate the number of years between redesigns to develop the unique 

redesign schedules for each vehicle model in the analysis. Thus, if a vehicle was last redesigned 

in MY 2008 and is assumed to have 6 years between redesigns, the redesign cycle will be as 

follows: MY 2008, MY 2014, and MY 2020. The refresh schedules were determined in a 

similar fashion, based on those of the baseline fleet and using the 2 to 3 year cycle assumption. 

NHTSA believes that this approach is reasonable given the nature of the current baseline, which 

as a single year (MY 2008) of CAFE certification data, as discussed in Chapter III above, does 

not contain its own refresh and redesign cycle cues for future model years. This approach also 

helps to ensure the complete transparency of the agency’s analysis.200 For the final rule NHTSA 

intends to update the baseline fleet, hopefully using the more current MY 2010 CAFE 

certification data in lieu of the MY 2008 certification data, and the agency will reassess vehicle 

redesign schedules as part of this update. The agency seeks comment on the approach taken to 

estimate vehicle redesign schedules and on the schedules themselves. No comments were 

submitted on this issue. 

We note that this approach taken for this final rule is different from what NHTSA has employed 

previously for determining redesign and refresh schedules. For the MYs 2012-2016 final rule, 

199 Sources included, but were not limited to, manufacturers’ web sites, industry trade publications (e.g., Automotive 

News), and commercial data sources (e.g., Ward’s Automotive, etc.). 200 While the greater transparency of using historical certification data is an undeniable benefit, using adjusted 

historical data rather than estimated future data also impacts how NHTSA is able to model the refresh/redesign cycle 

in its analysis of year-by-year maximum feasible CAFE standards. For example, manufacturers have indicated 

(either publicly or in their product plans) that some vehicles that exist in the MY 2008 certification-data based fleet 

will be discontinued (i.e., no longer produced or sold) prior to or within the rulemaking period. Conversely, some 

vehicle models have already been or will be introduced to the market during the rulemaking time frame, like GM’s 

Chevy Volt and Chrysler’s anticipated new models based on Fiat platforms. Since these vehicles were not sold in 

2008, they do not exist in the MY 2008 certification data, and thus do not exist in the model’s market data file for 

this NPRM analysis. To address this problem, the agency assumes that future vehicles are replacements for vehicles 

currently in the market and will tend to follow the same cycles as their predecessors, so it is appropriate to reflect the 

same redesign cycle in the market data file. 

NHTSA believes that it is reasonable to expect that the manufacturer will produce a similar vehicle, or 

some group of similar vehicles, to compete in the same market segment—whether the manufacturer will offer the 

same vehicle model, a fully redesigned but otherwise similar version of that model, or an entirely new vehicle or 

group of vehicles, sold as a new model or nameplate of a similar type. This is how NHTSA addresses the issue of 

the GM Volt: although it does not appear in the baseline market data file, it will be considered as one of the existing 

GM models of similar type and in the same market segment once it becomes available. 
 

                                                      

 

 

238 

NHTSA assumed that passenger cars would normally be redesigned every 5 years, consistent 

with industry trends over the last 10-15 years, unless a manufacturer had submitted product plans 

indicating that they expected to pursue a more rapid redesign and refresh schedule.201 In the 

MYs 2012-2016 final rule, NHTSA also projected a 5-year redesign cycle for the majority of 

light trucks.202 In the MY 2011 final rule, NHTSA reviewed manufacturers’ planned redesign 

and refresh schedules as stated in their confidential submissions and incorporated them into the 

market data file, or relied on other sources of information where that data did not exist. 

Even within the context of the phase-in caps discussed below, NHTSA considers these modelby-model scheduling constraints of refresh and redesign schedules necessary in order to produce 

an analysis that reasonably accounts for the need for a period of stability following the redesign 

of any given vehicle model. If engineering, tooling, testing, and other redesign-related resources 

were unlimited, every vehicle model could be redesigned every year. In reality, however, every 

vehicle redesign consumes resources simply to address the redesign, and thus cost expenditures 

occur. Phase-in caps, which are applied at the level of a manufacturer’s entire fleet, do not, by 

themselves, constrain the scheduling of changes to any particular vehicle model. Conversely, 

scheduling constraints to address vehicle freshening and redesign do not necessarily yield 

realistic overall penetration rates for a particular technology type (e.g., for strong hybrids), while 

phase-in caps do. Thus, the two constraints work together in the model to ensure that the timing 

and application rate for various fuel-saving technologies is feasible for manufacturers on a yearby-year basis, as required by EPCA/EISA.203 

The baseline market data file, available on NHTSA’s website, contains the refresh and redesign 

dates developed by NHTSA for this final rule. Table V-12 below provides whether particular 

technologies are “anytime” technologies, “redesign only” technologies, or “refresh or redesign” 

technologies, for purposes of this final rule. 

201 Exceptions were made for high performance vehicles and other vehicles that traditionally had longer than 

average design cycles due to their unique design characteristics and their evolutionary, as opposed to revolutionary 

product development practices (e.g., the Porsche 911 has remained the same basic vehicle for many years). 202 NHTSA recognized in the MY 2011 CAFE rulemaking that light trucks are currently redesigned every 5 to 7 

years, with some vehicles (like full-size vans) having longer redesign periods. However, in the most competitive 

SUV and crossover vehicle segments, the redesign cycle currently averages slightly above 5 years. NHTSA 

concluded that the light truck redesign schedule will be shortened in the future due to competitive market forces. 

Thus, for almost all light trucks scheduled for a redesign in the early portions of the rulemaking period, NHTSA 

projected a 5-year redesign cycle. 

203 49 U.S.C. § 32902(a) requires that NHTSA set CAFE standards at the maximum feasible level for each fleet, for 

each model year. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

239 

Table V-12. Technology Refresh and Redesign Application 

Technology Abbr. Redesign Only Redesign or Refresh Anytime 

Low Friction Lubricants - Level 1 LUB1 X 

Engine Friction Reduction - Level 1 EFR1 X 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_EFR2 X 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC CCPS X 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS X 

Cylinder Deactivation on SOHC DEACS X 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP X 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP X 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD X 

Continuously Variable Valve Lift (CVVL) CVVL X 

Cylinder Deactivation on DOHC DEACD X 

Stoichiometric Gasoline Direct Injection (GDI) SGDI X 

Cylinder Deactivation on OHV DEACO X 

Variable Valve Actuation - CCP and DVVL on OHV VVA X 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO X 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement TRBDS1_SD X 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement TRBDS1_MD X 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement TRBDS1_LD X 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement TRBDS2_SD X 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement TRBDS2_MD X 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement TRBDS2_LD X 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD X 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD X 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD X 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD X 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD X 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD X 

Advanced Diesel - Small Displacement ADSL_SD X 

Advanced Diesel - Medium Displacement ADSL_MD X 

Advanced Diesel - Large Displacement ADSL_LD X 

6-Speed Manual/Improved Internals 6MAN X 

High Efficiency Gearbox (Manual) HETRANSM X 

Improved Auto. Trans. Controls/Externals IATC X 

6-Speed Trans with Improved Internals (Auto) NAUTO X 

6-speed DCT DCT X 

8-Speed Trans (Auto or DCT) 8SPD X 

High Efficiency Gearbox (Auto or DCT) HETRANS X 

Shift Optimizer SHFTOPT X 

Electric Power Steering EPS X 

Improved Accessories - Level 1 IACC1 X 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) IACC2 X 

12V Micro-Hybrid (Stop-Start) MHEV X 

Integrated Starter Generator ISG X 

Strong Hybrid - Level 1 SHEV1 X 

Conversion from SHEV1 to SHEV2 SHEV1_2 X 

Strong Hybrid - Level 2 SHEV2 X 

Plug-in Hybrid - 30 mi range PHEV1 X 

Plug-in Hybrid PHEV2 X 

Electric Vehicle (Early Adopter) - 75 mile range EV1 X 

Electric Vehicle (Early Adopter) - 100 mile range EV2 X 

Electric Vehicle (Early Adopter) - 150 mile range EV3 X 

Electric Vehicle (Broad Market) - 150 mile range EV4 X 

Fuel Cell Vehicle FCV X 

Mass Reduction - Level 1 MR1 X 

Mass Reduction - Level 2 MR2 X 

Mass Reduction - Level 3 MR3 X 
 

 

 

 

 

 

 

 

 

                                                      

 

240 

Mass Reduction - Level 4 MR4 X 

Mass Reduction - Level 5 MR5 X 

Low Rolling Resistance Tires - Level 1 ROLL1 X 

Low Rolling Resistance Tires - Level 2 ROLL2 X 

Low Rolling Resistance Tires - Level 3 ROLL3 X 

Low Drag Brakes LDB X 

Secondary Axle Disconnect SAX X 

Aero Drag Reduction, Level 1 AERO1 X 

Aero Drag Reduction, Level 2 AERO2 X 

Can the technology be applied to this vehicle? (division of vehicles into subclasses) 

As part of its consideration of technological feasibility, the agency evaluates whether each 

technology could be implemented on all types and sizes of vehicles, and whether some 

differentiation is necessary in applying certain technologies to certain types and sizes of vehicles, 

and with respect to the cost incurred and fuel consumption and CO2 emissions reduction 

achieved when doing so. The 2010 NAS Report differentiated technology application using 

eight vehicle “classes” (4 car classes and 4 truck classes).204NAS’s purpose in separating 

vehicles into these classes was to create groups of “like” vehicles, i.e., vehicles similar in size, 

powertrain configuration, weight, and consumer use, and for which similar technologies are 

applicable. NAS also used these vehicle classes along with powertrain configurations (e.g., 4 

cylinder, 6 cylinder or 8 cylinder engines) to determine unique cost and effectiveness estimates 

for each class of vehicles. 

NHTSA similarly differentiates vehicles by “subclass” for the purpose of applying technologies 

to “like” vehicles and assessing their incremental costs and effectiveness. These technology 

subclasses should not be confused with the regulatory classifications pursuant to 49 CFR Part 

523. NHTSA assigns each vehicle manufactured in the rulemaking period to one of 12 

subclasses: for passenger cars, Subcompact, Subcompact Performance, Compact, Compact 

Performance, Midsize, Midsize Performance, Large, and Large Performance; and for light 

trucks, Small SUV/Pickup/Van, Midsize SUV/Pickup/Van, Large SUV/Pickup/Van, and 

Minivan. The agency sought comment on the appropriateness of these 12 subclasses for the 

MYs 2017-2025 timeframe. NHTSA did not receive any comments on this issue. 

For this FRM, NHTSA divides the vehicle fleet into subclasses based on model inputs, and 

applies subclass-specific estimates, also from model inputs, of the applicability, cost, and 

effectiveness of each fuel-saving technology. The model’s estimates of the cost to improve the 

fuel economy of each vehicle model thus depend upon the subclass to which the vehicle model is 

assigned. Each vehicle’s subclass is stored in the market forecast file. When conducting a 

204 The NAS classes included two-seater convertibles and coupes; small cars; intermediate and large cars; highperformance sedans; unit-body standard trucks; unit-body high-performance trucks; body-on-frame small and 

midsize trucks; and body 
 

241 

compliance analysis, if the CAFE model seeks to apply technology to a particular vehicle, it 

checks the market forecast to see if the technology is available and if the refresh/redesign criteria 

are met. If these conditions are satisfied, the model determines the vehicle’s subclass from the 

market data file, which it then uses to reference another input called the technology input file. 

NHTSA reviewed its methodology for dividing vehicles into subclasses for purposes of 

technology application that it used in the MY 2011 final rule and for the MYs 2012-2016 

rulemaking, and concluded that the same methodology would be appropriate for this FRM for 

MYs 2017–2025. The methodology is as follows: 

NHTSA examined the car and truck segments separately. First, for the car segment, NHTSA 

plotted the footprint distribution of vehicles in the baseline vehicle fleet and divided that 

distribution into four equivalent footprint range segments. The footprint ranges were named 

Subcompact, Compact, Midsize, and Large classes in ascending order. Cars were then assigned 

to one of these classes based on their specific footprint size. Vehicles in each range were then 

manually reviewed by NHTSA staff to evaluate and confirm that they represented a fairly 

reasonable homogeneity of size, weight, powertrains, consumer use, etc. However, each group 

contained some vehicles that were sports or high-performance models. Since different 

technologies and cost and effectiveness estimates may be appropriate for these type vehicles, 

NHTSA employed a performance subclass within each car subclass to maximize the accuracy of 

technology application. To determine which specific cars would be assigned to the performance 

subclasses, NHTSA graphed (in ascending rank order) the power-to-weight ratio for each vehicle 

in a subclass. An example of the Compact subclass plot is shown below in Figure V-32. The 

subpopulation was then manually reviewed by NHTSA staff to determine an appropriate 

transition point between “performance” and “non-performance” models within each class. 
 

242 

Figure V-32 Power/Weight Ratio for Compact Subclass 

Compact Subclass - P/W Ratio in Ascending Order 

0 

0.02 

0.04 

0.06 

0.08 

0.1 

0.12 

0.14 

0.16 

0.18 

0.2 

Power (HP) / Curb Wght. (Lbs) 

Compact 

Transition Area 

Normal Perf. High Perf. 

A total of eight classes (including performance subclasses) were identified for the car segment: 

Subcompact, Subcompact Performance, Compact, Compact Performance, Midsize, Midsize 

Performance, Large and Large Performance. In total, the number of cars that were ultimately 

assigned to a performance subclass was less than 10 percent. Table V-6 provides examples of 

the types of vehicles assigned to each car subclass. 
243 

Table V-13. Passenger Car Subclasses Example Vehicles 

Class Example vehicles 

Subcompact Chevrolet Aveo, Hyundai Accent 

Subcompact Performance Mazda MX-5, BMW Z4 

Compact Chevrolet Cobalt, Nissan Sentra and Altima 

Compact Performance Audi S4, Mazda RX8 

Midsize Chevrolet Impala, , Toyota Camry, Honda Accord, 

Hyundai Azera 

Midsize Performance Chevrolet Corvette, Ford Mustang (V8), Nissan 

350Z 

Large Audi A8, Cadillac CTS and DTS 

Large Performance Bentley Arnage, Mercedes-Benz CL600 

For light trucks, as in the MYs 2012-2016 final rule, NHTSA found less of a distinction in the 

anticipated vehicle fleet during the model years covered by the rulemaking between SUVs and 

pickup trucks than appeared to exist in earlier rulemakings. We anticipate fewer ladder-frame 

and more unibody pickups, and that many pickups will share common powertrains with SUVs. 

Thus, SUVs and pickups are grouped in the same subclasses. Additionally, it made sense to 

carry forward NHTSA’s decision from the MYs 2012-2016 final rule to employ a separate 

minivan class, because minivans (e.g., the Honda Odyssey) are more car-like and differ 

significantly in terms of structural and other engineering characteristics as compared to other 

vans (e.g., Ford’s E-Series—also known as Econoline—vans) intended for more passengers 

and/or heavier cargo and which are more truck-like. 

Thus, the remaining vehicles (other vans, pickups, and SUVs) were then segregated into three 

footprint ranges and assigned a class of Small Truck/SUV, Midsize Truck/SUV, and Large 

Truck/SUV based on their footprints. NHTSA staff then manually reviewed each population for 

inconsistent vehicles based on engine cylinder count, weight (curb and/or gross), or intended 

usage, since these are important considerations for technology application, and reassigned 

vehicles to classes as appropriate. This system produced four truck segment subclasses— 

minivans and small, medium, and large SUVs/Pickups/Vans. Table V-14 provides examples of 

the types of vehicles assigned to each truck subclass. 

Table V-14. Light Truck Subclasses Example Vehicles 

Class Example vehicles 

Minivans Dodge Grand Caravan, Toyota Sienna 

Small 

SUV/Pickup/Van 

Ford Escape & Ranger, Nissan Rogue 

Midsize 

SUV/Pickup/Van 

Chevrolet Colorado, Jeep Wrangler, Toyota Tacoma 
 

244 

Large Chevrolet Silverado, Ford E-Series, Toyota Sequoia 

SUV/Pickup/Van 

As mentioned above, NHTSA employed this method for assigning vehicle subclasses for this 

final rule after reviewing the process used in the MYs 2012-2016 final rule and concluding that it 

continued to be a reasonable approach for purposes of this rulemaking. NHTSA believes that 

this method continues to substantially improve the overall accuracy of the results as compared to 

systems employed previously, due to the close manual review by NHTSA staff to ensure proper 

assignments, the use of performance subclasses in the car segment, and the condensing of 

subclasses in the truck segment, all of which further refine the system without overly 

complicating the CAFE modeling process. Nevertheless, NHTSA invites comments on the 

method of assigning vehicles to subclasses for the purposes of technology application in the 

CAFE model, and on the issue of technology-application subclasses generally. The agency is 

also seeking comment on the continued appropriateness of maintaining separate “performance” 

vehicle classes or if as fuel economy stringency increases the market for performance vehicles 

will decrease. NHTSA did not receive any comments on these issues. 

We note that EPA uses different classifications in its Lumped Parameter Model (LPM), OMEGA 

model, and cost analysis. Because the LPM uses only 6 vehicle classes, and because NHTSA 

relied on EPA’s technology effectiveness estimates obtained through the LPM analysis for this 

rulemaking in the interest of harmonization, NHTSA needed to map its 12 vehicle subclasses 

into the LPM’s 6 vehicle classes for purposes of developing subclass-specific technology 

effectiveness estimates. Table V-15 shows how NHTSA’s vehicle classification lines up with 

EPA’s classifications for purposes of developing the joint cost and effectiveness estimates. 
 

                                                      

 

 

 

245 

Table V-15 Mapping between NHTSA and EPA Vehicle Classifications 

NHTSA/CAFE 

model Classification 

EPA Vehicle Class 

for Cost Purpose 

EPA Lumped 

Parameter 

Model 

Classification 

Example 

Subcompact 

Subcompact Perf PC Subcompact/Small 

Car Small Car Yaris Compact 

Compact Perf PC 

Midsize PC 

Midsize Perf PC Standard Car Standard Car Camry 

Large PC 

Large Perf PC Large Car Large Car Chrysler 300 

Small LT Small MPV Small MPV Saturn Vue 

Midsize LT 

Large MPV Large MPV Dodge Grand 

Minivan LT Caravan

Large LT Truck Truck Ford F150 

How much of the technology can be applied to the fleet this year? (phase-in caps) 

Besides the refresh/redesign cycles used in the CAFE model, which constrain the rate of 

technology application at the vehicle level so as to ensure a period of stability following any 

modeled technology applications, the other constraint on technology application employed in 

NHTSA’s analysis is “phase-in caps.” Unlike vehicle-level cycle settings, phase-in caps 

constrain technology application at the vehicle manufacturer level.205 Phase-in caps are intended 

to function as a proxy for a number of real-world limitations in deploying new technologies in 

the auto industry. These limitations can include, but are not intended to be limited to, 

engineering resources at the OEM or supplier level, financial resources, restrictions on 

intellectual property that limit deployment, and/or limitations in material or component supply as 

205 While phase-in caps are expressed as specific percentages of a manufacturer’s fleet to which a technology may be 

applied in a given model year, phase-in caps cannot always be applied as precise limits, and the CAFE model in fact 

allows “override” of a cap in certain circumstances. When only a small portion of a phase-in cap limit remains, or 

when the cap is set to a very low value, or when a manufacturer has a very limited product line, the cap might 

prevent the technology from being applied at all since any application would cause the cap to be exceeded. 

Therefore, the CAFE model evaluates and enforces each phase-in cap constraint after it has been exceeded by the 

application of the technology (as opposed to evaluating it before application), which can result in the described 

overriding of the cap. 
 

                                                      

246 

a market for a new technology develops. The inclusion of phase-in caps helps to ensure that 

resource capacity and other limitations are accounted for in the modeling process. At a high 

level, phase-in caps, refresh/redesign cycles and the logic of the model itself work in conjunction 

with one another to avoid the modeling process out-pacing an OEM’s limited pool of available 

resources during the rulemaking time frame and the years leading up to the rulemaking time 

frame, especially in years where many models may be scheduled for refresh or redesign. We 

emphasize that phase-in caps are not used to prescribe technology application rates; to NHTSA, 

phase-in caps represent the maximum amount of technology that the industry could apply in a 

given year recognizing the limitations described above. Phase-in caps, in combination with other 

constraints, thus help to ensure technological feasibility and economic practicability in 

determining the stringency of the standards. Despite the available lead time, these constraints 

remain important for this round of rulemaking: even though this rulemaking is being proposed 5 

years before it takes effect, OEM’s will still be utilizing their limited resources to meet the MYs 

2012-2016 CAFE standards. 

NHTSA has been developing the concept of phase-in caps for purposes of the agency’s modeling 

analysis over the course of the last several CAFE rulemakings, as discussed in greater detail in 

the MY 2011 final rule, in the MY 2012-2016 final rule and Chapter 3 of the Joint TSD. The 

MYs 2012-2016 final rule, like the MY 2011 final rule, employed non-linear phase-in caps (that 

is, caps that varied from year to year) that were designed to respond to previously received 

comments on technology deployment. 

For purposes of this FRM, as in the MY 2011 and MYs 2012-2016 final rules, NHTSA combines 

phase-in caps for some groups of similar technologies, such as valve phasing technologies that 

are applicable to different forms of engine design (SOHC, DOHC, OHV), since they are very 

similar from an engineering and implementation standpoint. When the phase-in caps for two 

technologies are combined, the maximum total application of either or both to any 

manufacturer’s fleet is limited to the value of the cap.206 

In developing phase-in cap values for purposes of this FRM, NHTSA reviewed the MYs 2012­

2016 final rule’s phase-in caps, which for the majority of technologies were set to reach 85 or 

100 percent by MY 2016, although more advanced technologies like diesels and strong hybrids 

reached only 15 percent by MY 2016. The phase-in caps used in the MYs 2012-2016 final rule 

were developed to harmonize with the similar caps used in EPA’s modeling, and reflected the 

fact that manufacturers, as part of the agreements supporting the National Program, appeared to 

be anticipating higher technology application rates than assumed by NHTSA in prior rulemaking 

analyses. NHTSA determined that these phase-in caps for MY 2016 were still reasonable and 

206 See 74 FR at 14270 (Mar. 30, 2009) for further discussion and examples. 
247 

thus used those caps as the starting point for the MYs 2017-2025 phase-in caps. For many of the 

carryover technologies, this means that for MYs 2017-2025 the phase-in caps are assumed to be 

100 percent. For the phase-in caps for the newly defined technologies that will be entering the 

market just before or during the MYs 2017-2025 time frame, as discussed in more detail in 

Chapter 3 of the Joint TSD, NHTSA, along with EPA, used confidential OEM submissions, trade 

press articles, company publications and press releases to estimate their values using engineering 

judgment,. For example, advanced cooled EGR engines are assigned a phase-in cap of 3 percent 

per year through MY 2021, and then 10 percent per year through 2025. The agency sought 

comment on the appropriateness of both the carryover phase-in caps and the newly defined ones 

proposed in the NPRM. The American Fuel and Petrochemical Manufacturers (AFPM) 

commented on their belief that the projections of electrification penetration were too high. They 

believed that the problem could be corrected by using smaller phase-in cap values for these 

technologies. They also commented that the phase-in caps were arbitrary and that the agencies 

should switch to using a consumer choice model. Additionally, NHTSA’s analysis shows that 

automakers can have low applications of strong hybrid, plug-in hybrid, and electric vehicle 

technologies, well under the phase-in caps, and still comply with the standards. 

Table V-16 shows phase-in rates, on a year-by-year basis, for the technologies used in the CAFE 

model for this FRM analysis. Most technologies are available at a rate of either 85 percent or 

100 percent beginning in 2016. Some advanced technologies expected to enter the market in the 

near future, such as EGR Boost, follow a 3 percent annual cap increase from 2016 to 2021, and 

then approximately 10 percent from 2021 to 2025. Diesels follow an annual 3 percent increase 

in phase-in cap through 2025. Hybrids follow a 3 percent annual increase from 2016 to 2012, 

then 5 percent from 2021 to 2015. PHEVs and EVs follow a 1 percent annual cap increase. 

Lower phase-in caps for Alternative Fueled Vehicles (AFVs) reflect additional investment in 

infrastructure that is required to achieve high levels of conversion to a new fuel type. These 

limited phase-in caps also reflect as-yet-unknown consumer responses to HEVs, PHEVs and 

BEVs. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

248 

Table V-16. Phase-in Caps for Technologies Used in 2017+ FRM Analysis for CAFE Model 

Technology Abbr. 

MY 

2009 

MY 

2010 

MY 

2011 

MY 

2012 

MY 

2013 

MY 

2014 

MY 

2015 

MY 

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - 

Level 1 LUB1 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Engine Friction Reduction 

- Level 1 EFR1 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Low Friction Lubricants 

and Engine Friction 

Reduction - Level 2 LUB2_EFR2 0% 0% 0% 0% 0% 0% 0% 0% 12% 24% 36% 48% 60% 72% 84% 96% 100% 

Variable Valve Timing 

(VVT) - CCP on SOHC CCPS 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Discrete Variable Valve 

Lift (DVVL) on SOHC DVVLS 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Cylinder Deactivation on 

SOHC DEACS 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Variable Valve Timing 

(VVT) - Intake Cam 

Phasing (ICP) ICP 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Variable Valve Timing 

(VVT) - Dual Cam 

Phasing (DCP) DCP 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Discrete Variable Valve 

Lift (DVVL) on DOHC DVVLD 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Continuously Variable 

Valve Lift (CVVL) CVVL 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Cylinder Deactivation on 

DOHC DEACD 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Stoichiometric Gasoline 

Direct Injection (GDI) SGDI 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Cylinder Deactivation on 

OHV DEACO 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Variable Valve Actuation - 

CCP and DVVL on OHV VVA 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Stoichiometric Gasoline 

Direct Injection (GDI) on 

OHV SGDIO 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Turbocharging and 

Downsizing - Level 1 (18 

bar BMEP) - SD TRBDS1_SD 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Turbocharging and 

Downsizing - Level 1 (18 

bar BMEP) - MD TRBDS1_MD 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Turbocharging and 

Downsizing - Level 1 (18 

bar BMEP) - LD TRBDS1_LD 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Turbocharging and 

Downsizing - Level 2 (24 

bar BMEP) - SD TRBDS2_SD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

Turbocharging and 

Downsizing - Level 2 (24 

bar BMEP) - MD TRBDS2_MD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

Turbocharging and 

Downsizing - Level 2 (24 

bar BMEP) - LD TRBDS2_LD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

CEGR- Level 1 (24 bar 

BMEP) – SD CEGR1_SD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

CEGR - Level 1 (24 bar 

BMEP) – MD CEGR1_MD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

CEGR - Level 1 (24 bar 

BMEP) – LD CEGR1_LD 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 45% 60% 75% 75% 

CEGR - Level 2 (27 bar 

BMEP) – SD CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 3% 6% 9% 12% 15% 25% 35% 45% 50% 

CEGR - Level 2 (27 bar 

BMEP) – MD CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 3% 6% 9% 12% 15% 25% 35% 45% 50% 

CEGR - Level 2 (27 bar 

BMEP) – LD CEGR2_LD 0% 0% 0% 0% 0% 0% 0% 0% 3% 6% 9% 12% 15% 25% 35% 45% 50% 

Advanced Diesel - Small ADSL_SD 0% 0% 0% 0% 3% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

249 

Displacement 

Advanced Diesel ­

Medium Displacement ADSL_MD 0% 0% 0% 0% 3% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 

Advanced Diesel - Large 

Displacement ADSL_LD 0% 0% 0% 0% 3% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 6% 

6-Speed Manual/Improved 

Internals 6MAN 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

High Efficiency Gearbox 

(Manual) HETRANSM 0% 0% 0% 0% 0% 0% 0% 0% 12% 24% 36% 48% 60% 72% 84% 96% 100% 

Improved Auto. Trans. 

Controls/Externals IATC 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

6-Speed Trans with 

Improved Internals (Auto) NAUTO 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

6-speed DCT DCT 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

8-Speed Trans (Auto or 

DCT) 8SPD 0% 0% 0% 0% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 

High Efficiency Gearbox 

(Auto or DCT) HETRANS 0% 0% 0% 0% 0% 0% 0% 0% 12% 24% 36% 48% 60% 72% 84% 96% 100% 

Shift Optimizer SHFTOPT 0% 0% 0% 0% 0% 0% 0% 0% 20% 40% 60% 80% 100% 100% 100% 100% 100% 

Electric Power Steering EPS 5% 20% 35% 50% 65% 80% 95% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Improved Accessories - 

Level 1 IACC1 5% 20% 35% 50% 65% 80% 95% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Improved Accessories - 

Level 2 IACC2 0% 0% 0% 0% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 

12V Micro-Hybrid (StopStart) MHEV 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Integrated Starter 

Generator ISG 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 35% 40% 45% 50% 

Strong Hybrid - Level 1 SHEV1 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 35% 40% 45% 50% 

Conversion from SHEV1 

to SHEV2 SHEV1_2 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 35% 40% 45% 50% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 3% 6% 9% 12% 15% 18% 21% 24% 27% 30% 35% 40% 45% 50% 

Plug-in Hybrid - 30 mi 

range PHEV1 0% 0% 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10% 11% 12% 13% 14% 

Plug-in Hybrid PHEV2 0% 0% 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10% 11% 12% 13% 14% 

Electric Vehicle (Early 

Adopter) - 75 mile range EV1 0% 0% 0% 1% 2% 3% 4% 5% 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Electric Vehicle (Early 

Adopter) - 100 mile range EV2 0% 0% 0% 1% 2% 3% 4% 5% 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Electric Vehicle (Early 

Adopter) - 150 mile range EV3 0% 0% 0% 1% 2% 3% 4% 5% 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Electric Vehicle (Broad 

Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 1% 2% 3% 4% 5% 6% 7% 8% 9% 10% 

Mass Reduction - Level 1 MR1 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Mass Reduction - Level 2 MR2 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Mass Reduction - Level 3 MR3 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Mass Reduction - Level 4 MR4 0% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 100% 100% 100% 

Mass Reduction - Level 5 MR5 0% 0% 0% 0% 0% 0% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 

Low Rolling Resistance 

Tires - Level 1 ROLL1 20% 35% 50% 65% 80% 95% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Low Rolling Resistance 

Tires - Level 2 ROLL2 0% 0% 0% 0% 0% 0% 0% 0% 15% 30% 45% 60% 75% 90% 100% 100% 100% 

Low Rolling Resistance 

Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 20% 35% 50% 65% 80% 95% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Secondary Axle 

Disconnect SAX 15% 25% 35% 45% 55% 65% 75% 85% 95% 100% 100% 100% 100% 100% 100% 100% 100% 

Aero Drag Reduction, 

Level 1 AERO1 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Aero Drag Reduction, 

Level 2 AERO2 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 100% 100% 100% 100% 100% 100% 100% 
 

                                                      

250 

Once the technology is applied, how much does it improve fuel economy? (effectiveness 

estimates) 

In the MYs 2012-2016 final rule, NHTSA and EPA based technology effectiveness estimates on 

two primary sources: NHTSA’s 2011 final rule, which was supported by recommendations from 

Ricardo, Inc. under contract to NHTSA; and EPA’s 2008 Staff Technical Report,207,which was 

supported by vehicle simulation modeling performed by Ricardo in 2007. 

EPA built upon its 2008vehicle simulation work by again hiring Ricardo to perform additional 

vehicle simulation modeling that could be used to derive the effectiveness estimates for this final 

rule. Ricardo used its proprietary dynamic vehicle simulation model, which they developed and 

implemented in MSC.EASY5TM, for this simulation work. MSC.EASY5TM is a commercially 

available software package used in industry for vehicle system analysis. In the current study, 

Ricardo has expanded the technology list previously modeled and included the following new 

engine and vehicle technologies: 

 Advanced, highly downsized, high BMEP turbocharged engine 

 High efficiency 8-speed automatic and DCT transmission 

 Optimized shift schedule to achieve best Brake Specific Fuel Consumption (BSFC) 

 Atkinson-cycle engines for hybrid vehicles 

The new analysis also includes modeling of the following hybrid architectures used in the FRM 

analysis: 

 Stop-start technology 

 P2 hybrid 

Detailed information about Ricardo’s work for this project can be found at Docket No, NHTSA2010-0131, and also in Section 3.2.1 of Chapter 3 of the joint TSD. 

Because the Ricardo findings are for predefined packages/combinations of technologies, the 

agencies needed a way to extract the individual effectiveness for each technology in order to be 

able to apply them one at a time or create different packages/combinations of technologies. To 

that end, EPA used the new Ricardo results to calibrate and update EPA’s Lumped Parameter 

Model (LPM), available at Docket No. NHTSA 2010-0131.The lumped parameter tool is a 

spreadsheet model used to develop the technology effectiveness estimates for this FRM analysis. 

The LPM represents energy consumption in terms of average performance over the fuel 

economy test procedure, rather than explicitly analyzing specific drive cycles. The tool begins 

with an apportionment of fuel consumption across several loss mechanisms and accounts for the 

average extent to which different technologies affect these loss mechanisms using estimates of 

207 EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-Duty 

Vehicle Carbon Dioxide Emissions. EPA420-R-08-008, March 2008. (Docket NHTSA-2010-0131) 
                                                      

 

251 

engine, drivetrain and vehicle characteristics that are averaged over the EPA fuel economy drive 

cycle. 

As part of the calibration/updating process, EPA adjusted the LPM inputs to ensure that the 

results closely aligned with those of the Ricardo work. Thus the results of this analysis using the 

LPM were generally consistent with Ricardo’s most recent full-scale vehicle simulation 

modeling.208 Detailed information about how the LPM works and how EPA used it to develop 

technology effectiveness values for this analysis can be found in Chapter 3 of the joint TSD. 

The technology effectiveness inputs used in the CAFE model for this analysis are based on 

entirely on the outputs of the newly updated LPM, and thus incorporate the Ricardo simulation 

work from 2007 and 2011. Table V-17 to Table V-27 below define how NHTSA mapped 

technology effectiveness calculations from the LPM into CAFE model-specific inputs. The 

LPM defines technologies specific to EPA’s OMEGA model so NHTSA had to create a process 

of mapping technologies in the LPM that are consistent with those found in the CAFE model’s 

decision trees. For example, to generate the effectiveness for the Improved Automatic 

Transmission Controls/Externals (IATC) NHTSA had to enable both “Early Upshift” and 

“Aggressive Torque Converter Lockup” in the LPM. NHTSA used this mapping technique to 

calculate the absolute effectiveness of each technology relative to a baseline vehicle. NHTSA 

then used these absolute effectiveness estimates, for each step in the decision trees, to calculate 

the incremental effectiveness estimates for each technology, which is what the CAFE model 

ultimately needs to analyze a heterogeneous fleet baseline fleet on a model year by model year 

basis. 

Table V-17. CAFE Model and LPM Mapping for Engine Technologies 

(non-Valvetrain Dependent Engine Technologies) 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

LUB1 Low Fric Lubes Low Fric Lubes 

EFR1 

Low Fric Lubes 

EF Reduction (Level=1) 

Low Fric Lubes 

EF Reduction (Level=1) 

LUB2_EFR2 EF Reduction (Level=2) 

208 Regardless of a generally consistent set of results for the vehicle class and set of technologies studied, the lumped 

parameter tool is not a full vehicle simulation and cannot replicate the physics of such a simulation. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

252 

Table V-18. CAFE Model and LPM Mapping for Engine Technologies 

(SOHC Path) 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

SOHC Path 

CCPS 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

EF Reduction (Level=2) 

CCP 

DVVLS 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

DVVL

EF Reduction (Level=2) 

CCP 

DVVL 

DEACS 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

DEAC 

EF Reduction (Level=2) 

CCP 

DEAC 

SGDI 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

DEAC 

GDI (stoich) 

EF Reduction (Level=2) 

CCP 

DEAC 

GDI (stoich) 

TRBDS1 

18bar 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DVVL

GDI (stoich) 

Turbo/Downsize (gas engines 

only) (Percent=33%) 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

TRBDS2 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR1 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR2 

27bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=56%) 

Adv Diesel Advanced Diesel (2020) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

253 

Table V-19. CAFE Model and LPM Mapping for Engine Technologies 

(DOHC DVVL Path) 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

DOHC DVVL Path 

ICP 

Low Fric Lubes 

EF Reduction (Level=1) 

ICP 

EF Reduction (Level=2) 

ICP 

DCP 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

EF Reduction (Level=2) 

DCP 

DVVLD 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DVVL

EF Reduction (Level=2) 

DCP 

DVVL 

DEACD 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DEAC 

EF Reduction (Level=2) 

DCP 

DEAC 

SGDI 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DEAC 

GDI (stoich) 

EF Reduction (Level=2) 

DCP 

DEAC 

GDI (stoich) 

TRBDS1 

18bar 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DVVL

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

TRBDS2 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR1 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR2 

27bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=56%) 

Adv Diesel Advanced Diesel (2020) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

254 

Table V-20. CAFE Model and LPM Mapping for Engine Technologies 

(DOHC CVVL Path) 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

DOHC CVVL Path 

CVVL 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

CVVL 

EF Reduction (Level=2) 

DCP 

CVVL 

DEACD This is ignored because effectiveness is less than CVVL 

SGDI 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

CVVL 

GDI (stoich) 

EF Reduction (Level=2) 

DCP 

CVVL 

GDI (stoich) 

TRBDS1 

18bar 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DVVL

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

TRBDS2 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR1 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR2 

27bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=56%) 

Adv Diesel Advanced Diesel (2020) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

255 

Table V-21. CAFE Model and LPM Mapping for Engine Technologies 

(OHV Path) 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

OHV Path 

DEACO 

Low Fric Lubes 

EF Reduction (Level=1) 

DEAC 

EF Reduction (Level=2) 

DEAC 

VVA 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

DEACO

EF Reduction (Level=2) 

CCP 

DEACO 

SGDI 

Low Fric Lubes 

EF Reduction (Level=1) 

CCP 

DEACO

GDI (stoich) 

EF Reduction (Level=2) 

CCP 

DEACO 

GDI (stoich) 

TRBDS1 

18bar 

Low Fric Lubes 

EF Reduction (Level=1) 

DCP

DVVL

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=33%) 

TRBDS2 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR1 

24bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=50%) 

CEGR2 

27bar 

EF Reduction (Level=2) 

DCP 

DVVL 

GDI (stoich) w/ cooled EGR 

Turbo/Downsize (gas engines only) (Percent=56%) 

Adv Diesel Advanced Diesel (2020) 
 

 

 

 

 

 

 

 

 

 

 

 

256 

Table V-22. CAFE Model and LPM Mapping for Transmission Technologies 

NHTSA Techs LPM Selection 

Model Years 2012-2016 2017+ 

IATC Early upshift (formerly ASL) 

Agg TC Lockup 

Early upshift (formerly ASL) 

Agg TC Lockup 

Baseline for the following technologies is 5-speed automatic transmission 

NAUTO 

6-spd gearbox 

Early upshift (formerly ASL) 

Agg TC Lockup 

High efficiency gear box (auto) (Percent= 7%) 

6-spd gearbox 

Early upshift (formerly ASL) 

Agg TC Lockup 

High efficiency gear box (auto) (Percent= 7%) 

DCT (Dry) 

6-spd gearbox 

DCT Dry 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

6-spd gearbox 

DCT Dry 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

DCT (Wet) 

6-spd gearbox 

DCT Wet 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

6-spd gearbox 

DCT Wet 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

8 SPD (Auto) 

8-spd gearbox 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

8 SPD (Dry DCT) 

8-spd gearbox 

DCT Dry 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

8 SPD (Wet DCT) 

8-spd gearbox 

DCT Wet 

Early upshift (formerly ASL) 

High efficiency gear box (auto) (Percent= 7%) 

HETRANS (Additional Selection over previous selection) 

High efficiency gear box (auto) (Percent= 25%) 

SHIFTOPT (Additional Selection over previous selection) 

Optimized shift strategy* 

Notes 

* Make sure "Early upshift (formerly ASL)" is turned off. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

257 

Table V-23. CAFE Model and LPM Mapping for Accessory Technologies 

NHTSA Techs LPM Selection 

EPS EPS 

EPS 

IACC1 Electric access (12v) 

High eff alternator (70%) 

EPS 

IACC2 Electric access (12v) 

High eff alternator (70%) 

Alternator regen on braking 

EPS 

MHEV 

(12v SS) 

Electric access (12v) 

High eff alternator (70%) 

Alternator regen on braking 

12V SS (idle off only) 

EPS 

ISG 6-spd AT 

Electric access (high V) 

Hybrid drivetrain (15 kW motor)a 

a

Motor size is adjusted to 10 kW for small cars and 18 kW 

for pickup trucks 

Table V-24. CAFE Model and LPM Mapping for Strong Hybrid Technologies 

(MY2012-2016 Technologies) 

SHEV1 (non-towing) 

(subcompact PC, compact PC with dry 

DCT) 

SHEV1 (non-towing) 

(midsize PC, large PC, small LT with 

wet DCT) 

SHEV1 (towing)* 

(Midsize LT, Minivan and Large LT with 

ATX) 

% or 

Level 

% or 

Level 

% or 

Level 

Low Fric Lubes Low Fric Lubes Low Fric Lubes 

EF Reduction 1 EF Reduction 1 EF Reduction 1 

DCP DCP DCP 

DVVL DVVL DVVL 

Turbo/Downsize (gas engines 

only) 35% 

6-spd gearbox 6-spd gearbox 6-spd gearbox 

DCT Dry DCT Wet 

Early upshift (formerly 

ASL) 

Early upshift (formerly 

ASL) Early upshift (formerly ASL) 

Agg TC Lockup 

High efficiency gearbox 

(auto) 7% 

High efficiency gearbox 

(auto) 7% High efficiency gearbox (auto) 7% 

EPS EPS EPS 

Electric access (12V) Electric access (12V) Electric access (12V) 

High efficiency alternator 

(70%) 

High efficiency alternator 

(70%) 

High efficiency alternator 

(70%) 

GDI (stoich) GDI (stoich) GDI (stoich) 
 

 

258 

Motor 

kW 

Motor 

kW 

Motor 

kW 

Hybrid drivetrain 17 Hybrid drivetrain 24 Hybrid drivetrain 36 

Atkinson cycle engine Atkinson cycle engine 

Notes 

*Vehicle with towing will have automatic transmission and non-Atkinson cycle engine with downsizing. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

259 

Table V-25. CAFE Model and LPM Mapping for Strong Hybrid Technologies 

(MY2017+ Technologies) 

SHEV2 (non-towing) 

(subcompact PC, compact PC with dry 

DCT) 

SHEV2 (non-towing) 

(midsize PC, large PC, small LT with 

wet DCT) 

SHEV2 (towing)* 

(Midsize LT, Minivan and Large LT with 

ATX) 

% or 

Level 

% or 

Level 

% or 

Level 

EF Reduction 2 EF Reduction 2 EF Reduction 2 

DCP DCP DCP 

DVVL DVVL DVVL 

Turbo/Downsize (gas engines 

only) 48% 

8-spd gearbox 8-spd gearbox 8-spd gearbox 

DCT Dry DCT Wet 

Optimized shift strategy Optimized shift strategy Optimized shift strategy 

Agg TC Lockup 

High efficiency gearbox 

(auto) 25% 

High efficiency gearbox 

(auto) 25% High efficiency gearbox (auto) 25% 

Alternator regen on braking Alternator regen on braking Alternator regen on braking 

EPS EPS EPS 

Electric access (12V) Electric access (12V) Electric access (12V) 

High efficiency alternator 

(70%) 

High efficiency alternator 

(70%) 

High efficiency alternator 

(70%) 

GDI (stoich) GDI (stoich) GDI (stoich) 

Motor 

kW 

Motor 

kW 

Motor 

kW 

Hybrid drivetrain 17 Hybrid drivetrain 24 Hybrid drivetrain 36 

Atkinson cycle engine Atkinson cycle engine 

Notes 

*Vehicle with towing will have automatic transmission and non-Atkinson cycle engine with downsizing. 

Table V-26. CAFE Model and LPM Mapping for Plug-in Hybrid Technologies 

(20-Mile Range) 

PHEV 20 Mile 

(subcompact PC, compact PC with dry DCT) 

PHEV 20 Mile 

(midsize PC, large PC, small LT with wet DCT) 

% or Level % or Level 

EF Reduction 2 EF Reduction 2 

DCP DCP 

DVVL DVVL 

8-spd gearbox 8-spd gearbox 

DCT Dry DCT Wet 

Optimized shift strategy Optimized shift strategy 

High efficiency gearbox (auto) 25% High efficiency gearbox (auto) 25% 

Alternator regen on braking Alternator regen on braking 

EPS 100% EPS 100% 

Electric access (12V) Electric access (12V) 

High efficiency alternator (70%) High efficiency alternator (70%) 

GDI (stoich) GDI (stoich) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

260 

Motor kW Motor kW 

Hybrid drivetrain 30 Hybrid drivetrain 30 

Atkinson cycle engine Atkinson cycle engine 

Plug-In 40% Plug-In 40% 

Table V-27. CAFE Model and LPM Mapping for Plug-in Hybrid Technologies 

(40-Mile Range) 

PHEV 40 Mile 

(subcompact PC, compact PC with dry DCT) 

PHEV 40 Mile 

(midsize PC, large PC, small LT with wet DCT) 

% or Level % or Level 

EF Reduction 2 EF Reduction 2 

DCP DCP 

DVVL DVVL 

8-spd gearbox 8-spd gearbox 

DCT Dry DCT Wet 

Optimized shift strategy Optimized shift strategy 

High efficiency gearbox (auto) 25% High efficiency gearbox (auto) 25% 

Alternator regen on braking Alternator regen on braking 

EPS 100% EPS 100% 

Electric access (12V) Electric access (12V) 

High efficiency alternator (70%) High efficiency alternator (70%) 

GDI (stoich) GDI (stoich) 

Motor kW Motor kW 

Hybrid drivetrain 30 Hybrid drivetrain 30 

Atkinson cycle engine Atkinson cycle engine 

Plug-In 63% Plug-In 63% 

We note that the U.S. D.O.T. Volpe Center, which supports NHTSA in its CAFE rulemaking 

work, contracted with Argonne National Laboratory (ANL) to provide full vehicle simulation 

modeling support for this MYs 2017-2025 rulemaking. While modeling was not completed in 

time for use in the NPRM, NHTSA used this modeling to update technology effectiveness 

estimates and synergy factors as appropriate for the CAFE model for the final rulemaking 

analysis. Specifically, the results were used to define the effectiveness of mild hybrids for both 

agencies, and NHTSA used the results to update the effectiveness of advanced transmission 

technologies coupled with naturally-aspirated engines for the CAFE analysis This simulation 

modeling was accomplished using ANL’s full vehicle simulation tool called “Autonomie,” 

which is the successor to ANL’s Powertrain System Analysis Toolkit (PSAT) simulation tool, 

and that includes sophisticated models for advanced vehicle technologies. The ANL simulation 

modeling process and results are documented in multiple reports that can be found in NHTSA’s 

docket.209 

209 Docket No: NHTSA-2010-0131 
261 

ANL modeled the results for five vehicle classes. In order to incorporate ANL’s results into the 

CAFE model, these 5 vehicles classes needed to be mapped to the CAFE model’s 12 vehicle 

classes. Table V-28describes the mapping of ANL’s 5 vehicle classes to NHTSA’s 12 vehicle 

classes. 

Table V-28. Mapping between ANL and NHTSA Vehicle Classifications 

ANL Vehicle Classification NHTSA/CAFE Model Vehicle Classification 

Compact Car 

Subcompact PC 

Subcompact Perf. PC 

Compact PC 

Compact Perf. PC 

Midsize Car 

Midsize PC 

Midsize Perf. PC 

Large PC 

Large Perf. PC 

Small SUV Small LT 

Midsize SUV Minivan LT 

Midsize LT 

Pickup Large LT 

Table V-29(a) and (b) show the ANL results for advanced transmission technologies when 

coupled to naturally aspirated engines. As discussed in greater detail below in the synergies 

section, these results were used to adjust the effectiveness of advanced transmission technologies 

when coupled to naturally aspirated engines. 
 

262 

Table V-29a. ANL Results for Transmission Technologies 

Compact Midsize Car Small SUV

INC % 0.9% $ 

% 0.9% $ 

Imp. Auto Trans Cnrt./ 

Externals (IATC) - TBL 

% 0.9% $ 

% 0.9% $ 

INC % 1.4% $ 

% 1.4% $ 

 Imp. Auto Trans Cnrt./ 

Externals (IATC) - TBL 

% 1.4% $ 

% 1.4% $ 

 2012- 2012- 2012- INC 

2016 ABS 2016 ABS 2016 ABS 

INC INC INC 2017+ 2017+ 2017+ ABS ABS ABS 

INC % 2.0% $ 

% 2.9% $ 

 6-spd Auto Trans w/Imp 

Internals (NAUTO) - TBL 

% 2.0% $ 

% 2.9% $ 

INC % 0.8% $ 

% 2.2% $ 

6-spd Auto Trans w/Imp 

Internals (NAUTO) - TBL

% 0.8% $ 

% 2.2% $ 

 2012- 2012- 2012- INC 

2016 ABS 2016 ABS 2016 ABS 

INC INC INC 2017+ 2017+ 2017+ ABS ABS ABS 

INC % 3.9% $ 

% 6.7% $ 

6-spd Dual Clutch Trans 

(DCT) - TBL

% 3.9% $ 

% 6.7% $ 

INC % 3.7% $ 

% 5.8% $ 

 6-spd Dual Clutch Trans 

(DCT) - TBL

% 3.7% $ 

% 5.8% $ 

 2012- 2012- 2012- INC 

2016 ABS 2016 ABS 2016 ABS 

INC INC INC 2017+ 2017+ 2017+ ABS ABS ABS 

INC % 1.9% $ 

% 8.4% $ 

 8-spd Trans (DCT) 

(8SPD) - TBL 

% 1.9% $ 

% 8.4% $ 

INC % 2.1% $ 

% 7.8% $ 

 8-spd Trans (DCT) 

(8SPD) - TBL

% 2.1% $ 

% 7.8% $ 

INC 2012- 2012- 2012-

2016 ABS 2016 ABS 2016 ABS 

INC INC INC 2017+ 2017+ 2017+ ABS ABS ABS 

INC % 2.7% $ 

% 11.0% $ 

High Eff. Gearbox (+4%) 

(DCT) 

% 2.7% $ 

% 11.0% $ 

INC % 2.8% $ 

% 10.3% $ 

High Eff. Gearbox (+4%) 

(DCT)

% 2.8% $ 

% 10.3% $ 

 2012- 2012- 2012- INC 

2016 ABS 2016 ABS 2016 ABS 

INC INC INC 2017+ 2017+ 2017+ ABS ABS ABS 

% 1.1% $ 

% 1.1% $ 

Imp. Auto Trans Cnrt./ 

Externals (IATC) - TBL 

% 1.1% $ 

% 1.1% $ 

% 1.2% $ 

% 2.2% $ 

 6-spd Auto Trans w/Imp 

Internals (NAUTO) - TBL 

% 1.2% $ 

% 2.2% $ 

% 2.2% $ 

% 4.3% $ 

 6-spd Dual Clutch Trans 

(DCT) - TBL 

% 2.2% $ 

% 4.3% $ 

% 1.5% $ 

% 5.8% $ 

 8-spd Trans (DCT) 

(8SPD) - TBL 

% 1.5% $ 

% 5.8% $ 

% 2.8% $ 

% 8.5% $ 

High Eff. Gearbox (+4%) 

(DCT) 

% 2.8% $ 

% 8.5% $
                                                      

 

263 

Table V-29Table V-29b. ANL Results for Transmission Technologies 

 2012-

2016 

 2017+

 2012-

2016 

 2017+

 2012-

2016 

 2017+

 2012-

2016 

 2017+ 

Synergies 

Midsize SUV

INC
 

ABS
 

INC
 

ABS
 

% 1.4% $ 

% 1.4% $ 

 Imp. Auto Trans Cnrt./ 

Externals (IATC) - TBL

% 1.4% $ 

% 1.4% $ 

INC
 

ABS
 

INC
 

ABS
 

% 0.7% $ 

% 2.1% $ 

 6-spd Auto Trans w/Imp 

Internals (NAUTO) - TBL

% 0.7% $ 

% 2.1% $ 

INC
 

ABS
 

INC
 

ABS
 

% 1.0% $ 

% 3.1% $ 

 8-spd Auto Trans (Auto) 

(8SPD) - TBL

% 1.0% $ 

% 3.1% $ 

INC
 

ABS
 

INC
 

ABS
 

% 2.5% $ 

% 5.5% $ 

High Eff. Gearbox (+4%) 

(Auto) - (HETRANS) TBL

% 2.5% $ 

% 5.5% $ 

2012-

2016 

2017+ 

2012-

2016 

2017+

 2012-

2016 

2017+

 2012-

2016 

2017+

Pickup

INC
 

ABS
 

INC
 

ABS
 

% 1.6% $ 

% 1.6% $ 

 Imp. Auto Trans Cnrt./ 

Externals (IATC) - TBL 

% 1.6% $ 

% 1.6% $ 

INC
 

ABS
 

INC
 

ABS
 

% 0.4% $ 

% 2.1% $ 

 6-spd Auto Trans w/Imp 

Internals (NAUTO) - TBL 

% 0.4% $ 

% 2.1% $ 

INC
 

ABS
 

INC
 

ABS
 

% 1.5% $ 

% 3.5% $ 

 8-spd Auto Trans (Auto) 

(8SPD) - TBL 

% 1.5% $ 

% 3.5% $ 

INC
 

ABS
 

INC
 

ABS
 

% 2.9% $ 

% 6.3% $ 

High Eff. Gearbox (+4%) 

(Auto) - (HETRANS) TBL 

% 2.9% $ 

% 6.3% $ 

When two or more technologies are added to a particular vehicle model to improve its fuel 

efficiency, the resultant fuel consumption reduction may sometimes be higher or lower than the 

product of the individual effectiveness values for those items.210 This may occur because one or 

210 More specifically, the resultant is calculated as the products of the differences between the numeric value one 

(i.e., 1.0) and the technology-specific levels of effectiveness in reducing fuel consumption (expressed as a numeric 

value also, i.e., 10% = 0.10). For example, not accounting for interactions, if technologies A and B are estimated to 

reduce fuel consumption by 10% (i.e., 0.1) and 20% (i.e., 0.2) respectively, the “product of the individual 

effectiveness values” would be (1 – 0.1) times (1 – 0.2), or 0.9 times 0.8, which equals 0.72, corresponding to a 
                                                                                                                                                                              

 

264 

more technologies applied to the same vehicle partially address the same source (or sources) of 

engine, drivetrain or vehicle losses. Alternately, this effect may be seen when one technology 

shifts the engine operating points, and therefore increases or reduces the fuel consumption 

reduction achieved by another technology or set of technologies. The difference between the 

observed fuel consumption reduction associated with a set of technologies and the product of the 

individual effectiveness values in that set is referred to as a “synergy.” Synergies may be 

positive (and thus result in greater fuel consumption reduction compared to the product of the 

individual effects) or negative (and thus result in less fuel consumption reduction). An example 

of a positive synergy might be a vehicle technology that reduces road loads at highway speeds 

(e.g., lower aerodynamic drag or low rolling resistance tires), that could effectively extend the 

vehicle operating range over which cylinder deactivation may be employed, thus allowing a 

greater fuel consumption reduction than anticipated or predicted by analysis. An example of a 

negative synergy might be a variable valvetrain technology, which reduces pumping losses by 

altering the profile of the engine speed/load map, and a six-speed automatic transmission, which 

shifts the engine operating points to a portion of the engine speed/load map where pumping 

losses are less significant, leaving less opportunity for the combined technologies to decrease 

fuel consumption. As the complexity of the technology combinations is increased, and the 

number of interacting technologies grows accordingly, it becomes increasingly important to 

account for these synergies. 

Because NHTSA applies technologies individually in its modeling analysis, NHTSA 

incorporates synergistic effects between pairings of individual technologies. The use of discrete 

technology pair incremental synergies is similar to that in DOE’s National Energy Modeling 

System (NEMS).211 Inputs to the CAFE model incorporate NEMS-identified pairs, as well as 

additional pairs from the specific set of technologies considered in the CAFE model. For the 

MYs 2012-2016 final rule and the MY 2011 final rule NHTSA used a modified version of the 

lumped parameter tool to evaluate accurate synergy values. During the 2011 final rule analysis, 

with the assistance of Ricardo, NHTSA modified the lumped parameter tool by updating the list 

of technologies and their associated effectiveness values, and expanding the list of synergy 

pairings based on further consideration of the technologies for which a competition for losses 

would be expected, for the purposes of evaluating appropriate synergy values. For this final rule, 

NHTSA used the version of the lumped parameter model as recently updated by EPA, as 

discussed above, to evaluate appropriate synergy values. 

combined effectiveness of (1 - .72 = .28) or 28% rather than the 30% obtained by adding 10% to 20%. The 

“synergy factors” discussed in this section further adjust these multiplicatively combined effectiveness values. 211 U.S. Department of Energy, Energy Information Administration, Transportation Sector Module of the National 

Energy Modeling System: Model Documentation 2009, June 2009, Washington, DC, DOE/EIAM070(2009), at 26­

27. Available at ftp://ftp.eia.doe.gov/modeldoc/m070(2009).pdf (last accessed Nov. 7, 2011). 
265 

As was done for the individual technology effectiveness estimates, NHTSA used the 6 unique 

vehicle classes in the lumped parameter tool to evaluate the synergies for each if the 12 vehicle 

subclasses. NHTSA systematically and thoroughly “walked” through the CAFE model’s 

application of individual technologies, via the decision trees, to evaluate the synergies between 

pairs of technologies. Once the synergies for a vast majority of the technology pairs were 

generated, NHTSA iteratively evaluated hundreds of technology combinations, and all the steps 

that build up to the different combinations, to ensure that these combinations of technologies 

with their individual effectiveness estimates and corresponding synergy values resulted in overall 

fuel consumptions reductions that closely aligned with the overall fuel consumption reductions 

that were predicted by the lumped parameter tool. Basically, the lumped parameter tool was 

used to calibrate the synergy values to make sure the overall fuel consumptions reductions for 

the various combinations of technologies closely align with those predicted by the lumped 

parameter tool. The agency paid special attention to technology combinations that the model 

most often tends to form dynamically. This iterative process was conducted for each of the 6 

vehicle classes, utilized by the lumped parameter tool, to develop vehicle class specific synergy 

factors. While the evaluation of technology combinations was not exhaustive, NHTSA believes 

that the hundreds of combinations evaluated were more than adequate to ensure accurate results, 

which replicate the results from the lumped parameter tool. 

NHTSA notes that synergies that occur within a particular decision tree are already accounted for 

within the incremental effectiveness values assigned for each technology, and therefore 

additional synergy pairs for these technologies are not required. For example, all engine 

technologies take into account the synergies that occur with the preceding/existing engine 

technologies, and all transmission technologies take into account synergies of preceding 

transmission technologies, etc. These synergy factors are accounted for in the fuel consumption 

improvement estimates in the input files used by the CAFE model. 

For applying incremental synergy factors in separate path technologies, i.e., between two or 

more decision trees, the CAFE model uses an input table (see Table V-30a-f) that lists 

technology pairings and incremental synergy factors associated with those pairings (most of 

which are between engine technologies and transmission/ electrification/hybrid technologies). 

When a technology is applied to a vehicle by the CAFE model, all instances of that technology in 

the incremental synergy table which match technologies already applied to the vehicle (either 

pre-existing or previously applied by the CAFE model) are summed and applied to the fuel 

consumption improvement factor of the technology being applied. Synergies between the strong 

and plug-in hybrid technologies and transmission and electrification technologies are included in 

the incremental value for the specific hybrid or plug-in hybrid technology because the model 

applies technologies in the order of the most effectiveness for least cost and also applies all 

available electrification and transmission technologies before applying strong and plug-in hybrid 

technologies. 
 

266 

As discussed above, NHTSA, based on the simulation work performed by ANL has updated the 

effectiveness estimates for advanced transmission technologies when coupled to naturally 

aspirated engines for this final rule. The effectiveness estimates for advanced transmission 

technologies coupled with turbocharged and downsized engines, with and without CEGR, are 

still based on the Ricardo simulation work, consistent with the proposal. Because the 

effectiveness estimates for transmission technologies can only be input as a single value, 

NHTSA used the synergy factors to adjust the effectiveness estimates of advanced transmission 

technologies when coupled to naturally aspirated engines (i.e., engine technologies prior to 

TRBDS1). The transmission effectiveness estimates found in the technology input file, as was 

the case in the NPRM, are still based on the Ricardo simulation work. In the case of an 

advanced transmission technology being applied to a naturally aspirated engine the model 

applies the effectiveness estimates found in the technology input file and then applies these 

newly added synergies to adjust the effectiveness estimate to be in line with the ANL simulation 

results. Once the turbocharging and downsizing technology, TRBDS1, is applied to a vehicle the 

model applies synergies that are the additive inverse of these newly added synergies to adjust the 

effectiveness to be back in line with the transmission effectiveness estimates found in the 

technology input file. As can be seen below, these new synergies and their inverses were added 

to the end of the synergy tables and start at the IATC to CCPS pairing. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

267 

Table V-30a Synergy pairings and values 

Fuel Consumption Improvement Synergy values by Vehicle Class 

Positive values are [positive] synergies, negative values are dissynergies. Blank cells are 

assumed to be zero. 

Technology A Technology B 

Subcompact 

PC 

Subcompact 

Perf. PC 

Compact 

PC 

Compact 

Perf. PC 

Midsize 

PC 

Midsize 

Perf. PC 

DCP SHFTOPT -0.60% -0.60% -0.60% -0.60% -0.60% -0.60% 

DCP IACC1 -0.20% -0.20% -0.20% -0.20% -0.40% -0.40% 

DCP IACC2 -0.40% -0.40% -0.40% -0.40% -0.80% -0.80% 

CCPS SHFTOPT -0.60% -0.60% -0.60% -0.60% -0.60% -0.60% 

CCPS IACC1 -0.20% -0.20% -0.20% -0.20% -0.40% -0.40% 

CCPS IACC2 -0.40% -0.40% -0.40% -0.40% -0.80% -0.80% 

DVVLS IATC -0.40% -0.40% -0.40% -0.40% -0.60% -0.60% 

DVVLS MHEV -0.50% -0.50% -0.50% -0.50% -0.30% -0.30% 

DVVLS IACC2 -0.80% -0.80% -0.80% -0.80% -0.80% -0.80% 

DVVLS 8SPD -0.70% -0.70% -0.70% -0.70% -0.70% -0.70% 

DEACS IATC 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

DVVLD IATC -0.40% -0.40% -0.40% -0.40% -0.60% -0.60% 

DVVLD MHEV -0.50% -0.50% -0.50% -0.50% -0.30% -0.30% 

DVVLD IACC2 -0.80% -0.80% -0.80% -0.80% -0.80% -0.80% 

DVVLD 8SPD -0.70% -0.70% -0.70% -0.70% -0.70% -0.70% 

CVVL IATC -0.40% -0.40% -0.40% -0.40% -0.60% -0.60% 

CVVL MHEV -0.50% -0.50% -0.50% -0.50% -0.30% -0.30% 

CVVL IACC2 -0.80% -0.80% -0.80% -0.80% -0.80% -0.80% 

CVVL 8SPD -0.70% -0.70% -0.70% -0.70% -0.70% -0.70% 

DEACD IATC -0.40% -0.40% -0.40% -0.40% -0.40% -0.40% 

DEACO IATC 0.00% 0.00% 0.00% 0.00% -0.60% -0.60% 

DEACO MHEV -0.50% -0.50% -0.50% -0.50% -0.30% -0.30% 

DEACO IACC1 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

DEACO IACC2 -0.80% -0.80% -0.80% -0.80% -0.80% -0.80% 

DEACO 8SPD -0.70% -0.70% -0.70% -0.70% -0.70% -0.70% 

VVA IATC -0.40% -0.40% -0.40% -0.40% -0.40% -0.40% 

VVA SHFTOPT -0.60% -0.60% -0.60% -0.60% -0.60% -0.60% 

VVA IACC1 -0.20% -0.20% -0.20% -0.20% -0.40% -0.40% 

VVA IACC2 -0.40% -0.40% -0.40% -0.40% -0.80% -0.80% 

TRBDS1_SD IATC -0.50% -0.50% -0.50% -0.50% -0.80% -0.80% 

TRBDS1_MD IATC -0.50% -0.50% -0.50% -0.50% -0.80% -0.80% 

TRBDS1_LD IATC -0.50% -0.50% -0.50% -0.50% -0.80% -0.80% 

TRBDS1_SD SHFTOPT -0.20% -0.20% -0.20% -0.20% -0.70% -0.70% 

TRBDS1_MD SHFTOPT -0.20% -0.20% -0.20% -0.20% -0.70% -0.70% 

TRBDS1_LD SHFTOPT -0.20% -0.20% -0.20% -0.20% -0.70% -0.70% 

TRBDS1_SD 8SPD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_MD 8SPD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_LD 8SPD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_SD MHEV 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_MD MHEV 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_LD MHEV 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_SD IACC2 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_MD IACC2 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS1_LD IACC2 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

TRBDS2_SD NAUTO -0.50% -0.50% -0.50% -0.50% -1.20% -1.20% 
TRBDS2_MD NAUTO -0.50% -0.50% -0.50% -0.50% -1.20% -1.20% 

268 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

269 

Table V-30b Synergy pairings and values 

Technology A Technology B 

Subcompact 

PC 

Subcompact 

Perf. PC 

Compact 

PC 

Compact 

Perf. PC 

Midsize 

PC 

Midsize 

Perf. PC 

TRBDS2_LD NAUTO -0.50% -0.50% -0.50% -0.50% -1.20% -1.20% 

TRBDS2_SD EPS -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

TRBDS2_MD EPS -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

TRBDS2_LD EPS -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

TRBDS2_SD IACC2 -0.10% -0.10% -0.10% -0.10% 0.00% 0.00% 

TRBDS2_MD IACC2 -0.10% -0.10% -0.10% -0.10% 0.00% 0.00% 

TRBDS2_LD IACC2 -0.10% -0.10% -0.10% -0.10% 0.00% 0.00% 

CEGR1_SD IACC2 -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

CEGR1_MD IACC2 -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

CEGR1_LD IACC2 -0.20% -0.20% -0.20% -0.20% 0.00% 0.00% 

CEGR2_SD NAUTO -0.60% -0.60% -0.60% -0.60% -0.80% -0.80% 

CEGR2_MD NAUTO -0.60% -0.60% -0.60% -0.60% -0.80% -0.80% 

CEGR2_LD NAUTO -0.60% -0.60% -0.60% -0.60% -0.80% -0.80% 

DCT MHEV -0.30% -0.30% -0.30% -0.30% -0.30% -0.30% 

SHFTOPT MHEV -0.30% -0.30% -0.30% -0.30% -0.30% -0.30% 

ROLL1 AERO1 0.20% 0.20% 0.20% 0.20% 0.20% 0.20% 

ROLL2 AERO2 0.10% 0.10% 0.10% 0.10% 0.10% 0.10% 

MR1 VVA 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR1 DCP 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR1 CCPS 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR2 ROLL1 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR4 TRBDS1_SD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR4 TRBDS1_MD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR4 TRBDS1_LD 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

MR4 AERO2 0.40% 0.40% 0.40% 0.40% 0.40% 0.40% 

MR5 ROLL1 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 

ADSL_SD IATC 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 

ADSL_MD IATC 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 

ADSL_LD IATC 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 

NAUTO SAX -0.40% -0.40% -0.40% -0.40% -0.40% -0.40% 

SHEV1 AERO2 1.0% 1.0% 1.0% 1.0% 1.4% 1.4% 

SHEV1 ROLL1 0.7% 0.7% 0.7% 0.7% 0.8% 0.8% 

SHEV1 MR2 -0.5% -0.5% -0.5% -0.5% -0.4% -0.4% 

SHEV1 MR3 -0.2% -0.2% -0.2% -0.2% -0.1% -0.1% 

SHEV1 MR4 -0.3% -0.3% -0.3% -0.3% -0.2% -0.2% 

SHEV1 MR5 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

SHEV1_2 AERO2 0.2% 0.2% 0.2% 0.2% -0.1% -0.1% 

SHEV1_2 ROLL2 0.3% 0.3% 0.3% 0.3% 0.3% 0.3% 

SHEV1_2 MR2 0.1% 0.1% 0.1% 0.1% -0.1% -0.1% 

SHEV1_2 MR3 0.0% 0.0% 0.0% 0.0% -0.2% -0.2% 

SHEV1_2 MR4 0.0% 0.0% 0.0% 0.0% -0.2% -0.2% 

SHEV1_2 MR5 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

SHEV2 AERO2 1.2% 1.2% 1.2% 1.2% 1.3% 1.3% 

SHEV2 ROLL2 1.0% 1.0% 1.0% 1.0% 1.1% 1.1% 

SHEV2 MR2 -0.4% -0.4% -0.4% -0.4% -0.5% -0.5% 

SHEV2 MR3 -0.2% -0.2% -0.2% -0.2% -0.3% -0.3% 

SHEV2 MR4 -0.3% -0.3% -0.3% -0.3% -0.4% -0.4% 

SHEV2 MR5 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

PHEV1 AERO2 0.1% 0.1% 0.1% 0.1% 0.0% 0.0% 
PHEV1 ROLL2 0.4% 0.4% 0.4% 0.4% 0.4% 0.4%

270 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

271 

Table V-30c Synergy pairings and values 

Technology A Technology B 

Subcompact 

PC 

Subcompact 

Perf. PC 

Compact 

PC 

Compact 

Perf. PC 

Midsize 

PC 

Midsize 

Perf. PC 

IATC CCPS -1.40% -1.40% -1.40% -1.40% -1.60% -1.60% 

IATC ICP -1.40% -1.40% -1.40% -1.40% -1.60% -1.60% 

IATC DEACO -1.40% -1.40% -1.40% -1.40% -1.60% -1.60% 

NAUTO CCPS 0.00% 0.00% 0.00% 0.00% -1.20% -1.20% 

NAUTO ICP 0.00% 0.00% 0.00% 0.00% -1.20% -1.20% 

NAUTO DEACO 0.00% 0.00% 0.00% 0.00% -1.20% -1.20% 

DCT CCPS 0.00% 0.00% 0.00% 0.00% -0.40% -0.40% 

DCT ICP 0.00% 0.00% 0.00% 0.00% -0.40% -0.40% 

DCT DEACO 0.00% 0.00% 0.00% 0.00% -0.40% -0.40% 

8SPD CCPS -1.90% -1.90% -1.90% -1.90% -2.50% -2.50% 

8SPD ICP -1.90% -1.90% -1.90% -1.90% -2.50% -2.50% 

8SPD DEACO -1.90% -1.90% -1.90% -1.90% -2.50% -2.50% 

HETRANS CCPS 0.50% 0.50% 0.50% 0.50% 0.00% 0.00% 

HETRANS ICP 0.50% 0.50% 0.50% 0.50% 0.00% 0.00% 

HETRANS DEACO 0.50% 0.50% 0.50% 0.50% 0.00% 0.00% 

IATC TRBDS1_SD 1.40% 1.40% 1.40% 1.40% 1.60% 1.60% 

IATC TRBDS1_MD 1.40% 1.40% 1.40% 1.40% 1.60% 1.60% 

IATC TRBDS1_LD 1.40% 1.40% 1.40% 1.40% 1.60% 1.60% 

NAUTO TRBDS1_SD 0.00% 0.00% 0.00% 0.00% 1.20% 1.20% 

NAUTO TRBDS1_MD 0.00% 0.00% 0.00% 0.00% 1.20% 1.20% 

NAUTO TRBDS1_LD 0.00% 0.00% 0.00% 0.00% 1.20% 1.20% 

DCT TRBDS1_SD 0.00% 0.00% 0.00% 0.00% 0.40% 0.40% 

DCT TRBDS1_MD 0.00% 0.00% 0.00% 0.00% 0.40% 0.40% 

DCT TRBDS1_LD 0.00% 0.00% 0.00% 0.00% 0.40% 0.40% 

8SPD TRBDS1_SD 1.90% 1.90% 1.90% 1.90% 2.50% 2.50% 

8SPD TRBDS1_MD 1.90% 1.90% 1.90% 1.90% 2.50% 2.50% 

8SPD TRBDS1_LD 1.9% 1.9% 1.9% 1.9% 2.5% 2.5% 

HETRANS TRBDS1_SD -0.5% -0.5% -0.5% -0.5% 0.0% 0.0% 

HETRANS TRBDS1_MD -0.5% -0.5% -0.5% -0.5% 0.0% 0.0% 

HETRANS TRBDS1_LD -0.50% -0.50% -0.50% -0.50% 0.00% 0.00% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

272 

Table V-30d Synergy pairings and values 

Technology A Technology B Large PC Large Perf. PC Minivan LT Small LT Midsize LT Large LT 

DCP SHFTOPT -0.80% -0.80% -0.8% -0.6% -0.8% -0.7% 

DCP IACC1 -0.40% -0.40% -0.1% -0.3% -0.1% -0.4% 

DCP IACC2 -0.80% -0.80% -0.6% -0.5% -0.6% -0.6% 

CCPS SHFTOPT -0.80% -0.80% -0.8% -0.6% -0.8% -0.7% 

CCPS IACC1 -0.40% -0.40% -0.1% -0.3% -0.1% -0.4% 

CCPS IACC2 -0.80% -0.80% -0.6% -0.5% -0.6% -0.6% 

DVVLS IATC -0.80% -0.80% -0.7% -0.5% -0.7% -0.5% 

DVVLS MHEV -0.40% -0.40% -0.4% -0.2% -0.4% -0.7% 

DVVLS IACC2 -0.90% -0.90% -0.7% -0.6% -0.7% -0.8% 

DVVLS 8SPD -0.80% -0.80% -0.8% -0.6% -0.8% -0.6% 

DEACS IATC 0.0% 0.0% 0.0% 0.0% 0.0% -0.1% 

DVVLD IATC -0.70% -0.70% -0.5% -0.5% -0.5% -0.6% 

DVVLD MHEV -0.40% -0.40% -0.4% -0.2% -0.4% -0.7% 

DVVLD IACC2 -0.90% -0.90% -0.7% -0.6% -0.7% -0.8% 

DVVLD 8SPD -0.80% -0.80% -0.8% -0.6% -0.8% -0.6% 

CVVL IATC -0.70% -0.70% -0.5% -0.5% -0.5% -0.6% 

CVVL MHEV -0.40% -0.40% -0.4% -0.2% -0.4% -0.7% 

CVVL IACC2 -0.90% -0.90% -0.7% -0.6% -0.7% -0.8% 

CVVL 8SPD -0.80% -0.80% -0.8% -0.6% -0.8% -0.6% 

DEACD IATC -0.10% -0.10% -0.2% -0.3% -0.2% -0.1% 

DEACO IATC -0.10% -0.10% -0.6% -0.1% -0.6% -0.1% 

DEACO MHEV -0.40% -0.40% -0.4% -0.2% -0.4% -0.7% 

DEACO IACC1 0.0% 0.0% -0.5% 0.0% -0.5% 0.0% 

DEACO IACC2 -0.90% -0.90% -1.0% -0.6% -1.0% -0.8% 

DEACO 8SPD -0.80% -0.80% -0.8% -0.6% -0.8% -0.6% 

VVA IATC -0.70% -0.70% -0.6% -0.4% -0.6% -0.6% 

VVA SHFTOPT -0.80% -0.80% -0.8% -0.6% -0.8% -0.7% 

VVA IACC1 -0.40% -0.40% -0.1% -0.3% -0.1% -0.4% 

VVA IACC2 -0.80% -0.80% -1.0% -0.5% -1.0% -0.6% 

TRBDS1_SD IATC -0.50% -0.50% -0.5% -0.5% -0.5% -0.5% 

TRBDS1_MD IATC -0.50% -0.50% -0.5% -0.5% -0.5% -0.5% 

TRBDS1_LD IATC -0.50% -0.50% -0.5% -0.5% -0.5% -0.5% 

TRBDS1_SD SHFTOPT -0.10% -0.10% -0.3% -0.3% -0.3% -0.3% 

TRBDS1_MD SHFTOPT -0.10% -0.10% -0.3% -0.3% -0.3% -0.3% 

TRBDS1_LD SHFTOPT -0.10% -0.10% -0.3% -0.3% -0.3% -0.3% 

TRBDS1_SD 8SPD -0.40% -0.40% -0.4% -0.4% -0.4% -0.4% 

TRBDS1_MD 8SPD -0.40% -0.40% -0.4% -0.4% -0.4% -0.4% 

TRBDS1_LD 8SPD -0.40% -0.40% -0.4% -0.4% -0.4% -0.4% 

TRBDS1_SD MHEV -0.60% -0.60% -0.2% -0.1% -0.2% -0.6% 

TRBDS1_MD MHEV -0.60% -0.60% -0.2% -0.1% -0.2% -0.6% 

TRBDS1_LD MHEV -0.60% -0.60% -0.2% -0.1% -0.2% -0.6% 

TRBDS1_SD IACC2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

TRBDS1_MD IACC2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

TRBDS1_LD IACC2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

TRBDS2_SD NAUTO -0.50% -0.50% -0.5% -0.2% -0.5% -0.5% 

TRBDS2_MD NAUTO -0.50% -0.50% -0.5% -0.2% -0.5% -0.5% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

273 

Table V-30e Synergy pairings and values 

Technology A Technology B Large PC Large Perf. PC Minivan LT Small LT Midsize LT Large LT 

TRBDS2_LD NAUTO -0.50% -0.50% -0.5% -0.2% -0.5% -0.5% 

TRBDS2_SD EPS -0.30% -0.30% -0.3% -0.3% -0.3% -0.3% 

TRBDS2_MD EPS -0.30% -0.30% -0.3% -0.3% -0.3% -0.3% 

TRBDS2_LD EPS -0.30% -0.30% -0.3% -0.3% -0.3% -0.3% 

TRBDS2_SD IACC2 -0.50% -0.50% -0.3% -0.3% -0.3% -0.3% 

TRBDS2_MD IACC2 -0.50% -0.50% -0.3% -0.3% -0.3% -0.3% 

TRBDS2_LD IACC2 -0.50% -0.50% -0.3% -0.3% -0.3% -0.3% 

CEGR1_SD IACC2 -0.20% -0.20% 0.0% 0.0% 0.0% 0.0% 

CEGR1_MD IACC2 -0.20% -0.20% 0.0% 0.0% 0.0% 0.0% 

CEGR1_LD IACC2 -0.20% -0.20% 0.0% 0.0% 0.0% 0.0% 

CEGR2_SD NAUTO -0.60% -0.60% -0.8% -0.6% -0.8% -0.8% 

CEGR2_MD NAUTO -0.60% -0.60% -0.8% -0.6% -0.8% -0.8% 

CEGR2_LD NAUTO -0.60% -0.60% -0.8% -0.6% -0.8% -0.8% 

DCT MHEV -0.30% -0.30% 0.0% -0.3% 0.0% 0.0% 

SHFTOPT MHEV -0.30% -0.30% -0.3% -0.3% -0.3% -0.3% 

ROLL1 AERO1 0.20% 0.20% 0.2% 0.2% 0.2% 0.1% 

ROLL2 AERO2 0.10% 0.10% 0.3% 0.2% 0.3% 0.2% 

MR1 VVA 0.20% 0.20% -0.1% 0.0% -0.1% 0.4% 

MR1 DCP 0.20% 0.20% -0.1% 0.0% -0.1% 0.4% 

MR1 CCPS 0.20% 0.20% -0.1% 0.0% -0.1% 0.4% 

MR2 ROLL1 0.0% 0.0% 0.0% 0.1% 0.0% -0.1% 

MR4 TRBDS1_SD 0.0% 0.0% 0.3% 0.3% 0.3% 0.6% 

MR4 TRBDS1_MD 0.0% 0.0% 0.3% 0.3% 0.3% 0.6% 

MR4 TRBDS1_LD 0.0% 0.0% 0.3% 0.3% 0.3% 0.6% 

MR4 AERO2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

MR5 ROLL1 0.0% 0.0% 0.4% 0.5% 0.4% 0.4% 

ADSL_SD IATC 1.2% 1.2% 0.8% 1.0% 0.8% 1.0% 

ADSL_MD IATC 1.2% 1.2% 0.8% 1.0% 0.8% 1.0% 

ADSL_LD IATC 1.2% 1.2% 0.8% 1.0% 0.8% 1.0% 

NAUTO SAX -0.40% -0.40% -0.40% -0.40% -0.40% -0.40% 

SHEV1 AERO2 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 

SHEV1 ROLL1 0.8% 0.8% 0.9% 0.8% 0.9% 1.1% 

SHEV1 MR2 -0.4% -0.4% -0.4% -0.4% -0.4% -0.4% 

SHEV1 MR3 -0.2% -0.2% -0.1% -0.2% -0.1% -0.1% 

SHEV1 MR4 -0.2% -0.2% -0.2% -0.1% -0.2% -0.2% 

SHEV1 MR5 0.0% 0.0% -0.2% -0.2% -0.2% -0.2% 

SHEV1_2 AERO2 0.0% 0.0% -0.1% 0.0% -0.1% -0.1% 

SHEV1_2 ROLL2 0.9% 0.9% 0.7% 0.80% 0.7% 0.7% 

SHEV1_2 MR2 0.0% 0.0% 0.2% 0.0% 0.2% 0.0% 

SHEV1_2 MR3 -0.1% -0.1% -0.1% 0.0% -0.1% -0.1% 

SHEV1_2 MR4 -0.1% -0.1% -0.1% -0.2% -0.1% 0.0% 

SHEV1_2 MR5 0.0% 0.0% -0.1% -0.1% -0.1% 0.0% 

SHEV2 AERO2 1.4% 1.4% 1.3% 1.3% 1.3% 1.3% 

SHEV2 ROLL2 1.7% 1.7% 1.6% 1.6% 1.6% 1.8% 

SHEV2 MR2 -0.4% -0.4% -0.2% -0.4% -0.2% -0.4% 

SHEV2 MR3 -0.3% -0.3% -0.2% -0.2% -0.2% -0.2% 

SHEV2 MR4 -0.3% -0.3% -0.3% -0.3% -0.3% -0.2% 

SHEV2 MR5 0.0% 0.0% -0.3% -0.3% -0.3% -0.2% 

PHEV1 AERO2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 

PHEV1 ROLL2 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

274 

Table V-30f Synergy pairings and values 

Technology A Technology B Large PC Large Perf. PC Minivan LT Small LT Midsize LT Large LT 

IATC CCPS -1.60% -1.60% -1.5% -1.3% -1.5% -1.3% 

IATC ICP -1.60% -1.60% -1.5% -1.3% -1.5% -1.3% 

IATC DEACO -1.60% -1.60% -1.5% -1.3% -1.5% -1.3% 

NAUTO CCPS -1.20% -1.20% -1.3% -0.8% -1.3% -1.7% 

NAUTO ICP -1.20% -1.20% -1.3% -0.8% -1.3% -1.7% 

NAUTO DEACO -1.20% -1.20% -1.3% -0.8% -1.3% -1.7% 

DCT CCPS -0.40% -0.40% 0.0% -1.6% 0.0% 0.0% 

DCT ICP -0.40% -0.40% 0.0% -1.6% 0.0% 0.0% 

DCT DEACO -0.40% -0.40% 0.0% -1.6% 0.0% 0.0% 

8SPD CCPS -2.50% -2.50% -3.9% -2.7% -3.9% -3.8% 

8SPD ICP -2.50% -2.50% -3.9% -2.7% -3.9% -3.8% 

8SPD DEACO -2.50% -2.50% -3.9% -2.7% -3.9% -3.8% 

HETRANS CCPS 0.00% 0.00% -0.6% 0.3% -0.6% -0.8% 

HETRANS ICP 0.00% 0.00% -0.6% 0.3% -0.6% -0.8% 

HETRANS DEACO 0.00% 0.00% -0.6% 0.3% -0.6% -0.8% 

IATC TRBDS1_SD 1.60% 1.60% 1.5% 1.3% 1.5% 1.3% 

IATC TRBDS1_MD 1.60% 1.60% 1.5% 1.3% 1.5% 1.3% 

IATC TRBDS1_LD 1.60% 1.60% 1.5% 1.3% 1.5% 1.3% 

NAUTO TRBDS1_SD 1.20% 1.20% 1.3% 0.8% 1.3% 1.7% 

NAUTO TRBDS1_MD 1.20% 1.20% 1.3% 0.8% 1.3% 1.7% 

NAUTO TRBDS1_LD 0.012 0.012 1.3% 0.8% 1.3% 1.7% 

DCT TRBDS1_SD 0.004 0.004 0.0% 1.6% 0.0% 0.0% 

DCT TRBDS1_MD 0.004 0.004 0.0% 1.6% 0.0% 0.0% 

DCT TRBDS1_LD 0.004 0.004 0.0% 1.6% 0.0% 0.0% 

8SPD TRBDS1_SD 0.025 0.025 3.9% 2.7% 3.9% 3.8% 

8SPD TRBDS1_MD 0.025 0.025 3.9% 2.7% 3.9% 3.8% 

8SPD TRBDS1_LD 2.5% 2.5% 3.9% 2.7% 3.9% 3.8% 

HETRANS TRBDS1_SD 0.0% 0.0% 0.6% -0.3% 0.6% 0.8% 

HETRANS TRBDS1_MD 0.0% 0.0% 0.6% -0.3% 0.6% 0.8% 

HETRANS TRBDS1_LD 0.00% 0.00% 0.60% -0.30% 0.60% 0.80% 

How much does the technology cost? 

Direct Cost Estimates 

As a general matter, the agencies believe that the best method to derive technology cost estimates 

is to conduct studies involving tear-down and analysis of actual vehicle components. A “teardown” involves breaking down a technology into its fundamental parts and manufacturing 

processes by completely disassembling actual vehicles and vehicle subsystems and precisely 
                                                      

 

 

 

275 

determining what is required for its production. The result of the tear-down is a “bill of 

materials” for each and every part of the vehicle or vehicle subsystem. This tear-down method 

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

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

on a large scale by researchers and regulators due to the expense required for such studies. 

While tear-down studies are highly accurate at costing technologies for the year in which the 

study is intended, their accuracy, like that of all cost projections, may diminish over time as costs 

are extrapolated further into the future because of uncertainties in predicting commodities (and 

raw material) prices, labor rates, and manufacturing practices. The projected costs may be 

higher or lower than predicted. 

Over the past several years, EPA has contracted with FEV, Inc. and its subcontractor Munro & 

Associates, to conduct tear-down cost studies for a number of key technologies evaluated by the 

agencies in assessing the feasibility of future GHG and CAFE standards. The analysis 

methodology included procedures to scale the tear-down results to smaller and larger vehicles, 

and also to different technology configurations. FEV’s methodology was documented in a report 

published as part of the MY 2012-2016 rulemaking process, detailing the costing of the first teardown conducted in this work (#1 in the below list).212 This report was peer reviewed by experts 

in the industry and revised by FEV in response to the peer review comments.213 Subsequent 

tear-down studies (#2-5 in the below list) were documented in follow-up FEV reports made 

available in the public docket for the MY 2012-2016 rulemaking.214 

Since then, FEV’s work under this contract has continued. Additional cost studies have been 

completed and are available for public review.215 The most extensive study, performed after the 

MY 2012-2016 final rule, involved whole-vehicle tear-downs of a 2010 Ford Fusion power-split 

hybrid and a conventional 2010 Ford Fusion. (The latter served as a baseline vehicle for 

comparison.) In addition to providing power-split HEV costs, the results for individual 

components in these vehicles were subsequently used to cost another hybrid technology, the P2 

hybrid, which employs similar hardware. This approach to costing P2 hybrids was undertaken 

because P2 HEVs were not yet in volume production at the time of hardware procurement for 

tear-down. Finally, an automotive lithium-polymer battery was torn down and costed to provide 

supplemental battery costing information to that associated with the NiMH battery in the Fusion 

212 U.S. EPA, “Light-Duty Technology Cost Analysis Pilot Study,” Contract No. EP-C-07-069, Work Assignment 1­

3, December 2009, EPA-420-R-09-020, Docket No. NHTSA-2010-0131 213 U.S. EPA, “Light-Duty Technology Cost Analysis Pilot Study Peer Review Report —Response to Comments 

Document”, December 21, 2009, Docket No. NHTSA-2010-0131 

214 U.S. EPA, “Light-duty Technology Cost Analysis – Report on Additional Case Studies,” Docket No. NHTSA2010-0131 

215 FEV, Inc., “Light-Duty Technology Cost Analysis, Report on Additional Transmission, Mild Hybrid, and 

Valvetrain Technology Case Studies", Contract No. EP-C-07-069, Work Assignment 3-3, November 2011, Docket 

No. NHTSA-2010-0131 
 

                                                      

 

276 

because we think automakers are moving to Li-ion battery technologies due to the higher energy 

and power density of these batteries. This HEV cost work, including the extension of results to 

P2 HEVs, has been extensively documented in a new report prepared by FEV.216 Because of the 

complexity and comprehensive scope of this HEV analysis, EPA commissioned a separate peer 

review focused exclusively on it. Peer reviewer comments for the P2 and power-split HEV study 

generally supported FEV’s methodology and results, while including a number of suggestions 

for improvement which were subsequently incorporated into FEV’s analysis and final report. 

The peer review comments and responses are available in the rulemaking docket.217 218 

Over the course of this entire contract between EPA and FEV, FEV performed teardown-based 

studies were performed on each of the technologies listed below. These completed studies 

provide a thorough evaluation of the new technologies’ costs relative to their baseline (or 

replaced) technologies. 

1.	 Stoichiometric gasoline direct injection (SGDI) and turbocharging with engine 

downsizing (T-DS) on a DOHC (dual overhead cam) I4 engine, replacing a 

conventional DOHC I4 engine. 

2.	 SGDI and T-DS on a SOHC (single overhead cam) on a V6 engine, replacing a 

conventional 3-valve/cylinder SOHC V8 engine. 

3.	 SGDI and T-DS on a DOHC I4 engine, replacing a DOHC V6 engine. 

4.	 6-speed automatic transmission (AT), replacing a 5-speed AT. 

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

6.	 8-speed AT replacing a 6-speed AT. 

7.	 8-speed DCT replacing a 6-speed DCT. 

8.	 Power-split hybrid (Ford Fusion with I4 engine) compared to a conventional vehicle 

(Ford Fusion with V6). As explained, the results from this tear-down were extended 

to address P2 hybrids. In addition, costs from individual components in this teardown study were also used by the agencies in developing cost estimates for PHEVs 

and EVs. 

9.	 Mild hybrid with stop-start technology (Saturn Vue with I4 engine), replacing a 

conventional I4 engine. 

10. Fiat Multi-Air engine technology. (Although results from this cost study are included 

in the rulemaking docket, they were not used by the agencies in this rulemaking’s 

technical analyses, because of the uncertainty related to industry-wide use due to 

potential intellectual property issues.) 

216 FEV, Inc., “Light-Duty Technology Cost Analysis, Power-Split and P2 HEV Case Studies”, Contract No. EP-C07-069, Work Assignment 3-3, EPA-420-R-11-015, November 2011, Docket No. NHTSA-2010-0131 

217 ICF, “Peer Review of FEV Inc. Report “Light Duty Technology Cost Analysis, Power-Split and P2 Hybrid 

Electric Vehicle Case Studies”, EPA-420-R-11-016, November 2011, Docket No. NHTSA-2010-0131 

218 FEV, Inc. and U.S. EPA, “FEV Inc. Report ‘Light Duty Technology Cost Analysis, Power-Split and P2 Hybrid 

Electric Vehicle Case Studies’, Peer Review Report – Response to Comments Document”, EPA-420-R-11-017, 

November 2011, Docket No. NHTSA-2010-0131 
                                                      

277 

In addition, FEV and EPA extrapolated the engine downsizing costs for the following scenarios 

that were based on the above study cases: 

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

2. Downsizing a DOHC V8 to a DOHC V6. 

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

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

The agencies have relied on the findings of FEV for estimating the cost of each of the 

technologies covered by the tear-down studies. However, we note that FEV based their costs on 

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

(450,000 units or more for each component or subsystem). If manufacturers are not able to 

employ the technology at the volumes assumed in the FEV analysis with fully learned costs, then 

the costs for each of these technologies would be expected to be higher. There is also the 

potential for stranded capital219 if technologies are introduced too rapidly for some indirect costs 

to be fully recovered. Because the production of automotive components is capital-intensive, it 

is possible for substantial capital investments in manufacturing equipment and facilities to 

become “stranded” (where their value is lost, or diminished). 

It is difficult to quantify accurately any capital stranding associated with new technology phaseins under the standards in this final rule because of the iterative dynamic involved – that is, the 

new technology phase-in rate strongly affects the potential for additional cost due to stranded 

capital. While the agencies consider the FEV tear-down analysis results to be generally valid for 

the 2017-2025 timeframe for fully mature, high sales volumes, in order to account for the 

possibility of stranded capital costs, the agencies asked FEV to perform a separate analysis of 

potential stranded capital costs associated with rapid phase-in of select technologies that FEV 

had already torn down, using data from FEV’s primary teardown-based cost analyses. Detailed 

information on how FEV performed this exercise and the results of this exercise can be found in 

Section 3.2.2.3 of Chapter 3 of the joint TSD, and we refer readers there for more information. 

DOT has modified the CAFE model, if specified for a given technology, when that technology is 

replaced by a newly applied technology, to apply a stream of costs representing the stranded 

capital cost of the replaced technology. This cost is in addition to the cost for producing the 

newly-applied technology. Because FEV assumed a ten year production life, for capital 

depreciation, any time a technology evaluated by FEV is replaced before its tenth year of being 

production, there is the potential for the stranding of capital. To account for this, the model 

determines how long a technology has been applied by the model. If a technology has been 

applied by the model for ten years or longer, the model does not apply these additional stranded 

219 The potential for stranded capital occurs when manufacturing equipment and facilities cannot be used in the 

production of a new technology. 
278 

capital costs when or if that technology gets replaced. However, if a technology is being 

replaced only five years after it was first applied by the model, then the model applies a stranded 

capital cost. FEV derived stranded capital costs for situations where a technology is replaced 

after three, five and eight years of production. FEV also assumed that for each of those years, 

the stranded capital would be recouped over a five year period. NHTSA extrapolated the FEV 

values to create a lookup table, Table V-31 below, which defines the stranded capital costs from 

years one through ten. For example, if a 6-speed DCT (DCT) is replaced by an 8-speed 

transmission (8SPD) 8 years after it was first applied, then the model will apply a cost of penalty 

of $8.04 to the 8SPD technology for 5 years. The allocation of stranded capital costs to the 

different technologies were changed slightly from the NPRM to more closely align with how the 

FEV derived stranded capital costs were meant to be employed. The stranded capital costs 

themselves did not change. The only change was how the stranded capital costs were applied to 

the unique technologies. The exact allocation of stranded capital costs can be found in the 

technology input file, available at Docket No. NHTSA-2010-0131. Additionally, like all other 

technology costs the stranded capital costs were updated from 2009$ to 2010$. 

For some of the technologies, NHTSA’s inputs, which are designed to be as consistent as 

practicable with EPA’s, indicate negative incremental costs. In other words, the agency is 

estimating that some technologies, if applied in a manner that holds performance and utility 

constant, will, following initial investment (for, e.g., R&D and tooling) by the manufacturer and 

its suppliers, incrementally improve fuel savings and reduce vehicle costs. Nonetheless, in the 

agency’s central analysis, these and other technologies are applied only insofar as is necessary to 

achieve compliance with standards defining any given regulatory alternative (where the baseline 

no action alternative assumes CAFE standards are held constant after MY2016). The agency has 

also performed a sensitivity analysis involving market-based application of technology—that is, 

the application of technology beyond the point needed to achieve compliance, if the cost of the 

technology is estimated to be sufficiently attractive relative to the accompanying fuel 

savings. NHTSA invited comment on all of its technology estimates, and specifically requested 

comment on the likelihood that each technology will, if applied in a manner that holds vehicle 

performance and utility constant, be able to both deliver the estimated fuel savings and reduce 

vehicle cost. The agency also invited comment on whether, for the final rule, its central analysis 

should be revised to include estimated market-driven application of technology. 

In their written comments on the proposal, the Center for Biological Diversity and the 

International Council on Clean Transportation argued that the long lead times being provided for 

the phase-in of new standards, stretching out as they do over two complete redesign cycles, will 

virtually eliminate any capital stranding, making it inappropriate to carry over what they consider 

to be a “relic” from shorter-term rulemakings. As discussed above, it is difficult to quantify 

accurately any capital stranding associated with new technology phase-ins, especially given the 

projected and unprecedented deployment of technologies in the rulemaking timeframe. The FEV 
279 

analysis attempted to define the possible stranded capital costs, for a select set of technologies, 

using the above set of assumptions. Since the direct manufacturing costs developed by FEV 

assumed a 10 year production life (i.e., capital costs amortized over 10 years) the agencies 

applied the FEV derived stranded capital costs whenever technologies were replaced prior to 

being utilized for the full 10 years. The other option would be to have assume a 5 year product 

life (i.e., capital costs amortized over 5 years), which would have increased the direct 

manufacturing costs. It seems only reasonable to account for stranded capital costs in the 

instances where the fleet modeling performed by the agencies replaced technologies before the 

capital costs were fully amortized. The agencies did not derive or apply stranded capital costs to 

all technologies only the ones analyzed by FEV. While there is uncertainty about the possible 

stranded capital costs (i.e., understated or overstated), their impact would not call into question 

the overall results of our cost analysis or otherwise affect the stringency of the standards, since 

costs of stranded capital are a relatively minor component of the total estimated costs of the 

rules. 

In other comments relating to cost estimates, VW raised concerns for the costs and effectiveness 

for certain key technologies including electrification, lightweighting, and advanced engine 

technologies. For vehicle lightweighting, VW believes the cost used by the agencies is too low 

and the maximum cost-effective amount of mass reduction the agencies used in the NPRM 

analysis is too high. VW’s opinion is that 10 percent of mass reduction, instead of 20 percent, is 

more cost-effective. After finishing the mass reduction study contracted with Electricore, 

NHTSA believes that 20 percent of mass reduction is cost-effective and feasible in the 

rulemaking period. However, NHTSA also acknowledges that each manufacturer has a different 

amount of lightweighting technologies already applied in its current fleet. If one OEM already 

has significantly more cost-effective lightweighting technologies used in its current fleet, it may 

have already applied the “low-hanging fruit” and may have to employ higher-cost lightweighting 

technologies if they chose to use lightweighting as a strategy to achieve the required fuel 

economy level. For high BMEP engines, VW raised particular concerns about the thermal and 

mechanical loads imparted on the components. These thermal and mechanical loads might 

impact the durability of these engines which in turn would incur additional cost to improve the 

durability. 

Also, VW believes that high BMEP engines might need a two-stage turbocharger system to 

address low end torque performance, which would add more cost. VW believes, as stated in its 

comments, “Considering all these factors we believe that the torque curve for future engines will 

be constrained over the rpm range by charging limits, exhaust temperature, peak cylinder 

pressures and mechanical forces that may limit the practicable increase in BMEP.” NHTSA 

acknowledges VW’s concerns. NHTSA will closely monitor the development of these 

technologies and review the cost, effectiveness and applications of these technologies during the 

mid-term review. 
 

 

280 

The National Automobile Dealers Association (NADA) offered comment on the issue of 

maintenance and other costs, stating that the final rule should evaluate the potential impact on a 

vehicle’s total cost of ownership, to include maintenance costs. In response, NHTSA identified a 

select list of technologies for which sufficient data on periodicity and cost exist to support 

quantification of changes in vehicle maintenance costs. This list includes costs associated with 

low rolling resistance tires, diesel fuel filters, and benefits resulting from electric vehicle 

characteristics that eliminate the need for oil changes as well as engine air filter changes. In the 

final rule as in the NPRM, repair costs during the warranty period remain a component of the 

indirect cost multiplier. A sensitivity analysis was added to examine repair costs in the postwarranty period, discussed further in Chapter X of this FRIA. 

Comments received from NRDC and the Union of Concerned Scientists discouraged the use of a 

consumer choice model that includes market-driven application of technology. Specifically, 

NRDC’s concern was that the model cannot capture technologies that do not already exist in the 

market and UCS commented that these models were once used by OEMs to dismiss hybrids, 

airbags, and other technologies. The Alliance of Automobile Manufacturers, American Fuel and 

Petrochemical Mfrs, and the Institute for Policy Integrity all commented supporting the use of a 

consumer choice model in the rulemaking analysis. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

281 

Table V-31 Stranded Capital Costs (2010$) 

Stranded Capital Cost Table 

Technology Abbr. 

Year 

1 

Year 

2 

Year 

3 

Year 

4 

Year 

5 

Year 

6 

Year 

7 

Year 

8 

Year 

9 

Year 

10 

Low Friction Lubricants - Level 1 

LUB1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Engine Friction Reduction - Level 1 EFR1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Low Friction Lubricants and Engine Friction 

Reduction - Level 2 LUB2_EFR2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Variable Valve Timing (VVT) - Coupled Cam 

Phasing (CCP) on SOHC CCPS $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Cylinder Deactivation on SOHC DEACS $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Variable Valve Timing (VVT) - Intake Cam 

Phasing (ICP) ICP $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Variable Valve Timing (VVT) - Dual Cam 

Phasing (DCP) DCP $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Continuously Variable Valve Lift (CVVL) CVVL $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Cylinder Deactivation on DOHC DEACD $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Stoichiometric Gasoline Direct Injection (GDI) SGDI $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Cylinder Deactivation on OHV DEACO $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Variable Valve Actuation - CCP and DVVL on 

OHV VVA $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Stoichiometric Gasoline Direct Injection (GDI) 

on OHV SGDIO $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ -

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Small Displacement TRBDS1_SD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Medium Displacement TRBDS1_MD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Large Displacement TRBDS1_LD $78.48 $69.69 $60.90 $52.20 $43.50 $34.80 $26.10 $17.40 $8.70 $0.00 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Small Displacement TRBDS2_SD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Medium Displacement TRBDS2_MD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Large Displacement TRBDS2_LD $78.48 $69.69 $60.90 $52.20 $43.50 $34.80 $26.10 $17.40 $8.70 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD $78.48 $69.69 $60.90 $52.20 $43.50 $34.80 $26.10 $17.40 $8.70 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD $78.48 $69.69 $60.90 $52.20 $43.50 $34.80 $26.10 $17.40 $8.70 $0.00 

Advanced Diesel - Small Displacement ADSL_SD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Advanced Diesel - Medium Displacement ADSL_MD $73.38 $65.16 $56.93 $48.80 $40.66 $32.53 $24.40 $16.27 $8.14 $0.00 

Advanced Diesel - Large Displacement ADSL_LD $78.48 $69.69 $60.90 $52.20 $43.50 $34.80 $26.10 $17.40 $8.70 $0.00 

6-Speed Manual/Improved Internals 6MAN $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

High Efficiency Gearbox (Manual) HETRANSM $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Improved Auto. Trans. Controls/Externals IATC $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­
 

282 

6-Speed Trans with Improved Internals (Auto) NAUTO $79.99 $67.61 $55.23 $47.34 $39.45 $31.56 $23.67 $15.78 $7.89 $0.00 

6-speed DCT DCT $36.18 $32.16 $28.14 $24.12 $20.10 $16.08 $12.06 $8.04 $4.02 $0.00 

8-Speed Trans (Auto or DCT) 8SPD $65.10 $56.68 $48.26 $41.36 $34.47 $27.58 $20.68 $13.79 $6.89 $0.00 

High Efficiency Gearbox (Auto or DCT) HETRANS $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Shift Optimizer SHFTOPT $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Electric Power Steering EPS $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Improved Accessories - Level 1 IACC1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Improved Accessories - Level 2 (w/ Alternator 

Regen and 70% efficient alternator) IACC2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

12V Micro-Hybrid (Stop-Start) MHEV $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Integrated Starter Generator ISG $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Strong Hybrid - Level 1 SHEV1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Conversion from SHEV1 to SHEV2 

SHEV1_2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Strong Hybrid - Level 2 SHEV2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Plug-in Hybrid - 30 mi range PHEV1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Plug-in Hybrid PHEV2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Electric Vehicle (Early Adopter) - 75 mile range EV1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Electric Vehicle (Early Adopter) - 100 mile 

range EV2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Electric Vehicle (Early Adopter) - 150 mile 

range EV3 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Electric Vehicle (Broad Market) - 150 mile 

range EV4 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Fuel Cell Vehicle 

FCV $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Mass Reduction - Level 1 

MR1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Mass Reduction - Level 2 

MR2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Mass Reduction - Level 3 

MR3 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Mass Reduction - Level 4 

MR4 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Mass Reduction - Level 5 

MR5 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Low Rolling Resistance Tires - Level 1 ROLL1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Low Rolling Resistance Tires - Level 2 ROLL2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Low Rolling Resistance Tires - Level 3 ROLL3 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Low Drag Brakes LDB $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Secondary Axle Disconnect SAX $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Aero Drag Reduction, Level 1 AERO1 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Aero Drag Reduction, Level 2 AERO2 $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­ $ ­

Learning Curves 

The agency uses learning curves to account for the cost reductions that manufacturers realize 

through experiential learning achieved through applying technologies. A complete discussion on 

the development and application of learning curves can be found in Chapter VII of this FRIA. 
 

283 

Indirect Cost Multiplier 

Indirect costs were accounted for through the application of Indirect Cost Multipliers (ICMs), 

which were created by EPA. ICMs were applied to each technology’s year-by-year direct cost to 

arrive at its total compliance cost, which are the costs used for modeling purposes. A full 

discussion of the development and application of the ICMs for purposes of this analysis can be 

found in Chapter VII of this FRIA. 

What specific technologies did NHTSA considered for application in this rulemaking, and 

what are NHTSA’s estimates of their incremental costs and effectiveness? 

ICE Engine Technologies 

What is an Internal Combustion Engine (ICE)? 

Most passenger cars and light trucks in the U.S. have gasoline-fueled spark ignition internal 

combustion engines. These engines move the vehicle by converting the chemical energy in 

gasoline fuel to useful mechanical work output as shaft torque and power delivered to the 

transmission and to the vehicle’s driving wheels. Vehicle fuel economy is directly proportional 

to the efficiency of the engine. Two common terms are used to define the efficiency of an 

engine are (1) Brake Specific Fuel Consumption (BSFC), which is the ratio of the mass of fuel 

used to the output mechanical energy; and (2) Brake Thermal Efficiency (BTE), which is the 

ratio of the fuel chemical energy, known as calorific value, to the output mechanical energy. 

The efficiency of an automotive spark ignition engine varies considerably with the rotational 

speed and torque output demanded from the engine. The most efficient operating condition for 

most current engine designs occurs around medium speed (30-50 percent of the maximum 

allowable engine rpm) and typically between 70-85 percent of maximum torque output at that 

speed. At this operating condition, BTE is typically 33-36 percent. However, at lower engine 

speeds and torque outputs, at which the engine operates in most consumer vehicle use and on 

standardized drive cycles, BTE typically drops to 20-25 percent. 

Spark ignition engine efficiency can be improved by reducing the energy losses that occur 

between the point of combustion of the fuel in the cylinders and the point where that energy 

reaches the output crankshaft. Reduction in this energy loss results in a greater proportion of the 

chemical energy of the fuel being converted into useful work. For improving engine efficiency 

at lighter engine load demand points, which are most relevant for CAFE fuel economy, the 

technologies that can be added to a given engine may be characterized by which type of energy 

loss is reduced. The main types of energy losses that can be reduced in gasoline engines to 
 

284 

improve fuel economy are exhaust energy losses, engine friction losses, and gas exchange losses. 

Converting the gasoline engine to a diesel engine can also reduce heat losses. 

How can ICE efficiency be improved? 

Exhaust Energy Loss Reduction 

Exhaust energy includes the kinematic and thermal energy of the exhaust gases, as well as the 

wasted chemical energy of unburned fuel. These losses represent approximately 32 percent of 

the initial fuel chemical energy and can be reduced in three ways: first, by recovering 

mechanical or electrical energy from the exhaust gases; second, by improving the hydrocarbon 

fuel conversion; and third, by improving the cycle thermodynamic efficiency. The 

thermodynamic efficiency can be improved by either increasing the engine’s compression ratio 

or by operating with a lean air/fuel ratio. 

Engine Friction Loss Reduction 

Friction losses can represent a significant proportion of the global losses at low load. These 

losses are dissipated through the cooling system in the form of heat. Besides via direct reduction 

measures, friction can also be reduced through downsizing the engine by means of increasing the 

engine-specific power output. 

Gas Exchange Loss Reduction 

The energy expended while delivering the combustion air to the cylinders and expelling the 

combustion products is known as gas exchange loss, commonly referred to as pumping loss. The 

main source of pumping loss in a gasoline engine is the use of an inlet air throttle, which 

regulates engine output by controlling the pre-combustion cylinder air pressure, but which is an 

inefficient way to achieve this pressure control. A more efficient way of controlling the cylinder 

air pressure is to modify the valve timing or lift. Another way to reduce the average pumping 

losses is to “downsize” the engine, making it run at higher loads or higher pressures. 

Several different technologies target pumping loss reduction, but the fuel consumption reduction 

from these technologies is not necessarily cumulative. Once most of the pumping work has been 

eliminated, adding further technologies that also target reduced pumping loss will have little 

additional effectiveness. Thus, in the decision trees used for this analysis, the effectiveness value 

shown for additional technologies targeting pumping loss depends on the existing technology 

combination already present on the engine. 

What technologies can improve fuel efficiency for both gasoline and diesel ICEs? 
 

                                                      

 

 

285 

Low Friction Lubricants (LUB) 

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

lower viscosity engine lubricants. More advanced multi-viscosity engine oils are available today 

with improved performance in a wider temperature band and with better lubricating properties. 

This can be accomplished by changes to the oil base stock (e.g., switching engine lubricants from 

a Group I base oils to lower-friction, lower viscosity Group III synthetic) and through changes to 

lubricant additive packages (e.g., friction modifiers and viscosity improvers). The use of 5W-30 

motor oil is now widespread and auto manufacturers are introducing the use of even lower 

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

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

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

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

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

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

for operation. 

Several manufacturers have previously commented confidentially, that low friction lubricants 

could have an effectiveness value between 0 to 1 percent. The agencies used the average 

effectiveness of 0.5 in the MYs 2012-2016 final rule. For purposes of this final rule, the 

agencies relied on the lumped parameter model and determined that the range for the 

effectiveness of low friction lubricant is 0.5 to 0.8 percent. 

In the 2012-2016 rule, the 2010 TAR and the recent HD GHG rule, EPA and NHTSA used a 

direct manufacturing cost (DMC) of $3 (2007$), and considered that cost to be independent of 

vehicle class since the engineering work required should apply to any engine size. The agencies 

continue to believe that this cost is appropriate and have updated it to $3 (2010$) for this 

analysis220. No learning is applied to this technology, so the DMC remains $3 year-over-year. 

The agencies have used a low complexity short-term ICM of 1.24 for this technology through 

2018, and a long-term ICM of 1.19 thereafter. The resultant costs are shown in Table V-32.221 

Table V-32 Costs for Engine Modifications to Accommodate Low Friction Lubes (2010$) 

Cost 

type 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

220 The cost was updated to 2009$. However, due to rounding to the whole dollar amount it still $3. 221 Note that the costs developed for low friction lubes for this analysis reflect the costs associated with any engine 

changes that would be required as well as any durability testing that may be required.
 
                                                      

 

286 

DMC All $3 $3 $3 $3 $3 $3 $3 $3 $3 

IC All $1 $1 $1 $1 $1 $1 $1 $1 $1 

TC All $4 $4 $4 $4 $4 $4 $4 $4 $4 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the 

baseline engine. 

Engine Friction Reduction Level I and II (EFR1and LUB2_EFR2) 

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

consumption by improving the design of engine components and subsystems. Approximately 10 

percent of the energy consumed by a vehicle is lost to friction, and just over half is due to 

frictional losses within the engine.222 Examples include improvements in low-tension piston 

rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, 

material coatings, material substitution, more optimal thermal management, and piston and 

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

improve, more opportunities for evolutionary friction reductions may become available. 

All reciprocating and rotating components in the engine are potential candidates for friction 

reduction, and minute improvements in several components can add up to a measurable fuel 

economy improvement. In the MYs 2012-2016 final rule, the agencies relied on the 2002 NAS, 

NESCCAF and EEA reports as well as confidential manufacturer data that suggested a range of 

effectiveness for engine friction reduction to be between 1 to 3 percent. Because of the 

incremental nature of the CAFE model, NHTSA used the narrower range of 1 to 2 percent, 

which resulted in an average effectiveness of 1.5 percent. For this rulemaking analysis, based on 

the 2011 Ricardo study, the effectiveness for engine friction reduction range has been increased 

to 2.0 to 2.7 percent incremental to low friction lubricant 1 (LUB1). 

Additionally, for this final rule, consistent with the proposal, the agencies have added a second 

level of incremental improvements in low friction lubricants and engine friction reduction 

(LUB2_EFR2). This LUB2_EFR2 includes some additional effectiveness improvements to low 

friction lubricant, relative to the low friction lubricant technology discussed above, based on 

assumptions based on manufacturer statements that further improvements will be made to low 

friction lubricants. The technologies for this second level of engine friction reduction and low 

friction lubricants are considered to be available for purposes of this analysis only after MY 

2017. The effectiveness for this second level, relative to the base engine, is 3.4 to 4.8 percent 

based on the lumped parameter model. However, because of the incremental nature of the CAFE 

model, NHTSA used the effectiveness range of 0.83 to 1.37 percent incremental to the first level 

of engine friction reduction (EFR1) and low friction lubricants (LUB1). 

222 “Impact of Friction Reduction Technologies on Fuel Economy,” Fenske, G. Presented at the March 2009 

Chicago Chapter Meeting of the ‘Society of Tribologists and Lubricated Engineers’ Meeting, March 18th, 2009. 

Available at: http://www.dtic.mil/cgi-bin/GetTRDoc?Location=U2&doc=GetTRDoc.pdf&AD=ADA508227 (last 

accessed November 13, 2011) 
 

 

 

 

 

 

 

 

 

 

287 

In the 2012-2016 rule, the 2010 TAR and the HD GHG final rule, NHTSA and EPA used a cost 

estimate of $11.71 (2007$) per cylinder as the direct manufacturing cost for EFR1, which is $12 

(updated to 2010$) per cylinder in this analysis. No learning is applied to this technology, so the 

DMC remains $12 (2010$) year-over-year. The agencies have used a low complexity ICM of 

1.24 for this technology through 2018 and a long-term ICM of 1.19 thereafter. The resultant 

costs are shown in Table V-33. 

Table V-33 Costs for Engine Friction Reduction – Level 1 (EFR1) (2010$) 

Cost 

type 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC I3 $36 $36 $36 $36 $36 $36 $36 $36 $36 

DMC I4 $48 $48 $48 $48 $48 $48 $48 $48 $48 

DMC V6 $71 $71 $71 $71 $71 $71 $71 $71 $71 

DMC V8 $95 $95 $95 $95 $95 $95 $95 $95 $95 

IC I3 $9 $9 $7 $7 $7 $7 $7 $7 $7 

IC I4 $11 $11 $9 $9 $9 $9 $9 $9 $9 

IC V6 $17 $17 $14 $14 $14 $14 $14 $14 $14 

IC V8 $23 $23 $18 $18 $18 $18 $18 $18 $18 

TC I3 $44 $44 $43 $43 $43 $43 $43 $43 $43 

TC I4 $59 $59 $57 $57 $57 $57 $57 $57 $57 

TC V6 $89 $89 $85 $85 $85 $85 $85 $85 $85 

TC V8 $118 $118 $113 $113 $113 $113 $113 $113 $113 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline 

engine. 

The agencies have estimated the DMC for the second level of friction reduction with a second 

level of low friction lube as double the combined DMCs of the first level of engine friction 

reduction and first level of low friction lube (that is, double the DMC relative to the baseline). 

The resultant costs of LUB2_EFR2 are as shown in Table V-34. For LUB2_EFR2 the agencies 

have used a low complexity ICM of 1.24 through 2024 and a long-term ICM of 1.19 thereafter. 

Table V-34 Costs for Engine Friction Reduction – Level 2(LUB2_EFR2) (2010$) 

Cost 

type 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC I3 $78 $78 $78 $78 $78 $78 $78 $78 $78 

DMC I4 $102 $102 $102 $102 $102 $102 $102 $102 $102 

DMC V6 $149 $149 $149 $149 $149 $149 $149 $149 $149 

DMC V8 $197 $197 $197 $197 $197 $197 $197 $197 $197 

IC I3 $19 $19 $19 $19 $19 $19 $19 $19 $15 

IC I4 $25 $25 $25 $25 $25 $25 $25 $25 $20 

IC V6 $36 $36 $36 $36 $36 $36 $36 $36 $29 

IC V8 $48 $48 $48 $48 $48 $48 $48 $48 $38 
 

 

                                                      

288 

TC I3 $97 $97 $97 $97 $97 $97 $97 $97 $93 

TC I4 $126 $126 $126 $126 $126 $126 $126 $126 $121 

TC V6 $185 $185 $185 $185 $185 $185 $185 $185 $178 

TC V8 $244 $244 $244 $244 $244 $244 $244 $244 $234 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

Gasoline Engine Technologies 

Variable Valve Timing (VVT) 

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

the intake valve, exhaust valve, or both, primarily to reduce pumping losses, increase specific 

power, and control the level of residual gases in the cylinder. VVT reduces pumping losses 

when the engine is lightly loaded by controlling valve timing closer to an optimum needed to 

sustain horsepower and torque. VVT can also improve volumetric efficiency at higher engine 

speeds and loads. Additionally, VVT can be used to alter (and optimize) the effective 

compression ratio where it is advantageous for certain engine operating modes (e.g., in the 

Atkinson Cycle). 

VVT has now become a widely adopted technology: in MY 2010, approximately 86 percent of 

all new cars and light trucks had engines with some method of variable valve timing.223 

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

variety of different names and methods. Manufacturers are currently using many different types 

of variable valve timing, which have a variety of different names and methods. Therefore, the 

degree of further improvement across the fleet is limited by the level of valvetrain technology 

already implemented on the vehicles. Information found in the 2008 baseline vehicle fleet file is 

used to determine the degree to which VVT technologies have already been applied to particular 

vehicles, to ensure that the proper level of VVT technology, if any, is applied. 

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

position relative to the crankshaft position, referred to as “camshaft phasing.” The phase 

adjustment results in changes to the pumping work required by the engine to accomplish the gas 

exchange process. The majority of current cam phaser applications use hydraulically-actuated 

units, powered by engine oil pressure and managed by a solenoid that controls the oil pressure 

supplied to the phaser. The three major types of VVT are listed below. 

Intake Cam Phasing (ICP) 

223 “Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends - 1975 through 

2009”, EPA420-S-07-001, September 2007, Docket No. NHTSA-2010-0131-0147. Available at 

http://www.epa.gov/oms/cert/mpg/fetrends/fetrends-archive.htm (last accessed November 13, 2011). 
 

 

 

 

 

289 

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

timing of the inlet valves by phasing the intake camshaft while the exhaust valve timing remains 

fixed. This requires the addition of a cam phaser on each bank of intake valves on the engine. 

An in-line 4-cylinder engine has one bank of intake valves, while V-configured engines have two 

banks of intake valves. 

In the MYs 2012-2016 final rule and TAR, NHTSA and EPA assumed an effectiveness range of 

2 to 3 percent for ICP. Based on the 2011 Ricardo study and updated lumped-parameter model 

the agencies have fine-tuned the range to 2.1 to 2.7 percent. 

In the 2012-2016 rule and the 2010 TAR, the agencies estimated the DMC of a cam phaser 

needed for ICP at $37 (2007$). This DMC becomes $39 (2010$) for this analysis and is 

considered applicable in the 2015 MY. This cost would be required for each cam shaft 

controlling intake valves; an overhead cam I4 would need one phaser, an overhead cam V6 or 

V8 would need two phasers, and an overhead valve V6 or V8 would need just one. This 

technology is considered to be on the flat-portion of the learning curve. The agencies have 

applied a low complexity ICM of 1.24 to this technology through 2018 and a long-term ICM of 

1.19 thereafter. The resultant costs are shown in Table V-35. 

Table V-35 Costs for Intake Cam Phasing (2010$) 

Cost 

type 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC OHCI4 $37 $36 $35 $35 $34 $33 $33 $32 $31 

DMC OHCV6/V8 $74 $72 $71 $70 $68 $67 $65 $64 $63 

DMC OHVV6/V8 $37 $36 $35 $35 $34 $33 $33 $32 $31 

IC OHCI4 $9 $9 $7 $7 $7 $7 $7 $7 $7 

IC OHCV6/V8 $19 $19 $15 $15 $15 $15 $15 $15 $15 

IC OHVV6/V8 $9 $9 $7 $7 $7 $7 $7 $7 $7 

TC OHCI4 $46 $46 $43 $42 $42 $41 $40 $40 $39 

TC OHCV6/V8 $93 $91 $86 $84 $83 $82 $80 $79 $78 

TC OHVV6/V8 $46 $46 $43 $42 $42 $41 $40 $40 $39 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; OHC=overhead cam; OHV=overhead valve; all costs 

are incremental to the baseline. 
                                                      

 

 

290 

Coupled Cam Phasing (CCPS and CCPO) 

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

valves and the exhaust valves an equal amount by phasing the camshaft of a single overhead cam 

(SOHC) engine or an overhead valve (OHV) engine. For overhead cam engines, this requires 

the addition of a cam phaser on each bank of the engine. Thus, an in-line 4-cylinder engine has 

one cam phaser, while SOHC V-engines have two cam phasers. For overhead valve (OHV) 

engines, which have only one camshaft to actuate both inlet and exhaust valves, CCP is the only 

VVT implementation option available and requires only one cam phaser.224 

The analysis for MYs 2012-2016 final rule used an effectiveness estimate for CCP of between 1 

to 4 percent. Due to the incremental nature and decision tree logic of the CAFE model, NHTSA 

estimated the effectiveness for coupled cam phasing on a SOHC engine to be 1 to 3 percent and 

1 to 1.5 percent for coupled cam phasing on an overhead valve engine. 

For this final rule, consistent with the proposal, the agencies, taking into account the additional 

review and the work performed for the 2011 Ricardo study, have revised the estimates for CCP. 

The effectiveness relative to the base engine is 4.1 to 5.5 percent based on the lumped parameter 

model. Because of the incremental nature of the CAFE model, NHTSA used the incremental 

effectiveness range of 4.14 to 5.36 percent for SOHC applications, which represents an increase 

over the estimates used in the MYs 2012-16 final rule and 2010 TAR. For OHV applications, 

CCP was paired with discrete variable valve lift (DVVL) to form a new technology descriptor 

called variable valve actuation (VVA). VVA is discussed later in this chapter. 

The same cam phaser has been assumed for intake cam phasing as for coupled cam phasing, thus 

CCP cost estimates are identical to those presented in Table V-35. 

Dual Cam Phasing (DCP) 

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

valve opening and closing events are controlled independently. This allows the option of 

controlling valve overlap, which can be used as an internal EGR strategy. At low engine loads, 

DCP creates a reduction in pumping losses, resulting in improved fuel consumption. Increased 

internal EGR also results in lower engine-out NOX emissions. The amount by which fuel 

consumption is improved depends on the residual tolerance of the combustion system. 

Additional improvements are observed at idle, where low valve overlap could result in improved 

combustion stability, potentially reducing idle fuel consumption. 

224 We note that coaxial camshaft developments would allow other VVT options to be applied to OHV engines. 

However, since they would potentially be adopted on only a limited number of OHV engines, because of the 

complexity of these systems, NHTSA did not include them in the decision tree for this analysis. 
291 

For the 2012-2016 final rule and TAR, the agencies assumed an effectiveness range for DCP of 

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

agencies have updated this range, based on the updated lumped parameter model, to 4.1 to 5.5 

percent relative to a base engine, or 2.0 to 2.7 percent relative to an engine with ICP. 

The costs for DCP are the same per phaser as described above for ICP. However, for DCP, an 

additional cam phaser is required for each camshaft controlling exhaust valves. As a result, an 

overhead cam I4 would need two phasers, an overhead cam V6 or V8 would need four phasers, 

and an overhead valve V6 or V8 would need two. NHTSA believes that with DCP the exhaust 

valves can be closed earlier to allow some in-cylinder EGR, so we subtracted the cost of an EGR 

valve per bank for DCP. The EGR valve cost is $6 (2007$) in MY 2012, so the DCP cost per 

bank is $31 (2007$). Converting to 2010$, the DCP cost is $33. This technology is considered to 

be on the flat-portion of the learning curve. The agencies have applied a medium complexity 

ICM of 1.39 to this technology through 2018 and 1.29 thereafter. The resultant costs are shown 

in Table V-36. 

Table V-36 Costs Per Cylinder Bank for VVT-Dual Cam Phasing (2010$) 

Index 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $32 $31 $30 $30 $29 $28 $28 $27 $27 

IC $13 $13 $10 $9 $9 $9 $9 $9 $9 

TC $45 $44 $40 $39 $38 $37 $37 $36 $36 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

base engine. 

Variable Valve Lift (VVL) 

Controlling the lift of the valves provides an opportunity for further efficiency improvements. 

By optimizing the valve-lift profile for specific engine operating regions, the pumping losses can 

be reduced by reducing the amount of throttling required to produce the desired engine power 

output. By moving the throttling losses further downstream of the throttle valve, the heat 

transfer losses that occur from the throttling process are directed into the fresh charge-air mixture 

just prior to compression, delaying the onset of knock-limited combustion processes. Variable 

valve lift control can also be used to induce in-cylinder mixture motion, which improves fuel-air 

mixing and can result in improved thermodynamic efficiency. Variable valve lift control can 

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

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

manufacturers have already implemented VVL into their fleets (Toyota, Honda, and BMW), but 

overall this technology is still available for most of the fleet. There are two major classifications 

of variable valve lift, as described below. 
292 

Discrete Variable Valve Lift (DVVLS, DVVLD, DVVLO) 

Discrete variable valve lift (DVVL) systems allow the selection between two or three discrete 

cam profiles by means of a hydraulically-actuated mechanical system. By optimizing the cam 

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

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

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

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

system). DVVL is normally applied together with VVT control. DVVL is also known as Cam 

Profile Switching (CPS). DVVL is a mature technology with low technical risk. 

In the MY 2012-16 final rule, based on previously-received confidential manufacturer data and 

the report from the Northeast States Center for a Clean Air Future (NESCCAF), the agencies 

estimated the effectiveness of DVVL to be between 1 to 4 percent above that realized by VVT 

systems. Based on the 2011 Ricardo study, NHTSA and EPA have revised the effectiveness 

range of DVVL systems to 2.8 to 3.9 percent above that realized by VVT systems for purposes 

of this analysis. 

In the 2012-2016 rule and the 2010 TAR, the agencies estimated the DMC of DVVL at $116 

(2007$), $169 (2007$) and $241 (2007$) for an I4, V6 and V8 engine, respectively. These 

DMCs become $122 (2010$), $177 (2010$) and $253 (2010$) or $30, $30 and $32 per cylinder 

for this analysis, all of which are considered applicable in MY 2015. Because the CAFE model 

uses cost per cylinder for this technology, NHTSA averaged the cost per cylinder for 4, 6 and 8 

cylinder engines into a cost of $31 (2010$) per cylinder for application in the CAFE model. This 

technology is considered to be on the flat-portion of the learning curve and is applicable only to 

engines with overhead cam configurations. The agencies have applied a medium complexity 

ICM of 1.39 to this technology through 2018 and a long-term ICM of 1.29 thereafter. The 

resultant costs are shown in 

Table V-37. 

Table V-37 Costs Per Cylinder for Discrete Variable Valve Lift (2010$) 

Index 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $29 $28 $28 $27 $27 $26 $26 $25 $25 

IC $12 $12 $9 $9 $9 $9 $9 $9 $9 

TC $41 $40 $37 $36 $36 $35 $35 $34 $33 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

base engine. 
293 

Continuously Variable Lift (CVVL) 

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

controlled by the engine control unit. The valve opening and phasing vary as the lift is changed 

and the relation depends on the geometry of the mechanical system. BMW has considerable 

production experience with CVVL systems and has sold port-injected “Valvetronic” engines 

since 2001. Fiat is now offering “MultiAir” engines enabling precise control over intake valve 

lift. CVVL allows the airflow into the engine to be regulated by means of intake valve opening 

reduction, which improves engine efficiency by reducing pumping losses from throttling the 

intake system further upstream as with a conventionally throttled engine. 

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

obtained with cam phase control only, with CVVL providing greater effectiveness than DVVL, 

since it can be fully optimized for all engine speeds and loads, and is not limited to a two or three 

step compromise. There may also be a small reduction in valvetrain friction when operating at 

low valve lift, resulting in improved low load fuel consumption for cam phase control with 

variable valve lift as compared to cam phase control only. Most of the fuel economy 

effectiveness is achieved with variable valve lift on the intake valves only. CVVL is only 

applicable to double overhead cam (DOHC) engines. 

In the MYs 2012-2016 final rule, the agencies estimated the effectiveness for CVVL at 1.5 to 3.5 

percent over an engine with DCP, but also recognized that it could go up as high as 5 percent 

above and beyond DCP to account for the implementation of more complex CVVL systems such 

as BMW’s “Valvetronic” and Fiat “MultiAir” engines. For this rulemaking, NHTSA has 

increased the incremental effectiveness values for this technology, based on the updated LPM, to 

a range of 3.6 to 4.9 percent from 1.5 to 3.5 percent in the MYs 2012-2016 final rule. 

In the MYs 2012-2016 rule and the 2010 TAR, the agencies estimated the DMC of CVVL at 

$174 (2007$), $320 (2007$) and $349 (2007$) for an OHC-I4, OHC-V6 and OHC-V8 engine, 

respectively. These DMCs become $182 (2010$), $333 (2010$) and $364 (2010$), or $45, $56 

and $45 per cylinder for this analysis, all of which are considered applicable in MY 2015. 

Because the CAFE model uses cost per cylinder for this technology, NHTSA averaged the cost 

per cylinder for 4, 6 and 8 cylinder engines into a cost of $48 (2010$) per cylinder for 

application in the CAFE model. This technology is considered to be on the flat-portion of the 

learning curve. The agencies have applied a medium complexity ICM of 1.39 to this technology 

through 2018 and a long-term ICM of 1.29 thereafter. The resultant costs are shown in 

Table V-38. 

Table V-38 Costs per Cylinder for Continuous Variable Valve Lift (2010$) 

Index 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $47 $46 $45 $44 $43 $42 $41 $41 $40 
294 

IC $19 $19 $14 $14 $14 $14 $14 $14 $14 

TC $66 $65 $59 $58 $57 $56 $55 $55 $54 

 DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

base engine. 

Variable Valve Actuation (VVA) 

For this final rule, consistent with the proposal, NHTSA has combined two valve control 

technologies for OHV engines; specifically, coupled cam phasing (CCPO) and discrete valve lift 

(DVVLO) have been combined into one technology, designated as variable valve actuation 

(VVA). The agency estimates the incremental effectiveness for VVA applied to an OHV engine 

as 2.71 to 3.59 percent. This effectiveness value is slightly lower than coupled cam phasing for 

overhead cam applications (CCPS), based on the assumption that VVA would be applied to an 

OHV engine after cylinder deactivation (DEAC). The cost for VVA is equal to the costs of 

CCPO and DVVLO together. However, since DEACO precedes VVA and includes the cost for 

lost motion devices, which enables DVVL, there is no additional cost for DVVL thus the VVA 

cost is equal to the CCPO cost. 

Table V-39 Costs per Cylinder for Variable Valve Actuation (2010$) 

Index 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $37 $36 $35 $35 $34 $33 $33 $32 $31 

IC $15 $15 $11 $11 $11 $11 $11 $11 $11 

TC $52 $51 $46 $46 $45 $44 $43 $43 $42 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

base engine. 

Cylinder Deactivation (DEACS, DEACD, DEACO) 

In conventional spark-ignited engines, throttling the airflow controls engine torque output. At 

partial loads, efficiency can be improved by using cylinder deactivation instead of throttling. 

Cylinder deactivation (DEAC) can improve engine efficiency by disabling or deactivating 

(usually) half of the cylinders when the load is less than half of the engine’s total torque 

capability – the valves are kept closed, and no fuel is injected – as a result, the trapped air within 

the deactivated cylinders is simply compressed and expanded as an air spring, with reduced 

friction and heat losses. The active cylinders combust at almost double the load required if all of 

the cylinders were operating. Pumping losses are significantly reduced as long as the engine is 

operated in this “part-cylinder” mode. 

Cylinder deactivation control strategy relies on setting maximum manifold absolute pressures or 

predicted torque within which it can deactivate the cylinders. Noise and vibration issues can 

reduce the operating range to which cylinder deactivation is allowed, although manufacturers 

continue exploring vehicle changes that enable increasing the amount of time that cylinder 
295 

deactivation might be suitable. Some manufacturers may choose to adopt active engine mounts 

and/or active noise cancellations systems to address NVH concerns and to allow a greater 

operating range of activation (and the agencies have estimated the costs for doing so, as noted 

below). Manufacturers have legitimately stated that use of DEAC on 4 cylinder engines would 

cause unacceptable NVH; therefore, as in the 2012-2016 rule and the TAR, the agencies are not 

applying cylinder deactivation to 4-cylinder engines in evaluating potential emission 

reductions/fuel economy improvements and attendant costs. 

Cylinder deactivation has seen a recent resurgence thanks to better valvetrain designs and engine 

controls. General Motors and Chrysler Group have incorporated cylinder deactivation across a 

substantial portion of their V8-powered lineups. Honda also offers V6 models (Odyssey, Pilot) 

with cylinder deactivation. 

Effectiveness improvements scale roughly with engine displacement-to-vehicle weight ratio: the 

higher displacement-to-weight vehicles, operating at lower relative loads for normal driving, 

have the potential to operate in part-cylinder mode more frequently. 

NHTSA and EPA reviewed effectiveness estimates from MYs2012-2016 final rule, TAR, and 

the FRIA for the heavy-duty GHG and fuel consumption rule. Previous estimates ranged from a 

6 percent reduction in CO2 emissions depending on vehicle class for the OMEGA model, which 

uses technology packages. The following ranges were used in the CAFE model, due to its 

incremental nature, depending on the engine valvetrain configuration: for DOHC engines which 

are already equipped with DCP and DVVLD, only up to 0.5 percent for DEACD; for SOHC 

engines which have CCP and DVVLS applied, from 2.5 to 3 percent for DEACS; and for OHV 

engines, without VVT or VVL technologies, from 3.9 to 5.5 percent for DEACO. 

For this final rule, consistent with the proposal, the agencies, taking into account the additional 

review and the work performed for the Ricardo study, have revised the estimates for cylinder 

deactivation. The effectiveness for relative to the base engine is 4.7 to 6.5 percent based on the 

lumped parameter model. Because of the incremental nature of the CAFE model, NHTSA used 

the effectiveness range of 0.44 to 0.66 percent incremental for SOHC and DOHC applications, 

and for OHV applications, the effectiveness was increased slightly with a range of 4.66 to 6.30 

percent. 

In the 2012-2016 rule and the 2010 TAR, the agencies used a DMC estimate of $140 (2007$) 

and $157 (2007$) for cylinder deactivation technology on V6 and V8 engines, respectively. The 

DMCs become $146 (2010$) and $165 (2010$) for this analysis and are considered applicable in 

MY 2015. This technology is considered to be on the flat-portion of the learning curve. The 

agencies have applied a low complexity ICM of 1.24 to this technology through 2018 and a longterm ICM of 1.19 thereafter. The resultant costs are shown in Table V-40. 
                                                      

296 

Table V-40 Costs for Cylinder Deactivation (2010$) 

Cost 

type 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC V6 $139 $136 $134 $131 $128 $126 $123 $121 $118 

DMC V8 $157 $153 $150 $147 $144 $142 $139 $136 $133 

IC V6 $56 $56 $42 $42 $42 $42 $42 $42 $42 

IC V8 $63 $63 $47 $47 $47 $47 $47 $47 $47 

TC V6 $196 $193 $176 $173 $170 $168 $165 $162 $160 

TC V8 $220 $217 $198 $195 $191 $189 $186 $183 $180 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

If lost motion devices are on the engine from the application of DVVL, the cost of DEACS and 

DEACD, for SOHC and DOHC engines respectively, would be $32 in MY 2017. This $32 

accounts for the potential additional application of active engine mounts on SOHC and DOHC 

engines.225 Further, this SOHC and DOHC engine estimate is relevant to the CAFE model only, 

because the OMEGA model does not apply technologies in the same incremental fashion as the 

CAFE model. 

Stoichiometric Gasoline Direct Injection (SGDI) 

Stoichiometric gasoline direct injection (SGDI), or Spark Ignition Direct injection (SIDI), 

engines inject fuel at high pressure directly into the combustion chamber (rather than the intake 

port in port fuel injection). SGDI requires changes to the injector design, an additional high 

pressure fuel pump, new fuel rails to handle the higher fuel pressures and changes to the cylinder 

head and piston crown design. Direct injection of the fuel into the cylinder improves cooling of 

the air/fuel charge within the cylinder, which allows for higher compression ratios and increased 

thermodynamic efficiency without the onset of combustion knock. Recent injector design 

advances, improved electronic engine management systems and the introduction of multiple 

injection events per cylinder firing cycle promote better mixing of the air and fuel, enhance 

combustion rates, increase residual exhaust gas tolerance and improve cold start emissions. 

SGDI engines achieve higher power density and match well with other technologies, such as 

boosting and variable valvetrain designs. 

Several manufacturers are currently manufacturing vehicles with SGDI engines, including 

VW/Audi, BMW, Toyota, Ford, and General Motors among others with plans to increase the 

number of SGDI engines across their portfolios. 

225 The $32 cost for active engine mounts comes from the $75 (RPE) estimate used in the MY 2011 final rule that 

was then adjusted to account for the use of the ICM instead of the RPE. The cost is then divided by two due to the 

assumption that only half the applications would require active engine mounts to meet NVH targets. 
                                                      

 

 

297 

NHTSA and EPA reviewed effectiveness estimates from the 2012-2016 final rule and TAR, 

which employed an effectiveness range for SGDI of between 2 and 3 percent. NHTSA and EPA 

reviewed estimates from the Alliance of Automobile Manufactures, which projects 3 percent 

gains in fuel efficiency and a 7 percent improvement in torque. The torque increase provides the 

opportunity to downsize the engine, allowing an increase in efficiency of up to 5.8 percent. 

NHTSA and EPA also reviewed other published literature reporting 3 percent effectiveness for 

SGDI.226 Confidential manufacturer data reported an efficiency effectiveness range of 1 to 2 

percent. Based on data from the recent Ricardo study and reconfiguration of the new lumped 

parameter model, EPA and NHTSA have revised this value to 1.5 percent227. Combined with 

other technologies (i.e., boosting, downsizing, and in some cases, cooled EGR), SGDI can 

achieve greater reductions in fuel consumption and CO2 emissions compared to engines of 

similar power output. 

The NHTSA and EPA cost estimates for SGDI take into account the changes required to the 

engine hardware, engine electronic controls, ancillary and NVH mitigation systems. Through 

contacts with industry NVH suppliers, and manufacturer press releases, the agencies believe that 

the NVH treatments will be limited to the mitigation of fuel system noise, specifically from the 

injectors and the fuel lines and have included corresponding cost estimates for these NVH 

controls. In the 2012-2016 final rule analysis, the agencies estimated the DMC for SGDI at $213 

(2007$), $321 (2007$) and $386 (2007$) for I3/I4, V6 and V8 engines, respectively. These 

DMCs become $222 (2010$), $334 (2010$) and $402 (2010$) or $56, $56 and $51 per cylinder 

for this analysis, all of which are considered applicable in MY 2012. Because the CAFE model 

uses cost per cylinder for this technology, NHTSA averaged the cost per cylinder for 4, 6 and 8 

cylinder engines into a cost of $54 (2010$) per cylinder for application in the CAFE model. This 

technology is considered to be on the flat-portion of the learning curve. The agencies have 

applied a medium complexity ICM of 1.39 to this technology through 2018 and a long-term ICM 

of 1.29 thereafter. The resultant costs are shown in Table V-41. 

Table V-41 Costs per Cylinder for Stoichiometric Gasoline Direct Injection (2010$) 

Index 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $47 $46 $45 $44 $43 $42 $41 $40 $40 

IC $20 $20 $15 $15 $15 $15 $15 $15 $15 

TC $67 $66 $60 $59 $58 $57 $56 $55 $55 

226 Paul Whitaker, Ricardo, Inc., “Gasoline Engine Performance And Emissions – Future Technologies and 

Optimization,” ERC Symposium, Low Emission Combustion Technologies for Future IC Engines, Madison, WI, 

June 8-9, 2005, Docket No. NHTSA-2010-0131. Available at 

http://www.erc.wisc.edu/symposiums/2005_Symposium/June%208%20PM/Whitaker_Ricardo.pdf (last accessed 

Nov. 4, 2011). 

227 However, because GDI is a key enabler for modern, highly downsized turbocharged engines, this difference will 

be overshadowed by the higher effectiveness for turbocharging and downsizing when they are combined. 
                                                      

298 

 DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

base engine. 

Turbocharging and Downsizing (TRDBS) 

The specific power of a naturally aspirated engine is primarily limited by the rate at which the 

engine is able to draw air into the combustion chambers. Turbocharging and supercharging 

(grouped together here as boosting) are two methods to increase the intake manifold pressure and 

cylinder charge-air mass above naturally aspirated levels. Boosting increases the airflow into the 

engine, thus increasing the specific power level, and with it the ability to reduce engine 

displacement while maintaining performance. This effectively reduces the pumping losses at 

lighter loads in comparison to a larger, naturally aspirated engine. 

Almost every major manufacturer currently markets a vehicle with some form of boosting. 

While boosting has been a common practice for increasing performance for several decades, 

turbocharging has considerable potential to improve fuel economy and reduce CO2 emissions 

when the engine displacement is also reduced. Specific power levels for a boosted engine often 

exceed 100 hp/L compared to naturally aspirated engine average power densities of 

approximately 70 hp/L. As a result, engines can be downsized roughly 30 percent or more while 

maintaining similar peak output levels. 

In the last decade, improvements to turbocharger turbine and compressor design have improved 

their reliability and performance across the entire engine operating range. New variable 

geometry turbines and ball-bearing center cartridges allow faster turbocharger spool-up (virtually 

eliminating the once-common “turbo lag”) while maintaining high flow rates for increased boost 

at high engine speeds. Low speed torque output has been dramatically improved for modern 

turbocharged engines. However, even with turbocharger improvements, maximum engine 

torque at very low engine speed conditions (for example, launch from standstill) is increased less 

than at mid and high engine speed conditions. In order to provide adequate acceleration from 

standstill, particularly up grades or at high altitudes, the potential to downsize engines may be 

less on vehicles with low displacement to vehicle mass ratios (for example, a very small 

displacement engine in a vehicle with significant curb weight). 

Use of GDI systems with turbocharged engines and air-to-air charge air cooling also reduces the 

fuel octane requirements for knock limited combustion and allows the use of higher compression 

ratios. Ford’s “Ecoboost” downsized, turbocharged GDI engines introduced on MY 2010 

vehicles allow the replacement of V8 engines with V6 engines with improved in 0-60 mph 

acceleration and with fuel economy improvements of up to 12 percent.228 

228 “Development and Optimization of the Ford 3.5L V6 EcoBoost Combustion System,” Yi,J., Wooldridge, S., 

Coulson, G., Hilditch, J. Iyer, C.O., Moilanen, P., Papaioannou, G., Reiche, D. Shelby, M., VanDerWege, B., 
 

                                                                                                                                                                              

 

 

 

 

299 

Recently published data with advanced spray-guided injection systems and more aggressive 

engine downsizing targeted towards reduced fuel consumption and CO2 emissions reductions 

indicate that the potential for reducing CO2 emissions for turbocharged, downsized GDI engines 

may be as much as 15 to 30 percent relative to port-fuel-injected engines.229 230 231 232 233 

Confidential manufacturer data suggests an incremental range of fuel consumption reduction of 

4.8 to 7.5 percent for turbocharging and downsizing. Other publicly-available sources suggest a 

fuel consumption reduction of 8 to 13 percent compared to current-production naturallyaspirated engines without friction reduction or other fuel economy technologies: a joint technical 

paper by Bosch and Ricardo suggests a fuel economy gain of 8 to 10 percent is possible for 

downsizing from a 5.7 liter port injection V8 to a 3.6 liter V6 with direct injection using a wallguided direct injection system;234 a Renault report suggests a 11.9 percent NEDC fuel 

consumption gain for downsizing from a 1.4 liter port injection in-line 4-cylinder engine to a 1.0 

liter in-line 4-cylinder engine, also with wall-guided direct injection;235 and a Robert Bosch 

paper suggests a 13 percent NEDC gain for downsizing to a turbocharged DI engine, again with 

wall-guided injection.236 237 These reported fuel economy benefits show a wide range depending 

on the SGDI technology employed. 

Weaver, C. Xu, Z., Davis, G., Hinds, B. Schamel, A. SAE Technical Paper No. 2009-01-1494, 2009, Docket EPAHQ-OAR-2009-0472-2860.

229 Cairns et al., Lotus, “Low Cost Solutions for Improved Fuel Economy in Gasoline Engines,” Global Powertrain
 

Congress September 27-29, 2005, vol. 33. Available at http://www.gpc-icpem.org/pages/publications.html (last 

accessed March 15, 2010). 

230 Tim Lake, John Stokes, Richard Murphy, and Richard Osborne of Ricardo and Andreas Schamel of FordWerke, “Turbocharging Concepts for Downsized DI Gasoline Engines,” VKA/ika Aachen Colloquium 2003. 

Available at http://cat.inist.fr/?aModele=afficheN&cpsidt=16973598 (last accessed Nov. 9, 2011). 

231 “Interim Report: New Powertrain Technologies and Their Projected Costs,” October 2005, EPA420-R-05-012.
 

Docket NHTSA-2010-0131. Available at http://www.epa.gov/otaq/technology/420r05012.pdf (last accessed 

November 14, 2011)
 

232 “Cost and Fuel Economy Comparison of Diesel and Gasoline Powertrains in Passenger Cars and Light Trucks,” 

submitted by FEV Engine Technology, Inc., April 23, 2003, contained as Appendix I within EPA Interim Technical 

Report EPA420-R-04-002. Docket N0o. NHTSA-2010-0131 

233 “Electric Cars: Plugged In, Batteries must be included,” Deutsche Bank Global Markets Research Company,
 

June 9, 2008. Docket NHTSA-2010-0131 or Available at 

http://www.inrets.fr/fileadmin/recherche/transversal/pfi/PFI_VE/pdf/deutch_bank_electric_cars.pdf (last accessed 

November 14, 2011)

234 David Woldring and Tilo Landenfeld of Bosch, and Mark J. Christie of Ricardo, “DI Boost: Application of a
 

High Performance Gasoline Direct Injection Concept,” SAE 2007-01-1410. Available at 

http://www.sae.org/technical/papers/2007-01-1410 (last accessed August. 8, 2012) 

235 Yves Boccadoro, Loïc Kermanac’h, Laurent Siauve, and Jean-Michel Vincent, Renault Powertrain Division, 

“The New Renault TCE 1.2L Turbocharged Gasoline Engine,” 28th Vienna Motor Symposium, April 2007.

236 Tobias Heiter, Matthias Philipp, Robert Bosch, “Gasoline Direct Injection: Is There a Simplified, Cost-Optimal
 

System Approach for an Attractive Future of Gasoline Engines?” AVL Engine & Environment Conference, 

September 2005. Docket No. NHTSA-2010-0131 

237 NEDC is the New European Driving Cycle. It was created to represent the typical driving pattern in Europe and 

is used in the EU emission and fuel economy certification tests. The cycle consists of the old European driving cycle 

(ECE15) and an Extra-Urban driving cycle (EUDC)
 
                                                      

300 

NHTSA and EPA reviewed estimates from MYs 2012-2016 final rule, the TAR, and existing 

public literature. The previous estimate from the MYs 2012-2016 assumed a 12 to 14 percent 

absolute effectiveness improvement, which included low friction lubricant (level one), engine 

friction reduction (level one), DCP, DVVL and SGDI, over a baseline fixed-valve engines, 

similar to the estimate for Ford’s Ecoboost engine, which is already in production. Additionally, 

the agencies analyzed Ricardo vehicle simulation data for various turbocharged engine packages. 

Based on this data, and considering the widespread nature of the public estimates, the agencies 

believe that the effectiveness of turbocharging and downsizing is highly dependent upon 

implementation and degree of downsizing. 

Given these variances, for this final rule, consistent with the proposal, the agencies evaluated 4 

different levels of downsized and turbocharged high Brake Mean Effective Pressure (BMEP)238 

engines: 18-bar (TRBDS1), 24-bar (TRBDS2), 24-bar with cooled exhaust gas recirculation 

(CEGR1), and 27-bar with cooled EGR (CEGR2). All engines are assumed to include gasoline 

direct injection (SGDI), and thus the effectiveness values for TRBDS include the benefits of this 

technology. In addition, the agencies believe that in order to implement in production a 27-bar 

level engine, it is necessary to incorporate cooled exhaust gas recirculation (EGR), and also to 

require a 2-stage turbocharger as well as engine changes to increase robustness of the engine to 

allow the engine to operate at these higher BMEP levels. The cooled EGR technology is 

discussed later in this section. To mitigate potential issues with launch performance for these 

highly downsized engines, NHTSA does not allow the application of 24- or 27-bar engines 

unless the vehicle utilizes an 8-speed automatic or DCT transmission or a 6-speed manual 

transmission. This requirement helps to ensure that the transmission’s gear ratio spread can 

accommodate a lower first gear, a.k.a. “granny gear”, to aid in launching the vehicle from a 

complete stop. Table V-42 lists the possible engine downsizing options that the agencies 

considered in this FRM analysis. 

Table V-42 Possible Engine Downsizing Options 

Base 

Engine 

18-bar 

Engine 

24-bar 

Engine 

27-bar 

Engine 

I4 I4 I3 I3 

V6 I4 I4 I4 

V8+ V6 V6 I4 

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

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

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

BMEP value contributes to higher overall efficiency. 
                                                      

301 

NHTSA and EPA have revised the effectiveness estimate for TRBDS to reflect the new Ricardo 

work, and now assume that turbocharging and downsizing, alone, will provide a 12 to 24.6 

percent absolute effectiveness improvement (depending on the degree of downsizing and boost 

levels) over naturally aspirated, fixed-valve engines. More specifically, 12.1 to 14.9 percent for 

18-bar engines, which is equal to the boost levels evaluated in the MYs 2012-2016 final rule, 

assuming 33 percent downsizing; 16.4 to 20.1 percent for 24-bar engines, assuming 50 percent 

downsizing; 19.3 to 23.0 percent for 24-bar engines with cooled EGR, assuming 50 percent 

downsizing; and 20.6 to 24.6 percent for 27-bar engines with cooled EGR, assuming 56 percent 

downsizing. For comparison purposes, an 18-bar engine with low friction lubricant (level one), 

engine friction reduction (level one), DCP, DVVL and SGDI, which as stated above was 

assumed to yield a 12 to 14 absolute effectiveness in the MYs 2012-2016 analysis, now results 

in a 16.8 to 20.9 percent absolute effectiveness improvement. Coupling turbocharging and 

downsizing with low friction lubricant (level one and two), engine friction reductions (level one 

and two), DCP, DVVL and SGDI, for the MYs 2017-2025 timeframe, yields 18.0 to 22.4 percent 

for 18-bar engines 20.4 to 25.2 percent for 24-bar engines, 23.2 to 27.9 percent for 24-bar engine 

with cooled EGR, and 24.0 to 28.8 percent for 27-bar with cooled EGR over naturally aspirated, 

fixed-valve engines. Thus, these changes have contributed significantly to the agencies’ ability 

to assume improvements in fuel economy during the rulemaking timeframe. 

As noted above, the agencies relied on engine teardown analyses conducted by EPA, FEV and 

Munro to develop costs for turbocharged GDI engines.239 Based on that work, in the 2012-2016 

final rule, the agencies estimated the DMC for turbocharging to 18 bar BMEP at $404 (2007$) 

and $681 (2007$) for I4 and V6/V8 engines, respectively, where the higher cost for the Vconfiguration engines represents twin turbochargers versus the single turbocharger in the Iconfiguration engine. Converting to 2010$, these DMCs become $420 and $708, respectively, 

for this analysis. For the higher BMEP engines, in the 2010 TAR, the agencies assumed costs 

for 24 bar BMEP turbocharging of 1.5x the cost of the 18 bar BMEP technology, and also 

assumed single stage turbo for these 24 bar BMEP engine. This additional cost covered the 

incremental cost increase of a variable geometry turbocharger (see 2010 TAR at page B-12). 

Using this methodology, the DMC for 24 bar BMEP would be $630 (2010$) and $1,062 (2010$) 

for I-configuration and V-configuration engines, respectively. Similarly, for this final rule the 

agencies are assuming the DMC of the 27 bar BMEP technology is 2.5x the DMC of the 18 bar 

BMEP technology, or $1,050 (2010$) and $1,771 (2010$) for I-configuration and Vconfiguration engines, respectively. For these 27 bar BMEP engine, the agencies assumed two 

stage turbos would be used to reach these boost levels. All turbocharger-related DMCs are 

considered applicable in MY 2012. The agencies consider each turbocharger technology to be 

on the flat portion of the learning curve and have applied a medium complexity ICM of 1.39 

239 U.S. Environmental Protection Agency, “Draft Report – Light-Duty Technology Cost Analysis Pilot Study,” 

Contract No. EP-C-07-069, Work Assignment 1-3, September 3, 2009, Docket No NHTSA-2010-0131. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

302 

through 2018 for 18 bar and through 2024 for 24 and 27 bar, then a long-term ICM of 1.29 to 

each thereafter. The resultant costs are shown in Table V-43. 

Table V-43 Costs for Turbocharging (2010$) 

Cost 

type 

Technology 

(BMEP) 

Engine 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC 18 bar I-engine $365 $357 $350 $343 $336 $330 $323 $316 $310 

DMC 18 bar Vengine $614 $602 $590 $578 $567 $555 $544 $533 $523 

DMC 24 bar I-engine $547 $536 $525 $515 $504 $494 $484 $475 $465 

DMC 24 bar Vengine $922 $903 $885 $867 $850 $833 $816 $800 $784 

DMC 27 bar I-engine $911 $893 $875 $858 $841 $824 $807 $791 $775 

DMC 27 bar Vengine $1,536 $1,505 $1,475 $1,446 $1,417 $1,389 $1,361 $1,334 $1,307 

IC 18 bar I-engine $160 $160 $120 $119 $119 $119 $119 $118 $118 

IC 18 bar Vengine $270 $270 $202 $201 $201 $200 $200 $200 $199 

IC 24 bar I-engine $240 $240 $239 $239 $238 $238 $238 $237 $177 

IC 24 bar Vengine $405 $404 $403 $403 $402 $401 $400 $400 $299 

IC 27 bar I-engine $401 $400 $399 $398 $397 $397 $396 $395 $296 

IC 27 bar Vengine $675 $674 $672 $671 $670 $669 $667 $666 $499 

TC 18 bar I-engine $525 $517 $470 $462 $455 $448 $442 $435 $428 

TC 18 bar Vengine $885 $872 $792 $779 $768 $756 $744 $733 $722 

TC 24 bar I-engine $787 $776 $765 $754 $743 $732 $722 $712 $643 

TC 24 bar Vengine $1,327 $1,308 $1,289 $1,270 $1,252 $1,234 $1,217 $1,200 $1,083 

TC 27 bar I-engine $1,312 $1,293 $1,274 $1,256 $1,238 $1,220 $1,203 $1,186 $1,071 

TC 27 bar Vengine $2,211 $2,179 $2,148 $2,117 $2,087 $2,057 $2,028 $2,000 $1,805 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

The cost for the downsizing portion of the turbo/downsize technology is more complex. The 

agencies have described those costs and how they were developed—based primarily on FEV 

teardowns but some were scaled to generate costs for downsizing situations that were not 

covered by teardowns—in both MYs 2012-2016 final rule and the TAR. The DMCs used for 

this analysis are identical to those used in the TAR, except that they have been updated to 2010 

dollars. We note that many of the downsizing costs are negative because they result in fewer 

parts and less material than the engine from which they are “derived.” For example, a V8 engine 

could be replaced by a turbocharged V6 engine having two fewer cylinders and as many as eight 

fewer valves (in the case of a V8 DOHC downsized to a V6 DOHC). However, the agencies’ 

approach to calculating indirect costs results in positive indirect costs regardless of whether the 

DMC is positive or negative. This is done by calculating indirect costs based on the absolute 
 

 

 

 

                                                      

 

 

303 

value of the DMC, then adding the indirect cost to the DMC to arrive at the total cost. This way, 

the agencies are never making a negative DMC “more negative” when accounting for the 

indirect costs. This approach has been used in MYs 2012-2016 final rule and in the TAR. Given 

the history of the downsizing costs used by the agencies, many are considered applicable in MY 

2012 and many in MY 2017.240 All are considered to be on the flat portion of the learning curve. 

The agencies have applied a medium complexity ICM of 1.39 through 2018 and a long-term 

ICM of 1.29 thereafter. The resultant costs are shown in 

Table V-44. 

Table V-44 Costs for Engine Downsizing (2010$) 

Cost 

type Technology 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC I4 DOHC to I3 -174 -171 -167 -164 -161 -157 -154 -151 -148 

DMC I4 DOHC to I4 -77 -75 -74 -72 -71 -69 -68 -67 -65 

DMC V6 DOHC to I4 -494 -484 -474 -465 -455 -446 -437 -429 -420 

DMC V6 SOHC 2V to 

I4 -345 -338 -331 -325 -318 -312 -306 -300 -294 

DMC V6 OHV to I4 281 272 264 256 249 241 236 232 227 

DMC V8 DOHC to I4 -854 -828 -804 -779 -756 -733 -719 -704 -690 

DMC V8 DOHC to V6 -247 -242 -237 -233 -228 -223 -219 -215 -210 

DMC V8 SOHC 2V to 

I4 -656 -637 -617 -599 -581 -564 -552 -541 -530 

DMC V8 SOHC 3V to 

I4 -731 -709 -687 -667 -647 -627 -615 -603 -591 

DMC V8 SOHC 2V to 

V6 -76 -74 -73 -71 -70 -68 -67 -66 -64 

DMC V8 SOHC 3V to 

V6 -140 -137 -135 -132 -129 -127 -124 -122 -119 

DMC V8 OHV to I4 -242 -234 -227 -220 -214 -207 -203 -199 -195 

DMC V8 OHV to V6 328 318 308 299 290 281 276 270 265 

IC I4 DOHC to I3 77 76 57 57 57 57 57 57 57 

IC I4 DOHC to I4 34 34 25 25 25 25 25 25 25 

IC V6 DOHC to I4 217 217 162 162 161 161 161 161 160 

IC V6 SOHC 2V to 

I4 152 151 113 113 113 113 112 112 112 

240 The engine downsizing costs based on actual FEV teardowns were considered applicable to the 2012MY, as was 

explained for some downsizing costs in the 2012-2016 final rule and others in the TAR. For other downsizing 

costs—the two changes from OHV engines to DOHC engines—the agencies did not use FEV teardowns or 

extrapolations from FEV teardowns, and instead used the methodology employed in the 2008 EPA Staff Report, a 

methodology determined to result in cost estimates more appropriate for MY 2017. The new downsizing costs— 

those for V8 engines downsized to I4 engines—use a combination of V8 to V6 then V6 to I4 downsizing costs and 

are considered applicable to MY 2017 within the context of this analysis. 
 

 

304 

IC V6 OHV to I4 109 108 81 81 80 80 80 80 80 

IC V8 DOHC to I4 331 330 246 245 244 244 243 243 242 

IC V8 DOHC to V6 109 108 81 81 81 81 80 80 80 

IC V8 SOHC 2V to 

I4 254 253 189 188 188 187 187 187 186 

IC V8 SOHC 3V to 

I4 283 282 210 210 209 208 208 208 207 

IC V8 SOHC 2V to 

V6 33 33 25 25 25 25 25 25 25 

IC V8 SOHC 3V to 

V6 62 61 46 46 46 46 46 46 45 

IC V8 OHV to I4 94 93 70 69 69 69 69 69 69 

IC V8 OHV to V6 127 126 94 94 94 93 93 93 93 

TC I4 DOHC to I3 -98 -94 -110 -107 -104 -101 -98 -95 -92 

TC I4 DOHC to I4 -43 -41 -48 -47 -46 -44 -43 -42 -40 

TC V6 DOHC to I4 -277 -267 -312 -303 -294 -285 -277 -268 -260 

TC V6 SOHC 2V to 

I4 -193 -187 -218 -212 -205 -199 -193 -187 -182 

TC V6 OHV to I4 390 381 345 337 329 321 316 311 307 

TC V8 DOHC to I4 -523 -499 -558 -534 -512 -490 -476 -462 -448 

TC V8 DOHC to V6 -139 -134 -156 -152 -147 -143 -138 -134 -130 

TC V8 SOHC 2V to 

I4 -402 -383 -429 -411 -393 -376 -365 -355 -344 

TC V8 SOHC 3V to 

I4 -448 -427 -477 -457 -438 -419 -407 -395 -383 

TC V8 SOHC 2V to 

V6 -42 -41 -48 -46 -45 -44 -42 -41 -40 

TC V8 SOHC 3V to 

V6 -79 -76 -89 -86 -83 -81 -78 -76 -74 

TC V8 OHV to I4 -148 -141 -158 -151 -145 -139 -134 -131 -127 

TC V8 OHV to V6 454 444 403 393 384 375 369 363 358 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline; all 

resultant engines are DOHC.
 

The agencies note that the V8 to I4 engine downsize is new for this final rule, consistent with the 

proposal. This level of engine downsizing is considered for this analysis only if it also includes 

27 bar BMEP turbo boost which requires the addition of cooled EGR (discussed below). As a 

result, any 27 bar BMEP engine in this analysis will be I4 configuration and include cooled 

EGR. 

With the information shown in Table V-43 and 

Table V-44, the costs for any turbo/downsize change considered by the agencies can be 

determined. These costs are shown in Table V-45. 

Table V-45 Total Costs for Turbo and Downsizing (2010$) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

305 

Downsize 

Technology 

Turbo 

Technolo 

gy 

(BMEP) 

2017 2018 2019 2020 2021 2022 2023 2024 2025 

I4 DOHC to I3 18 bar $427 $423 $359 $356 $352 $348 $344 $340 $337 

I4 DOHC to I3 24 bar $690 $681 $654 $647 $639 $632 $624 $617 $551 

I4 DOHC to I3 27 bar $1,214 $1,199 $1,164 $1,149 $1,134 $1,120 $1,106 $1,092 $979 

I4 DOHC to I4 18 bar $482 $476 $421 $415 $410 $404 $399 $393 $388 

I4 DOHC to I4 24 bar $744 $734 $716 $707 $697 $688 $679 $670 $602 

I4 DOHC to I4 27 bar $1,269 $1,251 $1,226 $1,209 $1,192 $1,176 $1,160 $1,145 $1,031 

V6 DOHC to I4 18 bar $248 $250 $157 $159 $161 $163 $165 $167 $169 

V6 DOHC to I4 24 bar $510 $508 $452 $450 $449 $447 $445 $444 $383 

V6 DOHC to I4 27 bar $1,035 $1,026 $962 $953 $944 $935 $927 $918 $811 

V6 SOHC 2V to I4 18 bar $331 $330 $251 $251 $250 $249 $248 $248 $247 

V6 SOHC 2V to I4 24 bar $594 $589 $546 $542 $537 $533 $529 $524 $461 

V6 SOHC 2V to I4 27 bar $1,119 $1,106 $1,056 $1,044 $1,032 $1,021 $1,010 $999 $890 

V6 OHV to I4 18 bar $914 $898 $815 $799 $784 $770 $758 $746 $735 

V6 OHV to I4 24 bar $1,177 $1,156 $1,110 $1,090 $1,072 $1,053 $1,038 $1,023 $949 

V6 OHV to I4 27 bar $1,701 $1,674 $1,619 $1,593 $1,567 $1,542 $1,519 $1,498 $1,378 

V8 DOHC to I4 18 bar $1 $18 -$88 -$72 -$56 -$41 -$34 -$27 -$19 

V8 DOHC to I4 24 bar $264 $277 $207 $219 $231 $243 $246 $250 $195 

V8 DOHC to I4 27 bar $789 $794 $716 $722 $726 $731 $728 $725 $623 

V8 DOHC to V6 18 bar $746 $738 $635 $628 $620 $613 $606 $599 $592 

V8 DOHC to V6 24 bar $1,188 $1,174 $1,132 $1,118 $1,105 $1,092 $1,078 $1,066 $953 

V8 DOHC to V6 27 bar $2,073 $2,045 $1,991 $1,965 $1,940 $1,914 $1,890 $1,866 $1,675 

V8 SOHC 2V to I4 18 bar $123 $134 $41 $52 $62 $72 $76 $80 $84 

V8 SOHC 2V to I4 24 bar $385 $392 $336 $343 $350 $356 $357 $357 $298 

V8 SOHC 2V to I4 27 bar $910 $910 $846 $845 $845 $844 $838 $832 $727 

V8 SOHC 3V to I4 18 bar $77 $90 -$8 $5 $18 $29 $35 $40 $45 

V8 SOHC 3V to I4 24 bar $339 $349 $287 $296 $305 $313 $315 $317 $259 

V8 SOHC 3V to I4 27 bar $864 $866 $797 $799 $800 $801 $796 $791 $688 

V8 SOHC 2V to V6 18 bar $842 $831 $744 $733 $723 $712 $702 $692 $682 

V8 SOHC 2V to V6 24 bar $1,284 $1,267 $1,241 $1,224 $1,207 $1,191 $1,175 $1,159 $1,043 

V8 SOHC 2V to V6 27 bar $2,169 $2,138 $2,100 $2,071 $2,042 $2,014 $1,986 $1,959 $1,766 

V8 SOHC 3V to V6 18 bar $806 $796 $703 $693 $684 $675 $666 $657 $648 

V8 SOHC 3V to V6 24 bar $1,248 $1,232 $1,200 $1,184 $1,169 $1,153 $1,138 $1,124 $1,010 

V8 SOHC 3V to V6 27 bar $2,133 $2,103 $2,059 $2,031 $2,003 $1,976 $1,950 $1,924 $1,732 

V8 OHV to I4 18 bar $377 $376 $312 $311 $311 $310 $307 $304 $302 

V8 OHV to I4 24 bar $639 $635 $607 $602 $598 $594 $587 $581 $516 

V8 OHV to I4 27 bar $1,164 $1,152 $1,116 $1,105 $1,093 $1,082 $1,069 $1,056 $944 

V8 OHV to V6 18 bar $1,339 $1,316 $1,194 $1,172 $1,151 $1,131 $1,113 $1,096 $1,080 

V8 OHV to V6 24 bar $1,781 $1,752 $1,691 $1,663 $1,636 $1,609 $1,586 $1,563 $1,441 

V8 OHV to V6 27 bar $2,666 $2,623 $2,550 $2,510 $2,471 $2,432 $2,397 $2,363 $2,163 

All costs are total costs (Direct manufacturing costs + Indirect costs); all costs are relative to the 

baseline; all resultant engines are DOHC; note that costs are shown for 27 bar BMEP engines 

with V6 engines. In fact, the agencies do not believe that manufacturers will employ 27 bar 

BMEP technology on V6 engines to comply with the final standards, instead using the additional 

boost to allow for downsizing V6 engines to smaller I4 engines than would be used for 18 bar 

BMEP or 24 bar BMEP I4 engines and/or downsizing V8 engines to I4 engines. As a result, 

whenever a 27 bar BMEP engine is chosen by either agency’s model, the engine configuration 

will be an I4 and will include cooled EGR, as discussed above. 

Cooled Exhaust Gas Recirculation/EGR Boost (CEGR) 
                                                      

 

 

 

306 

Cooled exhaust gas recirculation (CEGR) or “boosted” EGR is a combustion concept that 

involves utilizing EGR as a charge diluent for controlling combustion temperatures and cooling 

the EGR prior to its introduction to the combustion system. Higher exhaust gas residual levels at 

part load conditions reduce pumping losses for increased fuel economy. The additional charge 

dilution enabled by cooled EGR reduces the incidence of knocking combustion and obviates the 

need for fuel enrichment or higher octane fuel at high engine power. This allows for higher 

boost pressure and/or compression ratio and further reduction in engine displacement and both 

pumping and friction losses while maintaining performance. Engines of this type use GDI and 

both dual cam phasing and discrete variable valve lift. 

In the TAR, the agencies considered this technology as an advanced gasoline engine technology 

because it was considered an emerging and not yet available technology in the light-duty 

gasoline vehicle market. For the MYs 2012-2016 final rule and TAR, NHTSA and EPA 

assumed a 5 percent fuel consumption effectiveness for cooled EGR compared to a conventional 

downsized DI turbocharged engine. 241,242 While a cooled or “boosted” EGR technology was 

discussed in the MYs 2012-2016 rulemaking documents, the technology considered in this 

rulemaking is comparatively more advanced than the version described in the TAR. The 

agencies have therefore considered new costs and new effectiveness values for it. The 

effectiveness values used for engines with CEGR within this analysis were assumed by EPA and 

Ricardo to be conservative estimate of system performance at approximately 24-bar BMEP. 

Vehicle simulation modeling of technology packages using the more highly boosted and 

downsized cooled EGR engines (up to 27-bar BMEP, and utilizing EGR rates of 20-25%) with 

dual-stage turbocharging has been completed as part of EPA’s contract with Ricardo as 

described in TSD Section 3.3.1.2. 

For this FRM, consistent with the proposal, the agencies have updated the effectiveness of 

engines with CEGR using the new Ricardo vehicle simulation modeling runs. For 24-bar BMEP 

engines with CEGR, designated in the CAFE model inputs as CEGR1, would use a dual-loop 

system with both high and low pressure EGR loops and dual EGR coolers. The engines would 

also use single-stage, variable geometry turbocharging with higher intake boost pressure 

available across a broader range of engine operation than conventional turbocharged SI engines. 

Such a system is estimated to be capable of an additional 3 to 5 percent effectiveness relative to a 

turbocharged, downsized GDI engine without CEGR.243,244 The agencies have also considered a 

241 Cairns et al., Lotus, “Low Cost Solutions for Improved Fuel Economy in Gasoline Engines,” Global Powertrain
 

Congress September 27-29, 2005, vol. 33. 

242 Tim Lake, John Stokes, Richard Murphy, and Richard Osborne of Ricardo and Andreas Schamel of Ford-Werke, 

“Turbocharging Concepts for Downsized DI Gasoline Engines,” VKA/ika Aachen Colloquium 2003. Available at
 

http://cat.inist.fr/?aModele=afficheN&cpsidt=16973598 (last accessed Nov. 7, 2011). 243 Kaiser, M., Krueger, U., Harris, R., Cruff, L. “Doing More with Less - The Fuel Economy Benefits of Cooled
 

EGR on a Direct Injected Spark Ignited Boosted Engine,” SAE Technical Paper Series, No. 2010-01-0589.
 
 

                                                                                                                                                                              

307 

more advanced version of CEGR for 27-bar BMEP engines, designated in the CAFE model 

inputs as CEGR2, that employs very high combustion pressures by using dual stage 

turbocharging, developed by Ricardo as part of the simulation modeling work supporting this 

rulemaking. The agencies have considered both of these CEGR approaches for this final rule, 

consistent with the proposal. 

Based on the data from the Ricardo and Lotus reports, NHTSA and EPA estimate the 

incremental reduction in fuel consumption for CEGR to be 5 percent over a turbocharged and 

downsized DI engine. Thus, if CEGR is applied to 24-bar engine, multiplicatively combining 

the 19.3 percent from the turbocharging and downsizing (TRBDS2) to the 5 percent gain from 

CEGR results in total fuel consumption reduction of 22.1 percent for CEGR1. This is in 

agreement with the range suggested in the Lotus and Ricardo reports. 

In the 2010 TAR, the agencies estimated the DMC of the cooled EGR system at $240 (2007$, 

see 2010 TAR at page B-12). This DMC becomes $244 (updated to 2010$) for this analysis. 

This DMC is considered applicable in MY 2012. The agencies consider CEGR technology to be 

on the flat portion of the learning curve and have applied a medium complexity ICM of 1.39 

through 2024 then a long-term ICM of 1.29 thereafter. The resultant costs are shown in Table V46. 

Table V-46 Costs for Cooled EGR (2010$) 

Cost 

type Engine type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DM 

C All $212 $208 $204 $199 $195 $192 $188 $184 $180 

IC All $93 $93 $93 $93 $92 $92 $92 $92 $69 

TC All $305 $301 $296 $292 $288 $284 $280 $276 $249 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 

the baseline. 

Note that in the 2010 TAR, the agencies presented the CEGR system costs inclusive of turbo 

charging costs (see 2010 TAR, Table B2.2-1 at page B-12). For this analysis, the agencies are 

presenting the CEGR costs as a stand-alone technology that can be added to any turbo/downsized 

engine, provided sufficient boost is provided and sufficient engine robustness is accounted for in 

the engine design. As such, the CEGR system is considered applicable only to the 24 bar BMEP 

and 27 bar BMEP engines. Further, the agencies believe that 24 bar BMEP engines are capable 

244 Kapus, P.E., Fraidl, G.K., Prevedel, K., Fuerhapter, A. “GDI Turbo – The Next Steps,” JSAE Technical Paper 

No. 20075355, 2007. 
308 

of maintaining NOx control without CEGR, so the models may choose 24 bar BMEP engines 

with and/or without CEGR, although 27 bar BMEP engines are considered to require CEGR to 

maintain NOx emission control, so 27 bar BMEP technology cannot be applied in the analysis 

without also adding CEGR. 

Advanced Diesel Engine Technologies (ADSL) 

Diesel (compression ignition) engines have several characteristics that give them superior fuel 

efficiency compared to conventional gasoline, spark-ignited engines. Pumping losses are much 

lower due to lack of (or greatly reduced) throttling in a diesel engine. The diesel combustion 

cycle utilizes a higher compression ratio than that found in a typical gasoline engine. As a result, 

turbocharged light-duty diesels typically achieve much higher torque levels at lower engine 

speeds than equivalent-displacement naturally-aspirated gasoline engines. Future high BMEP 

turbocharged and downsized engines, mentioned above, are projected to improve torque levels at 

lower engine speeds thus reducing the diesel advantage in this area. Diesels also operate with a 

very lean air/fuel mixture. These attributes – reduced pumping losses, higher compression ratio 

and lean/air fuel mixture -- allow the engine to extract more energy from a given mass of fuel 

than a gasoline engine, and thus make it more efficient. Additionally, diesel fuel has higher 

energy content per gallon (approximately 128,700 Btu/gal (net)) than gasoline (115,400 Btu/gal 

(net)) fundamentally resulting from diesel fuel containing more carbon per gallon than gasoline: 

diesel produces 22.2 pounds of CO2 per gallon when burned, while gasoline produces 19.4 

pounds of CO2 per gallon. This higher carbon content slightly offsets the GHG emissions 

benefit of diesel fuel relative to gasoline, however, the disbenefit is more than compensated by 

the greater efficiency of the diesel engine. Since diesel engines are more fuel efficient than 

gasoline engines, the agencies anticipate that manufacturers will evaluate and potentially invest 

in diesel engine production as a way to comply with more stringent CAFE standards. 

However, there are two primary reasons why manufacturers might not choose to invest 

significantly in diesel engine technologies as a way to comply with the CAFE and GHG 

standards for MYs 2017-2025. 

As discussed above, even though diesel has higher energy content than gasoline it also has a 

higher carbon density that results in higher amounts of CO2 emitted per gallon, approximately 15 

percent more than a gallon of gasoline. This is commonly referred to as the “carbon penalty” 

associated with using diesel fuel – a diesel vehicle yields greater fuel economy improvements 

compared to its CO2 emissions reduction improvements, so a manufacturer that invests in diesel 

technology to meet CAFE standards may have more trouble meeting the GHG standards than if 

it used a different and more cost effective (from a GHG perspective) technology. 

Second, diesel engines also have emissions characteristics that present challenges to meeting 

federal Tier 2 NOx emissions standards. By way of comparison for readers familiar with the 
                                                      

309 

European on-road fleet, which contains many more diesel vehicles than the U.S. on-road fleet, 

U.S. Tier 2 emissions fleet average requirement of bin 5 require roughly 45 to 65 percent more 

NOx reduction compared to the Euro VI standards. 

Despite considerable advances by manufacturers in developing Tier 2-compliant diesel engines, 

it remains somewhat of a systems-engineering challenge to maintain the fuel consumption 

advantage of the diesel engine while meeting Tier 2 emissions regulations because some of the 

emissions reduction strategies can increase fuel consumption (relative to a Tier 1 compliant 

diesel engine), depending on the combination of strategies employed. A combination of 

combustion improvements (that reduce NOX emissions leaving the engine) and aftertreatment 

(capturing NOX emissions that have left the engine before they leave the vehicle tailpipe) are 

being introduced on Tier 2 compliant light-duty diesel vehicles today. 

We spend time here discussing available emissions reduction technologies for diesel engines as 

part of this rulemaking because of the potential they have to impact fuel economy and GHG 

emissions for the vehicles that have them. With respect to combustion improvements, we note 

that several key advances in diesel engine combustion technology have made it possible to 

reduce emissions coming from the engine prior to aftertreatment, which reduces the need for 

aftertreatment. These technologies include improved fuel systems (higher injection pressure and 

multiple-injection capability), advanced controls and sensors to optimize combustion and 

emissions performance, higher EGR levels and EGR cooling to reduce NOx, and advanced 

turbocharging systems. With the exception of EGR, these systems are available today and they 

do not adversely impact fuel efficiency. However, additional improvements in these 

technologies will be needed to reduce engine emissions further, should future emissions 

standards become more stringent. Further development may also be needed to reduce the fuel 

efficiency penalty associated with EGR. 

With respect to aftertreatment, the traditional 3-way catalyst aftertreatment used on gasolinepowered vehicles to meet criteria pollutant regulations is ineffective due to the lean-burn 

combustion of a diesel, because 3-way catalysts work only with stoichiometric engines. To 

reduce NOx, hydrocarbons, and particulate emissions, all diesels will require a diesel particulate 

filter (DPF) or catalyzed diesel particulate filter (CDPF), a diesel oxidation catalyst (DOC), and 

some kind of NOx reduction strategy to comply with Tier 2 emissions standards. The most 

common NOx reduction strategies include the use of lean NOx traps (LNT)245 or selective 

245 A lean NOx trap operates, in principle, by oxidizing NO to NO2 in the exhaust and storing NO2 on alkali sorbent 

material. When the control system determines (via mathematical model or a NOx sensor) that the trap is saturated 

with NOx, it switches the engine into a rich operating mode or may in some cases inject fuel directly into the exhaust 

stream to produce excess hydrocarbons that act as a reducing agent to convert the stored NOx to N2 and water, 

thereby “regenerating” the LNT and opening up more locations for NOx to be stored. LNTs preferentially store 

sulfate compounds from the fuel, which can reduce catalytic performance. The system must undergo periodic 
                                                                                                                                                                              

 

 

 

 

310 

catalytic reduction (SCR).246 A similar approach, but with greater catalyst volumes and 

potentially higher precious metal loading, would likely be used to meet potential and more 

stringent criteria emission standards. A fuel consumption penalty can be associated with some 

aftertreatment systems. This penalty is due to the fact that extra fuel is needed for the 

aftertreatment and this extra fuel is not used in the combustion process of the engine that 

provides torque to propel the vehicle thus reducing fuel efficiency. 

Thus, both combustion improvements (for Tier 2 purposes) and aftertreatment may be associated 

with a fuel consumption and an emissions reduction penalty; this penalty combined with the 

extra cost of diesel emissions control technologies that are not necessary for gasoline engines 

may also make diesels less attractive to manufacturers as a technology solution for more 

stringent CAFE and GHG standards. However, recognizing that some manufacturers may still 

employ diesel technology to meet the future standards, the agencies have included diesels in our 

analysis as follows: 

First, we sought to ensure that diesel engines would have equivalent performance to comparable 

gasoline engine vehicles. The purpose of this approach is to provide an adequate assessment of 

diesel fuel consumption performance. For the Subcompact, Compact, and Midsize Passenger 

Car, Performance Subcompact Car, and Small Light Truck vehicle subclasses, the agencies 

assumed that an I4 gasoline base engine would be replaced by an in-line 4-cylinder diesel engine 

with displacement varying around 2.0 liters. For the Performance Compact, Performance 

Midsize, Large Passenger Car, Minivan, and Midsize Truck vehicle subclasses for the CAFE 

model, the agencies assumed that a V6 gasoline base engine would be replaced by an in-line 4­

cylinder diesel engine with displacement varying around 2.8 liters. For the Large Truck and 

Performance Large Car vehicle subclasses for the CAFE model, the agencies assumed that a V8 

gasoline base engine would be replaced with a V6 diesel engine with displacement varying 

around 4.0 liters to meet vehicle performance requirements. It was also assumed that diesel 

engines for all of these classes would utilize SCR aftertreatment systems given recent 

improvements in SCR systems and system efficiency. These assumptions impacted our 

estimates of the costs of implementing diesel engines as compared to the base gasoline engines. 

desulfurization by operating at a net-fuel-rich condition at high temperatures in order to retain NOx trapping 

efficiency.

246 An SCR aftertreatment system uses a reductant (typically, ammonia derived from urea) that is injected into the 

exhaust stream ahead of the SCR catalyst. Ammonia combines with NOx in the SCR catalyst to form N2 and water. 

The hardware configuration for an SCR system is more complicated than that of an LNT, due to the onboard urea 

storage and delivery system (which requires a urea pump and injector to inject urea into the exhaust stream), which 

generally makes an SCR system cost more than an LNT system. While a rich engine-operating mode is not required 

for NOx reduction, the urea is typically injected at a rate of approximately 3 percent of the fuel consumed. The 

agencies understand that manufacturers designing SCR systems intend to align urea tank refills with standard 

maintenance practices such as oil changes as more diesel vehicles are introduced into the market. For diesel 

vehicles currently on the market, this is generally already the practice, and represents an ongoing maintenance cost 

for vehicles with this technology. 
                                                      

 

 

 

311 

Diesel engines are more costly than port-injected spark-ignition gasoline engines. These higher 

costs result from more costly components, more complex systems for emissions control, and 

other factors. The vehicle systems that are impacted include: 

 Fuel systems (higher pressures and more responsive injectors); 

 Controls and sensors to optimize combustion and emissions performance; 

 Engine design (higher cylinder pressures require a more robust engine, but higher 

torque output means diesel engines can have reduced displacement); 

 Turbocharger(s); 

 Aftertreatment systems, which tend to be more costly for diesels; 

In the MYs 2012-2016 final rule, the agencies estimated the DMC for converting a gasoline PFI 

engine with 3-way catalyst aftertreatment to a diesel engine with diesel aftertreatment at $1,697 

(2007$), $2,399 (2007$), $1,956 (2007$) and $2,676 (2007$) for a small car, large car, 

medium/large MPV & small truck, and large truck, respectively (see MYs 2012-2016 final Joint 

TSD, Table 3-12 at page 3-44). See table V-8 of the document to convert the vehicle classes 

listed above and in the MYs 2012-2016 final Joint TSD to NHTSA subclasses. All of these 

costs were for SCR-based diesel systems, with the exception of the small car, which was a LNTbased system. For this final rule, consistent with the proposal, we are using the same 

methodology as used in the MYs 2012-2016 final rule, but have made four primary changes to 

the cost estimates as was also done in the proposal for this rule. First, the agencies have not 

estimated costs for a LNT-based system, and instead have estimated costs for all vehicle types 

assuming they will employ SCR-based systems. Second, the agencies assumed that 

manufacturers would meet a Tier 2 bin 2 average rather than a Tier 2 bin 5 average, assuming 

that more stringent levels of compliance will be required in the future. In order to estimate costs 

for Tier 2 bin 2 compliant vehicles, catalyst volume costs were estimated based on an assumed 

increase in volume of 20 percent. This was the estimated necessary increase needed to meet Tier 

2, bin 2 emission level of 0.02 grams of NOx per mile. Increased catalyst volume resulted in a 

higher cost estimate for diesel aftertreatment than was estimated for the MYs 2012-2016 final 

rule. The third is to update all platinum group metal costs from the March 2009 values used in 

the 2012-2016 final rule to February 2011 values.247 The February 2011 values were used for 

purposes of the NPRM analysis, at which time they represented the most recent monthly average 

prices available at the time the agencies “locked-down” all cost estimates for the purposes of 

moving into the modeling phase of analysis.248 For the final rule analysis, the agencies did not 

247 As reported by Johnson-Matthey, the March 2009 monthly average costs were $1,085 per Troy ounce and $1,169 

per Troy ounce for platinum (Pt) and rhodium (Rh), respectively. As also reported by Johnson-Matthey, the 

February 2011 monthly average costs were $1,829 per Troy ounce and $2,476 per Troy ounce for Pt and Rh, 

respectively. See www.platinum.matthey.com. 248 Note that there is no good way of determining what PGM prices to use when conducting cost analyses. Spot 

prices are inherently dangerous to use because spot prices, like stock prices on the stock market, can vary 

considerably from day to day. One could argue that an average price is best, but average prices can vary 
 

 

 

                                                                                                                                                                              

 

 

312 

update the cost for platinum group metals. The fourth is to include an additional $50 DMC for all 

costs to cover costs associated with improvements to fuel and urea controls. All of the diesel 

costs are considered applicable to MY 2012. The agencies consider diesel technology to be on 

the flat portion of the learning curve and have applied a medium complexity ICM of 1.39 

through 2018, and then a long-term ICM of 1.29 thereafter. The resultant costs are shown in 

Table V-47. 

Table V-47 Costs for Conversion to Advanced Diesel (2010$) 

Cost 

type NHTSA Vehicle Subclass 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC 

Subcompact PC, Subcompact 

Perf. PC, Compact PC, 

Midsize PC and Small LT 

$2,059 $2,019 $1,979 $1,938 $1,900 $1,861 $1,825 $1,788 $1,752 

DMC 

Compact Perf. PC, Midsize 

Perf. PC, Large PC, Minivan 

LT and Midsize LT 

$2,082 $2,040 $2,000 $1,959 $1,920 $1,882 $1,844 $1,808 $1,772 

DMC Large Perf. PC and Large LT $2,887 $2,828 $2,771 $2,717 $2,662 $2,609 $2,556 $2,506 $2,455 

IC 

Subcompact PC, Subcompact 

Perf. PC, Compact PC, 

Midsize PC and Small LT 

$905 $904 $676 $675 $673 $672 $671 $670 $669 

IC 

Compact Perf. PC, Midsize 

Perf. PC, Large PC, Minivan 

LT and Midsize LT 

$915 $913 $683 $682 $681 $679 $678 $677 $676 

IC Large Perf. PC and Large LT $1,269 $1,266 $946 $944 $943 $941 $940 $938 $936 

TC 

Subcompact PC, Subcompact 

Perf. PC, Compact PC, 

Midsize PC and Small LT 

$2,965 $2,922 $2,653 $2,613 $2,572 $2,534 $2,496 $2,457 $2,421 

TC 

Compact Perf. PC, Midsize 

Perf. PC, Large PC, Minivan 

LT and Midsize LT 

$2,997 $2,953 $2,683 $2,641 $2,601 $2,560 $2,522 $2,485 $2,447 

considerably depending on the length of time included in the average. And if too much time is included in the 

average, then average prices from a time prior to PGM use in diesel engines may be included which would lead 

some to conclude that we had cherry picked our values. Given no good option, it seems most transparent and least 

selfserving to simply choose a price and report its basis. In the end, the PGM costs represent 16-23 percent of the 

diesel DMC in this analysis. Further, diesels play very little to no role in enabling compliance with the final 

standards. 
313 

TC Large Perf. PC and Large LT $4,155 $4,094 $3,718 $3,661 $3,606 $3,550 $3,497 $3,444 $3,392 

For the MYs 2012-2016 final rule and TAR, NHTSA and EPA estimated the fuel consumption 

reduction of a SCR-based diesel engine to be between 20 to 25 percent over a baseline gasoline 

engine. NHTSA and EPA have revisited these values based on the Ricardo 2011 study, and have 

now estimated the absolute effectiveness of a SCR-based diesel engine to be 28.4 to 30.5 

percent. 

Transmission Technologies 

NHTSA and EPA reviewed the transmission technology estimates used in the MYs 2012-2016 

final rule and the TAR. In doing so, NHTSA and EPA considered or reconsidered all available 

sources and updated the estimates as appropriate. The section below describes each of the 

transmission technologies considered for this rulemaking. As discussed above, for the final rule 

NHTSA has updated the effectiveness values for advanced transmissions when coupled to 

naturally-aspirated engines based on the ANL simulation modeling. These changes are 

documented in detail in the transmission section of NHTSA’s RIA Chapter V because they are 

specific to NHTSA’s analysis only. 

Improved Automatic Transmission Controls (IATC) 

Calibrating the transmission shift schedule to upshift earlier and quicker, and to lock-up or 

partially lock-up the torque converter under a broader range of operating conditions can reduce 

fuel consumption. However, this operation can also result in a perceptible degradation in noise, 

vibration, and harshness (NVH). The degree to which NVH can be degraded before it becomes 

noticeable to the driver is strongly influenced by characteristics of the vehicle, and although it is 

somewhat subjective, it always places a limit on how much fuel consumption can be improved 

by transmission control changes. Aggressive Shift Logic and Early Torque Converter Lockup 

are best optimized simultaneously when added to an automatic transmission, due to the fact that 

adding both of them requires only minor modifications to the transmission mechanical 

components or calibration software. As a result, these two technologies are combined in the 

modeling when added to an automatic transmission. Since a dual clutch transmission (DCT) has 

no torque converter, the early torque converter lockup technology cannot be applied to DCTs. 

Aggressive Shift Logic 

During operation, a transmission’s controller manages the operation of the transmission by 

scheduling the upshift or downshift, and, in automatic transmissions, locking or allowing the 

torque converter to slip based on a preprogrammed shift schedule. The shift schedule contains a 

number of lookup table functions, which define the shift points and torque converter lockup 

based on vehicle speed and throttle position, and other parameters such as temperature. 
                                                      

314 

Aggressive shift logic (ASL) can be employed in such a way as to maximize fuel efficiency by 

modifying the shift schedule to upshift earlier and inhibit downshifts under some conditions, 

which reduces engine pumping losses and engine friction. The application of this technology 

does require a manufacturer to confirm that drivability, durability, and NVH are not significantly 

degraded. 

ASL is an early upshift strategy whereby the transmission shifts to the next higher gear “earlier” 

(or at lower RPM during a gradual acceleration) than would occur in a traditional automatic 

transmission. This early upshift reduces fuel consumption by allowing the engine to operate at a 

lower RPM and higher load, which typically moves the engine into a more efficient operating 

region. 

Early Torque Converter Lockup 

A torque converter is a fluid coupling located between the engine and transmission in vehicles 

with automatic transmissions and continuously variable transmissions (CVT). This fluid 

coupling allows for slip so the engine can run while the vehicle is idling in gear (as at a stop 

light), provides for smoothness of the powertrain, and also provides for torque multiplication 

during acceleration, and especially launch. During light acceleration and cruising, inherent 

torque converter slippage between the torque converter rotor and stator increases fuel 

consumption. Modern automatic transmissions utilize a clutch mechanism as part of the torque 

converter to mechanically lock torque converter rotor and stator the preventing slippage. Fuel 

consumption can be further reduced by locking up the torque converter at lower vehicle speeds, 

provided there is sufficient power to propel the vehicle, and noise and vibration are not 

excessive.249 If the torque converter cannot be fully locked up for maximum efficiency, a partial 

lockup strategy can be employed to reduce slippage. Early torque converter lockup is applicable 

to all vehicle types with automatic transmissions. Some torque converters will require upgraded 

clutch materials to withstand additional loading and the slipping conditions during partial lockup. As with aggressive shift logic, confirmation of acceptable drivability, performance, 

durability and NVH characteristics is required to successfully implement this technology. 

In the MYs 2012-2016 final rule, the agencies estimated an effectiveness improvement of 1 to 2 

percent for aggressive shift logic and 0.5 percent for early torque converter lockup. This was 

supported by the 2002 NAS and NESCCAF reports as well as confidential manufacturer data. 

For this rulemaking, the agencies updated the effectiveness of ASL ranging from 1.9 to 2.7 based 

on the recent Ricardo study. For Early Torque Converter Lockup, MYs 2012-2016 final rule, 

TAR assumed an effectiveness improvement of 0.4 to 0.5 percent, and the recent Ricardo study 

249 Although only modifications to the transmission calibration software are considered as part of this technology, 

very aggressive early torque converter lock up may require an adjustment to damper stiffness and hysteresis inside 

the torque converter. 
315 

confirmed that amount. In the CAFE model, NHTSA combines ASL and early torque converter 

(together named Improved Automatic Transmission Control (IATC)) and assigns it an 

incremental effectiveness ranging from 2.3 to 3.1 percent and applicable starting in MY 2012. 

In the MYs 2012-2016 rule, the agencies estimated the DMC for ASL at $26 (2007$) and for 

early torque converter lockup at $23 (2007$), which was considered applicable to MY 2015. 

These DMCs become $27 for ASL and $24 for early torque converter lockup after being 

converted into 2010$. NHTSA added these costs together and applied it as IATC in the CAFE 

model. The agency considers IATC to be on the flat portion of the learning curve and applies a 

medium complexity ICM of 1.39 through 2018 then a long-term ICM of 1.29 thereafter. The 

resultant costs are shown in Table V-48. 

Table V-48 Costs for IATC (2010$) 

Index Transmission Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $50 $49 $48 $47 $46 $45 $44 $43 $42 

IC All $13 $13 $10 $10 $10 $10 $10 $10 $10 

TC All $62 $61 $58 $57 $56 $55 $54 $53 $52 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

Automatic 6-speed Transmission (NAUTO) 

Manufacturers can choose to replace 4- and 5-speed transmissions with 6-, 7-, or 8-speed 

automatic transmissions. Additional ratios allow for further optimization of engine operation 

over a wider range of conditions, but this is subject to diminishing returns as the number of gear 

ratios increases. As additional planetary gear sets are added (which may be necessary in some 

cases to achieve the higher number of ratios), additional weight and friction are introduced. 

Also, the additional shifting of such a transmission can be perceived as bothersome to some 

consumers, so manufacturers need to develop strategies for smooth shifts. For the most part, 

manufacturers are replacing 4- and 5-speed automatics with 6-speed automatics, and 7- and 8­

speed automatics are also in production. While a six speed transmission application is expected 

to be most prevalent for the timeframe of the 2012-2016 rulemaking, eight speed transmissions 

are expected to be readily available and applied in the 2017 through 2025 timeframe. 

As discussed in the MY 2011 CAFE final rule, confidential manufacturer data projected that 6­

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

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

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

                                                      

 

316 

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

transmissions.250 The 2008 EPA Staff Technical Report found a 4.5 to 6.5 percent fuel 

consumption improvement for a 6-speed over a 4-speed automatic transmission.251 Based on this 

information, NHTSA estimated in the MY 2011 rule, that the conversion to a 6-,7- and 8-speed 

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

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

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

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

In MYs 2012-2016 final rule, NHTSA and EPA reviewed these effectiveness estimates and 

concluded that they remain accurate. 

In this FRM analysis, consistent with the proposal, the agencies divided the improvement for this 

technology into two steps, first from 4- or 5- speed transmission to a 6-speed transmission 

(NAUTO), then from 6-speed transmission to 8 speed transmission (8SPD). The effectiveness 

estimates for NAUTO and 8SPD are based on the recent Ricardo study. In this section, only 

NAUTO is discussed. 8SPD will be discussed later in a section below. 

Based on the Ricardo study, the effectiveness for a 6-speed transmission, relative to a 4-speed 

base transmission, ranges from 3.1 to 3.9 percent (2.1 percent for large truck with an unimproved 

rear axle). NHTSA incorporated this effectiveness estimate into the CAFE model as an 

incremental improvement over IATC ranging from 1.89 to 2.13 percent, because the Ricardo 

simulation-based estimates included improvements from IATC. 

Based on the FEV teardown cost analysis, the DMC for 6-speed incremental to 5-speed 

automatic transmission is -$105.53 (2007$)—that is, a cost savings. In MYs 2012-2016 final 

rule, the agencies also assumed an incremental cost of moving from a 4-speed transmission to a 

5-speed transmission of $91 (2007$). Adding these two values, the agency derived the cost for a 

6-speed automatic transmission, incremental to a 4-speed automatic transmission, as -$14 

(2007$). Due to the fact that the market has significant amounts of both 4-speed and 5-speed 

automatic transmission already, NHTSA used the average of incremental cost from 4-speed to 6­

speed and from 5-speed to 6-speed automatic transmission to represent the incremental cost of 

the NAUTO technology; that is, -$60 (2007$). Converting into 2010$, this DMC is -$63, which 

is applicable in MY 2012. The agencies consider 6-speed automatic transmission technology to 

be on the flat portion of the learning curve and have applied a low complexity ICM of 1.24 

through 2018 then a long-term ICM of 1.19 thereafter. The resultant costs are shown in 

Table V-49. 

250 General Motors, news release, “From Hybrids to Six-Speeds, Direct Injection And More, GM’s 2008 Global 

Powertrain Lineup Provides More Miles with Less Fuel” (released Mar. 6, 2007). Available 

http://www.zercustoms.com/news/More-Hybrids-from-GM-in-2008.html (last accessed on Nov 3, 2011). 251 “EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty 

Vehicle Carbon Dioxide Emissions” Environmental Protection Agency, EPA420-R-08-008, March 2008, at page 17, 

Docket NHTSA-2010-0131. 
                                                      

317 

Table V-49 Costs for 6-Speed Automatic Transmissions (2010$) 

Index Transmission 

Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All -$54 -$53 -$52 -$51 -$50 -$49 -$48 -$47 -$46 

IC All $15 $15 $12 $12 $12 $12 $12 $12 $12 

TC All -$39 -$38 -$40 -$39 -$38 -$37 -$36 -$35 -$34 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 4/5-speed transmission. 

Dual Clutch Transmission (DCT) 

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

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

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

is essentially a manual transmission with automated clutch control and shifting. , DCTs are 

emerging as more common in the U.S. primarily because of shift quality issues with singleclutch designs252 which, at the time of this rulemaking have no widespread application plans in 

the U.S. Therefore, the agency’s analysis focused on DCT application as the foundation of the 

estimates that follow. 

A DCT uses separate clutches (and separate gear shafts) for the even-numbered gears and oddnumbered gears. In this way, the next expected gear is pre-selected, which allows for faster and 

smoother shifting. For example, if the vehicle is accelerating in third gear, the shaft with gears 

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

four, and six is idle, but has gear four engaged. When an upshift is required, the controller 

disengages the odd-gear clutch while simultaneously engaging the even-gear clutch, thus making 

a smooth shift. If, on the other hand, the driver slows down instead of continuing to accelerate, 

the transmission will have to change to the next lower gear on the idling shaft to anticipate a 

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

transferred on it. 

In addition to the differing single-clutch and dual-clutch AMT designs, there are also wet clutch 

and dry clutch designs of each which are used for different types of vehicle applications. Wet 

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

can apply the clutches and, as a by-product, cools the clutches allowing for increased clutch 

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

252 However, some U.S. DCT applications have resulted in reports of reduced consumer acceptance. 
318 

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

additional hydraulic hardware required. 

Overall, DCTs likely offer the greatest potential for effectiveness improvements among the 

various transmission options considered in this analysis because they offer the inherently lower 

losses of a manual transmission with the efficiency and shift quality advantages of electronic 

controls. The lower losses stem from the elimination of the conventional lock-up torque 

converter, and a greatly reduced need for high pressure hydraulic circuits to hold clutches or 

bands to maintain gear ratios (in automatic transmissions) or hold pulleys in position to maintain 

gear ratio (in continuously variable transmissions). However, the lack of a torque converter will 

affect how the vehicle launches from rest, so a DCT will most likely be paired with an engine 

that offers sufficient torque at low engine speeds to allow for adequate launch performance or 

provide lower launch gears (higher numerically) to approximate the torque multiplication of the 

torque converter providing equivalent performance. 

In the MYs 2012-2016 final rule, EPA and NHTSA estimated a 5.5 to 9.5 percent improvement 

in fuel consumption over a baseline 4/5-speed automatic transmission for a wet clutch DCT, 

which was assumed for all but the smallest of the vehicle subclasses, Subcompact and Compact 

cars and small LT. This results in an incremental effectiveness estimate of 2.7 to 4.1 percent 

over a 6-speed automatic transmission with IATC. For Subcompact and Compact Cars and 

small LT, which were assumed to use a dry clutch DCT, NHTSA estimated an 8 to 13 percent 

fuel consumption improvement over a baseline 4/5-speed automatic transmission, which equates 

to a 5.5 to 7.5 percent incremental improvement over the 6-speed transmission. 

For purposes of this analysis, based on the 2011 Ricardo study, EPA and NHTSA have 

concluded that 8 to 13 percent effectiveness is appropriate for 6-speed DCTs compared to a 

baseline 4/5 speed transmission. These values include not only the DCT but also the increase in 

stepped gears and also a high efficiency gearbox (mentioned later). Independent of other 

technologies, the effectiveness for the DCT, alone, is 4 to 5 percent (for wet-clutch designs) and 

5 to 6 percent (for dry-clutch designs) compared to a baseline automatic transmission of similar 

vintage and number of fixed gears. 

In the FRM analysis, consistent with the proposal, NHTSA applied an incremental effectiveness 

of 4 percent for a 6-speed dry DCT and 3.4 to 3.8 percent for a wet DCT compared to a 6-speed 

automatic transmission with IATC based on the lumped parameter model. This effectiveness 

value also includes the accompanied 7 percent transmission efficiency improvement for MY 

2010 and after transmissions. This translates to an effectiveness range of 7.4 to 8.6 percent 

compared to a 4 speed automatic transmission for dry clutch design and 7.4 to 7.9 percent for a 

wet clutch design. NHTSA did not apply DCTs to vehicles with towing requirements, such as 

Minivan LT, Midsize LT and Large LT. 
 

319 

Chapter 3 of the 2012-2016 final joint TSD referenced DCT costs of -$147 (2007$ and 

incremental to a 6-speed automatic transmission) based on an FEV tear-down study that assumed 

450,000 units of production, but because the agencies did not consider there to be sufficient U.S. 

capacity in the 2012-2016 timeframe to produce 450,000 units, the tear-down values were 

adjusted accordingly. In contrast, the TAR timeframe for consideration was 2017-2025, so in 

that analysis the agencies assumed that production capacity would exist and that therefore the 

FEV tear-down results were valid without adjustment. We continue to believe that to be the case 

for purposes of this analysis. In the final joint TSD supporting MYs 2012-2016 rule the agencies 

also noted that the negative tear-down estimates found by FEV were not surprising when 

considering the relative simplicity of a dual-clutch transmission compared to an automatic 

transmission. Again, the agencies continue to consider this to be true. 

For this analysis, then, the FEV teardown cost was employed for DCT. As stated in the MYs 

2012-2016 final rule, the 6-speed wet DCT incremental to 6-speed automatic transmission is ­

$147 (2007$), and the incremental cost from a dry DCT to a wet DCT is $67 (2007$). The 

agency derived the 6-speed dry DCT cost incremental to 6-speed automatic transmission cost as ­

$147-$67 = -$214 (2007$). Converting to 2010$, the incremental cost from a 6-speed automatic 

transmission to 6-speed dry DCT is -$226 and the incremental cost from a 6-speed automatic 

transmission to 6-speed wet DCT is -$155. These costs are applicable in MY 2012. The agencies 

consider the 6 speed DCT technology to be on the flat portion of the learning curve and have 

applied a medium complexity ICM of 1.39 through 2018 then a long-term ICM of 1.29 

thereafter. The resultant costs are shown in 

Table V-50. 

Table V-50 Costs for 6-Speed Dual Clutch Transmissions (2010$) 

Index Transmission 

Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Dry DCT -$194 -$190 -$187 -$183 -$179 -$176 -$172 -$169 -$166 

IC Dry DCT $85 $85 $64 $64 $64 $64 $64 $63 $63 

TC Dry DCT -$109 -$105 -$123 -$119 -$115 -$112 -$109 -$105 -$102 

DMC Wet DCT -$133 -$130 -$128 -$125 -$123 -$120 -$118 -$115 -$113 

IC Wet DCT $59 $59 $43 $43 $43 $43 $43 $43 $43 

TC Wet DCT -$75 -$72 -$84 -$82 -$80 -$77 -$75 -$73 -$70 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 6-speed automatic transmission. 

Automatic and Dual Clutch 8-Speed Transmission (8SPD) 
 

                                                      

 

320 

As stated in the previous section under NAUTO, the agencies separated 8-speed transmission 

from NAUTO in consideration of the fact that an 8-speed transmission is more effective in 

reducing fuel consumption than 6-speed transmission, and more 8-speed automatic transmissions 

are beginning to enter the market. 

In this FRM analysis, consistent with the proposal, the agencies assumed that 8-speed 

transmissions will not become available until MY 2017. NHTSA applied 8-speed automatic 

transmissions succeeding 6-speed automatic transmission to vehicles with towing requirements, 

such as minivans, midsize light trucks and large light trucks; all other vehicle subclasses use 8­

speed DCT to succeed 6-speed DCT. 

NHTSA derived effectiveness values from EPA’s lumped parameter model, updated with values 

from the recent Ricardo study, for an 8-speed DCT relative to a 4-speed automatic transmission 

ranging from 11.1 to 13.1 percent for subclasses except Minivan LT, Midsize LT and Large LT, 

which assume an 8-speed automatic transmission relative to 4-speed automatic transmission 

ranging from 8.7 to 9.2 percent. This translates into effectiveness values appropriate for the 

CAFE model in the range of 3.85 to 4.57 percent for an 8-speed DCT relative to a 6-speed DCT 

and 4.9 to 5.34 percent for 8-speed automatic transmission relative to 6-speed automatic 

transmission. 

For the cost of an 8-speed automatic transmission, the agencies have relied on a tear-down study 

completed by FEV since publication of the TAR.253 In that study, the 8-speed automatic 

transmission was found to have an incremental cost of $62 (2007$) compared to the 6-speed 

automatic transmission. Converting to 2010$, this DMC becomes $65 for this analysis. The 

agencies consider this DMC to be applicable to MY 2012, although, as stated, the technology 

will not be available for application until MY 2017. The agencies consider the 8-speed 

transmission technology to be on the flat portion of the learning curve and have applied a 

medium complexity ICM of 1.39 through MY 2018 then a long-term ICM of 1.29 thereafter.254 

Note that the cost for the 8-speed automatic transmission relative to the 6-speed automatic 

transmission is lower here than that used in the recent heavy-duty rulemaking analysis. In that 

rule, we remained consistent with the proposal for that rule which carried an estimated DMC of 

$210 (2008$). That DMC was based on an estimation derived by NAS (see NAS 2010, Table 7­

253 FEV Inc., “Light-Duty Technology Cost Analysis: Advanced 8-speed Transmissions”, Contract No. EP-C-07­

069, Work Assignment 3-3, EPA-420-R-11-015, November 2011, Docket NHTSA-2010-0131. 

254 This ICM would be applied to the 6 speed to 8 speed increment of $64 (2009$) applicable in 2012. The 4 speed
 

to 6 speed increment would carry the low complexity ICM. 
                                                      

321 

10).255 For this final rule, consistent with the proposal, we have chosen to use a DMC based on 

the more recent FEV tear-down analysis. 

New for this analysis is costing for an 8-speed DCT. For the cost of this technology, the 

agencies have relied on a tear-down study completed by FEV since publication of the TAR.256 

In that study, the 8-speed DCT was found to have an incremental cost of $198 (2007$) compared 

to the 6-speed DCT. Converting to 2010$, this DMC increment becomes $206 for this analysis. 

The agencies consider this DMC to be applicable to MY 2012. The agencies consider the 8­

speed DCT technology to be on the flat portion of the learning curve and have applied a medium 

complexity ICM of 1.39 through MY 2024 then a long-term ICM of 1.29 thereafter. The 8­

speed DCT has a later switch to long term ICMs because it is a newer technology that is not 

currently implemented in the fleet. The resultant costs for both 8-speed automatic transmission 

and 8-speed DCTs incremental to 6-speed transmission with same transmission type are shown 

in 

Table V-50. 

Table V-51 Costs for 8-Speed Automatic and Dual Clutch Transmissions (2010$) 

Index 

Transmi 

ssion 

Type 

2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Auto $56 $55 $54 $53 $52 $51 $49 $48 $47 

IC Auto $24 $24 $18 $18 $18 $18 $18 $18 $18 

TC Auto $81 $79 $72 $71 $70 $69 $68 $67 $66 

DMC DCT $179 $176 $172 $169 $166 $162 $159 $156 $153 

IC DCT $79 $79 $59 $59 $59 $59 $59 $59 $59 

TC DCT $258 $254 $230 $227 $223 $220 $217 $214 $210 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to 6-speed transmission of 

same type. 

255 National Academy of Sciences, “Assessment of Fuel Economy Technologies for Light-Duty Vehicles” Available 

at http://www.nap.edu/catalog.php?record_id=12924 (last accessed: November 15, 2011). 256 FEV Inc., “Light-Duty Technology Cost Analysis: Advanced 8-speed Transmissions”, Contract No. EP-C-07­

069, Work Assignment 3-3, EPA-420-R-11-015, November 2011 Docket NHTSA-2010-0131. 
 

 

 

 

                                                      

322 

High Efficiency Gear Box for Automatic, DCT and Manual Transmission 

(HETRANS and HETRANSM) 

For this rule, a high efficiency gearbox refers to some or all of a suite of incremental gearbox 

improvement technologies that should be available within the 2017 to 2025 timeframe. The 

majority of these improvements address mechanical friction within the gearbox. These 

improvements include, but are not limited to, shifting clutch technology improvements 

(especially for smaller vehicle classes); improved kinematic design; dry sump lubrication 

systems; more efficient seals, bearings and clutches (reducing drag); component superfinishing; 

and improved transmission lubricants. More detailed description can be found in the 2011 

Ricardo report.257 The high efficiency gearbox technology is applicable to any type of 

transmission. 

EPA analyzed detailed transmission efficiency input data provided by Ricardo and implemented 

it directly into the lumped parameter model. Based on the LPM effectiveness, resulting from 

these inputs, the agencies estimate that a high efficiency gearbox can provide a fuel consumption 

reduction in the range of 3.8 to 5.7 percent (3.8 percent for 4WD trucks with an unimproved rear 

axle) over a baseline transmission in MY 2017 and beyond. 

The agencies estimated the DMC of the high efficiency gearbox at $200 (2009$). We have 

based this on the DMC for engine friction reduction in a V8 engine which, as presented in Table 

V-34, is $197 (2010$). In the proposal, we rounded this value up to $200 (2009$) which 

becomes $202 (2010$) for this final analysis. This DMC is considered applicable for MY 2017. 

The agencies consider high efficiency gearbox technology to be on the flat portion of the 

learning curve and have applied a low complexity ICM of 1.24 through 2024 then a long-term 

ICM of 1.19 thereafter. The resultant costs are shown in Table V-52. 

Table V-52 Costs for High Efficiency Gearbox (2010$) 

Index Transmission 

Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $202 $196 $190 $184 $179 $173 $170 $167 $163 

IC All $49 $49 $49 $49 $49 $49 $48 $48 $39 

TC All $251 $245 $239 $233 $227 $222 $218 $215 $202 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

Shift Optimization (SHFTOPT) 

257 U.S. EPA, “Computer Simulation of Light-Duty Vehicle Technologies for Greenhouse Gas Emission Reduction 

in the 2020-2025 Timeframe”, Contract No. EP-C-11-007, Work Assignment 0-12 Docket NHTSA-2010-0131. 
                                                      

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In this FRM analysis, consistent with the proposal, the agencies introduced another level of 

aggressive shift logic based on the shift optimization algorithm employed in the recent Ricardo 

study. NHTSA named this technology Shift Optimization (SHFTOPT) in the CAFE model. As 

described in the 2011 Ricardo report, shift optimization is a strategy whereby the engine and/or 

transmission controller(s) continuously evaluate all possible gear options that would provide the 

necessary tractive power (while limiting the adverse effects on driveline NVH) and select the 

gear that lets the engine run in the most efficient operating zone. Thus, shift optimization tries to 

keep the engine operating near its most efficient point for a give power demand. The shift 

controller emulates a traditional CVT by selecting the best gear ratio for fuel economy at a given 

required vehicle power level to take full advantage of high BMEP engines.258 

Ricardo acknowledged in its report that the shift optimization currently causes significant 

implications for drivability and hence affects consumer acceptability. However, Ricardo 

recommended the inclusion of this technology for the 2020-2025 time frame based on the 

assumption that manufacturers will develop a means of yielding the fuel economy benefit 

without adversely affecting driver acceptability. The agencies believe these drivability 

challenges could include shift busyness – that is, more frequent shifting compared to current 

vehicles as perceived by the customers. The agencies note that in confidential discussions with 

two major transmission suppliers, the suppliers described transmission advances which reduce 

shifting time and provide smoother torque transitions than today’s designs, making the shifting 

event less apparent to the driver; however, these improvements will not influence the customer’s 

perception of shift busyness related to the changes in engine speed. 

In addition, the agencies note that several auto companies and transmission firms have 

announced future introduction of transmissions into the U.S. market with even a higher number 

of gears than were included in the Ricardo simulation and in the agencies’ feasibility assessment 

for this final rule (which is 8 forward speeds). These announcements include both 9 and 10 

speed transmissions which may present further challenges with shift busyness, given the 

availability of one or two additional gears. At the same time, the associated closer gear spacing 

will generally result in smaller engine speed changes during shifting that may be less noticeable 

to the driver. 

The agencies are including shift optimization in the analysis under the premise that 

manufacturers are developing means to mitigate these drivability issues by MY 2017, as assumed 

in the 2011 Ricardo study (more information on Ricardo’s treatment of the optimized shift 

strategy is described in Section 6.4 of the 2011 Ricardo report). If manufacturers are not able to 

solve these drivability issues, the assumed effectiveness could be lower and the cost could be 

higher or both. NHTSA sought comment on the feasibility of the shift optimization strategy 

258 In this analysis, the agencies have assumed that shift optimization is applicable to all vehicles, consistent with the 

proposal. 
324 

described above and the likelihood that and manner in which manufacturers will be able to 

overcome the drivability issues. No specific comment was given on shift optimization, but the 

Alliance emphasized that the agencies should examine the progress in the development of 

powertrain improvements as part of the mid-term evaluation and determine if researchers are 

making the kind of breakthroughs anticipated by the agencies for technologies like highefficiency transmissions. 

The effectiveness from the LPM for SHFTOPT ranges from 5.1 to 7.0 percent improvement over 

a transmission with non-optimized shift logic. In the CAFE model, an incremental effectiveness 

relative to IATC ranging from 3.27 to 4.31 percent is applied. 

The agencies are estimating the DMC for SHFTOPT to be equivalent to ASL’s cost of $27 

(2010$) in relative to baseline transmission. Essentially this yield a nearly negligible 

incremental cost of $1 for SHFTOPT over IATC, which, combined with its effectiveness, makes 

it a very attractive technology for the model to apply in the analysis. This cost for SHFTOPT is 

considered applicable to MY 2017. The timing of SHFTOPT is different from that for ASL 

because SHFTOPT is newer and not yet being implemented in the fleet. The agencies consider 

SHFTOPT technology to be on the flat portion of the learning curve and have applied a medium 

complexity ICM of 1.39 through 2024 then a long-term ICM of 1.29 thereafter. 

Table V-53 Cost for Shift Optimization (2010$) 

Index Transmission Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $1.0 $1.0 $0.9 $0.9 $0.9 $0.9 $0.8 $0.8 $0.8 

IC All $0.2 $0.2 $0.2 $0.2 $0.2 $0.2 $0.2 $0.2 $0.2 

TC All $1.2 $1.2 $1.2 $1.2 $1.1 $1.1 $1.1 $1.1 $1.0 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; cost incremental to IATC. 

6-Speed Manual Transmissions (6MAN) 

Manual transmissions depend entirely upon driver input to shift gears: the driver selects when to 

perform the shift and which gear to select. This is the most efficient transfer of energy of all 

transmission layouts, because it has the lowest internal gear losses, with a minimal hydraulic 

system, and the driver provides the energy to actuate the clutch. From a systems viewpoint, 

however, vehicles with manual transmissions have the drawback that the driver may not always 

select the optimum gear ratio for fuel economy. Nonetheless, increasing the number of available 

ratios in a manual transmission can improve fuel economy by allowing the driver to select a ratio 

that optimizes engine operation more often. Typically, this is achieved through adding overdrive 
 

 

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ratios to reduce engine speed at cruising velocities (which saves fuel through reduced engine 

pumping losses) and pushing the torque required of the engine towards the optimum level. 

However, if the gear ratio steps are not properly designed, this may require the driver to change 

gears more often in city driving, resulting in customer dissatisfaction. Additionally, if gear ratios 

are selected to achieve improved launch performance instead of to improve fuel economy, then 

no fuel saving effectiveness is realized. 

The MY 2012-2016 final rule assumed an effectiveness increase of 0.5 percent for replacing a 5­

speed manual with a 6-speed manual transmission, which was derived from confidential 

manufacturer data. Based on the updated LPM for this 2017-2025 rule, NHTSA has found that 

an effectiveness increase of 2.0 to 2.5 percent is possible when moving from a 5-speed to a 6­

speed manual transmission with improved internals. 

NHTSA updated costs from MYs 2012-2016 final rule to reflect the ICM low complexity 

markup of 1.11, which resulted in an incremental compliance cost of $250 as compared to $338 

for MY 2012. This represents a DMC of $225 (2007$) which becomes $234 (2010$) for this 

analysis, applicable in MY 2012. NHTSA continues to consider a 6 speed manual transmission 

to be on the flat portion of the learning curve and has applied a low complexity ICM of 1.24 

through 2018 then a long-term ICM of 1.19 thereafter. NHTSA’s resultant costs for a 6 speed 

manual transmission are shown in Table V-54. 

Table V-54 Costs for 6 Speed Manual Transmission (2010$) 

Index Transmission 

Type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Manual $204 $199 $196 $192 $188 $184 $181 $177 $173 

IC Manual $57 $57 $45 $44 $44 $44 $44 $44 $44 

TC Manual $260 $256 $240 $236 $232 $229 $225 $221 $218 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost; all costs are incremental to the baseline. 

Vehicle Accessory, Hybridization and Electrification Technologies 

Electrical Power Steering (EPS) and Electrohydraulic Power Steering 

(EHPS) 

Electric power steering (EPS) and Electro-hydraulic power steering (EHPS) provide a potential 

reduction in fuel consumption over hydraulic power steering because of reduced overall 

accessory loads. This eliminates the parasitic losses associated with belt-driven power steering 

pumps which consistently draw load from the engine to pump hydraulic fluid through the 

steering actuation systems even when the wheels are not being turned. EPS is an enabler for all 
326 

vehicle hybridization technologies since it provides power steering when the engine is off. EPS 

may be implemented on most vehicles with a standard 12V system. Some heavier vehicles may 

require a higher voltage system or EHPS, which may add cost and complexity. 

In the 2012-2016 final rule, EPA and NHTSA estimated a 1 to 2 percent effectiveness for EPS 

based on the 2002 NAS report, Sierra Research Report and confidential OEM data. The 2010 

Ricardo study also confirmed this estimate. The agencies continue to believe that these 

effectiveness estimates are accurate for the rulemaking timeframe, thus they have been retained 

for this final rule. For large pickup trucks the agencies used EHPS due to the utility requirement 

of these vehicles. The effectiveness of EHPS is estimated to be 0.8 percent based on the updated 

LPM results. 

In the MY 2012-2016 final rule, the agencies estimated the DMC at $88 (2007$). Converting to 

2010$, this DMC becomes $92 for this analysis, consistent with the recent heavy-duty GHG rule, 

and is considered applicable in MY 2015. The agencies use the same DMC for EPS as for 

EHPS. Technically, EHPS is less costly than EPS. However, we believe that EHPS is likely to 

be used, if at all, only on the largest trucks and utility vehicles. As such, it would probably need 

to be heavier-duty than typical EPS systems and the agencies consider the net effect to place 

EHPS on par with EPS in terms of costs. The agencies consider EPS/EHPS technology to be on 

the flat portion of the learning curve and have applied a low complexity ICM of 1.24 through 

2018 then a long-term ICM of 1.19 thereafter. The resultant costs are shown in Table V-55. 

Table V-55 Costs of Electrical/Electro-hydraulic Power Steering (2010$) 

Cost 

type 

2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $87 $86 $84 $82 $80 $79 $77 $76 $74 

IC $22 $22 $18 $18 $18 $18 $18 $18 $18 

TC $109 $108 $101 $100 $98 $96 $95 $93 $92 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Improved Accessories Level 1 and Level 2(IACC1 and IACC2) 

The accessories on an engine, including the alternator, coolant, and oil pumps, are traditionally 

mechanically-driven. A reduction in fuel consumption can be realized by driving them 

electrically, and only when needed (“on-demand”). 

Electric water pumps and electric fans can provide better control of engine cooling. For 

example, coolant flow from an electric water pump can be reduced and the radiator fan can be 
327 

shut off during engine warm-up or cold ambient temperature conditions which will reduce warmup time, reduce warm-up fuel enrichment, and reduce parasitic losses. 

Indirect benefit may also be obtained by reducing the flow from the water pump electrically 

during the engine warm-up period, allowing the engine to heat more rapidly and thereby 

reducing the fuel enrichment needed during cold starting of the engine. Further benefit may be 

obtained when electrification is combined with an improved, higher efficiency engine alternator. 

Intelligent cooling can more easily be applied to vehicles that do not typically carry heavy 

payloads, so larger vehicles with towing capacity present a challenge, as these vehicles have high 

cooling fan loads. 

The agencies considered whether to include electric oil pump technology for the rulemaking. 

Because it is necessary to operate the oil pump any time the engine is running, electric oil pump 

technology has an insignificant effect on efficiency. Therefore, the agencies decided to not 

include electric oil pump technology for this final rule, consistent with the proposal. 

In MYs 2012-2016 final rule, the agencies used an effectiveness value in the range of 1 to 2 

percent based on the technologies discussed above. NHTSA did not apply this technology to 

large pickup trucks due to the utility requirement concern for this vehicle subclass. 

For this final rule, consistent with the proposal, the agencies considered two levels of improved 

accessories. For level one of this technology (IACC1), NHTSA now incorporates a high 

efficiency alternator (70 percent efficient). The second level of improved accessories (IACC2) 

adds the higher efficiency alternator and incorporates a mild regenerative alternator strategy, as 

well as intelligent cooling. NHTSA and EPA jointly reviewed the estimates of 1 to 2 percent 

effectiveness used in the 2012-2016 final rule and TAR for level IACC1. For this final rule, the 

agencies used an effectiveness value in 1.2 to 1.8 percent range varying based on different 

vehicle subclasses. For IACC1, NHTSA assumes an incremental effectiveness for this 

technology relative to EPS in the CAFE model of 0.91 to 1.61 percent, and an incremental 

effectiveness for IACC2 relative to IACC1 ranging from 1.74 to 2.55 percent. 

In the 2012-2016 rule, the agencies estimated the DMC of IACC1 at $71 (2007$). Converting to 

2010$, this DMC becomes $75 for this analysis, applicable in MY 2015, and consistent with the 

heavy-duty rule. The agencies consider IACC1 technology to be on the flat portion of the 

learning curve and have applied a low complexity ICM of 1.24 through 2018 then a long-term 

ICM of 1.19 thereafter. 

The assumed cost is higher for IACC2 due to the inclusion of a higher efficiency alternator and a 

mild level of regeneration. The agencies estimate the DMC of the higher efficiency alternator 

and the regeneration strategy at $45 (2010$) incremental to IACC1, applicable in MY 2015. 
 

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Including the costs for IACC1 results in a DMC for IACC2 of $120 (2010$) relative to the 

baseline case, and applicable in MY 2015. The agencies consider the IACC2 technology to be 

on the flat portion of the learning curve. The agencies have applied a low complexity ICM of 

1.24 through 2018 then a long-term ICM of 1.19 thereafter. The resultant costs are shown in 

Table V-56. 

Table V-56 Costs for Improved Accessory Technology – Levels 1 & 2 (2010$) 

Cost 

type 

IACC 

Technology 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Level 1 $71 $70 $68 $67 $65 $64 $63 $62 $60 

DMC Level 2 $114 $112 $110 $107 $105 $103 $101 $99 $97 

IC Level 1 $18 $18 $14 $14 $14 $14 $14 $14 $14 

IC Level 2 $29 $29 $23 $23 $23 $23 $23 $23 $23 

TC Level 1 $89 $88 $82 $81 $80 $78 $77 $76 $75 

TC Level 2 $143 $141 $133 $131 $128 $126 $124 $122 $120 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Note that both levels of IACC technology are incremental to EPS in the CAFE model.
 

Air Conditioner Systems 

Air conditioning (A/C) use places excess load on an engine, which results in additional fuel 

consumption and GHG emissions. A number of methods related only to the A/C system 

components and their controls can be used to improve A/C systems. The A/C improving 

technologies considered for this final rule focus primarily, but not exclusively, on the 

compressor, electric motor controls, and system controls which reduce load on the A/C system 

(e.g., reduced ‘reheat’ of the cooled air and increased of use re-circulated cabin air). 

Technologies that reduce A/C related fuel consumption include internal heat exchanger, blower 

motor control, default to recirculated air, and reduced reheat with externally controlled with 

fixed or variable displacement compressor. Technologies that reduce air conditioning leakage or 

reduce the GWP of air conditioning refrigerant were not considered and are only included in the 

EPA GHG program. For purposes of this final rule, a detailed description of the A/C program 

can be found in Chapter 5 of the joint TSD. The reader is directed to that chapter to learn the 

specifics of the program, the fuel consumption improvement values involved, and details behind 

the costs that have been estimated. Table V-57 is a copy of Table 5-17 from that chapter of the 

TSD, showing the total costs for A/C controls used in this final rule, consistent with the proposal. 

Table V-57 Costs of A/C Controls Carried Over into the Final Rule (2010$) 

Car/ Cost 

type Rule 2017 2018 2019 2020 2021 2022 2023 2024 2025 

Truck 

TC Reference $76 $75 $70 $69 $68 $67 $66 $65 $64 

Car TC Control $25 $40 $57 $65 $79 $77 $72 $71 $69 

TC Both $101 $115 $127 $134 $147 $144 $138 $135 $133 

Truck TC Reference $58 $57 $54 $53 $52 $51 $50 $49 $49 
 

 

 

 

329 

TC Control $2 $46 $73 $82 $95 $93 $88 $86 $84 

TC Both $60 $103 $127 $134 $147 $144 $138 $135 $133 

Fleet TC Both $86 $111 $127 $134 $147 $144 $138 $135 $133 

12 volt Micro Hybrid or Stop-Start (MHEV) 

The stop-start technology we consider for this final rule, consistent with the proposal—also 

known as idle-stop or 12-volt micro-hybrid—is the most basic hybrid system that facilitates idlestop capability. When the vehicle comes to a stop, the system will automatically shut down the 

internal combustion engine and restart the engine when vehicle starts to move again. This is 

especially beneficial to reduce fuel consumption when vehicles spend significant amount of time 

stopped in traffic. Along with other enablers, this system typically replaces the standard 12-volt 

starter with an improved unit capable of higher power and increased cycle life. These systems 

typically incorporate an improved battery to prevent voltage-droop on restart. Different from 

MYs 2012-2016 rule, for this analysis this technology is applied to all vehicle classes, including 

large pickup trucks. 

In the MYs 2012-2016 final rule, the effectiveness NHTSA used in the CAFE model ranged 

from 2 to 4 percent, depending on whether the vehicle was equipped with a 4-, 6- or 8-cylinder 

engine, with the 4-cylinder engine having the lowest range and the 8-cylinder having the highest. 

In this FRM analysis, consistent with the proposal, when combining IACC1, IACC2 and 12V 

stop-start system, the estimated effectiveness based on 2010 Ricardo study ranges from 4.8 

percent to 5.9 percent. For CAFE modeling, the incremental effectiveness for 12V stop-start 

relative to IACC2 is 1.68 to 2.2 percent. Importantly, the effectiveness values presented here 

represent two-cycle effectiveness. Because stop-start technology provides additional off-cycle 

benefits, both agencies apply a credit value to the technology. Off-cycle credits are discussed in 

Chapter 5 of the Joint TSD. 

In the MYs 2012-2016 final rule, the agencies estimated the DMC at $282 (2007$) to $350 

(2007$) for small cars through large trucks, respectively. Converting to 2010$, these DMCs 

become $295 (2010$) through $367 (2010$) for this analysis, and are considered applicable in 

MY 2015. The agencies consider 12V stop-start technology to be on the steep portion of the 

learning curve in the 2012-2016 timeframe and flat thereafter, and have applied a medium 

complexity ICM of 1.39 through 2018 then a long-term ICM of 1.29 thereafter. The resultant 

costs are shown in Table V-58. 

Table V-58 Costs for 12V Micro Hybrid (2010$) 

Cost 

type NHTSA Vehicle Class 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Subcompact PC/Perf PC $232 $225 $219 $212 $206 $200 $194 $188 $182 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

330 

DMC Compact PC/Perf PC $251 $244 $236 $229 $222 $216 $209 $203 $197 

DMC Midsize PC/Perf PC $276 $268 $260 $253 $244 $237 $230 $223 $216 

DMC Large PC/Perf PC $297 $288 $279 $271 $263 $255 $247 $239 $232 

DMC Minivan $297 $288 $279 $271 $263 $255 $247 $239 $232 

DMC Midsize LT $304 $295 $286 $278 $269 $261 $254 $245 $238 

DMC Small LT $263 $255 $246 $239 $232 $225 $218 $212 $206 

DMC Large LT $343 $333 $323 $313 $304 $295 $286 $278 $270 

IC Subcompact PC/Perf PC $93 $92 $69 $69 $69 $69 $68 $68 $68 

IC Compact PC/Perf PC $100 $100 $75 $74 $74 $74 $74 $74 $73 

IC Midsize PC/Perf PC $110 $109 $82 $82 $81 $81 $81 $81 $81 

IC Large PC/Perf PC $118 $117 $88 $88 $87 $87 $87 $87 $86 

IC Minivan $118 $117 $88 $88 $87 $87 $87 $87 $86 

IC Midsize LT $121 $120 $90 $90 $89 $89 $89 $89 $89 

IC Small LT $104 $104 $78 $78 $77 $77 $77 $77 $77 

IC Large LT $136 $136 $102 $101 $101 $101 $101 $100 $100 

TC Subcompact PC/Perf PC $325 $318 $288 $281 $275 $268 $262 $256 $249 

TC Compact PC/Perf PC $351 $343 $311 $304 $297 $290 $283 $277 $271 

TC Midsize PC/Perf PC $386 $378 $341 $333 $325 $318 $311 $304 $297 

TC Large PC/Perf PC $415 $405 $367 $359 $349 $341 $334 $326 $319 

TC Minivan $415 $405 $367 $359 $349 $341 $334 $326 $319 

TC Midsize LT $425 $415 $376 $367 $359 $350 $342 $334 $326 

TC Small LT $367 $359 $324 $317 $309 $302 $295 $289 $282 

TC Large LT $481 $470 $425 $415 $405 $396 $387 $378 $370 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

High Voltage Stop-Start/Belt Integrated Starter Generator (ISG) 

Higher Voltage Stop-Start and Belt Mounted Integrated Starter Generator (BISG) systems are 

similar to a micro-hybrid system, offering idle-stop functionality, except that they utilize larger 

electric machine and a higher capacity battery, typically 42 volts or above, thus enabling a 

limited level of regenerative braking unavailable for a MHEV. The larger electric machine and 

battery also enables a limited degree of power assist, which MHEV cannot provide. However, 

because of the limited torque capacity of the belt-driven design, these systems have a smaller 

electric machine, and thus less capability than crank-integrated or stronger hybrid systems. 

These systems replace the conventional alternator with a belt-driven starter/alternator and may 

add electric power steering and an auxiliary automatic transmission pump. The limited electrical 

requirements of these systems allow the use of lead-acid batteries or super-capacitors for energy 

storage, or the use of a small lithium-ion battery pack, as is modeled in this analysis. While the 

mild hybrid system was not applied in the NPRM analysis because the agencies judged it was not 

cost-effective at that time, the agencies have decided to make the technology available for the 

final rule because credits are available for mild hybrid pickup trucks. The simulation modeling 
                                                      

331 

and cost estimation results show that the mild hybrid system could be a cost effective technology 

on the vehicle electrification technology path. 

For the BISG technology the agencies sized the system using a 15 kW starter/generator and 0.25 

kWh Li-ion battery pack, which is similar to General Motors’ eAssist BISG, which is available 

in MY 2012 Buick LaCrosse, Buick Regal, and Chevrolet Malibu vehicles. The agencies made 

this size system available to all vehicle subclasses, believing that manufacturers might use a 

similar strategy to control component complexity across the subclasses. As mentioned above, 

estimates were developed by ANL using Autonomie full vehicle simulation software. The 

absolute effectiveness for the CAFE analysis ranged from 8.5 to 11.6 percent depending on 

vehicle subclass. The effectiveness values include technologies that would be expected to 

incorporated with BISG which are stop/start (MHEV) and improved accessories (IACC1 and 

IACC2), however the effectiveness values do not include electric power steering (EPS). 

The costs for the mild hybrid technology are all new for this final rule and were developed in a 

manner consistent with costs generated for strong hybrids. The ISG costs are shown in Table V59. 

Table V-59 Costs for ISG Hybrid (2010$) 

Cost 

type 

NHTSA 

Vehicle Class 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $1,093 $1,065 $1,039 $1,013 $987 $963 $939 $915 $892 

IC All $1,642 $1,613 $1,527 $1,499 $1,472 $1,447 $1,421 $1,397 $1,255 

TC All $550 $548 $488 $487 $485 $484 $483 $482 $362 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Integrated Motor Assist (IMA)/Crank Integrated Starter Generator 

IMA is a system developed and marketed by Honda259 and is similar to CISG. They both utilize 

a thin axial electric motor bolted to the engine’s crankshaft and connected to the transmission 

through a torque converter or clutch. The axial motor is motor/generator that typically operates 

above 100 volts (but lower than the stronger hybrid systems discussed below, which typically 

operate at around 300 volts) and can provide sufficient torque for launch as well as generate 

sufficient current to provide significant levels of brake energy recovery. The motor/generator 

also acts as the starter for the engine and can replace a typical accessory-driven alternator. 

Current IMA/CISG systems typically do not launch the vehicle on electric power alone, although 

some commercially available systems can cruise on electric power and dual-clutch IMA/CISG 

systems capable of all-electric drive are under development. IMA and CISG could be applied to 

259 http://automobiles.honda.com/insight-hybrid/features.aspx?Feature=ima (last accessed on November 14, 2011) 
332 

all classes of vehicles. IMA technology is not included as an enabling technology in this 

analysis, although it is included as a baseline technology because it exists in the 2008 baseline 

fleet. Neither NHTSA nor EPA used this technology as an enabling technology in this FRM 

analysis. 

Batteries for MHEV, ISG, HEV, PHEV and EV Applications 

The design of battery secondary cells can vary considerably between MHEV, ISG, HEV, PHEV 

and EV applications. 

MHEV batteries: Due to their lower voltage (12-42 VDC) and reduced power and energy 

requirements, MHEV systems may continue to use lead-acid batteries even long term (2017 

model year and later). MHEV battery designs differ from those of current starved-electrolyte 

(typical maintenance free batteries) or flooded-electrolyte (the older style lead-acid batteries 

requiring water “top-off”) batteries used for starting, lighting and ignition (SLI) in automotive 

applications. Standard SLI batteries are primarily designed to provide high-current for engine 

start-up and then recharge immediately after startup via the vehicle’s charging system. Deeply 

discharging a standard SLI battery will greatly shorten its life. MHEV applications are expected 

to use: 

 Extended-cycle-life flooded (ELF) lead-acid batteries 

 Absorptive glass matt, valve-regulated lead-acid (AGM/VRLA) batteries –or – 

 Asymmetric lead-acid battery/capacitor hybrids (e.g., flooded ultra-batteries) 

MHEV systems using electrolytic double-layer capacitors are also under development and may 

provide improved performance and reduced cost in the post-2017 timeframe. 

ISG and HEV batteries: ISG and HEV applications operate in a narrow, short-cycling, 

charge-sustaining state of charge (SOC). Energy capacity in ISG and HEV applications is 

somewhat limited by the ability of the battery and power electronics to accept charge and by 

space and weight constraints within the vehicle design. ISG and HEV battery designs tend to be 

optimized for high power density rather than high energy density, with thinner cathode and 

anode layers and more numerous current collectors and separators (Figure V-33). 

EV batteries: EV batteries tend to be optimized for high energy density and are 

considerably larger and heavier than HEV batteries in order to provide sufficient energy 

capacity. EV battery cells tend to have thicker cathode and anode layers and fewer collectors 

and separators than HEV cells. This reduced the specific cost on a per-kWh basis for EV battery 

cells relative to HEV battery cells. 

PHEV batteries: PHEV battery designs are intermediate between power-optimized HEV 

and energy-optimized EV battery cell designs. PHEV batteries must provide both charge 

depleting operation similar to an EV and charge sustaining operation similar to an HEV. Unlike 

HEV applications, charge-sustaining operation with PHEVs occurs at a relatively low battery 
                                                      

 

 

   Collector (-) Cathode (-) 

Separator 

Anode (+) 

Collector (+) 

HEV Power-optimized Battery Cell 

333 

SOC, which can pose a significant challenge with respect to attaining acceptable battery cycle 

life. In the case of the GM Volt, this limits charge depleting operation to a minimum SOC of 

approximately 30 percent.260 An alternative approach for PHEV applications that has potential 

to allow extension of charge depletion to a lower battery SOC is using energy-optimized lithiumion batteries for charge depleting operation in combination with the use of supercapacitors for 

charge sustaining operation.261 

Figure V-33: Schematic representation of power and energy optimized 

prismatic-layered battery cells 

EV Energy-optimized Battery Cell 

Power-split hybrid vehicles from Toyota, Ford and Nissan (which uses the Toyota system under 

license), integrated motor assist hybrid vehicles from Honda and the GM 2-mode hybrid vehicles 

currently use nickel-metal hydride (NiMH) batteries. Lithium-ion (Li-ion) batteries offer the 

potential to approximately double both the energy and power density relative to current NiMH 

batteries, enabling much more electrical-energy-intensive automotive applications such as 

PHEVs and EVs. 

260 “Latest Chevrolet Volt Battery Pack and Generator Details and Clarifications.” Lyle Dennis interview of Rob 

Peterson (GM) regarding the all-electric drive range of the GM Volt, August 29, 2007. Accessed on the Internet on 

November 14, 2011 at http://gm-volt.com/2007/08/29/latest-chevy-volt-battery-pack-and-generator-details-andclarifications/

261 “Active Combination of Ultracapacitors and Batteries for PHEV ESS.” Bohn, T. U.S. Department of Energy 

2009 Vehicle Technologies Merit Review, May 20, 2009, Docket No. NHTSA-2010-0131 or available at 

http://www1.eere.energy.gov/vehiclesandfuels/pdfs/merit_review_2009/vehicles_and_systems_simulation/vss_15_b 

ohn.pdf (last accessed November 14, 2011) 
                                                      

334 

Li-ion batteries for high-volume automotive applications differ substantially from those used in 

consumer electronics applications with respect to cathode chemistry, construction and cell size. 

Li-ion battery designs currently in production by CPI (LG-Chem) for the GM Volt PHEV and by 

AESC and GS-Yuasa (respectively) for the Nissan Leaf and Mitsubishi iMiEV use large-format, 

layered-prismatic cells assembled into battery modules. The modules are then combined into 

battery packs. 

Two families of cathode chemistries are used in large-format, automotive Li-ion batteries 

currently in production – LiMn2O4-spinel (CPI, GS-Yuasa, AESC) and LiFePO4 (A123 

Systems). Current production batteries typically use graphite anodes. Automotive Li-ion 

batteries using lithium nickel manganese cobalt (NMC) oxide cathodes with graphite anodes are 

in advanced stages of development for PHEV and EV applications. The agencies expect largeformat Li-ion batteries to completely replace NiMH batteries for post-2017 HEV applications. 

We also expect that large-format stacked and/or folded prismatic Li-ion cell designs will 

continue to be used for PHEV and EV applications and that NMC/graphite Li-ion batteries will 

be a mature technology for 2017-2025 light-duty vehicle applications. Another more distant 

future option may be lithium-sulfur batteries, but we have not accounted for them in this 

rulemaking analysis due to the need to resolve certain safety concerns and the potential for loss 

of polysulfides from the dilithium crystals to the electrolyte, leading to fading of battery capacity 

over time.262 

HEV, PHEV and EV System Sizing and Cost Estimating Methodology 

Battery packs are (and will continue to be) one of the most expensive components for EVs, 

PHEVs and HEVs. To obtain reasonable cost estimates for electrified vehicles, it is important to 

establish a reliable approach for determining battery attributes for each vehicle and class. Both 

battery energy content (“size”) and power rating are key inputs used to establish costs per ANL’s 

battery costing model. For EVs and PHEVs in particular, battery size and weight are closely 

related, and so battery weight must be known as well. The following section details the steps 

taken to size a battery and how battery costs are derived by EPA using ANL’s BatPaC model. 

Battery Pack Sizing and Hybrid System Sizing 

Calculation of required battery pack energy requirements for EVs and PHEVs is not 

straightforward. Because vehicle energy consumption is strongly dependent on weight, and 

battery packs are very heavy, the weight of the battery pack itself can change the energy required 

to move the vehicle. As vehicle energy consumption increases, the battery size must increase for 

262 See http://www-ssrl.slac.stanford.edu/content/sites/default/files/documents/science-highlights/pdf/lis.pdf (last 

accessed Aug. 5, 2012). 
       

   

   

         

            

2008 Fuel Economy vs. Inertia Weight

(source: Fuel Economy Trends Report, Table M‐80)

CombinedFE (mpg) 60

50

40

30

20

10

0

0 1000 2000 3000 4000 5000 6000 7000

y = 0.00000180x2 ‐ 0.02194637x + 85.81284974

R2 = 0.99565332

Inertia wt (lbs)

335 

a given range (in the case of EVs and PHEVs) – as a result, vehicle weight increases, and permile energy consumption increases as well, increasing the battery size, and so on. 

EPA built spreadsheets to estimate the required battery size for each vehicle and class. Listed 

below are the steps EPA has taken in these spreadsheets to estimate not only battery size, but 

associated weight for EVs and PHEVs of varying ranges and designs. 

1. Establish baseline FE/energy consumption 

2. Assume nominal weight of electrified vehicle (based on weight reduction target) 

3. Calculate vehicle energy demand at this target weight 

4. Calculate required battery energy 

5. Calculate actual battery and vehicle weight 

6. Do vehicle weight and battery size match estimated values? 

Steps 2-6 were iterated until assumed weight reduction target (and nominal vehicle weight) 

reconciled with required battery size and the calculated weight of each vehicle. 

Vehicle energy consumption is estimated based on a fitted trendline for fuel economy versus 

inertia weight, or estimated test weight (ETW) (from FE Trends data for 2008 MY vehicles, 

table M-80) and converting to Wh/mi. This is shown in Figure V-34. 

Figure V-34 Average fuel economy based on inertia weight (ETW) from FE Trends data 

Then, fuel economy was converted into energy consumption (assuming 33,700 Wh energy in 1 

gallon of gasoline) and used to populate a range of test weights between 2,000 and 6,000 lbs. A 

linear trend line was used to fit this curve and then applied to estimate generic energy 

consumption for baseline vehicles of a given ETW, shown below in Figure V-35. 
   

   

   

2008    Energy Consumption      vs. Inertia Weight

Energy Consumption (Wh/mi) 2000

1800

1600

1400

1200

1000

800

600

400

200

0

Inertia wt (lbs)

y = 0.3135x

R2 = 0.9929

0 1000 2000 3000 4000 5000 6000 7000

336 

Figure V-35 Equivalent energy consumption (in Wh/mi) for baseline vehicles 

To calculate battery pack size, the electrified vehicle weight must first be known; to calculate 

vehicle weight, the battery pack size must first be known. This circular reference required an 

iterative solution. EPA assumed a target vehicle glider (a rolling chassis with no powertrain) 

weight reduction and applied that to the baseline curb weight. The resulting nominal vehicle 

weight was then used to calculate the vehicle energy demand. To calculate the energy demand 

(efficiency) of an electric vehicle in Wh/mi, the following information was needed: 

 Baseline energy consumption / mpg 

 Efficiency (η) improvement of electric vehicle 

 Change in road loads 

In Table V-60 below, the following definitions apply: 

	 Brake eff (brake efficiency) – the % amount of chemical fuel energy converted to energy 

at the engine crankshaft (or, for batteries, the amount of stored electrical energy 

converted to shaft energy entering the transmission) 

	 D/L eff (driveline efficiency) – the % of the brake energy entering the transmission 

delivered through the driveline to the wheels 

 Wheel eff (wheel efficiency) – the product of brake and driveline efficiency 

 Cycle eff (cycle efficiency) – the % of energy delivered to the wheels used to overcome 

road loads and power the vehicle (it does not include energy lost as braking heat) 

 Vehicle efficiency – the product of wheel and cycle efficiency 

 Road loads – the amount of resistant energy the vehicle must overcome during a 

city/highway test. Composed of vehicle weight (inertia), aerodynamic drag and rolling 

resistance 
 

 

 

 

 

 

 

 

                                                      

337 

	 Vehicle efficiency – the product of wheel and cycle efficiency 

	 Road loads – the amount of resistant energy the vehicle must overcome during a 

city/highway test. Composed of vehicle weight (inertia), aerodynamic drag and rolling 

resistance. 

Table V-60: EV100 efficiency and energy demand calculations, 20% appl. weight reduction 

Vehicle Class Brake 

eff 

D/L 

eff 

Wheel 

eff 

Cycle 

eff 

Vehicle 

eff 

Road 

loads 

Energy 

reduction 

Energy 

eff 

increase 

IWbased, 

base ICE 

nominal 

mpgge 

Base 

fuel 

energy 

req’d 

Wh/mi 

FTP 

fuel 

energy 

req’d 

Wh/mi 

Onroad 

fuel 

energy 

req’d 

Wh/mi 

Baseline gas 

ICE 24% 81% 20% 77% 15% 100% 

Sub/Compact 

PC 85% 93% 79% 97% 77% 88% 83% 478% 37 912 158 225 

Midsize PC 85% 93% 79% 97% 77% 88% 83% 478% 30 1122 194 277 

Large PC 85% 93% 79% 97% 77% 88% 83% 478% 25 1332 230 329 

Small LT 85% 93% 79% 97% 77% 89% 83% 475% 29 1180 205 293 

Midsize LT 85% 93% 79% 97% 77% 89% 83% 475% 23 1497 260 372 

Large LT 85% 93% 79% 97% 77% 88% 83% 482% 20 1727 297 424 

The energy efficiency of a baseline vehicle (around 15 percent), as indicated in the table above, 

was estimated using efficiency terms derived from EPA’s lumped parameter model 

(engine/battery brake efficiency, driveline efficiency, cycle efficiency and road load ratio to 

baseline). To calculate the energy consumption of an EV (or PHEV in charge-depleting mode), 

the following assumptions were made: 

	 “Brake” efficiency (for an EV, the efficiency of converting battery energy to tractive 

energy at the transmission input shaft) was estimated at 85% - assuming, roughly a 

95% efficiency for the battery, motor, and power electronics, respectively. 

	 The driveline efficiency (including the transmission) was comparable to the value 

calculated by the lumped parameter model for an advanced 6-speed dual-clutch 

transmission at 93%. 

	 The cycle efficiency assumes regenerative braking where 97% recoverable braking 

energy is recaptured. As a result, most of the energy delivered to the wheels is used 

to overcome road loads. 

	 The road loads were based on the weight reduction of the vehicle. In the case of a 

100 mile EV with a 20% weight reduction, road loads (as calculated by the LP model) 

are reduced to 88-89% of the baseline vehicle.263 

The energy consumption of the EV includes ratio of the road loads of the EV to the baseline 

vehicle, and the ratio of the efficiency of the EV compared to the baseline vehicle. It is 

expressed mathematically as shown below in Equation V-1. 

263 Included in this example road load calculation is a 10% reduction in rolling resistance and aerodynamic drag. 
338 

Equation V-4: EV energy consumption 

%ܴ݋݈ܽ݀݋ܽ݀௘௡௪ ܧா௏_ி்௉ሺ /ܹ݄݉݅ ሻ ൌ ܧ௔௕௦௘௟௜௡௘_ி்௉ ∗ ቆ %ܴ݋݈ܽ݀݋ܽ݀௟௢ௗ

∗ ߟ௩௘௛௜௖௟௘_௢௟ௗ ቇ ߟ௩௘௛௜௖௟௘_௡௘௪

In Table V-60, the baseline energy required (in Wh/mi) is in the column labeled “Base fuel 

energy reqd.” The energy required for each vehicle class EV over the FTP is in the column 

“FTP fuel energy reqd Wh/mi” and incorporates the equation above. This energy rate refers to 

the laboratory or unadjusted test cycle value, as opposed to a real-world “on-road” value. EPA 

assumes a 30% fuel economy shortfall, based loosely on the 5-cycle Fuel Economy Labeling 

Rule from 2006 which is directionally correct for electrified vehicles. This corresponds to an 

increase in fuel consumption of 43%. Applying this 43% increase gives the onroad energy 

consumption values for EVs as shown in the far right column of the previous table. From this 

value, one can determine an appropriate battery pack size for the vehicle. 

The required battery energy for EVs equals the on-road energy consumption, multiplied by the 

desired range, divided by the useful state-of-charge window of the battery. It is calculated as 

follows in 

Equation V-5. 

Equation V-5: Required battery pack energy (size) for EVs 

ሻൈݎ ݁݃݊ܽ ሺ݉݅ሻ ݉݅

ௗሺ௢௡௥௢௔ܧ ܹ݄

ܤܲሺܹ݄݇ሻ ൌ ܱܵܥ%

Assumed usable SOC windows were 80% for EVs (10-90%) and 70% for PHEVs (15%-85%). 

The battery pack sizes are listed in orange in Table V-61 for the 100-mile EV case and show 

both the on-road energy consumption (“EV adj Wh/mi” column) and the nominal battery energy 

content or “battery pack size.” 

Table V-61: Battery pack sizes for 100-mile EV based on inertia weight, 20% applied 

weight reduction 
 

339 

Class Baseline curb wt 

(lb) 

Inertia wt 

(lb) 

EV unadj 

(Wh/mi) 

EV adj 

(Wh/mi) 

100 mile batt pack size 

(kWh) 

2008 Baseline 

Small car 2633 2933 158 225 28.2 

Std car 3306 3606 194 277 34.7 

Large car 3897 4197 230 329 41.1 

Small MPV 3474 3774 205 293 36.7 

Large MPV 4351 4651 260 372 46.5 

Truck 5108 5408 297 424 53.0 

2010 Baseline 

Small car 2753 3053 164 234 29.2 

Std car 3387 3687 200 286 35.7 

Large car 4035 4335 241 344 43.0 

Small MPV 3528 3828 209 298 37.3 

Large MPV 4313 4613 257 367 45.8 

Truck 5346 5646 307 439 54.8 

EPA used Equation V-3 to determine weight of an EV: 

Equation V-6: EV weight calculation 

ܹா௏ ൌ ܹ௕௔௦௘ െ ܹܴ௚௟௜ௗ௘௥ െ ܹூ஼ா_௣௢௪௘௥௧௥௔௜௡ ൅ ܹ௘௟௘௖௧௥௜௖_ௗ௥௜௩௘

Any weight reduction technology was applied only to the glider (baseline vehicle absent 

powertrain) as defined in Equation V-4: 

Equation V-7: Weight reduction of the glider 

ܹܴ௚௟௜ௗ௘௥ ൌ % ܴܹ ∗ ሺܹ௕௔௦௘ െ ܹூ஼ா_௣௢௪௘௥௧௥௔௜௡ሻ

In the case of PHEVs, it was assumed that the base ICE powertrain remains so it is not deducted; 

the proper equation for PHEVs is shown in equation V-5: 

Equation V-5: Weight calculation for PHEV 

ܹ௉ுா௏ ൌ ܹ௕௔௦௘ െ ܹܴ௚௟௜ௗ௘௥ ൅ ܹ௘௟௘௖௧௥௜௖_ௗ௥௜௩௘

Listed in Table V-62 are the assumed baseline ICE-powertrain weights, by vehicle class: 

Table V-62: Baseline ICE-powertrain weight assumptions, by class 
 

 

 

 

 

 

 

 

 

                                                      

 

340 

Vehicle Class Engine Trans 

(diff not included) 

Fuel sys 

(50% fill) 

Engine mounts/ 

NVH treatments 

Exhaust 12V batt Total ICE 

powertrain weight 

Sub/Compact PC 250 125 50 25 20 25 495 

Midsize PC 300 150 60 25 25 30 590 

Large PC 375 175 70 25 30 35 710 

Small LT 300 150 60 25 25 30 590 

Midsize LT 400 200 80 25 30 40 775 

Large LT 550 200 100 25 40 50 965 

EPA then estimated the weight of the electric drive subsystem using the energy content of the 

battery pack as an input. EPA scaled the weight by applying a specific energy for the electric 

drive subsystem, including the battery pack, drive motor, wiring, power electronics, etc., of 120 

Wh/kg (or 18.33 lb/kWh). This specific energy value is based on adding components to an 

assumed battery pack specific energy of 150 Wh/kg.264 Then, the gearbox (the only subsystem 

excluded from the electric drive scaling) was added to the weight of the electric drive subsystem; 

this total was included into the electric vehicle weight calculation as Welectric_drive.

265 A summary 

table of electric drive weights for 100-mile EVs is shown in Table V-63: 

Table V-63: Total electric drive weights for 100-mile EVs 

Class Batt pack size 

(kWh) 

2020 electric content 

 (lbs) 

Gearbox 

(power-split or other ) 

2020 EV 

powertrain total 

2008 Baseline 

Sub/Compact PC 28.2 517 50 567 

Midsize PC 34.7 635 60 695 

Large PC 41.1 754 70 824 

Small LT 36.7 672 60 732 

Midsize LT 46.5 853 80 933 

Large LT 53.0 972 100 1072 

2010 Baseline 

Sub/Compact PC 29.2 536 50 586 

Midsize PC 35.7 655 60 715 

Large PC 43.0 788 70 858 

Small LT 37.3 683 60 743 

Midsize LT 45.8 840 80 920 

Large LT 54.8 1005 100 1105 

The difference between the actual weight and the predicted or nominal weight should be zero. 

However, if not then a revised weight reduction was used for another iteration of steps 2-6 until 

the two vehicle weights match. Spreadsheet tools such as “solver” in MS Excel were used for 

automating this iterative process. 

264 150 Wh/kg is a conservative estimate for year 2017 and beyond: outputs from ANL’s battery cost model show 

specific energy values of 160- 180 Wh/kg for a similar timeframe. 265 Applies only to the EV. Because the baseline ICE powertrain weight (which includes gearbox weight) was not 

deducted from the PHEV, it is not added back in for the PHEV. 
 

 

341 

Table V-64 shows example results for 100-mile range EVs; in this case a 20% applied glider 

weight reduction for a variety of vehicle classes. 

Table V-64: Sample calculation sheet for 100-mile EVs for the 2008 baseline 

Class 

Base 

curb wt 

(lb) 

Base 

power/w 

t ratio 

Powertr 

ain 

weight 

(lb) 

Base 

glider 

wt 

(lb) 

WR 

of 

glider 

New EV 

wt 

(nominal 

lb) 

Energy 

cons 

adjusted 

(Wh/mi) 

Batt 

pack 

size 

(kWh) 

Electric 

drive wt 

(lb) 

New 

EV 

weight 

(lb) 

Error 

% WR 

from 

curb 

% 

RL 

vs 

base 

Sub/Compac 

t PC 2633 0.0486 495 2138 428 2205 225 28.2 567 2277 0 13.5 

% 

88 

% 

Midsize PC 3306 0.0575 590 2716 543 2763 277 34.7 695 2868 0 13.2 

% 

88 

% 

Large PC 3897 0.0872 710 3187 637 3260 329 41.1 824 3374 0 13.4 

% 

88 

% 

Small LT 3474 0.0463 590 2884 577 2897 293 36.7 732 3039 0 12.5 

% 

89 

% 

Midsize LT 4351 0.0565 775 3576 715 3636 372 46.5 933 3794 0 12.8 

% 

89 

% 

Large LT 5108 0.0617 965 4143 829 4279 424 53.0 1072 4387 0 14.1 

% 

88 

% 

Table V-65 shows the effect on net electric vehicle weight reduction after 20% glider weight 

reduction was applied to EVs and PHEVs. As battery pack size increases for larger-range EVs 

and PHEVs, the overall realized vehicle weight reduction decreases (because it requires more 

energy to carry the extra battery weight). In this example, EVs with a 150 mile range require 

almost 20% weight reduction to the glider to make up for the additional weight of the electric 

drive and battery pack compared to a conventional ICE-based powertrain. 

Table V-65: Actual weight reduction percentages for EVs and PHEVs with 20% weight 

reduction applied to glider 
 

 

 

 

 

 

 

 

 

 

 

 

 

342 

75 Mile EV 

Actual %WR 

vs. 

base vehicle 

100 Mile EV 

Actual %WR vs. 

base vehicle 

150 Mile EV 

Actual %WR vs. 

base vehicle 

20 Mile PHEV 

Actual %WR vs. 

base vehicle 

40 Mile PHEV 

Actual %WR vs. 

base vehicle 

2008 Baseline 

Sub/Compact 

PC 19% 14% 2% 12% 7% 

Midsize PC 18% 13% 2% 12% 7% 

Large PC 19% 13% 2% 12% 7% 

Small LT 18% 13% 1% 12% 7% 

Midsize LT 18% 13% 1% 12% 7% 

Large LT 19% 14% 3% 11% 6% 

2010 Baseline 

Sub/Compact 

PC 18% 13% 1% 12% 7% 

Midsize PC 18% 13% 1% 12% 7% 

Large PC 18% 13% 1% 12% 7% 

Small LT 18% 12% 1% 12% 8% 

Midsize LT 18% 13% 1% 12% 7% 

Large LT 19% 14% 3% 11% 6% 

Because there is no “all-electric range” requirement for HEVs, battery pack sizes were relatively 

consistent for a given weight class. Furthermore, because battery pack sizes are at least an order 

of magnitude smaller for HEVs than for all-electric vehicles, the sensitivity of HEV vehicle 

weight (and hence energy consumption) to battery pack size is rather insignificant. For these 

reasons, a more direct approach (rather than an iterative process) works for battery sizing of 

HEVs. HEV batteries were scaled similar to the 2010 Fusion Hybrid based on nominal battery 

energy per lb ETW (equivalent test weight), at 0.37 Wh/lb. A higher usable SOC window of 

40% (compared to 30% for Fusion Hybrid) reduced the required Li-Ion battery size to 75% of 

the Fusion Hybrid’s NiMH battery. This resulted in a 0.28 Wh/lb ETW ratio. In comparing 

anecdotal data for HEVs, the agencies assumed a slight weight increase of 4-5% for HEVs 

compared to baseline non-hybridized vehicles. The added weight of the Li-ion pack, motor and 

other electric hardware were offset partially by the reduced size of the base engine. 

HEV, PHEV and EV Battery Pack Cost Analysis using the ANL BatPac Model 

The U.S. Department of Energy (DOE) has established long term industry goals and targets for 

advanced battery systems as it does for many energy efficient technologies. Argonne National 

Laboratory (ANL) was funded by DOE to provide an independent assessment of Li-ion battery 

costs because of their expertise in the field as one of the primary DOE National Laboratories 

responsible for basic and applied battery energy storage technologies for future HEV, PHEV and 

EV applications. A basic description of the ANL Li-ion battery cost model and initial modeling 

results for PHEV applications were published in a peer-reviewed technical paper presented at 
                                                      

 

 

 

343 

EVS-24.266 ANL has extended modeling inputs and pack design criteria within the battery cost 

model to include analysis of manufacturing costs for EVs and HEVs as well as PHEVs.267 In 

early 2011, ANL issued a draft report detailing the methodology, inputs and outputs of their 

Battery Performance and Cost (BatPac) model.268 A complete independent peer-review of the 

BatPac model and its inputs and results for HEV, PHEV and EV applications has been 

completed.269 ANL recently provided the agencies with an updated report documenting the 

BatPac model that addresses many of the issues raised within the peer review.270 Based on the 

feedback from peer-reviewers, ANL updated the model in the following areas: 

1.	 Battery pack cost is adjusted upward. This adjustment is based on the feedback from 

several peer-reviewers, and changes are related to limiting electrode thickness to 100 

microns, changing allocation of overhead cost to more closely represent a Tier 1 auto 

supplier, increasing cost of tabs, changing capital cost of material preparation, etc; 

2.	 Battery management system cost is increased to represent the complete monitoring and 

control needs for proper battery operation and safety as shown in Table 5.3 in the report; 

3.	 Battery automatic and manual disconnect unit cost is added based on safety 

considerations as shown in Table 5.3 in the report; 

4.	 Liquid thermal management system is added. ANL stated in the report that the liquidcooled closure design it uses in the model would not have sufficient surface area and cell 

spacing to be cooled by air effectively as shown in Table 5.3 in the report. 

Subsequently, the agencies requested that an option be added to select between liquid or air 

thermal management and that adequate surface area and cell spacing be determined accordingly. 

Also, the agencies requested a feature to allow battery packs to be configured as subpacks in 

parallel or modules in parallel, as additional options for staying within voltage and cell size 

limits for large packs. 

ANL added these features in a version of the model distributed March 1, 2012. This version of 

the model is used for the battery cost estimates in the final rule. This model and the peer review 

report are available in the public dockets for this rulemaking. 

266 Nelson, P.A., Santini, D.J., Barnes, J. “Factors Determining the Manufacturing Costs of Lithium-Ion Batteries for 

PHEVs,” 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24, 

Stavenger, Norway, May 13-16, 2009 Docket No. NHTSA-2010-0131 or Available at 

http://www.transportation.anl.gov/pdfs/B/624.PDF (last accessed November 14, 2011). 267 Santini, D.J., Gallagher, K.G., and Nelson, P.A. “Modeling of Manufacturing Costs of Lithium-Ion Batteries for 

HEVs, PHEVs, and EVs,” Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric Vehicle 

Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010. Available at http://www.docin.com/p99138808.html (last accessed November 14, 2011). 268 The ANL draft report can be found at Docket No. NHTSA-2010-0131. 269 The ANL peer review can be found in at Docket No. NHTSA-2010-0131. 270 The ANL final report on BatPac can be found at Docket No. NHTSA-2010-0131. 
344 

NHTSA and EPA decided to use the ANL BatPaC model, for estimating large-format lithiumion batteries for this final rule, consistent with the proposal, for the following reasons. First, the 

ANL model has been described and presented in the public domain and does not rely upon 

confidential business information (which would therefore not be reviewable by the public). The 

model was developed by scientists at ANL who have significant experience in this area. The 

model uses a bill of materials methodology which the agencies believe is the preferred method 

for developing cost estimates. The ANL model appropriately considers the vehicle applications 

power and energy requirements, which are two of the fundamental parameters when designing a 

lithium-ion battery for an HEV, PHEV, or EV. The ANL model can estimate high volume 

production costs, which the agencies believe is appropriate for the 2025 time frame. Finally, the 

ANL model’s cost estimates, while generally lower than the estimates we received from the 

OEMs, is consistent with some of the supplier cost estimates the agencies received from largeformat lithium-ion battery pack manufacturers. A portion of those data was received from onsite visits to vehicle manufacturers and battery suppliers done by the EPA in 2008. 

The ANL battery cost model is based on a bill of materials approach in addition to specific 

design criteria for the intended application of a battery pack. The costs include materials, 

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

manufacturing step as well as the design criteria include a vehicle application’s power and 

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

of cells per module and modules per battery pack. The model assumes use of a laminated multilayer prismatic cell and battery modules consisting of double-seamed rigid containers. The 

model also assumes that the battery modules are liquid-cooled. The model takes into 

consideration the cost of capital equipment, plant area and labor for each step in the 

manufacturing process for battery packs and places relevant limits on electrode coating 

thicknesses and other processes limited by existing and near-term manufacturing processes. The 

ANL model also takes into consideration annual pack production volume and economies of scale 

for high-volume production. 

Basic user inputs to BatPaC include performance goals (power and energy capacity), choice of 

battery chemistry (of five predefined chemistries), the vehicle type for which the battery is 

intended (HEV, PHEV, or EV), the desired number of cells and modules, and the volume of 

production. BatPaC then designs the cells, modules, and battery pack, and provides an itemized 

cost breakdown at the specified production volume. 

BatPaC provides default values for engineering properties and material costs that allow the 

model to operate without requiring the user to supply detailed technical or experimental data. In 

general, the default properties and costs represent what the model authors consider to be 

reasonable values representing the state of the art expected to be available to large battery 
345 

manufacturers in the year 2020. Users are encouraged to change these defaults as necessary to 

represent their own expectations or their own proprietary data. 

In using BatPaC, it is extremely important that the user monitor certain properties of the cells, 

modules, and packs that it generates, to ensure that they stay within practical design guidelines, 

adjusting related inputs if necessary. In particular, pack voltage and individual cell capacity 

should be limited to appropriate ranges for the application. These design guidelines are not 

rigidly defined but approximate ranges are beginning to emerge in the industry. 

Also inherent in BatPaC are certain modeling assumptions that are still open to some uncertainty 

or debate in the industry. For some, such as the available portion of total battery energy (aka 

"SOC window") for a PHEV/EV/HEV, the user can easily modify a single parameter to 

represent a value other than the default. For others, such as specific unit costs for thermal 

management or battery monitoring components, changes can often be made by replacing the 

relevant components of the model outputs. 

The cost outputs used by the agencies to determine 2025 HEV, PHEV and EV battery costs were 

based on the following inputs and assumptions: 

EPA selected basic user inputs as follows. For performance goals, EPA used the power and 

energy requirements derived from the scaling analysis described in the previous section. 

Specifically, these covered each of the six classes of vehicles (Small Car, Standard Car, Large 

Car, Small MPV, Large MPV, and Truck) under each of the five weight reduction scenarios (0%, 

2%, 7.5%, 10%, and 20%). The chosen battery chemistries were NMC441-G (for EVs and 

PHEV40) and LMO-G (for P2 HEVs and PHEV20). Vehicle types were EV75, EV100, EV150 

(using the BatPaC "EV" setting); PHEV20 and PHEV40 (using the "PHEV" setting), and P2 

HEV (using the "HEV-HP" setting). All modules were composed of 32 cells, with each pack 

having a varying number of modules. Cost outputs were generated for annual production 

volumes of 50K, 125K, 250K, and 450K packs. The cost outputs for the 450K production 

volume are used in the FRM analysis, consistent with the proposal, as being applicable in MY 

2017 (HEV) and MY 2025 (EVs and PHEVs). 

For engineering properties and material costs, and for other parameters not identified below, 

EPA used the defaults provided in the model. For design guidelines regarding pack voltage and 

cell capacity, EPA chose guidelines based on knowledge of current practices and developing 

trends of battery manufacturers and OEMs, supplemented by discussions with the BatPaC 

authors. Specifically: (1) allowable pack voltage was targeted to approximately 120V for HEVs 

and approximately 350-400V for EVs and PHEVs (with some EV150 packs for larger vehicles 

allowed to about 460-600V); (2) allowable cell capacity was limited to less than approximately 

80 A-hr. 
346 

EPA made several modeling assumptions that differed from the default model: (1) The SOC 

window for HEVs was increased to 40% rather than the default 25%. (2) HEV packs were 

modeled as air cooled instead of liquid cooled (except for Truck and MPV with Towing, which 

are modeled as liquid-cooled). EPA replaced the model's projected costs for air cooling 

components (blower motor, ducting, and temperature feedback) with costs derived from FEV’s 

teardown studies, which may be more representative of volume production than the default 

values provided in the model. 

Additionally, EPA did not include warranty costs computed by BatPaC in the total battery cost 

because these are accounted for elsewhere in the agencies’ rulemaking analysis by means of 

indirect cost multipliers (ICMs). 

Table V-66 Summary of Inputs and Assumptions Used with BatPaC 

Category of 

input/Assumptions 

BatPaC Default or 

Suggested Values 

Agency Inputs for FRM 

Analysis 

Annual production 

volume 

n/a 450,000 

Battery chemistry n/a for HEV, PHEV20: LMO-G 

for PHEV40, EV: NMC441-G 

Allowable pack voltage for HEV: 160-260 V 

for PHEV, EV: 290-360 V 

for HEV: ~ 120 V 

for PHEV, EV: ~ 360-600 V 

Allowable cell capacity < 60 A-hr < 80 A-hr 

Cells per module 16-32 32 

SOC window for HEVs 25% 40% 

Thermal management Liquid Air, for small/medium HEVs 

Liquid for all others 

The cost projections produced by BatPaC are sensitive to the inputs and assumptions the user 

provides. Significant uncertainty remains regarding which will best represent manufacturer 

practice in the year 2020. The battery pack cost projection from BatPaC model ranges from 

$160/kWh for EV150 for large truck to $306/kWh for PHEV40 for large passenger car with 

NMC as chemistry and to $376/kWh for PHEV20 for large passenger car using LMO as shown 

in Table V-68. The agencies note that costs used in the analysis are lower than the costs 

generally reported in stakeholder meetings, which ranged from $300/kW-hour to $400/kW-hour 

range for 2020 and $250 to $300/kW-hour range for 2025. A comparison of BatPaC modeling 

results to the costs used in MYs 2012-2016 final rule and to cost estimates compiled by EPA 

from battery suppliers and auto OEMs is shown in Table V-67 Table from ANL 

Recommendation 

. 
                                                      

 

 

347 

In the comments for NPRM, ICCT commented that future versions of the BatPac model should 

include the option to select either air or liquid cooling.271 Tesla commented that that while it 

thought the BatPac model was helpful, Tesla rather “supports a more comprehensive approach to 

assessing battery cost,” i.e., by “factor[ing] in all the costs of the battery and attendant systems 

including cell management, thermal management and the disconnect unit.”272 Tesla stated that 

the battery systems in its Model S would cost only $350/kWh at production levels of 

25,000/year, and that it expected its costs to come down in the future.273 Porsche, in contrast, 

argued that the battery costs used in the NPRM were significantly underestimated, which 

“inflates the apparent cost-effectiveness” of the standards.274 As stated above, for the final 

rulemaking the agencies’ requested ANL to update the BatPaC model to allow for either air or 

liquid cooling. This option was used in the final rule analysis. Additionally, the agencies are 

accounting for the costs of cell management, thermal management, and battery disconnect. 

The agencies also reviewed publically available PHEV and EV battery cost literature including 

reports from Anderman275, Frost & Sullivan276, TIAX277, Boston Consulting Group278, and 

NRC279. Due to the uncertainties inherent in estimating battery costs through the 2025 model 

year, a sensitivity analysis will be provided in each agency’s RIA using a range of costs 

estimated by DOE technical experts to represent a reasonable outer bound to the results from the 

BatPaC model. In a recent report to NHTSA and EPA, DOE and ANL suggested the following 

range for the sensitivity study with 95% confidence interval after analyzing the confidence 

bound using the BatPaC model. NHTSA incorporated the BatPaC sensitivity ranges suggested 

by ANL, below, while EPA used bounds described in Chapter 3 of their final RIA. 

Table V-67 Table from ANL Recommendation280 

271 ICCT, Docket No. NHTSA-2010-0131-0258, at 21-22. 272 Tesla, Docket No. NHTSA-2010-0131-0259, at 5. 273 Id. 274 Porsche, Docket No. NHTSA-2010-0131-0224, at 6.
 275 Anderman, M. (2010) Feedback on ARB’s Zero-Emission Vehicle Staff Technical Report of 11/25/2009
 

including attachment A: Status of EV Technology Commercialization, Advanced Automotive Batteries, January 6,
 

2010. NHTSA Docket: NHTSA-2010-0131.
 276 Frost & Sullivan (2009b) World Hybrid Electric and Electric Vehicle Lithium-ion Battery Market, N6BF-27, Sep
 

2009. 

277 Barnett, B. (2009) “PHEV Battery Cost Assessment” TIAX LLC presentation at U.S. DOE/EERE 2009 Vehicle 

Technologies Program Annual Merit Review, May 19, 2009. Accessed on the Internet on Aug 3, 2012 at:
 

http://www1.eere.energy.gov/vehiclesandfuels/pdfs/merit_review_2009/energy_storage/es_02_barnett.pdf. NHTSA
 

Docket: NHTSA-2010-0131.
 278 Boston Consulting Group (2010) Batteries for Electric Cars – Challenges, Opportunities, and the Outlook to
 

2020. Available at http://electricdrive.org/index.php?ht=a/GetDocumentAction/id/27906 (Accessed on Aug 14, 

2012). Docket: NHTSA-2010-0131. 

279 National Research Council (2010) Transitions to Alternative Transportation Technologies--Plug-in Hybrid
 

Electric Vehicles. Available at https://download.nap.edu/catalog.php?record_id=12826 (Accessed on Aug 14, 2012). 

Docket: NHTSA-2010-0131.
 280 K. G. Gallagher, P. A. Nelson, (2010) “An Initial BatPac Variation Study” in Docket: NHTSA-2010-0131. 
 

 

                                                      

 

348 

Suggested confidence bounds as percentage of the 

calculated point estimate for a graphite based Li-ion 

battery using the default inputs in BatPaC 

Confidence 

Interval 

Battery type Cathodes lower upper 

HEV LMO, LFP, NCA, 

NMC -10% 10% 

PHEV, EV NMC, NCA -10% 20% 

PHEV, EV LMO, LFP -20% 35% 

While it is expected that other Li-ion battery chemistries with higher energy density, higher 

power density and lower cost will likely be available in the 2017-2025 timeframe, the specific 

chemistries used for the cost analysis were chosen due to their known characteristics and to be 

consistent with both public available information on current and near term HEV, PHEV and EV 

product offerings from Hyundai, GM and Nissan as well as confidential business information on 

future products currently under development.281,282,283,284 The specific cost outputs from the 

BatPaC model used by NHTSA in this analysis pre-consideration of mass reduction are shown in 

Table V-68. 

Table V-68 MY2017 Direct Manufacturing Costs (2010$) for P2 HEV, PHEVs and EVs at 

0% Net Vehicle Mass Reduction 

NHTSA Vehicle 

Class 

P2 HEV 

(LMO) @ 

450K/yr 

volume 

PHEV20 

(LMO) @ 

450K/yr 

volume 

PHEV40 

(NMC) @ 

450K/yr 

volume 

EV75 (NMC) 

@ 450K/yr 

volume 

EV100 

(NMC) @ 

450K/yr 

volume 

EV150 (NMC) 

@ 450K/yr 

volume 

2008 Baseline 

Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

281 “Hyundai ups tech ante with Sonata Hybrid,” Automotive News, August 2, 2010. Available at 

http://www.autonews.com/apps/pbcs.dll/article?AID=/20100802/RETAIL03/308029942/1186 (last accessed 

November 14, 2011).

282 “Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty,” GM Press release 

available at 

http://media.gm.com/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/July/07
 

14_volt_battery (last accessed: November 14, 2011). 283 “Nissan’s new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6,” SAE Automotive Engineering 

Online, February 15, 2010. Available at http://ev.sae.org/article/7651 (last accessed November 14, 2011) 284 “Lithium-ion Battery,” Nissan Global Technology Information Available at http://www.nissanglobal.com/EN/TECHNOLOGY/OVERVIEW/li_ion_ev.html (last accessed November 14, 2011). 
 

 

 

 

 

 

 

349 

Subcompact 

PC/Perf. PC 

Compact PC/Perf. 

PC 

$726 $896 $2,531 $364 $3,644 $262 $5,115 $224 $6,105 $201 $8,080 $177 

Midsize PC/Perf. PC $801 $804 $2,962 $347 $4,390 $257 $6,021 $215 $7,054 $189 $9,753 $174 

Large PC/Perf. PC $938 $809 $3,734 $368 $6,006 $296 $7,724 $232 $8,630 $195 $11,120 $167 

Small LT $779 $747 $2,835 $316 $4,247 $236 $5,995 $203 $7,293 $186 $10,109 $171 

Minivan/Midsize LT $876 $682 $3,424 $300 $5,269 $231 $7,310 $195 $8,641 $173 $12,114 $162 

Large LT $1,010 $676 $3,874 $295 $6,122 $233 $8,332 $193 $9,962 $173 $13,878 $161 

2010 Baseline 

Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

Subcompact 

PC/Perf. PC 

Compact PC/Perf. 

PC 

$732 $904 $2,572 $370 $3,722 $268 $5,232 $221 $6,255 $198 $8,298 $175 

Midsize PC/Perf. PC $809 $813 $3,019 $353 $4,494 $263 $6,152 $214 $7,173 $187 $9,928 $173 

Large PC/Perf. PC $950 $819 $3,813 $376 $6,158 $304 $7,923 $229 $8,863 $192 $11,432 $166 

Small LT $788 $756 $2,933 $326 $4,351 $242 $6,070 $203 $7,375 $185 $10,228 $171 

Minivan/Midsize LT $878 $683 $3,434 $301 $5,286 $232 $7,312 $197 $8,586 $174 $12,032 $162 

Large LT $1,019 $682 $3,922 $298 $6,215 $236 $8,472 $191 $10,158 $172 $14,166 $160 

Due to the weight increases of adding electrification system such as battery pack, and the weight 

decreases by applying smaller or no conventional internal combustion system for HEVs, PHEVs 

and EVs, the net mass reduction for HEV, PHEV and EV varies for different electrification 

packages and vehicle classes. The agencies estimated vehicle mass reduction offsets for 

different electrification packages as shown in Table V-69. These mass reduction offsets can be 

positive or negative depending on whether the added electrification system is heavier or lighter 

than the mass change due to the downsized conventional powertrain or even the elimination of 

the conventional internal combustion system. For example, for a 20-mile range subcompact 

PHEV shown in Table V-69, a 7% mass reduction of the glider (vehicle systems not including 

powertrain) is offset by the additional weight of the electrification system, and therefore 7% 

mass reduction is needed to achieve a net 0% overall vehicle mass reduction. On the other hand, 

for a 75-mile range large electric passenger car, because a conventional engine and transmission 

weigh more than the addition of the electrification systems, a net mass reduction of 1 percent can 

be achieved by simply switching from conventional gasoline powered vehicle to EV75 without 

applying any mass reduction to the glider. The agencies differentiate between “applied” mass 
 

 

 

 

350 

reduction and “net” mass reduction in this analysis. The applied mass reduction is the mass 

reduction applied to a vehicle to achieve the net mass reduction after considering the interaction 

between mass reduction and electrification system, i.e., the applied mass reduction includes all 

the offsets shown in Table V-69. 

Table V-69 Mass reduction Offset Associated with Electrification Technologies 

Vehicle Class P2 HEV PHEV20 PHEV40 EV75 EV100 EV150 

2008 Baseline 

Subcompact/Compact 5% 7% 13% 0% 6% 18% 

Midsize car 5% 7% 12% 0% 6% 18% 

Large car 5% 8% 14% -1% 5% 17% 

Small LT 5% 7% 12% 0% 6% 18% 

Midsize LT 4% 7% 12% 1% 7% 19% 

Large truck 5% 7% 13% 0% 6% 18% 

2010 Baseline 

Subcompact/Compact 5% 7% 12% 0% 6% 19% 

Midsize car 5% 7% 12% 1% 7% 19% 

Large car 5% 8% 13% 0% 6% 17% 

Small LT 5% 7% 12% 1% 7% 19% 

Midsize LT 5% 7% 12% 1% 7% 19% 

Large LT 4% 7% 12% 0% 6% 19% 

Using the ANL model outputs, the agencies calculated battery system costs for HEVs, PHEVs 

and EVs for different vehicle classes with different level of mass reduction. These results are 

summarized in Table V-70 to Table V-75. NHTSA assumes that all minivans and midsize light 

trucks will maintain current towing capability so that consumers will not lose that functionality 

when moving to electrified vehicles. 

Table V-70 MY2017 Direct Manufacturing Costs for P2 HEV packages at different levels 

of applied vehicle mass reduction (2010 dollars, markups not included) 

P2 HEV (LMO) @ 450K/yr volume 0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$726 $896 $722 $909 $712 $950 $708 $970 $700 $1,008 

Standard Car Midsize PC/Perf. PC $801 $804 $796 $815 $783 $849 $777 $866 $765 $901 

Large Car Large PC/Perf. PC $938 $809 $929 $817 $909 $848 $900 $862 $882 $894 

Small MPV Small LT $779 $747 $775 $758 $762 $790 $757 $806 $746 $839 

Large MPV Minivan $876 $682 $870 $691 $853 $718 $846 $731 $830 $760 
 

351 

Midsize LT 

Truck Large LT $1,010 $676 $1,003 $685 $983 $711 $974 $724 $957 $747 

2010 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$732 $904 $729 $918 $718 $958 $714 $978 $705 $1,017 

Standard Car Midsize PC/Perf. PC $809 $813 $805 $824 $791 $858 $785 $875 $773 $909 

Large Car Large PC/Perf. PC $950 $819 $943 $830 $920 $858 $911 $873 $893 $904 

Small MPV Small LT $788 $756 $784 $767 $771 $800 $765 $816 $754 $848 

Large MPV 

Minivan 

Midsize LT 

$878 $683 $872 $692 $855 $720 $847 $733 $832 $762 

Truck Large LT $1,019 $682 $1,012 $691 $992 $718 $983 $731 $967 $754 

Table V-71 MY2025 Direct Manufacturing Costs for PHEV20 packages at different levels 

of applied vehicle mass reduction (2010 dollars, markups not included) 

PHEV20 (LMO) @ 450K/yr volume 0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$2,531 $364 $2,517 $364 $2,469 $370 $2,447 $371 $2,431 $373 

Standard Car Midsize PC/Perf. PC $2,962 $347 $2,938 $348 $2,835 $345 $2,808 $346 $2,784 $347 

Large Car Large PC/Perf. PC $3,734 $368 $3,696 $369 $3,592 $369 $3,546 $368 $3,510 $369 

Small MPV Small LT $2,835 $316 $2,813 $317 $2,754 $319 $2,730 $320 $2,703 $323 

Large MPV Minivan 

Midsize LT $3,424 $300 $3,393 $301 $3,309 $302 $3,274 $303 $3,244 $303 

Truck Large LT $3,874 $295 $3,834 $295 $3,732 $295 $3,681 $297 $3,671 $296 

2010 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$2,572 $370 $2,554 $370 $2,507 $376 $2,487 $377 $2,468 $379 

Standard Car Midsize PC/Perf. PC $3,019 $353 $2,992 $354 $2,927 $357 $2,858 $352 $2,829 $353 

Large Car Large PC/Perf. PC $3,813 $376 $3,773 $376 $3,668 $376 $3,621 $376 $3,575 $376 

Small MPV Small LT $2,933 $326 $2,911 $328 $2,811 $326 $2,783 $326 $2,754 $329 

Large MPV Minivan 

Midsize LT $3,434 $301 $3,403 $302 $3,319 $303 $3,282 $303 $3,253 $304 

Truck Large LT $3,922 $298 $3,881 $298 $3,778 $299 $3,732 $301 $3,706 $298 

Table V-72 MY2025 Direct Manufacturing Costs for PHEV40 packages at different levels 

of applied vehicle mass reduction (2010 dollars, markups not included) 

PHEV40 (NMC) @ 450K/yr volume 0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car Subcompact PC/Perf. PC $3,644 $262 $3,619 $262 $3,542 $264 $3,542 $264 $3,542 $264 
 

 

 

 

 

352 

Compact PC/Perf. PC 

Standard Car Midsize PC/Perf. PC $4,390 $257 $4,343 $257 $4,228 $258 $4,228 $258 $4,228 $258 

Large Car Large PC/Perf. PC $6,006 $296 $5,921 $295 $5,671 $291 $5,671 $291 $5,671 $291 

Small MPV Small LT $4,247 $236 $4,207 $237 $4,101 $238 $4,100 $237 $4,100 $237 

Large MPV Minivan 

Midsize LT $5,269 $231 $5,212 $231 $5,065 $231 $5,065 $231 $5,065 $231 

Truck Large LT $6,122 $233 $6,050 $233 $5,900 $232 $5,900 $232 $5,900 $232 

2010 Baseline 

Small Car Subcompact PC/Perf. PC 

Compact PC/Perf. PC $3,722 $268 $3,690 $267 $3,606 $269 $3,606 $269 $3,606 $269 

Standard Car Midsize PC/Perf. PC $4,494 $263 $4,447 $263 $4,324 $263 $4,324 $263 $4,324 $263 

Large Car Large PC/Perf. PC $6,158 $304 $6,073 $303 $5,850 $300 $5,850 $300 $5,850 $300 

Small MPV Small LT $4,351 $242 $4,309 $243 $4,198 $243 $4,198 $243 $4,198 $243 

Large MPV Minivan 

Midsize LT $5,286 $232 $5,228 $232 $5,080 $232 $5,080 $232 $5,080 $232 

Truck Large LT $6,215 $236 $6,142 $236 $5,980 $235 $5,980 $235 $5,980 $235 

Table V-73 MY2025 Direct Manufacturing Costs for EV75 packages at different levels of 

applied vehicle mass reduction (2010 dollars, markups not included) 

EV75 (NMC) @ 450K/yr volume 0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car Subcompact PC/Perf. PC 

Compact PC/Perf. PC $5,115 $224 $5,098 $225 $4,996 $228 $4,962 $229 $4,768 $233 

Standard Car Midsize PC/Perf. PC $6,021 $215 $5,965 $215 $5,818 $216 $5,755 $216 $5,509 $219 

Large Car Large PC/Perf. PC $7,724 $232 $7,635 $232 $7,397 $231 $7,295 $231 $6,907 $231 

Small MPV Small LT $5,995 $203 $5,952 $204 $5,843 $206 $5,800 $207 $5,625 $211 

Large MPV Minivan 

Midsize LT $7,310 $195 $7,237 $196 $7,045 $196 $6,963 $196 $6,610 $197 

Truck Large LT $8,332 $193 $8,242 $193 $8,005 $193 $7,883 $194 $7,474 $194 

2010 Baseline 

Small Car Subcompact PC/Perf. PC 

Compact PC/Perf. PC $5,232 $221 $5,195 $222 $5,106 $225 $5,071 $226 $4,912 $231 

Standard Car Midsize PC/Perf. PC $6,152 $214 $6,092 $214 $5,940 $215 $5,874 $215 $5,624 $218 

Large Car Large PC/Perf. PC $7,923 $229 $7,832 $229 $7,586 $229 $7,479 $228 $7,092 $228 

Small MPV Small LT $6,070 $203 $6,016 $203 $5,904 $205 $5,860 $206 $5,684 $210 

Large MPV Minivan 

Midsize LT $7,312 $197 $7,238 $198 $7,046 $198 $6,962 $198 $6,605 $198 

Truck Large LT $8,472 $191 $8,380 $191 $8,141 $191 $8,036 $191 $7,629 $191 

Table V-74 MY2025 Direct Manufacturing Costs for EV100 packages at different levels of 

applied vehicle mass reduction (2010 dollars, markups not included) 

EV100 (NMC) @ 450K/yr volume 0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car Subcompact PC/Perf. PC 

Compact PC/Perf. PC $6,105 $201 $6,083 $201 $5,950 $204 $5,906 $205 $5,817 $206 

Standard Car Midsize PC/Perf. PC $7,054 $189 $7,001 $189 $6,826 $190 $6,770 $191 $6,662 $192 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

353 

Large Car Large PC/Perf. PC $8,630 $195 $8,535 $195 $8,283 $194 $8,175 $194 $7,999 $194 

Small MPV Small LT $7,293 $186 $7,237 $186 $7,096 $188 $7,039 $189 $6,953 $190 

Large MPV Minivan 

Midsize LT $8,641 $173 $8,571 $174 $8,392 $175 $8,321 $176 $8,215 $177 

Truck Large LT $9,962 $173 $9,879 $174 $9,676 $175 $9,554 $176 $9,392 $177 

2010 Baseline 

Small Car Subcompact PC/Perf. PC 

Compact PC/Perf. PC $6,255 $198 $6,209 $199 $6,094 $201 $6,048 $202 $5,956 $204 

Standard Car Midsize PC/Perf. PC $7,173 $187 $7,118 $188 $6,980 $190 $6,884 $189 $6,802 $190 

Large Car Large PC/Perf. PC $8,863 $192 $8,765 $192 $8,504 $192 $8,393 $192 $8,251 $192 

Small MPV Small LT $7,375 $185 $7,318 $185 $7,174 $187 $7,117 $188 $7,031 $189 

Large MPV Minivan 

Midsize LT $8,586 $174 $8,516 $174 $8,338 $176 $8,268 $176 $8,128 $177 

Truck Large LT $10,158 $172 $10,075 $172 $9,865 $174 $9,782 $174 $9,615 $175 

Table V-75 MY2025 Direct Manufacturing Costs for EV150 packages at different levels of 

applied vehicle mass reduction (2010 dollars, markups not included) 

EV150 (NMC) @ 450K/yr 

volume 

0% mass 

reduction 

2% mass 

reduction 

7.5% mass 

reduction 

10% mass 

reduction 

20% mass 

reduction 

EPA 

Vehicle 

Class 

NHTSA Vehicle 

Class Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh Pack $/kWh 

2008 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$8,080 $177 $8,048 $178 $8,048 $178 $8,048 $178 $8,048 $178 

Standard Car Midsize PC/Perf. PC $9,753 $174 $9,714 $174 $9,714 $174 $9,714 $174 $9,714 $174 

Large Car Large PC/Perf. PC $11,120 $167 $11,073 $167 $11,073 $167 $11,073 $167 $11,073 $167 

Small MPV Small LT $10,109 $171 $10,109 $171 $10,109 $171 $10,109 $171 $10,109 $171 

Large MPV Minivan 

Midsize LT $12,114 $162 $12,112 $162 $12,112 $162 $12,112 $162 $12,112 $162 

Truck Large LT $13,878 $161 $13,818 $161 $13,759 $161 $13,759 $161 $13,759 $161 

2010 Baseline 

Small Car 

Subcompact PC/Perf. 

PC 

Compact PC/Perf. PC 

$8,298 $175 $8,265 $176 $8,265 $176 $8,265 $176 $8,265 $176 

Standard Car Midsize PC/Perf. PC $9,928 $173 $9,888 $173 $9,888 $173 $9,888 $173 $9,888 $173 

Large Car Large PC/Perf. PC $11,432 $166 $11,384 $166 $11,384 $166 $11,384 $166 $11,384 $166 

Small MPV Small LT $10,228 $171 $10,228 $171 $10,228 $171 $10,228 $171 $10,228 $171 

Large MPV Minivan 

Midsize LT $12,032 $162 $11,981 $163 $11,981 $163 $11,981 $163 $11,981 $163 

Truck Large LT $14,166 $160 $14,045 $160 $14,044 $160 $14,044 $160 $14,044 $160 

The agencies then generated linear regressions of battery pack costs against percentage net mass 

reduction using the costs shown in Table V-68. The regression results are shown in Table V-76. 

These regression results are used to account for the cost reduction from using a smaller battery 

due to down-weighting of the vehicle. Detailed discussion of how these results are used can be 

found in section 0 of this chapter. For P2 HEV battery packs, the direct manufacturing costs 

shown in Table V-76 are considered applicable to MY 2017. The agencies consider the P2 

battery packs technology to be on the flat portion of the learning curve during the 2017-2025 

timeframe. The agencies have applied a “high1” complexity ICM of 1.56 through 2024 then a 
 

 

 

 

 

354 

long-term ICM of 1.35 thereafter. For PHEV and EV battery packs, the direct manufacturing 

costs shown in Table V-76 are considered applicable to MY2025 because more development 

work is needed for this technology to have a high penetration in the U.S. market, including 

research in battery material, safety systems, etc. For the PHEV and EV battery packs, the 

agencies have applied the learning curve discussed in learning section of this chapter. The 

agencies have applied a “high2” complexity ICM of 1.77 through 2024 then a long-term ICM of 

1.50 thereafter. 

Table V-76 Linear Regressions of Battery Pack Direct Manufacturing Costs vs Net Mass 

reduction (2010$) 

EPA 

Vehicle 

Class 

NHSTA Vehicle 

Class 

P2 HEV 

@MY2017 

PHEV20 

@MY2025 

PHEV40 

@MY2025 

EV75 

@MY2025 

EV100 

@MY2025 

EV150 

@MY2025 

2008 Baseline 

Small car 

Subcompact 

PC/Perf. PC -$181x+$726 -$861x+$2,533 -$1,517x+$3,646 -$1,859x+$5,131 -$2,168x+$6,115 -$2,045x+$8,080 Compact 

PC/Perf. PC 

Standard car Midsize PC/Perf. 

PC -$240x+$801 -$1,543x+$2,962 -$2,195x+$4,389 -$2,754x+$6,023 -$2,958x+$7,056 -$2,552x+$9,753 

Large car Large PC/Perf. 

PC -$369x+$937 -$1,881x+$3,734 -$4,700x+$6,010 -$4,356x+$7,725 -$4,647x+$8,630 -$2,840x+$11,120 

Small MPV Small LT -$240x+$801 -$1,543x+$2,962 -$2,195x+$4,389 -$2,754x+$6,023 -$2,958x+$7,056 -$2,552x+$9,753 

Large MPV Minivan 

Midsize LT -$303x+$876 

Truck Large LT -$367x+$1,010 

2010 Baseline 

Small car 

Subcompact 

PC/Perf. PC -$188x+$733 -$866x+$2,572 -$1,612x+$3,722 -$1,717x+$5,233 -$2,209x+$6,256 -$2,700x+$8,298 Compact 

PC/Perf. PC 

Standard car Midsize PC/Perf. 

PC -$248x+$810 -$1,573x+$3,024 -$2,291x+$4,494 -$2,887x+$6,154 -$2,883x+$7,178 -$3,242x+$9,928 

Large car Large PC/Perf. 

PC -$387x+$950 -$1,957x+$3,813 -$4,217x+$6,158 -$4,543x+$7,925 -$4,744x+$8,862 -$4,250x+$11,432 

Small MPV Small LT -$233x+$789 -$1,516x+$2,934 -$2,022x+$4,350 -$2,155x+$6,067 -$2,706x+$7,375 -$21x+$10,228 

Large MPV Minivan 

Midsize LT -$305x+$878 

Truck Large LT -$364x+$1,019 

Notes: 

“x” in the equations represents the net mass reduction as a percentage, so a subcompact P2 HEV with a 20% applied weight reduction 

and, therefore, a 15% net weight reduction would cost (-$181)x(15%)+$726=$698. 

The small MPV EV150 regression has no slope since the net weight reduction is always 0 due to the 19.1% weight reduction required 

for the base vehicle. 

The agencies did not regress PHEV or EV costs for the minivan, midsize LT and large truck vehicle classes since we do not believe 

these vehicle classes would use the technologies.
 
                                                      

355 

For Mild HEV batteries, the agencies used a similar approach to estimating the cost of the 

battery pack but used a different approach to determining its size. Our Mild HEV system used in 

the analyses is based, largely, on the Buick eAssist system.285 According to the press releases, it 

includes a 15 kW motor and a 15 kW/0.5kWh/115 Volt two-module battery. For the agencies’ 

analyses, a 15kW/0.25kWh/110 Volt single-module battery was selected for several reasons. 

First, the Buick system uses a 20% state-of-charge (SOC) swing for the battery. We believe that, 

in the 2017-2025 timeframe, a 40% SOC swing is reasonable. As such, the energy capacity of 

the battery can be halved (from 0.5 to 0.25 kWh).286 The 110V system used in the analysis is 

essentially the same as Buick’s 115V system. The voltage change is due to our use of a 28 cell 

single-module battery pack rather than the 32 cell double-module battery pack which is used in 

the eAssist system. Such changes are consistent with our expectation that cells will increase in 

size allowing for fewer cells and fewer modules. Further, for the Mild HEV technology, the 

agencies are using the same system regardless of vehicle class or subclass. In other words, the 

Mild HEV system is a stand-alone technology that can be applied to any subclass without unique 

modifications for each class or subclass. As such, it adds more weight as a percentage to a 

smaller vehicle than to a larger vehicle but it provides more effectiveness to a smaller vehicle 

than to a larger vehicle. Since the same system is used regardless of vehicle class or subclass, 

the costs are identical regardless of vehicle class or subclass. Using the ANL BatPaC model, the 

Mild HEV battery DMC was calculated as $553 and is considered applicable to the MY 2017. 

The agencies derived the Mild HEV battery pack cost using the same methodology that was used 

for the P2 HEV battery pack, and consider cost to be on the flat portion of the learning curve 

during the 2017-2025 timeframe. The agencies have applied a high1 complexity ICM of 1.56 

through 2024 then 1.35 thereafter. The resultant Mild HEV battery pack costs are as shown in 

Table V-77. 

Table V-77 Costs for Mild Hybrid Battery Packs for both 2008 and 2010 Baselines (2010$) 

Cost type Vehicle class 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $553 $536 $520 $505 $490 $475 $461 $447 $433 

IC All $312 $311 $310 $309 $308 $307 $306 $305 $187 

TC All $865 $847 $830 $813 $797 $782 $766 $752 $621 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

285 “eAssist” is a Buick (or General Motors) term and is not a generic term for this technology, hence our use of the
 

term mild hybrid. 

286 Note that projected battery cost is relatively insensitive to kWh capacity at the high power-to-energy ratio of
 

these batteries. A 0.5 kWh battery could alternatively be specified at a similar cost. 
356 

Table V-78 NHTSA Weight Reduction Offset Associated with Mild HEVs for both the 2008 

and 2010 Baselines (2010$) 

EPA Vehicle Class NHTSA Vehicle Class Weight 

Penalty 

Small car 

Subcompact PC / Perf. 

Subcompact PC / 

Compact PC / Perf. 

Compact PC 

3.5% 

Standard car Midsize PC/Perf. PC 3.0% 

Large car Large PC/Perf. PC 2.5% 

Small MPV Small LT 2.5% 

Large MPV Minivan 

Midsize LT 2.5% 

Truck Large LT 2.0% 

Non-battery System Costs for MHEVs, HEVs, PHEVs and EVs 

This section addresses the costs of non-battery components which are required for electric drive 

vehicles. Some of these components are not found in every electric-drive vehicle (e.g., an HEV 

does not have an on-board battery charger as found in a PHEV or EV). Others are found in all 

electric drive vehicles and must be scaled to the vehicle type or class to properly represent the 

cost. As discussed in the TAR and NPRM, the agencies derived the costs of these components 

from the FEV teardown study. Where appropriate, costs were scaled to vehicle class and in the 

case of the motor and inverter the sizing methodology used for battery sizing was applied. 

The electric drive motor and inverter provide the motive power for any electric-drive vehicle by 

converting electrical energy from the battery into kinetic energy for propulsion. In an electricdrive vehicle, energy stored in the battery is routed to the inverter which converts it to a voltage 

and wave form that can be used by the motor. 

In many cases, such as HEVs, the combined cost of the motor and inverter exceed the battery 

cost. As batteries become larger in PHEVs and EVs, the battery cost grows faster than motor 

and inverter cost. For this analysis, the agencies used the vehicle power requirement calculation 

discussed in Section “HEV, PHEV and EV System Sizing and Cost Estimating Methodology” to 

calculate the required motor and inverter size for each vehicle class at each weight reduction 

point. Then, for the HEVs and PHEVs, a regression was created from the FEV teardown data for 

motors and inverters and this regression was used to calculate the motor and inverter cost for 

each combination of vehicle class and weight reduction. This regression for use with the 2008 

baseline was $13.78x(motor size in kW)+$781.50 (values in 2010$), and for use with the 2010 

baseline was $14.13x(motor size in kW)+$771.21 (values in 2010$). The results are shown as 

the “Motor assembly” line items in Table V-79 through Table V-90, which show our scaled 
 

357 

DMC for P2 HEV, PHEV20 and PHEV40 for both 2008 and 2010 baselines. NHTSA averaged 

the cost of PHEV20 and PHEV40 for the cost of a PHEV30 used in the FRM analysis. 

For EVs, the agencies used the motor and inverter cost regression from the 2010 TAR (see 2010 

TAR at page B-21) and we used that regression for both the 2008 and 2010 baselines. Since the 

FEV teardown was conducted on an HEV Ford Fusion, the agencies believe the technology for 

an EV is different enough to warrant using the TAR regression. The regression presented in the 

TAR showed the DMC being equal to $8.45x(motor size in kW)+$185.05. The results are 

presented as separate line items for “Motor inverter” and “Motor assembly” in Table V-85 

through Table V-90 which show our scaled DMC for EV75, EV100 and EV150, for both 2008 

and 2010 baselines. 

In addition to electric drive motors and inverters, there are several other components in electric 

drive vehicles that are required. These components include the following: 

	 Body Modifications required on HEVs and PHEVs include changes to sheet metal to 

accommodate electric drive components and the addition of fasteners to secure 

components such as electric cables. These costs come from the FEV teardown and are 

scaled by vehicle class. For EVs, these costs are assumed to be included in the base 

vehicle because they are less likely to be adapted from conventional vehicles. 

	 Brake System changes include the addition of a braking system that can control the 

vehicle’s regenerative braking system—a key enabler of electric drive vehicle efficiency. 

The brake system costs are from the FEV teardown and are scaled to vehicle class. 

	 Climate Control System includes components such as an electric air conditioning 

compressor that enables operation while the engine is off for HEVs and PHEVs as well 

as for an EV which has no engine. Climate control system costs come from the FEV 

teardown and are scaled to vehicle class. 

	 Conventional vehicle battery and alternator are deleted in these vehicles, for a cost 

savings, replaced by the DC-DC converter which converts the high-voltage traction 

battery to a nominal 12V DC to operate the vehicle’s accessories. This comes from the 

FEV teardown study and is scaled to vehicle class. 

	 DC-DC converter converts the high-voltage battery voltage to a nominal 12V battery 

voltage to run vehicle accessories such as the radio, lights and wipers. This cost comes 

from the FEV teardown study and is scaled to vehicle class. 

	 Power distribution and Control consists of those components which route electricity to 

the motor, inverter and contains the controllers to operate and monitor the electric drive 

system. This cost applies to HEVs and PHEVs and comes from the FEV teardown study. 

It is scaled to vehicle class. 

	 On-Vehicle Charger consists of the components necessary to charge a PHEV or EV from 

an outlet. It includes the charging port, wiring and electronics necessary to convert a 
 

 

 

 

 

 

 

 

358 

120V or 240V AC input to the high-voltage DC power necessary to charge the battery. 

Because the FEV teardown study subject vehicle did not have an on-vehicle charger, the 

costs from the TAR were used for this item. It is not scaled to vehicle class; however the 

EV charger is assumed to cost twice the amount of the PHEV charger to account for a 

higher current capacity. This cost does not include off-vehicle charger components 

which are discussed below. 

	 Supplemental heating is required for passenger comfort on PHEVs and EVs which may 

operate for long periods with no engine heat available. This cost comes from the FEV 

teardown study and is scaled to vehicle class. The supplemental heater on the EV is 

assumed to be three times more costly than the PHEV because the entire cabin comfort is 

dependent on the supplemental heater. In a PHEV, it is assumed that in extreme 

conditions, the internal combustion engine will start to provide additional cabin heat and 

defrost functions. 

	 High Voltage Wiring is an item used on EVs only. It includes the high voltage cabling 

from the battery to the inverter and motor as well as control components. It is equivalent 

to the power distribution and control used on HEVs and PHEVs and comes from the FEV 

teardown study. It is scaled to vehicle class. 

	 Delete Internal Combustion Engine and Transmission For EVs, the engine and 

transmission are deleted and a credit is applied. These credits come from work done in 

support of the 2010 TAR and are scaled to vehicle class. 

	 Battery Discharge System For HEVs, PHEVs and EVs, it is expected that manufacturers 

will provide the means to safely discharge battery packs following a vehicle crash. The 

agencies have assumed that this would include dedicated DC terminals, an access panel 

for the terminals, and a diagnostics port. The estimated cost of this capability is the same 

for all vehicle classes, but is different for HEVs than for PHEVs and EVs. 

The results of the scaling exercise applied to non-battery components are presented in Table V79 through Table V-90 for P2 HEVs, PHEV20, PHEV40, EV75, EV100 and EV150, for the 

2008 and 2010 baselines, respectively. 

Table V-79 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for P2 HEV 

for the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

Large 

MPV Truck 

0% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $221 $228 $231 $225 $233 $240 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $162 $152 $152 $177 

Power Distr & control $196 $201 $204 $200 $206 $220 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

359 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,045 $1,172 $1,480 $1,112 $1,287 $1,429 

Total $1,675 $1,857 $2,175 $1,777 $2,052 $2,169 

2% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $221 $228 $231 $225 $233 $240 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $162 $152 $152 $177 

Power Distr & control $196 $201 $204 $200 $206 $220 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,039 $1,164 $1,467 $1,106 $1,277 $1,416 

Total $1,670 $1,849 $2,161 $1,771 $2,042 $2,156 

7.5% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $221 $228 $231 $225 $233 $240 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $162 $152 $152 $177 

Power Distr & control $196 $201 $204 $200 $206 $220 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,025 $1,143 $1,428 $1,088 $1,249 $1,381 

Total $1,655 $1,828 $2,123 $1,752 $2,014 $2,121 

10% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $221 $228 $231 $225 $233 $240 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $162 $152 $152 $177 

Power Distr & control $196 $201 $204 $200 $206 $220 

Battery discharge system $6 $6 $6 $6 $6 $6 

Motor assembly $1,018 $1,133 $1,411 $1,079 $1,237 $1,364 

Total $1,649 $1,818 $2,105 $1,744 $2,002 $2,104 

20% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $221 $228 $231 $225 $233 $240 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $162 $152 $152 $177 

Power Distr & control $196 $201 $204 $200 $206 $220 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

360 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,007 $1,115 $1,377 $1,064 $1,212 $1,337 

Total $1,637 $1,800 $2,071 $1,729 $1,977 $2,077 

Table V-80 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for P2 HEV 

for the 2010 baseline (2010$) 

System Small 

Car 

Std 

Car 

Large 

Car 

Small 

MPV 

Large 

MPV Truck 

0% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $223 $229 $232 $225 $232 $242 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $177 $162 $162 $177 

Power Distr & control $197 $202 $205 $201 $206 $221 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,051 $1,191 $1,512 $1,134 $1,299 $1,445 

Total $1,683 $1,878 $2,224 $1,811 $2,073 $2,188 

2% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $223 $229 $232 $225 $232 $242 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $177 $162 $162 $177 

Power Distr & control $197 $202 $205 $201 $206 $221 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,045 $1,183 $1,497 $1,127 $1,288 $1,432 

Total $1,677 $1,869 $2,210 $1,804 $2,063 $2,175 

7.5% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $223 $229 $232 $225 $232 $242 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $177 $162 $162 $177 

Power Distr & control $197 $202 $205 $201 $206 $221 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,030 $1,159 $1,457 $1,107 $1,259 $1,395 

Total $1,662 $1,846 $2,169 $1,784 $2,034 $2,138 

10% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

361 

Body system $6 $6 $6 $6 $6 $6 

Brake system $223 $229 $232 $225 $232 $242 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $177 $162 $162 $177 

Power Distr & control $197 $202 $205 $201 $206 $221 

Battery discharge system $6 $6 $6 $6 $6 $6 

Motor assembly $1,023 $1,149 $1,438 $1,098 $1,246 $1,378 

Total $1,655 $1,836 $2,150 $1,775 $2,021 $2,121 

20% WR 

Body system $6 $6 $6 $6 $6 $6 

Brake system $223 $229 $232 $225 $232 $242 

Climate controls $140 $157 $168 $164 $250 $186 

Delete electrical ($60) ($65) ($82) ($86) ($86) ($94) 

DC-DC converter $121 $152 $177 $162 $162 $177 

Power Distr & control $197 $202 $205 $201 $206 $221 

Battery discharge 

system $6 $6 $6 $6 $6 $6 

Motor assembly $1,010 $1,129 $1,402 $1,081 $1,220 $1,350 

Total $1,642 $1,816 $2,114 $1,757 $1,994 $2,093 

Table V-81 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for PHEV20 

for the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,097 $2,735 $4,276 $2,436 

Battery discharge system $13 $13 $13 $13 

Total $2,878 $3,575 $5,129 $3,258 

2% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

362 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,071 $2,695 $4,207 $2,403 

Battery discharge system $13 $13 $13 $13 

Total $2,852 $3,536 $5,059 $3,225 

7.5% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $1,999 $2,588 $4,014 $2,312 

Battery discharge system $13 $13 $13 $13 

Total $2,780 $3,428 $4,867 $3,134 

10% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $1,966 $2,539 $3,927 $2,271 

Battery discharge system $13 $13 $13 $13 

Total $2,747 $3,379 $4,780 $3,093 

20% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $1,943 $2,500 $3,861 $2,235 

Battery discharge system $13 $13 $13 $13 
Total $2,724 $3,341 $4,714 $3,057

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

363 

Table V-82 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for PHEV20 

for the 2010 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,169 $2,870 $4,476 $2,586 

Battery discharge system $13 $13 $13 $13 

Total $2,951 $3,712 $5,347 $3,419 

2% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,141 $2,828 $4,402 $2,549 

Battery discharge system $13 $13 $13 $13 

Total $2,924 $3,670 $5,272 $3,383 

7.5% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

364 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,064 $2,712 $4,198 $2,450 

Battery discharge system $13 $13 $13 $13 

Total $2,847 $3,554 $5,069 $3,283 

10% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,029 $2,660 $4,106 $2,404 

Battery discharge system $13 $13 $13 $13 

Total $2,812 $3,502 $4,976 $3,238 

20% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,002 $2,616 $4,031 $2,364 

Battery discharge system $13 $13 $13 $13 

Total $2,785 $3,458 $4,901 $3,197 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-83 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for PHEV40 

for the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

365 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,097 $2,735 $4,276 $2,436 

Battery discharge system $13 $13 $13 $13 

Total $2,878 $3,575 $5,129 $3,258 

2% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,071 $2,695 $4,207 $2,403 

Battery discharge system $13 $13 $13 $13 

Total $2,852 $3,536 $5,059 $3,225 

7.5% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,007 $2,591 $4,025 $2,313 

Battery discharge system $13 $13 $13 $13 

Total $2,788 $3,432 $4,878 $3,135 

10% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,007 $2,591 $4,025 $2,312 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

366 

Battery discharge system $13 $13 $13 $13 

Total $2,788 $3,432 $4,878 $3,134 

20% WR 

Body system $6 $6 $6 $6 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

Power Distr & control $196 $201 $204 $200 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,007 $2,591 $4,025 $2,312 

Battery discharge system $13 $13 $13 $13 

Total $2,788 $3,432 $4,878 $3,134 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-84 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for PHEV40 

for the 2010 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,169 $2,870 $4,476 $2,586 

Battery discharge system $13 $13 $13 $13 

Total $2,951 $3,712 $5,347 $3,419 

2% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

367 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,141 $2,828 $4,402 $2,549 

Battery discharge system $13 $13 $13 $13 

Total $2,924 $3,670 $5,272 $3,383 

7.5% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,068 $2,714 $4,206 $2,450 

Battery discharge system $13 $13 $13 $13 

Total $2,851 $3,556 $5,076 $3,283 

10% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,068 $2,714 $4,206 $2,449 

Battery discharge system $13 $13 $13 $13 

Total $2,851 $3,556 $5,076 $3,283 

20% WR 

Body system $6 $6 $6 $6 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

Power Distr & control $197 $202 $205 $201 

On vehicle charger $105 $105 $105 $105 

Supplemental heater $38 $43 $45 $44 

Motor assembly $2,068 $2,714 $4,206 $2,449 

Battery discharge system $13 $13 $13 $13 

Total $2,851 $3,556 $5,076 $3,283 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

368 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-85 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV75 for 

the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $703 $1,044 $1,868 $885 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $992 $1,383 $2,329 $1,200 

Battery discharge 

system $13 $13 $13 $13 

Total $350 $1,145 $2,060 ($12) 

2% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $689 $1,023 $1,831 $867 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $976 $1,359 $2,286 $1,180 

Battery discharge 

system $13 $13 $13 $13 

Total $320 $1,100 $1,979 ($50) 

7.5% WR 

Brake system $221 $228 $231 $225 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

369 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $650 $966 $1,728 $818 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $932 $1,293 $2,168 $1,124 

Battery discharge 

system $13 $13 $13 $13 

Total $237 $977 $1,759 ($154) 

10% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $633 $939 $1,681 $796 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $911 $1,263 $2,114 $1,099 

Battery discharge 

system $13 $13 $13 $13 

Total $199 $921 $1,659 ($202) 

20% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $571 $851 $1,519 $727 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $840 $1,162 $1,928 $1,020 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

370 

Battery discharge 

system $13 $13 $13 $13 

Total $65 $731 $1,309 ($350) 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-86 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV75 for 

the 2010 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $729 $1,094 $1,932 $946 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,021 $1,441 $2,402 $1,271 

Battery discharge 

system $13 $13 $13 $13 

Total $406 $1,255 $2,214 $132 

2% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $714 $1,072 $1,893 $927 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,004 $1,416 $2,358 $1,249 

Battery discharge 

system $13 $13 $13 $13 

Total $375 $1,208 $2,131 $92 

7.5% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

371 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $674 $1,012 $1,787 $875 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $958 $1,347 $2,236 $1,189 

Battery discharge 

system $13 $13 $13 $13 

Total $289 $1,079 $1,903 ($20) 

10% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $656 $985 $1,739 $851 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $938 $1,315 $2,180 $1,162 

Battery discharge 

system $13 $13 $13 $13 

Total $250 $1,020 $1,799 ($71) 

20% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $595 $895 $1,580 $780 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

372 

Motor assembly $867 $1,212 $1,998 $1,080 

Battery discharge 

system $13 $13 $13 $13 

Total $118 $828 $1,458 ($225) 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-87 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV100 for 

the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $703 $1,044 $1,868 $885 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $992 $1,383 $2,329 $1,200 

Battery discharge 

system $13 $13 $13 $13 

Total $350 $1,145 $2,060 ($12) 

2% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $689 $1,023 $1,831 $867 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $976 $1,359 $2,286 $1,180 

Battery discharge 

system $13 $13 $13 $13 

Total $320 $1,100 $1,979 ($50) 

7.5% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

373 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $650 $966 $1,728 $818 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $932 $1,293 $2,168 $1,124 

Battery discharge 

system $13 $13 $13 $13 

Total $237 $977 $1,759 ($154) 

10% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $633 $939 $1,681 $796 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $911 $1,263 $2,114 $1,099 

Battery discharge 

system $13 $13 $13 $13 

Total $199 $921 $1,659 ($202) 

20% WR 

Brake system $221 $228 $231 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $608 $906 $1,617 $774 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

374 

Motor assembly $883 $1,224 $2,041 $1,073 

Battery discharge 

system $13 $13 $13 $13 

Total $146 $848 $1,521 ($249) 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-88 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV100 for 

the 2010 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $729 $1,094 $1,932 $946 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,021 $1,441 $2,402 $1,271 

Battery discharge 

system $13 $13 $13 $13 

Total $406 $1,255 $2,214 $132 

2% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $714 $1,072 $1,893 $927 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,004 $1,416 $2,358 $1,249 

Battery discharge 

system $13 $13 $13 $13 

Total $375 $1,208 $2,131 $92 

7.5% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

375 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $674 $1,012 $1,787 $875 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $958 $1,347 $2,236 $1,189 

Battery discharge 

system $13 $13 $13 $13 

Total $289 $1,079 $1,903 ($20) 

10% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $656 $985 $1,739 $851 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $938 $1,315 $2,180 $1,162 

Battery discharge 

system $13 $13 $13 $13 

Total $250 $1,020 $1,799 ($71) 

20% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $633 $954 $1,684 $829 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

376 

Motor assembly $912 $1,280 $2,118 $1,137 

Battery discharge 

system $13 $13 $13 $13 

Total $201 $954 $1,682 ($118) 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-89 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV100 for 

the 2008 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $703 $1,044 $1,868 $885 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $992 $1,383 $2,329 $1,200 

Battery discharge 

system $13 $13 $13 $13 

Total $351 $1,146 $2,061 ($11) 

2% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $692 $1,028 $1,837 $878 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $979 $1,364 $2,293 $1,193 

Battery discharge 

system $13 $13 $13 $13 

Total $328 $1,111 $1,995 ($26) 

7.5% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

377 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $692 $1,028 $1,837 $878 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $979 $1,364 $2,293 $1,193 

Battery discharge 

system $13 $13 $13 $13 

Total $328 $1,111 $1,995 ($26) 

10% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $692 $1,028 $1,837 $878 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $979 $1,364 $2,293 $1,193 

Battery discharge 

system $13 $13 $13 $13 

Total $328 $1,111 $1,995 ($26) 

20% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $162 $152 

High voltage wiring $196 $201 $204 $200 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $692 $1,028 $1,837 $878 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

378 

Motor assembly $979 $1,364 $2,293 $1,193 

Battery discharge 

system $13 $13 $13 $13 

Total $328 $1,111 $1,995 ($26) 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Table V-90 Scaled Non-battery DMC by Applied Vehicle Weight Reduction for EV100 for 

the 2010 baseline (2010$) 

System Small 

car 

Standard 

car 

Large 

car 

Small 

MPV 

0% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $729 $1,094 $1,932 $946 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,021 $1,441 $2,402 $1,271 

Battery discharge 

system $13 $13 $13 $13 

Total $406 $1,255 $2,214 $132 

2% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $720 $1,081 $1,910 $941 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,011 $1,425 $2,377 $1,265 

Battery discharge 

system $13 $13 $13 $13 

Total $387 $1,226 $2,167 $121 

7.5% WR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

379 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $720 $1,081 $1,910 $941 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,011 $1,425 $2,377 $1,265 

Battery discharge 

system $13 $13 $13 $13 

Total $387 $1,226 $2,167 $121 

10% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $720 $1,081 $1,910 $941 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 

Motor assembly $1,011 $1,425 $2,377 $1,265 

Battery discharge 

system $13 $13 $13 $13 

Total $387 $1,226 $2,167 $121 

20% WR 

Brake system $223 $229 $232 $225 

Climate controls $140 $157 $168 $164 

Delete electrical ($60) ($65) ($82) ($86) 

DC-DC converter $121 $152 $177 $162 

High voltage wiring $197 $202 $205 $201 

Supplemental heater $76 $85 $91 $89 

On vehicle charger $316 $316 $316 $316 

Motor inverter $720 $1,081 $1,910 $941 

Controls $121 $121 $121 $121 

Delete IC engine ($1,596) ($1,596) ($2,466) ($2,394) 

Delete transmission ($894) ($894) ($894) ($894) 
 

 

 

 

 

 

380 

Motor assembly $1,011 $1,425 $2,377 $1,265 

Battery discharge 

system $13 $13 $13 $13 

Total $387 $1,226 $2,167 $121 

a The agencies have not estimated PHEV or EV costs for the large MPV and truck 

vehicle classes since we do not believe these vehicle classes would use the 

technologies. 

Similar to the approach taken for battery pack costs, the agencies generated linear regressions of 

non-battery system costs against percent of net mass reduction and the results are shown in Table 

V-91. This was done using the same weight reduction offsets as used for battery packs as 

presented in Table V-69. These regression results are used to account for the cost reduction from 

using a smaller battery due to down-weighting of the vehicle. Detailed discussion of how these 

results are used can be found in the next section of this chapter. The agencies separated battery 

pack costs from the remainder of the systems for each type of electrified vehicle. The advantage 

of separating the battery pack costs from other system costs is that it allows each to carry unique 

indirect cost multipliers and learning effects which are important given that battery technology is 

an emerging technology, while electric motors and inverters are more stable technologies. 

Table V-91 Linear Regressions of Non-Battery System Direct Manufacturing Costs vs Net 

Mass reduction (2010$) 

EPA 

Vehicle 

Class 

Small car 

Standard 

car 

Large car 

Small 

MPV 

Large 

MPV 

Truck 

Small car 

Standard 

car 

Large car 

Small 

MPV 

Large 

MPV 

NHTSA 

Vehicle 

Class 

Subcompact 

PC/Perf. PC 

Compact 

PC/Perf. PC 

Midsize 

PC/Perf. PC 

Large 

PC/Perf. PC 

Small LT 

Minivan 

Midsize LT 

Large LT 

Subcompact 

PC/Perf. PC 

Compact 

PC/Perf. PC 

Midsize 

PC/Perf. PC 

Large 

PC/Perf. PC 

Small LT 

Minivan 

Midsize LT 

P2 HEV 

@MY2017 

-$263x+$1,675 

-$391x+$1,857 

-$699x+$2,175 

-$331x+$1,777 

-$506x+$2,052 

-$648x+$2,169 

-$279x+$1,683 

-$420x+$1,878 

-$741x+$2,224 

-$363x+$1,811 

-$528x+$2,073 

PHEV20 

@MY2025 

PHEV40 

@MY2025 

2008 Baseline 

-$1,316x+$2,878 -$1,316x+$2,878 

-$1,953x+$3,575 -$1,953x+$3,575 

-$3,495x+$5,129 -$3,495x+$5,129 

-$1,655x+$3,258 -$1,655x+$3,258 

2008 Baseline 

-$1,397x+$2,951 -$1,397x+$2,951 

-$2,099x+$3,712 -$2,099x+$3,712 

-$3,705x+$5,347 -$3,705x+$5,347 

-$1,814x+$3,419 -$1,814x+$3,419 

EV75 

@MY2025 

EV100 

@MY2025 

-$1,510x+$350 -$1,510x+$350 

-$2,242x+$1,145 -$2,242x+$1,145 

-$4,012x+$2,060 -$4,012x+$2,060 

-$1,900x+-$12 -$1,900x+-$12 

-$1,565x+$406 -$1,565x+$406 

-$2,350x+$1,255 -$2,350x+$1,255 

-$4,149x+$2,214 -$4,149x+$2,214 

-$2,032x+$132 -$2,032x+$132 

EV150 

@MY2025 

-$1,510x+$351 

-$2,242x+$1,146 

-$4,012x+$2,061 

-$1,900x+-$11 

-$1,565x+$406 

-$2,350x+$1,255 

-$4,149x+$2,214 

-$2,032x+$132 
 

 

 

 

381 

Truck Large LT -$674x+$2,188 

Notes: 

“x” in the equations represents the net mass reduction as a percentage, so a small car P2 HEV (2008 baseline) with a 20% applied 

weight reduction and, therefore, a 15% net weight reduction would cost (-$263)x(15%)+$1,675=$1,635. 

The small MPV EV150 regression has no slope since the net weight reduction is always 0 due to the 19.1% weight reduction 

required for the base vehicle. 

The agencies did not regress PHEV or EV costs for the minivan, midsize LT and large truck vehicle classes since we do not 

believe these vehicle classes would use the technologies.
 

For P2 HEV non-battery components, the direct manufacturing costs shown in Table V-91 are 

considered applicable to MY 2017. The agencies consider the P2 and PHEV non-battery 

component technologies to be on the flat portion of the learning curve during the 2017-2025 

timeframe. The agencies have applied a high1 complexity ICM of 1.56 through 2018 then a 

long-term ICM of 1.35 thereafter. For EV non-battery components, the direct manufacturing 

costs shown in Table V-91 are considered applicable to MY 2025. The agencies consider the 

PHEV and EV non-battery component technologies to be on the flat portion of the learning curve 

during the 2017-2025 timeframe. The agencies have applied a high2 complexity ICM of 1.77 

through 2024 then a long-term ICM of 1.50 thereafter. 

For Mild HEV non-battery components, the agencies have used a combination of cost sources 

which include the FEV teardown of a Saturn Vue along with estimates used for P2 HEVs as 

described above. For the electrical power distribution and control system and the DC-DC 

converter, estimates presented in the FRM for subcompacts were used with a presumed 20% 

weight reduction because those systems were estimated to include a 16 kW motor (essentially the 

same as the 15 kW motor assumed for the Mild HEV technology). These costs and the FEV 

Saturn Vue teardown costs we used are shown in Table V-92. 

Table V-92 FEV Teardown Results & P2 HEV Values used for MHEV Non-Battery Direct 

Manufacturing Cost Estimates 

System Teardown result 

(2007$) 

P2 HEV 

(2009$)a 

2010$ 

Cooling subsystem (including water pumps) $88.71 $92.37 

Accessory drive subsystem $30.75 $32.02 

Body system $14.83 $15.44 

Brake system $42.30 $44.05 

Climate control system $0 $0 

Transmission oil pump and filter subsystem $53.86 $56.09 

Generator/alternator and regulatory subsystem $51.94 $54.09 

Electrical power distribution & control system $203.22 $205.25 

DC-DC converter $115.33 $116.48 

Total $615.79 a

See the joint TSD, Table 3-80, 20% WR (EPA-420-D-11-901, November 2011). 

For Mild HEV non-battery components, the direct manufacturing costs shown in Table V-92 are 

considered applicable MY 2012. The agencies consider the Mild HEV non-battery component 
382 

technologies to be on the flat portion of the learning curve during the 2017-2025 timeframe. The 

agencies have applied a medium complexity ICM of 1.39 through 2018 then 1.29 thereafter. The 

resultant costs used in this final analysis are shown in Table V-93. 

Table V-93 Costs for Mild HEV Non-Battery Components for both the 2008 and 2010 

Baselines (2010$) 

Cost type Vehicle class 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC All $534 $524 $513 $503 $493 $483 $473 $464 $455 

IC All $235 $234 $175 $175 $175 $174 $174 $174 $173 

TC All $769 $758 $688 $678 $667 $657 $647 $637 $628 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

How Did NHTSA Account for the Cost Synergy between Mass Reduction 

and Electrification System in CAFE Model? 

The CAFE model does not use pre-built packages and applies technologies incrementally as 

necessary to meet the fuel consumption reduction requirement, so the cost interaction between 

any particular technology and other technologies (cost synergies) must be defined. This allows 

flexibility so that when a technology is picked, the model will automatically look through the 

cost synergy defined in a table and apply cost adjustments accordingly. The total cost for mass 

reduction and electrification is composed of the following four parts: 

(1) Cost of net mass reduction; 

(2) Cost of electrification with zero mass reduction; 

(3) Mass reduction cost synergy for increased or decreased amount of mass reduction 

due to switching from conventional powertrain to electrification systems, as 

defined in Table V-69. For example, if a midsize passenger car needs both 10 

percent net mass reduction and P2 hybrid to meet the CAFE target, the model will 

need to find the cost of additional 5 percent of mass reduction to consider the 

vehicle weight increase due to switching from conventional powertrain system to 

P2 electrification packages. This additional 5 percent of mass reduction is 

calculated starting from 10 percent mass reduction, not zero as shown in Figure 

V-36 because mass reduction cost versus mass reduction percent is not a linear 

function. The cost increases faster as the amount of mass reduction becomes 

higher. 

(4) Electrification system cost synergies (battery and non-battery components) due to 

mass reduction as defined in Table V-76 and Table V-91: Continuing the example 

in the steps above, if a midsize passenger car needs both 10 percent net mass 

reduction and P2 hybrid to meet the CAFE target, after calculating the costs 

above, the model will need to find the cost of electrification systems, including 

battery system and non-battery system, with the required net amount of mass 

reduction using the equations in Table V-76 and Table V-91. Then the delta cost 

between this cost and the cost calculated in step (2), i.e., electrification system 
       

             

383 

cost with zero applied mass reduction is calculated and treated as a cost synergy. 

These cost deltas are normally negative, i.e., a cost reduction, due to the 

downsizing of the electrification system resulting from mass reduction. 

The sum of item (3) and (4) in the above list are calculated as cost synergy and stored in the cost 

synergy table as defined ”Synergies” section earlier in this Chapter. 

Figure V-36 Mass Reduction Cost Example for Applied and Net Mass Reduction 

$‐

$100

$200

$300

$400

$500

$600

0% 5% 10% 15% 20%

Mass Reduction Cost [$]

Amount of Mass Reduction [%]

Example of Applied and Net Mass Reduction

Costs

Hardware Costs for Charging Grid-Connected Vehicles 

Grid-connected vehicles such as EVs and PHEVs require a means to charge their on-board 

batteries to enable their electric range capabilities. These vehicles require certain hardware to 

charge, both on-vehicle and off-vehicle. The agencies’ September 2010 Technical Assessment 

Report contains an in-depth analysis of the topic of charging and infrastructure. The TAR 

analysis and assumptions did not receive any significant comment on this issue, and a review of 

the current state of the industry indicates the assumptions in the TAR are still valid. Therefore, 

the assumptions for the cost of Electric Vehicle Support Equipment (EVSE) are unchanged. 

Additionally, while some of the characteristics of the modeled grid-connected vehicles such as 

battery size and energy demand have changed somewhat due to further analysis, the application 

of Level 1 and Level 2 charging by vehicle type based on charge time has not changed. 

Three charging levels are currently under consideration. Level 1 charging uses a standard 120 

volt (V), 15-20 amps (A) rated (12-16 A usable) circuit and is available in standard residential 

and commercial buildings. Level 2 charging uses a single phase, 240 V, 20-80 A circuit and 
384 

allows much shorter charge times. Level 3 charging—sometimes colloquially called “quick” or 

“fast” charging—uses a 480 V, three-phase circuit, available in mainly industrial areas, typically 

providing 60-150 kW of off-board charging power. It is expected that 97 to 99% of charging 

will take place at home, so a cost for a home charger, appropriate to the duty cycle of the vehicle, 

is added to the vehicle cost. Level 3 charging is available to commercial users and vehicles that 

charge at Level 3 stations will be assumed to pay at the charge station for the convenience of fast 

charging. Therefore Level 3 charger costs are not included in overall vehicle cost. 

The specific equipment required for charging a grid-connected vehicle consists of the following: 

Charger: A charger that converts electricity from alternating current (AC) from the electricity 

source to direct current (DC) required for the battery, and also converts the incoming 120 or 240 

volt current to 300 or higher volts. Grid-connected vehicles carry an on-board charger capable of 

accepting AC current from a wall plug (Level 1 circuit) or, from a Level 2 charging station. Onboard charger power capability ranges from 1.4 to 10 kW and is usually proportional to the 

vehicle’s battery capacity. The lowest charging power, 1.4 kW, is expected only when gridconnected vehicles are connected to 120 volt (Level 1) outlets, and all currently known PHEV 

and EV on-board chargers are expected to provide at least 3.3 kW charging when connected to a 

Level 2 (220 volt, 20+ A) charging station. The latest SAE connection recommended practice, 

J1772, allows for delivery of up to ~19 kW to an on-board vehicle charger. For higher capacity 

charging under Level 3, a charging station that delivers DC current directly to the vehicle’s 

battery is incorporated off-board in the wall or pedestal mounted. 

Charging Station: The charging station needed to safely deliver energy from the electric circuit 

to the vehicle, called electric vehicle support equipment (EVSE). The EVSE may at a minimum, 

be a specialized cordset that connects a household Level 1/120V socket to the vehicle; otherwise, 

the EVSE will include a cordset and a charging station (a wall or pedestal mounted box 

incorporating a charger and other equipment). Charging stations may include optional advanced 

features such as timers to delay charging until off-peak hours, communications equipment to 

allow the utility to regulate charging, or even electricity metering capabilities. Stakeholders are 

working on which features are best located on the EVSE or on the vehicle itself, and it is 

possible that redundant capabilities and features may be present in both the vehicle and EVSEs 

in the near future until these issues are worked out. EVSE and vehicle manufacturers are also 

working to ensure that current SAE-compliant “basic” EVSEs are charge-compatible with future 

grid-connected vehicles. 

Dedicated Circuit: A Level 1 circuit is standard household current, 120V AC, rated at 15 or 20 A 

(12 or 16 A usable). A Level 2 circuit is rated at 208 to 240V and up to 80 A and is similar to 

the type of circuit that powers electric stoves (up to 50 A) and dryers (usually 30 A). Generally, 

Level 1 and 2 circuits used for electric vehicle recharging must be dedicated circuits, i.e., there 
385 

cannot be other appliances on that circuit. For a Level 2 circuit, the homeowner or other user 

must install a charging station and will need a permit. A homeowner may choose to install the 

charger on a separately-metered circuit to take advantage of special electrical rates for off-peak 

charging, where available. 

In addition to the costs of purchasing and installing charging equipment, charging station 

installation may include the costs of upgrading existing electrical panels and installing the 

electrical connection from the panel to the desired station location. These costs may be 

dramatically lowered if new construction incorporates the panel box and wiring required for 

charging stations, or even includes charging stations or outlets for charging stations as standard 

equipment. 

The current costs of charging stations are highly variable depending on the level of service (and 

alternative power capabilities within these categories), location (individual residence, grouped 

residences, retail or business, parking lot or garage), level of sophistication of the station, and 

installation requirements, including electrical upgrading requirements. Estimated costs for 

charging stations are included in Table V-94 below. 

Table V-94: Estimated Costs for Charging Stations Used in the 2010 TAR (2008$) 

Level Location Equipment Installation 

1 Single 

Residence 

$30- $200 (charge cord only, 

included at no cost to consumer 

with EV/PHEV) when an 

accessible household plug (e.g., 

in a garage or adjacent to a 

driveway) with a ground fault 

interrupter is already available 

$400-$1000+ may be necessary 

depending on difficulty of 

installing a new circuit at the 

desired location, but in most 

cases, owners with sufficient 

panel capacity would opt for a 

more capable 220 VAC Level 2 

installation instead of a Level 1 

dedicated circuit because the 

additional installation cost is 

only marginally higher 

2 Residential, 3.3 kW EVSE (each): $300- 3.3- 6.6 kW installation cost: 

Apartment 

Complex, 

$4,000 $400-$2,300 without 

wiring/service panel upgrade, or 

or Fleet 6.6 kW EVSE (each): $400- $2,000-$5,000 with panel 

Depotb $4,000 upgrade 
 

 

                                                      

 

386 

refs: 287,288, 289, 290 

a

 Detailed information on charger cost for each charging level and location and specific sources for cost estimates 

are available in the TAR, Appendix G. 

b Level 2 EVSE installation costs vary considerably for single-family residences, multi-family residences, and fleet 

depots, depending upon the need for wiring and service panel upgrades. The range depicted here reflects the 

anticipated variability of these costs. However, EPRI estimates that the typical residential Level 2 installation costs 

to be approximately $1,500. See the TAR, Appendix G for additional information. 

Application of Charging Level by Vehicle Type 

The home charging availability for a specific consumer will need to be differentiated among 

EV/PHEVs with different battery capacity. The electric outlets in existing homes are most likely 

ready for Level 1 charging, which is about sufficient for fully recharging a PHEV20 SUV during 

normal nighttime, provided the outlet is not being heavily utilized by other loads. Shorter 

available charging time or owning a PHEV or an EV with a larger battery make the capability to 

fully charge overnight with a Level 1 system less likely, but upgrading to a Level 2 system in 

such cases will allow full recharge to happen more quickly. 

Table V-95 shows the application of charge level by vehicle type and range. Charging types 

were chosen based on nominal time to charge a fully-depleted battery in a vehicle with no net 

weight reduction. Charge times exceeding 9 hours for Level 1 were deemed unacceptable and 

Level 2 charging was specified. For charge times between 6 hours and 9 hours on Level 1, a mix 

of Level 1 and Level 2 was specified. This was done to recognize the varying consumer value of 

faster, but more expensive, Level 2 charging over Level 1 charging. 

Table V-95: Charger Type by Vehicle Technology and Class 

NHTSA Vehicle PHEV20 PHEV40 EV75 EV100 EV150 

Class L1 L2 L1 L2 L1 L2 L1 L2 L1 L2 

Subcompact 

PC/Perf. PC 

Compact PC/Perf. 

PC 

100% - 25% 75% - 100% - 100% - 100% 

Midsize PC/Perf. 

PC 100% - 10% 90% - 100% - 100% - 100% 

287 Morrow, Karner, and Francfort, “Plug-in Hybrid Electric Vehicle Charging Infrastructure Review,” INL/EXT-08­

15058, November 2008. Docket No. NHTSA-2010-0131 or Available at 

http://avt.inel.gov/pdf/phev/phevInfrastructureReport08.pdf (last accessed November 14, 2011). 288 May and Mattila, “Plugging In: A Stakeholder Investment Guide for Public Electric-Vehicle Charging 

Infrastructure,” Rocky Mountain Institute, July 2009, Docket No. NHTSA-2010-0131 or Available at 

http://projectgetready.com/docs/Plugging%20In%20-%20A%20Stakeholder%20Investment%20Guide.pdf (last 

accessed November 14, 2011)

289 ETEC, 2009. 290 Electrification Coalition, “Electrification Roadmap”, November 2009. Available at 

http://www.electrificationcoalition.org/electrification-roadmap.php. (last accessed November 14, 2011). Docket No. 

NHTSA-2010-0131-0143. 
387 

Large PC/Perf. PC 100% - - 100% - 100% - 100% - 100% 

Minivan 

Midsize LT 100% - - 100% - 100% - 100% - 100% 

Small LT 100% - - 100% - 100% - 100% - 100% 

Large LT 50% 50% - 100% - 100% - 100% - 100% 

For this final rule, consistent with the proposal, the resultant costs associated with in-home 

chargers and installation of in-home chargers are included in the total cost for an EV and or 

PHEV. However, here we summarize specially the costs for chargers and installation labor. The 

agencies have estimated the DMC of a level 1 charge cord at $31 (2010$) based on typical costs 

of similar electrical equipment sold to consumers today and that for a level 2 charger at $204 

(2010$). Labor associated with installing either of these chargers is estimated at $1,020 (2010$). 

Further, we have estimated that all PHEV20 vehicles (PHEVs with a 20 mile range) would be 

charged via a level 1 charger and that all EVs, regardless of range, would be charged via a level 

2 charger. For the PHEV40 vehicles (PHEVs with a 40 mile range), we have estimated that: 

25% of subcompacts would be charged with a level 1 charger with the remainder charged via a 

level 2 charger; 10% of midsize cars would be charged with a level 1 charger with the remainder 

charged via a level 2 charger; and all remaining PHEV 40 vehicles would be charged via a level 

2 charger. All costs presented here are considered applicable in the 2025 model year. The 

agencies have applied the learning curve 19 as presented in Section 0 to all charger costs. The 

agencies have also applied a High1 ICM of 1.56 through 2024 then 1.34 thereafter. Installation 

costs, being labor costs, have no learning impacts or ICMs applied. 

P2 Hybrid 

A P2 hybrid is hybrid technology that uses a transmission-integrated electric motor placed 

between the engine and a gearbox or CVT and coupled to the engine crankshaft via a clutch. 

The engine and the drive motor are mechanically independent of each other, allowing the engine 

or motor to power the vehicle separately or combined. Disengaging the engine clutch allows allelectric operation and more efficient brake-energy recovery. The P2 HEV system is similar to 

the Honda IMA HEV architecture, with the exception of the added clutch and larger batteries and 

motors. Examples of this include the Hyundai Sonata HEV and Infiniti M35h. The agencies 

believe that the P2 is an example of a “strong” hybrid technology that is typical of what will be 

prevalent in the timeframe of this rule. The agencies could have equally chosen the power-split 

architecture as the representative HEV architecture. These two HEVs have similar average 

effectiveness values (combined city and highway fuel economy), though the P2 systems may 

have lower cost due to having only a single, smaller motor/generator. 

For purposes of this rulemaking analysis, the agencies are assuming that P2 hybrids will become 

the dominant technology in the MYs 2017-2025 timeframe, replacing costlier power-split or 2­
                                                      

388 

mode architectures while providing substantially similar efficiency improvement. At the present 

time, P2 hybrids are relatively new to the market and the agencies have not attempted to quantify 

any measurable performance differential between these technologies. As mentioned, the 2011 

Hyundai Sonata, 2011 Volkswagen Touareg Hybrid, the 2011 Porsche S Hybrid, and the 2012 

Infiniti M35 Hybrid are examples of a P2 hybrid currently in production and available to 

consumers. While generally positive, some early reviews have specifically critiqued the 

drivability of the vehicle.291 The agencies recognize that manufacturers will have several years 

to test, develop and improve P2 technology in the years before 2017. We expect that 

manufacturers will address any perceived integration issues in early production models. 

However, we believe it is important to continue to monitor development of P2 hybrids and 

market acceptance of this technology. We will continue to gather information on these issues 

and consider them as part of the mid-term evaluation. NHTSA sought comment regarding the 

potential of P2 hybrids to overcome these issues or others, and we specifically sought comment 

from automakers developing and considering P2 technology on whether they believe these to be 

significant impediments to deployment and how they may be addressed. No comments were 

submitted. 

The effectiveness used for vehicle packages with the P2-hybrid configuration within this analysis 

reflects what the agencies believe to be a conservative estimate of system performance. Vehicle 

simulation modeling of technology packages using the P2 hybrid has recently been completed 

under a contract with Ricardo Engineering. The agencies have updated the effectiveness of 

hybrid electric vehicle packages using the new Ricardo vehicle simulation modeling runs for this 

analysis. 

Due to the lower cost and comparative effectiveness of P2 hybrid in relative to other strong 

hybrid technologies, such as power-split hybrid and 2-mode hybrid, the agencies assume P2 

hybrid application for all vehicle sub-classes in this FRM analysis, consistent with the proposal. 

Based on the recent Ricardo study, the effectiveness for P2 hybrid used in this FRM, consistent 

with the proposal, is 46.2 percent for subcompact and compact passenger cars, 48.6 percent for 

midsize passenger car, 49.4 percent for large passenger car, 46.1 percent for small light truck, 

45.7 percent for midsize SUV, truck and minivan and 45.1 percent for large pickup truck relative 

to the baseline vehicle. This represents an increase in strong HEV effectiveness of 

approximately 2 percent as compared to the estimate employed in the MYs 2012-2016 final rule 

based on published data for new HEVs that have entered into production, such as 2011 Hyundai 

291 Car and Driver praised the Sonata’s fuel economy but followed with “the integration of the hybrid system is far 

less impressive” (June, 2011), while Edmunds.com criticized the “clumsy braking response” 

(http://www.edmunds.com/hyundai/sonata-hybrid/2011/, last accessed Nov. 3, 2011). Other reviews have indicated 

that the driveability issues are more pronounced when the vehicle is in fuel-efficient “Blue Mode.” See, e.g., 

http://www.cars.com/hyundai/sonata-hybrid/2011/expert-reviews/?revid=56695(last accessed Nov. 3, 2011). 
 

                                                      

 

 

389 

Sonata hybrid, 2010 Hyundai Elantra LPI HEV (Korean market only), 2011 Infiniti G35 Hybrid 

and 2011 Volkswagen Touareg Hybrid). 

Additionally, for the Large Car, Minivan, and Small Truck subclasses for this FRM analysis, the 

agencies estimated that HEV effectiveness could be increased by allowing for down-powering of 

the gasoline engine. This could impact the towing capacity for some vehicles when converted to 

a HEV powertrain.292 The agencies believe that consumers interested in these vehicles who 

require towing capacity could acquire it by purchasing a vehicle with a non-hybrid powertrain 

(as they do today).293 The approach used by the agencies allows more HEV and engine downpowering being applied to vehicle fleet, which increases estimated overall HEV system 

incremental effectiveness by 5 to 10 percent for Large Cars, Minivans, and Small Trucks, similar 

to the HEV effectiveness value assumed for Small Cars and Compact Cars.294 Moreover, it is 

likely that some fraction of consumers who purchase the larger engine option do so for purposes 

of hauling and acceleration performance, not just maximum towing. 

The battery sizing is different for the 2008 and 2010 baseline vehicle fleets, because vehicle 

mass for each subclass is slightly different between the two baseline fleets, thus requiring a 

slightly different battery size to maintain equivalent performance. The battery sizes with no 

applied mass reduction are listed in Table V-96. 

Table V-96: NHTSA Battery Sizes for P2 Hybrid Applied in CAFE Model without Mass 

Reduction (kWh) 

Baseline 

Fleet 

Subcompact 

PC/ Perf PC 

Compact PC/ 

Perf PC 

Midsize 

PC/Perf PC 

Large PC/Perf 

PC 

Midsize LT 

Minivan Small LT Large LT 

2008 0.81 1.00 1.16 1.28 1.04 1.49 

2010 0.84 1.02 1.20 1.27 1.06 1.56 

292 At issue are those small SUVs and Minivans with a towing capacity of at least 3500 lbs when equipped with an 

OEM or dealer installed towing package. While their towing capacity should be maintained, they may see a 

performance degradation in the event that the motive power is delivered exclusively by the gasoline engine which 

could occur during an extended uphill drive at maximum capacity. 

293 The agencies recognize that assuming that certain consumers will choose to purchase non-hybrid vehicles in 

order to obtain their desired towing capacity could lead to some increase in fuel consumption and CO2 emissions as 

compared to assuming that towing capacity is maintained for hybrid vehicles across the board. However, the 

agencies think it likely that the net improvement in fuel consumption and CO2 emissions due to the increased 

numbers of hybrids available for consumers to choose could offset the potential increase in fuel consumption and 

CO2 emissions resulting from consumers selecting the higher-performance non-hybrid powertrain vehicles. 294 The effectiveness of HEVs for heavier vehicles which require conventional towing capabilities is markedly less 

because the rated power of the IC engine must be similar to its non-hybrid brethren. As such, there is less 

opportunity for downsizing with these vehicles. 
 

 

390 

The costs for P2 hybrids without mass reduction as used in the CAFE model are listed in 

Table V-97. The battery costs are calculated using the battery sizes for both the 2008 and 2010 

baseline fleets. NHTSA accounts the cost impact from the interaction between mass reduction 

and sizing of the electrification system (battery and non-battery system) as a cost synergy as 

described in Section “How Did NHTSA Account for the Cost Synergy between Mass Reduction 

and Electrification System in CAFE Model?” The agencies have applied a high complexity ICM 

to both the battery and non-battery component costs for P2 hybrids, although the timing of the 

ICMs varies: for the battery components in P2 hybrids, the ICM switches from the short-term 

value of 1.56 to the long-term value of 1.35 in 2024, while for the non-battery component the 

switch to long-term ICMs happens in 2018. 

Table V-97 NHTSA Costs for P2 Hybrid Applied in CAFE Model without Mass 

Reduction (2010$) 

Tech. Cost 

Type 

NHTSA 

Vehicle 

Class 

Baseline 

Fleet 2017 2018 2019 2020 2021 2022 2023 2024 2025 

Battery DMC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $733 $711 $689 $669 $648 $629 $610 $592 $574 

2008 $726 $704 $683 $662 $642 $623 $604 $586 $569 

Battery DMC Midsize 

PC/Perf PC 

2010 $818 $793 $769 $746 $724 $702 $681 $661 $641 

2008 $809 $784 $761 $738 $716 $694 $674 $653 $634 

Battery DMC Large 

PC/Perf PC 

2010 $959 $931 $903 $876 $849 $824 $799 $775 $752 

2008 $946 $918 $890 $864 $838 $813 $788 $765 $742 

Battery DMC Midsize LT 

Minivan 

2010 $887 $860 $834 $809 $785 $761 $739 $716 $695 

2008 $885 $858 $832 $807 $783 $760 $737 $715 $693 

Battery DMC Small LT 2010 $796 $773 $749 $727 $705 $684 $663 $643 $624 

2008 $787 $763 $740 $718 $697 $676 $655 $636 $617 

Battery DMC Large LT 2010 $1,029 $998 $968 $939 $911 $884 $857 $831 $807 

2008 $1,020 $989 $960 $931 $903 $876 $850 $824 $799 

Nonbattery DMC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $1,474 $1,445 $1,416 $1,388 $1,360 $1,333 $1,306 $1,280 $1,254 

2008 $1,468 $1,438 $1,410 $1,381 $1,354 $1,327 $1,300 $1,274 $1,249 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 $1,645 $1,612 $1,580 $1,549 $1,518 $1,487 $1,457 $1,428 $1,400 

2008 $1,627 $1,595 $1,563 $1,531 $1,501 $1,471 $1,441 $1,413 $1,384 

Nonbattery DMC Large 

PC/Perf PC 

2010 $1,949 $1,910 $1,872 $1,834 $1,798 $1,762 $1,727 $1,692 $1,658 

2008 $1,906 $1,868 $1,830 $1,794 $1,758 $1,723 $1,688 $1,655 $1,621 

Nonbattery DMC Midsize LT 

Minivan 

2010 $1,817 $1,780 $1,745 $1,710 $1,676 $1,642 $1,609 $1,577 $1,546 

2008 $1,798 $1,762 $1,727 $1,693 $1,659 $1,626 $1,593 $1,561 $1,530 
391 

Nonbattery DMC Small LT 2010 $1,587 $1,555 $1,524 $1,493 $1,464 $1,434 $1,406 $1,378 $1,350 

2008 $1,557 $1,526 $1,496 $1,466 $1,436 $1,408 $1,380 $1,352 $1,325 

Nonbattery DMC Large LT 2010 $1,918 $1,879 $1,842 $1,805 $1,769 $1,733 $1,699 $1,665 $1,631 

2008 $1,901 $1,863 $1,825 $1,789 $1,753 $1,718 $1,684 $1,650 $1,617 

Battery IC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $413 $411 $410 $409 $407 $406 $405 $404 $248 

2008 $409 $408 $406 $405 $404 $402 $401 $400 $246 

Battery IC Midsize 

PC/Perf PC 

2010 $461 $459 $458 $456 $455 $453 $452 $451 $277 

2008 $456 $454 $453 $451 $450 $448 $447 $446 $274 

Battery IC Large 

PC/Perf PC 

2010 $541 $539 $537 $535 $534 $532 $530 $529 $325 

2008 $533 $532 $530 $528 $526 $525 $523 $522 $320 

Battery IC Midsize LT 

Minivan 

2010 $500 $498 $496 $495 $493 $492 $490 $489 $300 

2008 $499 $497 $495 $494 $492 $490 $489 $488 $299 

Battery IC Small LT 2010 $449 $447 $446 $444 $443 $442 $440 $439 $270 

2008 $443 $442 $440 $439 $438 $436 $435 $434 $266 

Battery IC Large LT 2010 $580 $578 $576 $574 $572 $571 $569 $567 $348 

2008 $575 $573 $571 $569 $567 $566 $564 $562 $345 

Nonbattery IC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $943 $941 $578 $577 $576 $575 $574 $574 $573 

2008 $939 $937 $575 $574 $574 $573 $572 $571 $570 

Nonbattery IC Midsize 

PC/Perf PC 

2010 $1,053 $1,050 $645 $644 $643 $642 $641 $640 $639 

2008 $1,041 $1,039 $638 $637 $636 $635 $634 $633 $632 

Nonbattery IC Large 

PC/Perf PC 

2010 $1,247 $1,244 $764 $763 $762 $761 $759 $758 $757 

2008 $1,219 $1,217 $747 $746 $745 $744 $743 $741 $740 

Nonbattery IC Midsize LT 

Minivan 

2010 $1,162 $1,160 $712 $711 $710 $709 $708 $707 $706 

2008 $1,150 $1,148 $705 $704 $703 $702 $701 $700 $699 

Nonbattery IC Small LT 2010 $1,015 $1,013 $622 $621 $620 $619 $618 $617 $616 

2008 $996 $994 $610 $610 $609 $608 $607 $606 $605 

Nonbattery IC Large LT 2010 $1,227 $1,224 $752 $751 $749 $748 $747 $746 $745 

2008 $1,216 $1,213 $745 $744 $743 $742 $741 $739 $738 

Battery TC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $1,145 $1,122 $1,099 $1,077 $1,056 $1,035 $1,015 $996 $822 

2008 $1,135 $1,111 $1,089 $1,067 $1,046 $1,025 $1,006 $986 $814 

Battery TC Midsize 

PC/Perf PC 

2010 $1,278 $1,252 $1,227 $1,202 $1,179 $1,155 $1,133 $1,111 $918 

2008 $1,264 $1,239 $1,213 $1,189 $1,166 $1,143 $1,121 $1,099 $907 

Battery TC Large 

PC/Perf PC 

2010 $1,500 $1,469 $1,440 $1,411 $1,383 $1,356 $1,330 $1,304 $1,077 

2008 $1,480 $1,449 $1,420 $1,392 $1,364 $1,337 $1,311 $1,286 $1,062 
392 

Battery TC Midsize LT 

Minivan 

2010 $1,386 $1,358 $1,331 $1,304 $1,278 $1,253 $1,229 $1,205 $995 

2008 $1,383 $1,355 $1,327 $1,301 $1,275 $1,250 $1,226 $1,202 $993 

Battery TC Small LT 2010 $1,245 $1,220 $1,195 $1,171 $1,148 $1,125 $1,104 $1,082 $894 

2008 $1,230 $1,205 $1,181 $1,157 $1,134 $1,112 $1,090 $1,069 $883 

Battery TC Large LT 2010 $1,609 $1,576 $1,544 $1,513 $1,483 $1,454 $1,426 $1,399 $1,155 

2008 $1,595 $1,562 $1,531 $1,500 $1,470 $1,442 $1,414 $1,386 $1,145 

Nonbattery TC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $2,418 $2,386 $1,994 $1,965 $1,936 $1,908 $1,881 $1,854 $1,827 

2008 $2,407 $2,375 $1,985 $1,956 $1,927 $1,899 $1,872 $1,845 $1,819 

Nonbattery TC Midsize 

PC/Perf PC 

2010 $2,698 $2,663 $2,225 $2,192 $2,160 $2,129 $2,098 $2,068 $2,039 

2008 $2,668 $2,633 $2,201 $2,168 $2,137 $2,106 $2,075 $2,046 $2,016 

Nonbattery TC Large 

PC/Perf PC 

2010 $3,196 $3,155 $2,636 $2,597 $2,559 $2,522 $2,486 $2,450 $2,415 

2008 $3,125 $3,085 $2,577 $2,540 $2,503 $2,466 $2,431 $2,396 $2,362 

Nonbattery TC Midsize LT 

Minivan 

2010 $2,979 $2,940 $2,457 $2,421 $2,386 $2,351 $2,317 $2,284 $2,252 

2008 $2,949 $2,910 $2,432 $2,396 $2,361 $2,327 $2,294 $2,261 $2,229 

Nonbattery TC Small LT 2010 $2,602 $2,568 $2,146 $2,115 $2,084 $2,054 $2,024 $1,995 $1,966 

2008 $2,554 $2,520 $2,106 $2,075 $2,045 $2,015 $1,986 $1,958 $1,930 

Nonbattery TC Large LT 2010 $3,144 $3,103 $2,593 $2,555 $2,518 $2,482 $2,446 $2,411 $2,376 

2008 $3,116 $3,076 $2,570 $2,533 $2,496 $2,460 $2,424 $2,389 $2,355 

Power Split Hybrid 

Power-split hybrid (PSHEV) is a hybrid electric drive system that replaces the traditional 

transmission with a single planetary gear set and two motor/generators. The smaller 

motor/generator uses the engine to either charge the battery or to supply additional power to the 

drive motor. The second, more powerful motor/generator is permanently connected to the 

vehicle’s final drive and always turns with the wheels. The planetary gear splits engine power 

between the first motor/generator and the drive motor to either charge the battery or supply 

power to the wheels. Power-split hybrid technology is currently in production and used on 

vehicles, such as Toyota Prius and Ford Fusion Hybrid, but the agencies have chosen not to 

apply it in this FRM analysis, consistent with the proposal, because the agencies believe that P2 

hybrid is a more cost-effective hybrid technology, as described in the previous section. 

2-Mode Hybrid 

2-mode hybrid (2MHEV) – is a hybrid electric drive system that uses an adaptation of a 

conventional stepped-ratio automatic transmission by replacing some of the transmission 

clutches with two electric motors that control the ratio of engine speed to vehicle speed, while 
 

393 

clutches allow the motors to be bypassed. This improves both the transmission torque capacity 

for heavy-duty applications and reduces fuel consumption at highway speeds relative to other 

types of hybrid electric drive systems. 

2-mode hybrid technology exists in the baseline fleet, and OEMs have used 2-mode hybrids on 

vehicles with towing requirements, such as the Chevrolet Tahoe and the Chevrolet Silverado 

pickup truck. However, the agencies have chosen not to apply it in this FRM analysis, consistent 

with the proposal, because the agencies believe that P2 hybrid is a more cost-effective hybrid 

technology, as described in the previous section. The agencies may re-consider this hybrid 

technology in vehicles with towing requirements, such as pickup trucks, in future rulemakings, 

based on new information obtained. 

Plug-in Electrical Hybrid Vehicles (PHEV) 

Plug-In Hybrid Electric Vehicles (PHEVs) are very similar to Hybrid Electric Vehicles, but with 

three significant functional differences. The first is the addition of a means to charge the battery 

pack from an outside source of electricity (e.g., the electric grid). Second, a PHEV would have a 

larger battery pack with more energy storage, and a greater capability to be discharged. Finally, 

a PHEV would have a control system that allows the battery pack to be significantly depleted 

during normal operation. 

Table V-98 below illustrates how PHEVs compare functionally to both hybrid electric vehicles 

(HEV) and electric vehicles (EV). These characteristics can change significantly within each 

vehicle class/subclass, so this is simply meant as an illustration of the general characteristics. In 

reality, the design options are so varied that all of these vehicles exist on a continuum, with 

HEVs on one end and EVs on the other. 

Table V-98 Conventional Vehicles, HEVs, PHEVs, and EVs Compared 

Increasing Electrification 

Attribute Conventional HEV PHEV EV 

Drive Power Engine Blended 

Engine/Electric 

Blended 

Engine/Electric Electric 

Engine Size Full Size Full Size or 

Smaller 

Smaller or Much 

Smaller No Engine 

Electric Range None None to Very 

Short Short to Medium Medium to Long 

Battery 

Charging None On-Board Grid/On-Board Grid Only 

Deriving some of their propulsion energy from the electric grid provides several advantages for 

PHEVs. PHEVs offer a significant opportunity to replace petroleum used for transportation 

energy with domestically-produced electricity. The reduction in petroleum usage does, of 
 

 

                                                      

394 

course, depend on the amount of electric drive the vehicle is capable of under its duty 

cycle. PHEVs also provide electric utilities the possibility to increase electricity generation 

during “off-peak” periods (such as overnight) when there is excess generation capacity and 

electricity prices are lower. Utilities like to increase this “base load” because it increases overall 

system efficiency and lowers average costs. PHEVs can lower localized emissions of criteria 

pollutants and air toxics, especially in urban areas, by operating on electric power: the emissions 

from the power generation occur outside the urban area at the power generation plant, which 

provides health benefits for residents of the more densely populated urban areas by moving 

emissions of ozone precursors out of the urban air shed. Additionally, unlike most other 

alternative fuel technologies, PHEVs can initially use an existing infrastructure for refueling 

(charging and liquid refueling) so investments in infrastructure may be reduced. 

In analyzing the impacts of grid-connected vehicles like PHEVs and EVs, the emissions from the 

electricity generation can be accounted for if a full upstream and downstream analysis is 

desired. These effects are considered in NHTSA’s assessment of the benefits of this rulemaking, 

see Chapter VIII below, as well as NHTSA’s EIS, but they are not considered directly for 

purposes of determining the effectiveness of the technologies at improving fuel economy. 

PHEVs will be considerably more costly than conventional vehicles and some other advanced 

technologies due to the fact that PHEVs require both conventional internal combustion engine 

and electrical driving systems and the larger expensive battery pack. 

For purposes of CAFE analysis, we assume that all future PHEVs during the rulemaking 

timeframe will meet the range requirements to qualify as a dual fuel vehicle. When calculating 

the fuel economy of a dual-fuel PHEV, NHTSA uses a petroleum equivalency factor for 

electricity consumption as stated in 49 U.S.C. 32904 and 32905. Because PHEVs are just starting 

to enter the marketplace, fuel economy estimates for these vehicles remain difficult to obtain for 

purposes of this analysis. NHTSA therefore based the effectiveness estimations for PHEVs and 

EVs on experimental data. When evaluating the effectiveness of PHEVs and EVs at reducing 

fuel consumption, NHTSA referenced the UDDS and highway fuel economy data of 3 pairs of 

vehicles for which NHTSA has fuel economy data in the CAFE database: 

 The MiniE electric vehicle and the gasoline-powered Mini with automatic transmission, 

 The Tesla Roadster electric vehicle and the gasoline-powered rear-wheel-drive Lotus 

Elise Sedan with a 6-speed manual transmission,295 and 

 The MY 2012 Nissan Leaf electric vehicle and the gasoline-powered Nissan Sentra with 

automatic transmission.296 

295 The Tesla Roadster is based on the Lotus Elise body, which makes the Elise the most comparable vehicle to the 

Roadster for purposes of this analysis. 
	 	 	 	

                                                                                                                                                                              

395 

The fuel economy and fuel consumption for the first two pairs are shown in 

Table V-99; the agency was unable to show the information for the last pair because the 

information for the Nissan Leaf is confidential. 

Table V-99 EV Fuel Economy and Fuel Consumption 

104 Mile Range (Mini Website) Fuel Economy 

[mpg] 

Fuel Consumption 

[gpm]

 MiniE (mpg) 342.4 0.0029206

 Mini Gas ATX (mpg) 38.6 0.0259067 

227 Mile Range (EPA) 

Tesla Roadster 346.8 0.0028835 

Lotus Elise Sedan M6 RWD 30.6 0.0326797 

Because technologies are applied in the CAFE model in an incremental manner, the effectiveness 

for each technology is incremental to the previous technology on the decision tree. In the 

electrification decision tree of the CAFE model, the order of technology selection starts from 

gasoline-only powertrain, then moves to strong hybrid, to plug-in hybrid electric vehicle, and 

finally to electric vehicle. So the incremental effectiveness for each step has to be defined. In 

order to calculate the effectiveness of the PHEV technology for purposes of CAFE analysis, 

operation on both gasoline and electricity has to be considered. 

First, the incremental fuel economy benefit for gasoline operation is determined using the 

incremental effectiveness of strong hybrid (SHEV) from the LPM, which indicates that the 

incremental effectiveness for SHEV is 46.2 percent. For example, the fuel economy for Mini 

Gas ATX is 38.6 mpg. Applying the 46.2 percent fuel consumption reduction, the fuel economy 

for an SHEV Mini can be calculated as follows. 

1 ൌ ݅݊݅ܯ ݊݋ ݁݀ݏܾܽ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܵ

ቀ 1 ൌ 71.7	݉݌݃

ൈ ሺ100% െ 46.2%ቁ 38.6

Then the fuel economy from gasoline source for PHEV is assumed to be the same as SHEV fuel 

economy, e.g., 71.7 mpg in the case of Mini E. 

296 Sentra is used as the baseline for Leaf comparison because these two vehicles are of similar size from the same 

manufacturer. 
                                                      

396 

Next, the petroleum-equivalent fuel economy for electric operation for the PHEV is set to be 

equal to the measured fuel economy of an example EV, e.g., 342.4 mpg in the case of the Mini 

E. And finally, the fuel economy benefit from the gasoline operation and the fuel economy 

benefit from electric operation need to be combined. Through MY 2019, for compliance 

purposes, the statute requires the fuel economy of PHEVs to be calculated assuming that 50 

percent of the operation is on electricity and 50 percent on gasoline.297 After 2019, NHTSA will 

use the utility factor method defined by SAE standard J1711 for calculating CAFE fuel economy 

of PHEV. NHTSA expects that a PHEV with a 30 mile charge depleting range may reasonably 

represent the PHEVs that manufacturers may produce in MYs 2017 to 2025. According to SAE 

standard J2841, a vehicle with 30 mile charge depleting range has a 0.668 city specific utility 

factor and a 0.337 highway specific utility factor, which together give a 0.52 combined utility 

factor (55% city/45% highway split). Therefore NHTSA selected a PHEV with a 30 mile range 

for the CAFE model analysis, and the selection of a PHEV with a 30 mile range maintains 

continuity between pre-2020 and post-2020 PHEV fuel economy calculations. NHTSA assumes 

a 0.50 utility factor for MY2020 and beyond. 

NHTSA thus calculated the combined fuel economy for PHEV for purposes of this analysis 

using a 50-50 weighting factor, as follows: 

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܾ݉݅݊݁݀݋ܥ ܸܧܪܲ

ݎ݋ݐܽܿܨ	ܹ݄݁݅݃݅݊݃ ܧܨ ݈݅݊݁݋ݏܽܩ ൅ ݎ݋ݐܽܿܨ ܹ݄݁݅݃݅݊݃ ܧܨ ݅ܿݎݐ݈݁ܿܧ ൌ 1

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ݈݅݊݁݋ݏܽܩ

ൌ ൌ 118.6	mpg 0.5

71.7 ൅

1

0.5

342.4

The incremental fuel consumption reduction for PHEV is then calculated relative to SHEV. 

Using the example of Mini E, the incremental fuel consumption reduction for PHEV relative to 

SHEV is 39.5 percent, as shown below: 

297 See 49 U.S.C. § 32905. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

397 

ܸܧܪܲ ݎ݋݂ ݊݋݅ݐܿݑܴ݁݀ ݊݋݅ݐ݌݉ݑݏ݊݋ܥ ݈݁ݑܨ ݈ܽݐ݁݉݁݊ݎ݊ܿܫ

൬ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܲ െ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܵ ൰ 1 1

1 100%ݔ ൌ

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܵ

ൌ ቀ 1

71.7ቁ 118.6

1

െ 1

ݔ100% ൌ െ39.5%

71.7

Table V-100 lists NHTSA’s incremental effectiveness calculation for two pairs of vehicles, the 

Mini E and the Tesla Roadster. Again, the table does not contain an incremental fuel 

consumption calculation for PHEV based on the Nissan Leaf due to the confidentiality of that 

vehicle’s current fuel economy rating for compliance purposes. The derived incremental 

effectiveness for Nissan Leaf is 40.6 percent. Together, the average incremental effectiveness of 

these three pairs of vehicles is 40.65 percent, which is the number used by NHTSA in the CAFE 

modeling for this FRM analysis, consistent with the proposal. 

Table V-100 Incremental Effectiveness Calculation for purposes of CAFE modeling 

Mini E 

Gasoline SHEV2 PHEV1 EV1 

Combined Fuel Economy [mpg] 38.6 71.7 118.6 342.4 

Gasoline Fuel Economy [mpg] 71.7 71.7 

Electric Petroleum Equivalent Fuel Economy [mpg] 342.4 

Combined Fuel Consumption[gpm] 0.0139414 0.0084310 0.0029206 

Gasoline Fuel Consumption [gpm] 0.0139414 0.0139414 

Incremental Combined Fuel Consumption [%] 39.5% 65.4% 

Gasoline Weighing Factor[%] 50% 0% 

Electricity Weighing Factor [%] 50% 100% 

Tesla 

Gasoline SHEV2 PHEV1 EV1 

Combined Fuel Economy [mpg] 30.6 56.7 97.4 346.8 

Gasoline Fuel Economy [mpg] 56.7 56.7 

Electric Petroleum Equivalent Fuel Economy [mpg] 346.8 

Combined Fuel Consumption[gpm] 0.017647 0.0102653 0.0028835 

Gasoline Fuel Consumption [gpm] 0.017647 0.0176471 

Incremental Combined Fuel Consumption [%] 41.8% 71.9% 

Gasoline Weighing Factor[%] 50% 0% 

Electricity Weighing Factor [%] 50% 100% 
 

 

398 

Once the fuel economy of the PHEV is calculated, the effectiveness of PHEV incremental to EV 

can be calculated similarly using the formula below. 

ܸܧ ݎ݋݂ ݐ݁݉݁݊ݒ݋ݎ݌݉ܫ ݊݋݅ݐ݌݉ݑݏ݊݋ܥ ݈݁ݑܨ ݈ܽݐ݁݉݁݊ݎ݊ܿܫ

ሺ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧ െ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܲ ሻ 1 1

ൌ 1

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܲ

 
100%ݔ

Using that formula, the average effectiveness for the three pairs of vehicles is 68.54 percent, 

which is the value used in the analysis for this FRM analysis, consistent with the proposal. 

The cost of PHEV consists of three parts: the cost for the battery, the cost for the non-battery 

systems (including, for example, the gasoline engine and transmission), and the cost for the 

charger and the labor to install it. Costs for PHEVs without mass reduction as used in the CAFE 

model are listed in Table V-101 . NHTSA accounts for the cost synergy due to the interaction 

between mass reduction and sizing of the electrification system (battery and non-battery system) 

as described in Section “How Did NHTSA Account for the Cost Synergy between Mass 

Reduction and Electrification System in CAFE Model?” of this chapter. EPA developed costs 

for a PHEV20 and a PHEV40 with the methodologies discussed in Section “Battery Pack Sizing 

and Hybrid System Sizing”; because NHTSA modeled a PHEV 30 for this final rule, NHTSA 

averaged EPA’s direct costs for the PHEV20 and the PHEV40. 

For indirect costs, a high complexity ICM is used for the non-battery component costs for 

PHEVs and PHEV chargers, which switches from the short-term value of 1.56 to the long-term 

value of 1.35 at 2018. A higher ICM factor is used for PHEV batteries due to the fact that they 

represent a more complex technology. The ICM for PHEV batteries switches from the shortterm value of 1.77 to the long-term value of 1.50 at 2024. 

Table V-101 NHTSA Costs for PHEV30 Applied in the CAFE Model with No Mass 

Reduction (2010$) 

Tech. Cost 

Type 

NHTSA 

Vehicle 

Class 

Baseline 

Fleet 

2017 2018 2019 2020 2021 2022 2023 2024 2025 

Battery DMC Subcompact 

PC/Perf PC 

2010 $6,208 $8,259 $8,259 $6,607 $6,607 $6,607 $6,607 $6,607 $5,286 

Compact 

PC/Perf PC 

2008 $6,095 $8,097 $8,097 $6,477 $6,477 $6,477 $6,477 $6,477 $5,182 

Battery DMC Midsize 2010 $7,415 $5,932 $5,932 $4,746 $4,746 $4,746 $4,746 $4,746 $3,797 
 

399 

PC/Perf PC 2008 $7,251 $5,801 $5,801 $4,640 $4,640 $4,640 $4,640 $4,640 $3,712 

Battery DMC Large 

PC/Perf PC 

2010 $9,835 $7,868 $7,868 $6,294 $6,294 $6,294 $6,294 $6,294 $5,035 

2008 $9,610 $7,688 $7,688 $6,150 $6,150 $6,150 $6,150 $6,150 $4,920 

Nonbattery DMC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $2,586 $2,535 $2,484 $2,434 $2,386 $2,338 $2,291 $2,245 $2,200 

2008 $2,522 $2,472 $2,422 $2,374 $2,326 $2,280 $2,234 $2,190 $2,146 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 $3,252 $3,187 $3,124 $3,061 $3,000 $2,940 $2,881 $2,824 $2,767 

2008 $3,132 $3,070 $3,008 $2,948 $2,889 $2,831 $2,775 $2,719 $2,665 

Nonbattery DMC Large 

PC/Perf PC 

2010 $4,685 $4,591 $4,499 $4,409 $4,321 $4,235 $4,150 $4,067 $3,986 

2008 $4,494 $4,405 $4,316 $4,230 $4,145 $4,063 $3,981 $3,902 $3,824 

Charger DMC All 2008/2010 $210 $168 $168 $134 $134 $134 $134 $134 $108 

Charger 

Labor 

DMC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Battery IC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $2,671 $2,579 $2,579 $2,506 $2,506 $2,506 $2,506 $2,506 $1,578 

2008 $2,622 $2,532 $2,532 $2,460 $2,460 $2,460 $2,460 $2,460 $1,550 

Battery IC Midsize 

PC/Perf PC 

2010 $3,190 $3,081 $3,081 $2,993 $2,993 $2,993 $2,993 $2,993 $1,885 

2008 $3,119 $3,012 $3,012 $2,927 $2,927 $2,927 $2,927 $2,927 $1,844 

Battery IC Large 

PC/Perf PC 

2010 $4,231 $4,086 $4,086 $3,970 $3,970 $3,970 $3,970 $3,970 $2,501 

2008 $4,134 $3,993 $3,993 $3,879 $3,879 $3,879 $3,879 $3,879 $2,444 

Nonbattery IC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $1,655 $1,651 $1,014 $1,012 $1,011 $1,009 $1,008 $1,006 $1,005 

2008 $1,614 $1,610 $989 $987 $986 $984 $983 $981 $980 

Nonbattery IC Midsize 

PC/Perf PC 

2010 $2,081 $2,077 $1,275 $1,273 $1,271 $1,269 $1,267 $1,265 $1,264 

2008 $2,004 $2,000 $1,228 $1,226 $1,224 $1,222 $1,220 $1,219 $1,217 

Nonbattery IC Large 

PC/Perf PC 

2010 $2,997 $2,991 $1,836 $1,834 $1,831 $1,828 $1,825 $1,823 $1,820 

2008 $2,875 $2,869 $1,762 $1,759 $1,756 $1,754 $1,751 $1,749 $1,746 

Charger IC All 2008/2010 $67 $65 $65 $62 $62 $62 $62 $62 $37 

Charger 

Labor 

IC All 2008/2010 $0 $0 $0 $0 $0 $0 $0 $0 $0 

Battery TC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $8,878 $7,545 $7,545 $6,479 $6,479 $6,479 $6,479 $6,479 $4,757 

2008 $8,717 $7,408 $7,408 $6,361 $6,361 $6,361 $6,361 $6,361 $4,670 

Battery TC Midsize 

PC/Perf PC 

2010 $10,605 $9,013 $9,013 $7,739 $7,739 $7,739 $7,739 $7,739 $5,682 

2008 $10,370 $8,813 $8,813 $7,567 $7,567 $7,567 $7,567 $7,567 $5,556 

Battery TC Large 

PC/Perf PC 

2010 $14,066 $11,954 $11,954 $10,264 $10,264 $10,264 $10,264 $10,264 $7,536 

2008 $13,744 $11,681 $11,681 $10,030 $10,030 $10,030 $10,030 $10,030 $7,364 
 

 

400 

Nonbattery TC Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $4,241 $4,186 $3,498 $3,446 $3,396 $3,347 $3,299 $3,251 $3,205 

2008 $4,136 $4,082 $3,411 $3,361 $3,312 $3,264 $3,217 $3,171 $3,126 

Nonbattery TC Midsize 

PC/Perf PC 

2010 $5,333 $5,264 $4,399 $4,334 $4,271 $4,209 $4,148 $4,089 $4,031 

2008 $5,136 $5,069 $4,236 $4,174 $4,113 $4,054 $3,995 $3,938 $3,882 

Nonbattery TC Large 

PC/Perf PC 

2010 $7,682 $7,582 $6,336 $6,243 $6,152 $6,063 $5,975 $5,890 $5,806 

2008 $277 $233 $233 $197 $197 $197 $197 $197 $145 

Charger TC All 2008/2010 $277 $233 $233 $197 $197 $197 $197 $197 $145 

Charger 

Labor 

TC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Electric Vehicle (EV) 

Electric vehicles (EV) are vehicles with all-electric drive and with vehicle systems powered by 

energy-optimized batteries charged primarily from grid electricity. While the MYs 2012-2016 

final rule analysis did not anticipate a significant penetration of EVs, in this analysis, EVs with 

several different ranges have been included. As discussed in the section above for PHEVs, 

NHTSA uses DOE’s petroleum equivalency factor in calculating the fuel economy effectiveness 

for EVs since electric operation does not involve miles per gallon. The PEF is determined by the 

U.S. Department of Energy as specified in 10 CFR Part 474. The PEF accounts for U.S. average 

fossil-fuel electricity generation and transmission efficiencies, petroleum refining and 

distribution efficiency, the energy content of gasoline, and includes a 0.15 divisor to incentivize 

the use of electricity in vehicles. The current PEF for electricity is 82.049 kWh per gallon of 

gasoline. 

Using the fuel economy of the PHEV calculated as shown in the previous section, the 

effectiveness of EV incremental to PHEV can be calculated similarly using the formula below. 

ܸܧ ݎ݋݂ ݐ݁݉݁݊ݒ݋ݎ݌݉ܫ ݊݋݅ݐ݌݉ݑݏ݊݋ܥ ݈݁ݑܨ ݈ܽݐ݁݉݁݊ݎ݊ܿܫ

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧ െ 1 ሺ

1 100%ݔ ൌ ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܲ ሻ 1

ݕ݉݋݊݋ܿܧ ݈݁ݑܨ ܸܧܪܲ

The average effectiveness for the three pairs of EVs of 68.54 percent is used in CAFE modeling 

as incremental effectiveness relative to PHEVs. 
 

 

 

 

 

 

 

401 

For battery costs, NHTSA assumes that battery packs for EV applications will be designed to last 

for the full useful life of the vehicle at a useable state of charge equivalent to 80 percent of the 

nominal battery pack capacity. NHTSA considered both a 75-mile range EV (EV75) and a 150­

mile range EV (EV150) in this FRM analysis, consistent with the NPRM. The EV75 was 

employed to represent costs relevant to vehicles sold to “early adopters.” We assumed that as 

this technology is entering the market, the OEM will try to keep costs low at the beginning to 

spur the technology, which, given the high cost of the battery packs at this early stage of EVs, 

will require the battery pack size to be limited to reduce cost. Therefore NHTSA applied a 75­

mile range EV for early adoption of this technology in the market, up to 5% penetration. Larger 

battery packs to address “range anxiety” concerns should not be necessary at this stage, since we 

assume that early adopters tend to be urban drivers. As the technology develops and as the 

market penetration increases beyond 5%, NHTSA expects that OEMs would provide longer 

driving range to help the consumers overcome range anxiety. NHTSA applied 150-mile EV for 

this broad market adoption of this technology. 

The cost of an EV consists of three parts: the cost of the battery pack, the cost of non-battery 

systems, and the cost of a charger and charger installation labor. The battery sizes applied in the 

CAFE model for each type of EV and vehicle subclass are listed in Table V-92 below. 

Table V-102 NHTSA Battery Sizes for EVs Applied in CAFE Model without Mass 

Reduction (kWh) 

Baseline 

Fleet 

Subcompact 

PC/ Perf PC 

Compact 

PC/ Perf PC 

Midsize 

PC/Perf 

PC 

Large 

PC/Perf 

PC 

Midsize 

LT 

Minivan 

Small 

LT 

Large 

LT 

EV75 

2008 22.79 28.03 33.28 n/a 29.48 n/a 

2010 23.65 28.72 34.54 n/a 29.95 n/a 

EV100 

2008 30.39 37.38 44.37 n/a 39.3 n/a 

2010 31.54 38.3 46.05 n/a 39.94 n/a 

EV150 

2008 45.58 56.07 66.55 n/a 58.96 n/a 

2010 47.31 57.45 69.08 n/a 59.9 n/a 

A high complexity ICM was applied to the non-battery component cost for EVs and EV 

chargers, which switches from the short-term value of 1.56 to the long-term value of 1.35 at 

2018. A higher ICM factor was applied to EV batteries due to the fact that they represent a more 

complex technology. The ICM for EV battery switches from the short-term value of 1.77 to the 

long-term value of 1.50 at 2024. The costs of EVs without mass reduction as applied in the 
 

402 

CAFE model for this analysis are listed in Table V-103 to Table V-104. NHTSA accounts for 

the cost synergy due to the interaction between mass reduction and sizing of the electrification 

system (battery and non-battery system) as described in Section “How Did NHTSA Account for 

the Cost Synergy between Mass Reduction and Electrification System in CAFE Model?” 
 

403 

Table V-103 NHTSA Costs Applied in CAFE model for EV75 with No Mass Reduction 

(2010$) 

Tech. Cost 

Type 

NHTSA 

Vehicle 

Class 

Baseline 

Fleet 2017 2018 2019 2020 2021 2022 2023 2024 2025 

Battery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $10,324 $8,259 $8,259 $6,607 $6,607 $6,607 $6,607 $6,607 $5,286 

2008 $10,121 $8,097 $8,097 $6,477 $6,477 $6,477 $6,477 $6,477 $5,182 

Battery DMC Midsize 

PC/Perf PC 

2010 $12,140 $9,712 $9,712 $7,769 $7,769 $7,769 $7,769 $7,769 $6,215 

2008 $11,881 $9,505 $9,505 $7,604 $7,604 $7,604 $7,604 $7,604 $6,083 

Battery DMC Large PC/Perf 

PC 

2010 $15,634 $12,507 $12,507 $10,006 $10,006 $10,006 $10,006 $10,006 $8,005 

2008 $15,238 $12,190 $12,190 $9,752 $9,752 $9,752 $9,752 $9,752 $7,802 

Nonbattery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $410 $398 $386 $375 $363 $352 $345 $338 $332 

2008 $354 $343 $333 $323 $313 $304 $298 $292 $286 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 $1,267 $1,229 $1,193 $1,157 $1,122 $1,088 $1,067 $1,045 $1,024 

2008 $1,156 $1,122 $1,088 $1,055 $1,024 $993 $973 $954 $935 

Nonbattery DMC Large PC/Perf 

PC 

2010 $2,236 $2,169 $2,104 $2,041 $1,980 $1,920 $1,882 $1,844 $1,808 

2008 $2,080 $2,018 $1,957 $1,899 $1,842 $1,786 $1,751 $1,716 $1,681 

Charger DMC All 2008/2010 $395 $316 $316 $253 $253 $253 $253 $253 $202 

Charger 

Labor DMC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Battery IC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $4,441 $4,289 $4,289 $4,167 $4,167 $4,167 $4,167 $4,167 $2,625 

2008 $4,354 $4,205 $4,205 $4,086 $4,086 $4,086 $4,086 $4,086 $2,573 

Battery IC Midsize 

PC/Perf PC 

2010 $5,222 $5,044 $5,044 $4,901 $4,901 $4,901 $4,901 $4,901 $3,087 

2008 $5,111 $4,936 $4,936 $4,796 $4,796 $4,796 $4,796 $4,796 $3,021 

Battery IC Large PC/Perf 

PC 

2010 $6,725 $1,717 $1,712 $1,708 $1,703 $1,699 $1,696 $1,693 $1,090 

2008 $6,555 $6,331 $6,331 $6,151 $6,151 $6,151 $6,151 $6,151 $3,874 

Nonbattery IC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $316 $315 $314 $313 $313 $312 $311 $311 $200 

2008 $272 $272 $271 $270 $269 $269 $268 $268 $172 

Nonbattery IC Midsize 

PC/Perf PC 

2010 $976 $973 $970 $968 $965 $963 $961 $960 $618 

2008 $890 $888 $885 $883 $881 $878 $877 $876 $563 

Nonbattery IC Large PC/Perf 

PC 

2010 $1,722 $18 $18 $18 $18 $18 $18 $18 $10 

2008 $1,602 $1,597 $1,593 $1,588 $1,584 $1,580 $1,578 $1,575 $1,014 

Charger IC All 2008/2010 $126 $121 $121 $117 $117 $117 $117 $117 $70 

Charger 

Labor IC All 2008/2010 $0 $0 $0 $0 $0 $0 $0 $0 $0 
 

404 

Battery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $14,765 $12,548 $12,548 $10,775 $10,775 $10,775 $10,775 $10,775 $7,911 

2008 $14,475 $12,302 $12,302 $10,563 $10,563 $10,563 $10,563 $10,563 $7,755 

Battery TC Midsize 

PC/Perf PC 

2010 $17,362 $14,755 $14,755 $12,670 $12,670 $12,670 $12,670 $12,670 $9,302 

2008 $16,992 $14,441 $14,441 $12,400 $12,400 $12,400 $12,400 $12,400 $9,104 

Battery TC Large PC/Perf 

PC 

2010 $22,359 $19,002 $19,002 $16,317 $16,317 $16,317 $16,317 $16,317 $11,980 

2008 $21,793 $18,521 $18,521 $15,903 $15,903 $15,903 $15,903 $15,903 $11,676 

Nonbattery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $726 $713 $700 $688 $676 $664 $657 $649 $532 

2008 $626 $615 $603 $593 $582 $572 $566 $559 $458 

Nonbattery TC Midsize 

PC/Perf PC 

2010 $2,243 $2,203 $2,163 $2,125 $2,087 $2,051 $2,028 $2,005 $1,642 

2008 $2,047 $2,010 $1,973 $1,938 $1,904 $1,871 $1,850 $1,829 $1,498 

Nonbattery TC Large PC/Perf 

PC 

2010 $3,959 $3,887 $3,817 $3,749 $3,683 $3,619 $3,578 $3,538 $2,897 

2008 $3,682 $3,615 $3,550 $3,487 $3,426 $3,367 $3,328 $3,291 $2,695 

Charger IC All 2008/2010 $521 $437 $437 $370 $370 $370 $370 $370 $272 

Charger 

Labor IC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Table V-104 NHTSA Costs Applied for EV100 in CAFE model with No Mass Reduction 

(2010$) 

Tech. Cost 

Type 

NHTSA 

Vehicle 

Class 

Baseline 

Fleet 2017 2018 2019 2020 2021 2022 2023 2024 2025 

Battery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$12,341 

$12,063 

$9,873 

$9,651 

$9,873 

$9,651 

$7,898 

$7,720 

$7,898 

$7,720 

$7,898 

$7,720 

$7,898 

$7,720 

$7,898 

$7,720 

$6,319 

$6,176 

Battery DMC Midsize 

PC/Perf PC 

2010 

2008 

$14,159 

$13,919 

$11,327 

$11,135 

$11,327 

$11,135 

$9,062 

$8,908 

$9,062 

$8,908 

$9,062 

$8,908 

$9,062 

$8,908 

$9,062 

$8,908 

$7,250 

$7,127 

Battery DMC Large PC/Perf 

PC 

2010 

2008 

$17,482

$17,025

 $13,985 

$13,620 

$13,985

$13,620

 $11,188

 $10,896

 $11,188

 $10,896

 $11,188 

$10,896 

$11,188 

$10,896 

$11,188 

$10,896 

$8,951 

$8,717 

Nonbattery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$410 

$354 

$398 

$343 

$386 

$333 

$375 

$323 

$363 

$313 

$352 

$304 

$345 

$298 

$338 

$292 

$332 

$286 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 

2008 

$1,267 

$1,156 

$1,229 

$1,122 

$1,193 

$1,088 

$1,157 

$1,055 

$1,122 

$1,024 

$1,088 

$993 

$1,067 

$973 

$1,045 

$954 

$1,024 

$935 

Nonbattery DMC Large PC/Perf 

PC 

2010 

2008 

$2,236 

$2,080 

$2,169 

$2,018 

$2,104 

$1,957 

$2,041 

$1,899 

$1,980 

$1,842 

$1,920 

$1,786 

$1,882 

$1,751 

$1,844 

$1,716 

$1,808 

$1,681 

Charger DMC All 2008/2010 $395 $316 $316 $253 $253 $253 $253 $253 $202 
 

 

405 

Charger 

Labor DMC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Battery IC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$5,309 

$5,189 

$5,127 

$5,012 

$5,127 

$5,012 

$4,982 

$4,870 

$4,982 

$4,870 

$4,982 

$4,870 

$4,982 

$4,870 

$4,982 

$4,870 

$3,138 

$3,067 

Battery IC Midsize 

PC/Perf PC 

2010 

2008 

$6,091 

$5,988 

$5,883 

$5,783 

$5,883 

$5,783 

$5,716 

$5,619 

$5,716 

$5,619 

$5,716 

$5,619 

$5,716 

$5,619 

$5,716 

$5,619 

$3,600 

$3,539 

Battery IC Large PC/Perf 

PC 

2010 

2008 

$7,520 

$7,324 

$7,263 

$7,073 

$7,263 

$7,073 

$7,057 

$6,873 

$7,057 

$6,873 

$7,057 

$6,873 

$7,057 

$6,873 

$7,057 

$6,873 

$4,445 

$4,329 

Nonbattery IC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$316 

$272 

$315 

$272 

$314 

$271 

$313 

$270 

$313 

$269 

$312 

$269 

$311 

$268 

$311 

$268 

$200 

$172 

Nonbattery IC Midsize 

PC/Perf PC 

2010 

2008 

$976 

$890 

$973 

$888 

$970 

$885 

$968 

$883 

$965 

$881 

$963 

$878 

$961 

$877 

$960 

$876 

$618 

$563 

Nonbattery IC Large PC/Perf 

PC 

2010 

2008 

$1,722 

$1,602 

$1,717 

$1,597 

$1,712 

$1,593 

$1,708 

$1,588 

$1,703 

$1,584 

$1,699 

$1,580 

$1,696 

$1,578 

$1,693 

$1,575 

$1,090 

$1,014 

Charger IC All 2008/2010 $126 $121 $121 $117 $117 $117 $117 $117 $70 

Charger 

Labor IC All 2008/2010 $0 $0 $0 $0 $0 $0 $0 $0 $0 

Battery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$17,650

$17,253

 $15,000 

$14,662 

$15,000

$14,662

 $12,880

 $12,590

 $12,880

 $12,590

 $12,880 

$12,590 

$12,880 

$12,590 

$12,880 

$12,590 

$9,457 

$9,244 

Battery TC Midsize 

PC/Perf PC 

2010 

2008 

$20,250

$19,907

 $17,210 

$16,918 

$17,210

$16,918

 $14,778

 $14,527

 $14,778

 $14,527

 $14,778 

$14,527 

$14,778 

$14,527 

$14,778 

$14,527 

$10,850 

$10,666 

Battery TC Large PC/Perf 

PC 

2010 

2008 

$25,002

$24,349

 $21,248 

$20,693 

$21,248

$20,693

 $18,245

 $17,769

 $18,245

 $17,769

 $18,245 

$17,769 

$18,245 

$17,769 

$18,245 

$17,769 

$13,396 

$13,046 

Nonbattery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 

2008 

$726 

$626 

$713 

$615 

$700 

$603 

$688 

$593 

$676 

$582 

$664 

$572 

$657 

$566 

$649 

$559 

$532 

$458 

Nonbattery TC Midsize 

PC/Perf PC 

2010 

2008 

$2,243 

$2,047 

$2,203 

$2,010 

$2,163 

$1,973 

$2,125 

$1,938 

$2,087 

$1,904 

$2,051 

$1,871 

$2,028 

$1,850 

$2,005 

$1,829 

$1,642 

$1,498 

Nonbattery TC Large PC/Perf 

PC 

2010 

2008 

$3,959 

$3,682 

$3,887 

$3,615 

$3,817 

$3,550 

$3,749 

$3,487 

$3,683 

$3,426 

$3,619 

$3,367 

$3,578 

$3,328 

$3,538 

$3,291 

$2,897 

$2,695 

Charger IC All 2008/2010 $521 $437 $437 $370 $370 $370 $370 $370 $272 

Charger 

Labor IC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 
 

406 

Table V-105 NHTSA Costs Applied for EV150 in CAFE model with No Mass Reduction 

(2010$) 

Tech. Cost 

Type 

NHTSA 

Vehicle 

Class 

Baseline 

Fleet 2017 2018 2019 2020 2021 2022 2023 2024 2025 

Battery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $16,369 $13,095 $13,095 $10,476 $10,476 $10,476 $10,476 $10,476 $8,381 

2008 $15,939 $12,751 $12,751 $10,201 $10,201 $10,201 $10,201 $10,201 $8,161 

Battery DMC Midsize 

PC/Perf PC 

2010 $19,585 $15,668 $15,668 $12,534 $12,534 $12,534 $12,534 $12,534 $10,028 

2008 $19,240 $15,392 $15,392 $12,313 $12,313 $12,313 $12,313 $12,313 $9,851 

Battery DMC Large 

PC/Perf PC 

2010 $22,552 $18,042 $18,042 $14,433 $14,433 $14,433 $14,433 $14,433 $11,547 

2008 $21,936 $17,549 $17,549 $14,039 $14,039 $14,039 $14,039 $14,039 $11,231 

Nonbattery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $410 $398 $386 $375 $363 $352 $345 $338 $332 

2008 $355 $344 $334 $324 $314 $305 $299 $293 $287 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 $1,267 $1,229 $1,193 $1,157 $1,122 $1,088 $1,067 $1,045 $1,024 

2008 $1,157 $1,123 $1,089 $1,056 $1,025 $994 $974 $954 $935 

Nonbattery DMC Large 

PC/Perf PC 

2010 $2,236 $2,169 $2,104 $2,041 $1,980 $1,920 $1,882 $1,844 $1,808 

2008 $2,082 $2,019 $1,959 $1,900 $1,843 $1,788 $1,752 $1,717 $1,682 

Charger DMC All 2008/2010 $395 $316 $316 $253 $253 $253 $253 $253 $202 

Charger 

Labor DMC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Battery IC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $7,042 $6,801 $6,801 $6,608 $6,608 $6,608 $6,608 $6,608 $4,162 

2008 $6,857 $6,622 $6,622 $6,434 $6,434 $6,434 $6,434 $6,434 $4,053 

Battery IC Midsize 

PC/Perf PC 

2010 $8,425 $8,137 $8,137 $7,906 $7,906 $7,906 $7,906 $7,906 $4,980 

2008 $8,277 $7,993 $7,993 $7,767 $7,767 $7,767 $7,767 $7,767 $4,892 

Battery IC Large 

PC/Perf PC 

2010 $9,702 $9,370 $9,370 $9,104 $9,104 $9,104 $9,104 $9,104 $5,734 

2008 $9,437 $9,114 $9,114 $8,855 $8,855 $8,855 $8,855 $8,855 $5,578 

Nonbattery DMC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $316 $315 $314 $313 $313 $312 $311 $311 $200 

2008 $273 $273 $272 $271 $270 $270 $269 $269 $173 

Nonbattery DMC Midsize 

PC/Perf PC 

2010 $976 $973 $970 $968 $965 $963 $961 $960 $618 

2008 $891 $889 $886 $884 $881 $879 $878 $876 $564 

Nonbattery DMC Large 

PC/Perf PC 

2010 $1,722 $1,717 $1,712 $1,708 $1,703 $1,699 $1,696 $1,693 $1,090 

2008 $1,603 $1,598 $1,594 $1,590 $1,585 $1,581 $1,579 $1,576 $1,014 
                                                      

 

407 

Charger IC All 2008/2010 $126 $121 $121 $117 $117 $117 $117 $117 $70 

Charger 

Labor IC All 2008/2010 $0 $0 $0 $0 $0 $0 $0 $0 $0 

Battery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $23,411 $19,896 $19,896 $17,084 $17,084 $17,084 $17,084 $17,084 $12,543 

2008 $22,796 $19,373 $19,373 $16,635 $16,635 $16,635 $16,635 $16,635 $12,214 

Battery TC Midsize 

PC/Perf PC 

2010 $28,010 $23,805 $23,805 $20,441 $20,441 $20,441 $20,441 $20,441 $15,007 

2008 $27,517 $23,385 $23,385 $20,080 $20,080 $20,080 $20,080 $20,080 $14,743 

Battery TC Large 

PC/Perf PC 

2010 $32,254 $27,411 $27,411 $23,537 $23,537 $23,537 $23,537 $23,537 $17,281 

2008 $31,372 $26,662 $26,662 $22,894 $22,894 $22,894 $22,894 $22,894 $16,809 

Nonbattery TC 

Subcompact 

PC/Perf PC 

Compact 

PC/Perf PC 

2010 $726 $713 $700 $688 $676 $664 $657 $649 $532 

2008 $628 $617 $606 $595 $585 $574 $568 $561 $460 

Nonbattery TC Midsize 

PC/Perf PC 

2010 $2,243 $2,203 $2,163 $2,125 $2,087 $2,051 $2,028 $2,005 $1,642 

2008 $2,048 $2,011 $1,975 $1,940 $1,906 $1,873 $1,852 $1,831 $1,499 

Nonbattery TC Large 

PC/Perf PC 

2010 $3,959 $3,887 $3,817 $3,749 $3,683 $3,619 $3,578 $3,538 $2,897 

2008 $3,685 $3,618 $3,552 $3,489 $3,428 $3,369 $3,330 $3,293 $2,697 

Charger IC All 2008/2010 $521 $437 $437 $370 $370 $370 $370 $370 $272 

Charger 

Labor IC All 2008/2010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 $1,010 

Vehicle Technologies 

Mass Reduction 

From 1987-2011, there has been a generally increasing trend in the weight of the light duty 

vehicle fleet as shown in Figure V-37 from EPA’s Fuel Economy Trends Report298. A number 

of factors have contributed to this weight increase, including the choices of manufacturers and 

consumers to build and purchase larger vehicles, including heavier trucks, SUVs, and CUVs. 

Also contributing to this weight increase has been an increase in vehicle content including: safety 

features (air bags, antilock brakes, energy absorbent and intrusion resistant vehicle structures, 

etc.), noise reduction (additional damping material), added comfort and convenience features (air 

298 “Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 Through 

2011”, EPA420-R-12-001a, U.S. Environmental Protection Agency Office of Transportation and Air Quality, March 

2012 
5000 

Trucks 

Both Cars 

Vehicle test weight (lb) 4500 

4000 

3500 

3000 

1975 1980 1985 1990 1995 2000 2005 2010 

Model year 

24 16

acceleration 

fuel economy 

Adjusted fuel economy (mpg) 

Acceleration, 0-60 mph (sec) 

22 

20 

15

14

18 13

16 12

14 11

12 10

10 9

8 8

1975 1980 1985 1990 1995 2000 2005 2010 

Model year 

408 

conditioning, power locks and windows), luxury features (infotainment systems, powered seats), 

etc. 

Figure V-37 Light duty fleet weight trends: 1975-2011 

Despite this increase in weight, the average acceleration of vehicles has grown steadily faster 

without any marked or consistent reduction in fuel economy since 1987, as shown in Figure 

V-38. This combination of increased vehicle performance, stable fuel economy, and increased 

vehicle weight has been partially enabled by the development and adoption of more efficient 

technologies, especially in engines and transmissions. The impressive improvements in 

powertrain efficiency during this period have offset increases in energy consumption that result 

from improvements in weight carrying, towing and volume capacities, safety, consumer features, 

vehicle refinement, and acceleration performance. 

Figure V-38 Light duty fleet trends for acceleration and fuel economy: 1975-2011 
                                                      

409 

Figure V-39 U.S. Vehicle Fatality Rates for the past 60 years299 

Vehicle mass reduction (also referred to as “down-weighting” or ‘light-weighting”), reduces the 

energy needed to overcome inertial forces, thus yielding lower fuel consumption and GHG 

emissions. While keeping everything else constant, a lighter vehicle will require less energy to 

operate than a heavier vehicle. Mass reduction can be achieved through a number of approaches 

described below, even while maintaining vehicle size. Alternatively, mass reduction can also be 

achieved by vehicle “downsizing” which involves reducing vehicle exterior dimensions, such as 

shifting from a midsize vehicle to a compact vehicle. Consistent with the proposal, the agencies 

did not analyze downsizing as a mass reduction strategy in this analysis for the final rule. In 

part, this is because a manufacturer’s ability to downsize its vehicles is constrained by consumer 

preferences (such as for interior passenger or cargo volume), which are in turn influenced by 

many factors that are difficult to predict in the future, such as the consumer’s utility needs, fuel 

prices, economic conditions, etc. Also, the final CAFE and GHG emission standards are based 

on vehicle footprint (the area bounded by where the four tires contract the ground), and generally 

assign higher fuel economy targets (and lower CO2 emission targets) for vehicles with smaller 

footprints and lower fuel economy targets (and higher CO2 emission targets) for vehicles with 

larger footprints. As discussed in Chapter 2 of the joint TSD, the agencies believe the shape of 

the footprint-based target curves will not create incentives for manufacturers to either upsize or 

downsize their vehicles. Based on these considerations, the agencies are assuming that 

manufacturers will favor mass reduction through material substitution, design optimization, and 

adopting other advanced manufacturing technologies rather than compromising a vehicle’s 

299 Adrian Lund, IIHS, “The Relative Safety of Large and Small Passenger Vehicles.” Available at 

http://www.nhtsa.gov/staticfiles/rulemaking/pdf/MSS/MSSworkshop-Lund.pdf (last accessed Jun. 10, 2012). 
                                                      

 

410 

attributes and functionality, such as occupant or cargo space, vehicle safety, comfort, 

acceleration, etc. Consequently, the compliance paths the agencies have investigated for the 

promulgated standards do not include downsizing. 

Mass reduction has an important relationship with vehicle powertrain selection and sizing. 

Vehicle powertrain selection depends on an OEM’s product strategy, and may include a variety 

of options such as naturally aspirated engines, boosted and downsized gasoline engines, diesel 

engines, or vehicle electrification (P/H/EV). Regardless of the strategy selected, vehicle mass 

reduction for non-powertrain systems is an important enabler to further reduce vehicle fuel 

consumption and reduce the size of the powertrain system. The term “glider” refers to a 

complete vehicle minus the powertrain. Figure V-40 illustrates the mass breakdown by system 

for a typical vehicle300. The non-powertrain systems normally account for 75 percent of vehicle 

weight. The agencies have accounted for some of the costs of engine mass reduction when 

applying engine downsizing technologies. The agencies have also accounted for the amount of 

mass change due to the application of hybrid and electrification technologies in the vehicle 

electrification sections. Therefore, this section focuses on both the mass reduction of the glider as 

well as mass reduction technologies that are specifically targeted at reducing the weight of the 

powertrain301 rather than on mass reduction resulting from powertrain efficiency improvements. 

An example of a mass reduction technology for the powertrain that is not related to powertrain 

efficiency improvement is material substitution, such as changing the engine block from cast iron 

to aluminum or changing the size of the fuel tank). Mass reduction is calculated for both the 

glider and the vehicle including powertrain in the studies sponsored by the agencies as shown 

later in this section. 

300 Lutsey, “Review of technical literature and trends related to automobile mass-reduction technology”, UCD-ITSRR-10-10, May 2010 . Available at http://pubs.its.ucdavis.edu/publication_detail.php?id=1390 (last accessed Jun. 

10, 2012).

301 Rather than on mass reduction resulting from powertrain efficiency improvements, such as in the case of adding a 

turbocharger to a downsized engine.
 
411 

Figure V-40 Vehicle system mass approximation 

A vehicle can be divided into 6 major systems, which are shown in Figure V-40. Mass reduction 

can potentially be applied to any of a vehicle’s subsystems, including the engine, exhaust system, 

transmission, chassis, suspension, brakes, body, closure panels, glazing, seats and other interior 

components, engine cooling systems, and HVAC systems. While manufacturers may reduce the 

mass of some individual components during a vehicle refresh, they generally undertake larger 

amounts of mass reduction systematically and more broadly across all vehicle systems when 

redesigning a vehicle. In the redesign process, OEMs normally set weight targets by 

benchmarking other vehicles in the same segment and projecting weight trends into the future, 

and then identifying targets for all components and subsystems that support achieving the target. 

The agencies believe this holistic approach, which takes into consideration all secondary mass 

savings, is likely the most effective way for OEMs to achieve large amounts of mass reduction. 

During a vehicle redesign where mass reduction is a strategic vehicle program goal, OEMs can 

consider modular systems design, secondary mass effects, multi-material concepts, and new 

manufacturing processes to help optimize the design. There are several studies in the public 

domain that illustrate the potential for these approaches to achieve significant amounts of mass 

reduction, although it is important to also recognize that the studies use some assumptions that 

do not account for some of the considerations that are important to manufacturers. One example 

is the need to share components across platforms to manage cost and part complexity for 

assembly and service, which limits the ability to optimize the amount of mass reduction on every 

vehicle component. Care must also be taken in any study to assure that vehicle functionality and 

performance, such as stiffness, NVH, safety and vehicle dynamics, continue to meet 

manufacturer objectives and consumer demands. It is important for design studies to use tools 

such as simulation modeling to assess the design’s ability to meet functionality and performance 

targets. In this rulemaking, the agencies have targeted to preserve vehicle function and 

performance in their analysis of mass reduction. An example of this approach is illustrated in 
 

                                                       

412 

Figure V-25, which summarizes the results of the phase I Lotus Engineering mass reduction 

study of a Toyota Venza. 

Mass-reduction  Redesign conventional mid-size vehicle for mass optimization, with two redesign architectures 

features, findings  Low Development vehicle technology with industry-leading manufacturing techniques that were 

deemed feasible for 2014 (for model year 2017 production) for assembly at existing facilities 

 High Development vehicle technology, with modifications to conventional joining and assembly 

processes that were deemed feasible for 2017 (for model year 2020) production 

 Extensive use of material substitution with high-strength steel, advanced high–strength steel, 

aluminum, magnesium, plastics and composites throughout vehicles 

 Conservative use of emerging design and parts integration concepts to minimize technical risk 

 Using synergistic total vehicle substantial mass reduction opportunities found at minimized piece costs 

 The Low Development vehicle was found to have likely piece cost reductions, whereas the High 

Development vehicle had nominal estimated cost increase of 3% (with potential for cost reduction) 

Mass-reduction 

impact 

 Body structure reduction for Low Development Vehicle: 55 lb (6.6%) 

 Body structure reduction for High Development Vehicle: 356 lb (42%) 

 Overall glider reduction for Low Development Vehicle: 538 lb (19%) 

 Overall glider reduction for High Development Vehicle: 1096 lb (39%) 

 Overall vehicle reduction for Low Development Vehicle (with hybrid powertrain): 657 lb (17.6%) 

 Overall vehicle reduction for High Development Vehicle (with hybrid powertrain): 1209 lb (32%) 

Status  Engineering design study conducted by Lotus Engineering 

 First phase of project, development of two mass-reduced vehicle designs completed in April 2010 

 Second phase to test structural integrity, impact load paths, crash worthiness to validate the vehicle 

designs. 

Source  Lotus Engineering, Inc. 2010. An Assessment of Mass Reduction Opportunities for a 2017-2020 

Model Year 

Illustrations 

Figure V-41 Example of a holistic vehicle redesign study from Lotus Engineering302 

Mass reduction can be considered in terms of the “percent by which the redesigned vehicle is 

lighter than the previous version,” recognizing that the value likely represents both “primary” 

mass reduction (that which the manufacturer set out to make lighter), and “secondary” mass 

reduction (from ancillary systems and components that can now be lighter due to the primary 

mass reductions). 

As summarized by NAS in its 2011 report,303 there are two key strategies for primary mass 

reduction: 1) changing the design to use less material or 2) substituting lighter materials for 

heavier materials. The first key strategy of using less material compared to the baseline 

302 Lotus Engineering, Inc. “An Assessment of Mass Reduction Opportuties for a 2017-2020 Model Year Vehicle 

program”, March 2010, Docket EPA-HQ-OAR-2010-0799 or NHTSA-2010-0131-0099. 

303 Committee on the Assessment of Technologies for Improving Light-Duty Vehicle Fuel Economy; National 

Research Council, “Assessment of Fuel Economy Technologies for Light-Duty Vehicles”, 2011. Available at 

http://www.nap.edu/catalog.php?record_id=12924 (last accessed Jun 27, 2012). 
 

 

                                                       

 

413 

component can be achieved by optimizing the design and structure of the component, system or 

vehicle structure. For example, a number of “body on frame” vehicles have been redesigned with 

a lighter “unibody” construction, eliminating components, reducing the weight of the body 

structure, and resulting in significant reductions in overall mass and related costs. The unibody 

design currently dominates the passenger car segment and has increased penetration into what 

used to be mostly body-on-frame vehicles, such as SUVs. This technique was used in the 2011 

Ford Explorer redesign, which also employed the extensive use of high strength steels.304 Figure 

V-42 depicts body-on-frame and unibody designs for two sport utility vehicles. 

Figure V-42 Illustration of Body-on-Frame (BoF) and Unibody vehicle construction 

To further reduce mass inefficiencies in vehicle design, vehicle manufacturers are using 

continually-improving Computer Aided Engineering (CAE) tools. For example, the Future Steel 

Vehicle (FSV) project305 sponsored by WorldAutoSteel used three levels of optimization: 

topology optimization, low fidelity 3G (Geometry Grade and Gauge) optimization, and subsystem optimization, to achieve 30 percent mass reduction in the body structure of a vehicle 

with a mild steel unibody structure (see Figure V-43). Designs similar to those proposed in the 

FSV project have been applied in production vehicles, such as the B-pillar of 2010 Ford 

Focus.306 

304 Ford Sustainability Report 2010/11, http://corporate.ford.com/microsites/sustainability-report-2010-11/issuesclimate-plan-economy (last accessed Aug. 26, 2011) 305 ETA, US Steel, Tata Steel, “The ACP ProcessTM as Applied to the Future Steel Vehicle”, Docket NHTSA-2010­

0131”, http://www.eta.com/index.php/engineering/product-design-development/the-acp-process/success-stories/181­

the-acp-process-as-applied-to-the-future-steel-vehicle- (last accessed Aug. 2, 2012) 306 SAE World Congress, “Focus B-pillar ‘tailor rolled’ to 8 different thicknesses,” Feb. 24, 2010. Available at 

http://www.sae.org/mags/AEI/7695 (last accessed Jun. 10, 2012). 
414 

Figure V-43 Example of vehicle body load path mapping for mass optimization 

Vehicle manufacturers have long used these continually-improving CAE tools to optimize 

vehicle designs. But because any design must meet component and system functionality and 
 

                                                      

415 

manufacturability targets, there are practical limitations to the amount of additional mass 

reduction that can be achieved through optimization. For example, an optimization program 

would need to account for safety, stiffness, NVH, manufacturing, and other requirements to 

assure the design is suitable for its intended function and for mass production. Additionally, 

ultimate optimization of vehicle design for mass reduction may be limited by an OEM’s use of 

shared components and common platform for multiple vehicle models. While optimization may 

concentrate on the vehicle that has the largest production volume for a platform, designs must 

also support the most demanding functional requirements of all of the vehicles that share that 

platform, or those functional requirements will not be met. In addition, the engineering resources 

and capital for tooling and equipment that would be needed to optimize every vehicle component 

at each redesign affects the ability to fully optimize a new vehicle to achieve all of the 

theoretically possible secondary mass reduction. Therefore, some level of mass inefficiency will 

inherently exist on many or all of the vehicles that share a platform. The agencies sought 

comment and information in the NPRM on the degree to which shared vehicle components and 

architectures affect the feasible amount of mass reduction and the cost for mass reduction 

relative to what could be achieved if mass reduction was optimized for a single vehicle design. 

Volkswagen confirmed in its comments that with platform sharing, “a weight reduction 

technology which may be acceptable in terms of price or performance for one model may disrupt 

the economics or utility of another.”307 

Using less material can also be achieved through improving the manufacturing process, such as 

by using improved joining technologies and parts consolidation. This method is often used in 

combination with applying new materials. For example, more precise manufacturing techniques 

such as laser welding may reduce the flange size necessary for welding, and thus marginally 

decrease the mass of an assembly. Also, when complex assemblies are constructed from fewer 

pieces, the mass of the assembly tends to be lower. However, while synergies in mass reduction 

certainly exist, and while certain technologies can enable one another (e.g., parts consolidation 

and molding of advanced composites), others may be incompatible (e.g., laser welding and 

magnesium casting). 

The second key strategy to reduce mass of an assembly or component involves the substitution 

of lower density and/or higher strength materials. Table V-106 shows material usage typical of 

contemporary high-volume vehicles. Material substitution includes replacing materials, such as 

mild steel, with higher-strength and advanced steels, aluminum, magnesium, and composite 

materials. The substitution of advanced high strength steel (AHSS) for mild steel can reduce the 

mass of a strength-critical part because the gauge of the AHSS components can be reduced, 

despite the fact that the densities of the materials are not significantly different. Aluminum has 

also been used over the years in a variety of components, such as vehicle closures, suspension 

307 VW comments, NHTSA-2010-0131-0247, at page 16 
                                                      

416 

parts, engine cradles, etc. Aluminum has one third the density of steel and therefore can provide 

a notable amount of mass reduction. Changing parts from steel to aluminum generally requires 

part redesign, and extra material may have to be added for strength or durability. Aluminum also 

has a shorter fatigue life than steel and therefore the alloy selected and the application must be 

carefully considered. Magnesium can provide additional mass reduction as it has lower density 

than aluminum. It has been used for instrument panel cross-car beams by several OEMs for a 

number of years. It has also been used in an engine block produced by BMW for several years. 

Its brittle nature must be considered, however, when selecting the alloy and the application 

within the vehicle. 

Table V-106 Distribution of Material in Typical Contemporary Vehicles (e.g., Toyota 

Camry or Chevrolet Malibu)308
 

Automobiles also utilize a wide range of plastic types, including polypropylenes, polyesters, and 

vinyl esters. These materials are utilized in hatches, roofs, interior panels, instrument panels, and 

hundreds of other parts. Although primarily used in nonstructural vehicle components, plastics 

have continued to make in-roads in bumper systems and in composite beam applications, and 

some studies have found potential to supplant structural beams and frame components. Lighter 

plastics have also been developed by the industry, and the application of these materials has been 

increasing. 

Included in the category of plastics are composites like glass fiber and carbon fiber reinforced 

polymers. While these more costly advanced materials have primarily been used in a limited 

number of low production volume vehicle applications, some manufacturers are considering 

these composites for broader use. While these materials currently have the potential to be 

applied to components with little or no exposure to impact pulses, the advanced microstructure 

and limited industry experience may make these longer-term solutions. For example, advanced 

composite materials (such as carbon fiber-reinforced plastic), depending on the specific fiber, 

matrix, reinforcement architecture, and processing method, can be subject to dozens of 

competing damage and failure mechanisms that may complicate a manufacturer’s ability to 

ensure equivalent levels of durability and crashworthiness. As the industry gains experience with 

308 Committee on the Assessment of Technologies for Improving Light-Duty Vehicle Fuel Economy; National 

Research Council, “Assessment of Fuel Economy Technologies for Light-Duty Vehicles”, 2011, Docket NHTSA2010-0131-0100. Also available at http://www.nap.edu/catalog.php?record_id=12924 (last accessed Jun 27, 2012). 
417 

these materials, these concerns will inevitably diminish, but may remain relevant during the 

timeframe of this final rulemaking. 

In practice, material substitution tends to be quite specific to the manufacturer and situation. 

Some materials work better than others for particular vehicle components, and a manufacturer 

may invest more heavily in adjusting to a particular type of advanced material, thus complicating 

its ability to consider others. The agencies recognize that like any type of mass reduction, 

material substitution has to be conducted not only with consideration to maintaining equivalent 

component strength, but also to maintaining all the other attributes of that component, system or 

vehicle, such as crashworthiness, durability, and noise, vibration and harshness (NVH). 

If vehicle mass is reduced sufficiently through application of the two primary strategies of using 

less material and material substitution described above, secondary mass reduction options may 

become available. Secondary mass reduction is enabled when the load requirements of a 

component are reduced as a result of primary mass reduction. If the primary mass reduction 

reaches a sufficient level, a manufacturer may use a smaller, lighter, and potentially more 

efficient powertrain while maintaining vehicle acceleration performance. If a powertrain is 

downsized, approximately half of the mass reduction may be attributed to the reduced torque 

requirement which results from the lower vehicle mass. The lower torque requirement enables a 

reduction in engine displacement, changes to transmission torque converter and gear ratios, and 

changes to final drive gear ratio. The reduced powertrain torque enables the downsizing and/or 

mass reduction of powertrain components and accompanying reduced rotating mass (e.g., for 

transmission, driveshafts/halfshafts, wheels, and tires) without sacrificing powertrain durability. 

Likewise, the combined mass reductions of the engine, drivetrain, and body in turn reduce 

stresses on the suspension components, steering components, wheels, tires, and brakes, which 

can allow further reductions in the mass of these subsystems. Reducing the unsprung masses 

such as the brakes, control arms, wheels, and tires further reduce stresses in the suspension 

mounting points, which will allow for further optimization and potential mass reduction. 

Secondary mass reduction can occur for each kilogram of primary mass reduction, when all 

subsystems are redesigned to take the initial primary mass reduction into account. In the MYs 

2012-2016 rulemaking analysis, the agencies assumed that 1 kg of primary mass reduction could 

enable up to 1.25 kg of secondary mass reduction. In the two most recent mass reduction 

projects by EPA and NHTSA, every 1 kg of primary mass reduction enabled 0.7 kg of secondary 

mass reduction. We note that these estimates may not be applicable in all real-world instances of 

mass reduction, and that the literature indicates that the amount of secondary mass reduction 

potentially available varies significantly from an additional 0.5 kg to 1.25 kg per 1 kg of primary 

mass reduction, depending on assumptions such as which components or systems primary mass 
                                                      

 

418 

reduction is applied to, and whether the powertrain is available for downsizing.309,310,311 The 

amount of secondary mass reduction is also affected by the degree of component sharing that 

occurs among a manufacturer’s models. Component sharing is used by manufacturers to achieve 

production economies of scale that affect cost and the number of unique parts that must be 

managed in production and for service. In addition, the engineering resources and capital for 

tooling and equipment that would be needed to optimize every vehicle component at each 

redesign affects the ability to fully optimize a new vehicle to achieve all of the theoretically 

possible secondary mass reduction. While there is agreement in the literature that primary mass 

reduction can enable secondary mass reduction, the agencies recognize that care must be taken 

when reviewing reports on mass reduction methods and practices to ascertain the manner and 

extent to which compounding effects have been considered. 

All manufacturers are using some or all of these methods to reduce mass in the vehicles they are 

producing today, and the agencies expect that the industry will continue to learn and improve the 

application of these techniques for more vehicles during the rulemaking timeframe. We consider 

mass reduction in net percentage terms in our analysis not only because effectively determining 

specific appropriate mass reduction methods for each vehicle in the baseline fleet is a large task 

beyond the scope of this rulemaking, but also because we recognize that even as manufacturers 

reduce mass to make vehicles more efficient, they may also be adding mass in the form of 

increased vehicle features and safety content in response to market forces and other 

governmental regulations. For these reasons, when the agencies discuss the amount of mass 

reduction that we are assuming is feasible for purposes of our analysis, we are implicitly 

balancing both the considerable opportunities that we believe exist for mass reduction in the 

future, and the reality that vehicle manufacturing is complex and that mass reduction methods 

must be applied thoughtfully and judiciously as safety and content demands on vehicles continue 

to increase over time. Despite our considerable discussion of the topic, the agencies’ application 

of mass reduction in our analysis is fairly simplified. As applied in our models, the percentage 

reduction for a given vehicle that is assumed for a given year is an abstraction of all the specific 

mass reduction methods described above. 

How much mass reduction do the agencies believe is feasible in the rulemaking timeframe? 

309 Malen, E. and K. Reddy, “Preliminary Vehicle Mass Estimation Using Empirical Subsystem Influence 

Coefficients,” Auto-Steel Partnership Report, May 2007. Docket NHTSA-2010-0131. Available at http://www.asp.org/~/media/Files/Autosteel/Research/Lightweighting/mass_compoundingpdf.ashx (last accessed Jun. 27, 2012). 310 Bull, M., R. Chavali, A. Mascarin, “Benefit Analysis: Use of Aluminum Structures in “Conjunction with
 

Alternative Powertrain Technologies in Automobiles,” Aluminum Association Research Report, May 2008. Docket 

NHTSA-2010-0131-0097. Available at http://aluminumintransportation.org/downloads/IBIS-Powertrain-Study.pdf 

(last accessed Aug. 17, 2011). 

311 Bjelkengren, C, “The Impact of Mass Decompounding on Assessing the Value of Vehile Lightweighting”, 

Docket NHTSA-2010-0131, Available at http://msl.mit.edu/theses/Bjelkengren_C-thesis.pdf (last accessed Aug 3, 

2012). 
                                                      

 

 

 

419 

Feasibility, if narrowly defined as the ability to reduce mass without any constraints, is nearly 

unbounded. However, in practice, the feasible amount of mass reduction is affected by other 

considerations. Cost effectiveness is one of those constraints and is discussed further below in 

the mass reduction cost section. In the analysis for the current rulemaking for MYs 2017-2025, 

the agencies reviewed a number of public reports and accompanying data, as well as confidential 

information from manufacturers, and believe that mass reduction of up to 20 percent from a MY 

2008 baseline vehicle can be achieved in a cost effective manner using technologies currently in 

production. More detail on studies reviewed by the agencies and additional studies currently in 

progress by the agencies is located below in Table V-115 and in the paragraphs under the 

question “What additional studies are the agencies conducting to inform our estimates of mass 

reduction amounts, cost, and effectiveness?” 

From a general planning perspective, nearly all automakers have made some public statement 

regarding vehicle mass reduction being a core part of the overall technology strategy that they 

will utilize to achieve future fuel economy and CO2 emission standards. 

- Estimates from Ducker Worldwide indicate that the automobile industry will see an 

annual increase in AHSS of about 10% through 2020312. 

- Ford has stated that it intends to reduce the weight of its vehicles by 250-750 lb per 

model from 2011 to 2020313. For context, the midpoint of that range of reductions 

would correspond to a 12% reduction from the current Ford new light-duty vehicle 

sales fleet. 

- Mazda has released a statement about achieving a 220-lb reduction per vehicle by 

2016314. This is equivalent to about a 6% reduction for the company’s current fleet. 

- Land Rover executives have stated that the company remains committed to a goal of 

reducing curb weights of its SUVs by as much as 500 kilograms over the next 10 

315 years . 

- In its comment to the NPRM, Volkswagen stated that they expect to reduce the mass 

of their vehicles by 7-10% on average during the period of this regulation. 

312 American Iron and Steel Institute (AISI), 2009. “New Study Finds Increased Use of Advanced High-Strength 

Steels Helps Decrease Overall Vehicle Weight.” Docket NHTSA-2010-0131. Available at 

http://www.steel.org/en/sitecore/content/Global/Document%20Types/News/2009/Auto%20­

%20New%20Study%20Finds%20Increased%20Use%20of%20Advanced%20High-Strength%20Steels.aspx (last 

accessed on Aug 3, 2012). 

313 Ford, 2010. “The 5.0Liter is Back: 2011 Ford Mustang GT Leads Class with 412 HP, Fuel Efficiency, Chassis 

Dynamics.” Docket NHTSA-2010-0131. Available at http://media.ford.com/article_display.cfm?article_id=31645 

(last accessed Aug. 3, 2012). 

314 Information copied from http://www.mazda.com/csr/environment/making_car/ weight_reduction.html and 

docketed. EPA-HQ-OAR-2010-0799. 

315 The New York Times, “Automakers Resolve to Drop a Few pounds”, Sept 2011. 

http://www.nytimes.com/2011/09/18/automobiles/autoshow/in-frankfurt-automakers-vow-to-drop-a-fewpounds.html?_r=1&smid=tw-nytimeswheels&seid=auto EPA Docket EPA-HQ-OAR-2010-0799. 
 

 

 

 

 

420 

Several reports focusing on the OEM’s approaches for light weighting are summarized in the 

University of California Davis study as shown Table V-107. 

Table V-107 Automaker industry statements regarding plans for vehicle mass-reduction 

technology 

Affiliation Quote Source 

General 

Motors 

”We use a lot of aluminum today – about 300 pounds per vehicle - and are likely to 

use more lightweight materials in the future” 

Keith, 2010 

Ford “The use of advanced materials such as magnesium, aluminum and ultra highstrength boron steel offers automakers structural strength at a reduced weight to help 

improve fuel economy and meet safety and durability requirements” 

BMW and 

SGL, 2010 

Nissan “We are working to reduce the thickness of steel sheet by enhancing the stregnth, 

expanding the use of aluminum and other lightweight materials, and reducing vehicle 

weight by rationalizing vehicle body structure” 

Goede et al, 

2009 

BMW “Lightweight construction is a core aspect for sustainable mobility improving both 

fuel consumption and CO2 emissions, two key elements of our Efficient Dynamics 

strategy ... we will be able to produce carbon fiber components in large volumes at 

competitive costs for the first time. This is particularly relevant for electric-powered 

vehicles.” 

Nunez, 2009 

Volkswagen “Material design and manufacturing technologies remain key technologies in vehicle 

development. Only integrated approaches that work on these three key technologies 

will be successful in the future. In addition to the development of metals and light 

metals, the research on fibre-reinforced plastics will play a major role.” 

Goede et al, 

2009 

 Fiat “A reduction of fuel consumption attains big importance because of the possible 

economical savings. In order to achieve that, different ways are followed: alternative 

engine concepts (for example electric engines instead of combustion ones) or weight 

reduction of the vehicle structure. Using lightweight materials and different joining 

techniques hleps to reach this aim” 

Nunez, 2009 

Volkswagen “Lightweight design is a key measure for reducing vehicle fuel consumption along 

with powertrain efficiency, aerodynamics and electrical power management” 

Krinke, 2009 

BMW “A dynamic vehicle with a low fuel consumption finally demands a stiff body with a 

low weight. To achieve the initially mentioned targets, it is therefore necessary to 

design a body which offers good stiffness values and a high level of passive safety at 

a low weight.” 

Prestorf, 

2009 

BMW “Light weight design can be achieved by engineering light weight, manufacutring 

light weight and material light weight design.” 

Prestorf, 

2009 

Although the focus on mass reduction by manufacturers is widespread, the agencies believe the 

practical limits of mass reduction will be different for each vehicle model as each model starts 

with a different mix of conventional and advanced materials, components, and features intended 
421 

to meet the function and price of a particular market segment. A vehicle that already has a 

significant fraction of advanced high strength steel (AHSS) or any other advanced material in its 

structure, for example, will not have the opportunity to realize the same percentage of mass 

reduction as a vehicle of more traditional construction. Given the myriad methods of achieving 

mass reduction, and the difficulty in obtaining data, accounting for the current level of mass 

reduction technology for every model in production in a baseline model year would be an 

impractical task. However, the agencies believe that reducing vehicle weight to reduce fuel 

consumption has a continuum of solutions and the technologies employed will have levels of 

effectiveness and feasibility that will vary by manufacturers and by vehicle. 

What was the agency’s methodology for estimating safety effects for the final rule? 

As explained in preamble section II.G, the agencies consider the latest 2012 statistical analysis of 

historical crash data by NHTSA to represent the best estimates of the potential relationship 

between mass reduction and fatality increases in the future fleet. This section discusses how the 

agencies used NHTSA’s 2012 analysis to calculate specific estimates of safety effects of the final 

rule, based on the analysis of how much mass reduction manufacturers might use to meet the 

final rule. 

The CAFE/GHG standards do not mandate mass reduction or require that mass reduction occur 

in any specific manner. However, mass reduction is one of the technology applications available 

to the manufacturers and a degree of mass reduction is used by both agencies’ models to 

determine the capabilities of manufacturers and to predict both cost and fuel 

consumption/emissions impacts of more stringent CAFE/GHG standards. To estimate the 

amount of mass reduction to apply in the rulemaking analysis, the agencies considered fleet 

safety effects for mass reduction. The agencies use the results from the Kahane studies to analyze 

the fleet safety effect of mass reduction. The Kahane studies are discussed in details in Chapter 

IX of this FRIA. As shown in Table IX-1 and Table IX-2 in Chapter IX, , both the Kahane 2011 

preliminary report and the Kahane 2012 final report show that applying mass reduction to CUVs 

and light duty trucks will generally decrease societal fatalities, while applying mass reduction to 

passenger cars will increase fatalities. The CAFE model uses coefficients from the Kahane study 

along with the mass reduction level applied to each vehicle model to project societal fatality 

effects in each model year. NHTSA used the CAFE model and conducted iterative modeling 

runs varying the maximum amount of mass reduction applied to each subclass in order to 

identify a combination that achieved a high level of overall fleet mass reduction while not 

adversely affecting overall fleet safety. These maximum levels of mass reduction for each 

subclass were then used in the CAFE model for the rulemaking analysis. The agencies believe 

that mass reduction of up to 20 percent is feasible on light trucks, CUVs and minivans as 

discussed in the Joint TSD Section 3.3.5.5, as well as this section of FRIA. Thus, the amount of 

mass reduction selected for this rulemaking is based on our assumptions about how much is 
                                                      

 

 

 

422 

technologically feasible without compromising safety. While we are confident that 

manufacturers will build safe vehicles and meet (or surpass) all applicable federal safety 

standards, we cannot predict with certainty that they will choose to reduce mass in exactly the 

ways that the agencies have analyzed in response to the standards. In the event that 

manufacturers ultimately choose to reduce mass and/or footprint in ways not analyzed or 

anticipated by the agencies, the safety effects of the rulemaking may likely differ from the 

agencies’ estimates. 

In this final rule analysis, NHTSA utilized the 2012 Kahane study relationships between weight 

and safety, expressed as percent changes in fatalities per 100-pound mass reduction while 

holding footprint constant. However, as mentioned previously, there are several identifiable 

safety trends already occurring, or expected to occur in the foreseeable future, that are not 

accounted for in the study. For example, the two important new safety standards that were 

discussed above for electronic stability control and head curtain airbags have already been issued 

and began phasing in after MY 2008. The recent shifts in market shares from pickups and SUVs 

to cars and CUVs may continue, or grow, if gasoline prices remain high or rise further. The 

growth in vehicle miles travelled may continue to stagnate if the economy does not improve or 

gasoline prices remain high. And improvements in driver (and passenger) behavior, such as 

higher safety belt use rates, may continue. All of these will tend to reduce the absolute number 

of fatalities in the future. The agencies estimated the overall change in fatalities by calendar year 

after adjusting for ESC, Side Impact Protection, and other Federal safety standards and 

behavioral changes projected through this time period. The smaller percent changes in risk from 

mass reduction (from both the Kahane 2011 preliminary analysis and the Kahane 2012 final 

analysis), coupled with the reduced number of baseline fatalities, results in smaller absolute 

increases in fatalities than those predicted in the MYs 2012-2016 rulemaking. 

NHTSA examined the impacts of identifiable safety trends over the lifetime of the vehicles 

produced in each model year from 2007 through 2020. An estimate of these impacts was 

contained in a previous agency report that examined the impact of both safety standards and 

behavioral safety trends on fatality rates.316 In the NPRM analysis, based on these projections, 

we estimated a 12.6 percent reduction in fatality levels between the 2007 fatality base year and 

2020 for the combination of safety standards and behavioral changes anticipated in this study 

(such as electronic stability control, head-curtain air bags, and increased belt use). See 76 FR at 

74959. The estimates derived from applying NHTSA fatality percentages to a baseline of 2007 

316 Blincoe, L. and Shankar, U, “The Impact of Safety Standards and Behavioral Trends on Motor Vehicle Fatality 

Rates,” DOT HS 810 777, January 2007. See Table 5 comparing 2020 to 2007 (37,906/43,363 = 0.874 or a 

reduction of 12.6% (100%-87.4% = 12.6%). Since 2008 was a recession year, it did not seem appropriate to use that 

as a baseline, so 2007 was used as the baseline for fatalities in the NPRM. Note that additional improvements may 

occur between 2020 and 2025. However, since current research only projected the impact of changes through 2020, 

only those improvements could have been applied to that analysis. 
 

                                                      

 

 

423 

fatalities were multiplied by 0.874 to account for changes that NHTSA believes will take place in 

passenger car and light truck safety between the 2007 baseline on-road fleet used for this 

particular safety analysis and year 2020. Using this same methodology, for the final rule 

analysis, which is based on a 2010 baseline fleet, we estimated a 9.6317 percent reduction in 

fatality level between 2010 and 2020 for the anticipated combination of safety standards and 

behavioral changes that will occur during that time frame. The estimates derived from applying 

NHTSA fatality percentages to a baseline of 2010 fatalities were multiplied by 0.904 to account 

for changes that NHTSA believes will take place in passenger car and light truck safety between 

the 2010 baseline on-road fleet and year 2020. 

To estimate the amount of mass reduction to apply in the rulemaking analysis, the agencies 

considered fleet safety effects for mass reduction. As previously discussed the agencies believe 

that mass reduction of up to 20 percent is feasible on light trucks, CUVs and minivans, 318 but 

that less mass reduction should be implemented on other vehicle types to avoid increases in 

societal fatalities. For the NPRM analysis, NHTSA used the mass reduction levels shown in 

Table V-108 with the fatality coefficients derived in Kahane 2011 preliminary study. 

Table V-108 Mass Reduction Levels to Achieve Safety Neutral Results in the CAFE NPRM 

Analysis 

Absolute 

% 

Subcompact 

and 

Subcompact 

Perf. PC 

Compact 

and 

Compact 

Perf. PC 

Midsize PC 

and Midsize 

Perf. PC 

Large PC 

and Large 

Perf. PC 

Minivan LT 

Small, 

Midsize and 

Large LT 

MR1* 

MR2 

MR3 

MR4 

MR5 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

2.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.5% 

5.0% 

0.0% 

0.0% 

0.0% 

1.5% 

7.5% 

10.0% 

0.0% 

0.0% 

1.5% 

7.5% 

10.0% 

15.0% 

20.0% 

1.5% 

7.5% 

10.0% 

15.0% 

20.0% 

Notes:
 

*MR1-MR5: different levels of mass reduction used in CAFE model
 

In order to find a safety neutral compliance path for use in the agencies’ final rulemaking 

analysis given the coefficients from the Kahane 2012 study, the maximum amount of mass 

reduction applied in the final rule analysis has been modified from the NPRM levels for compact 

317 Blincoe, L. and Shankar, U, “The Impact of Safety Standards and Behavioral Trends on Motor Vehicle Fatality 

Rates,” DOT HS 810 777, January 2007. See Table 5 comparing 2020 to 2010 (37,906/41,945 = 0.904 or a 

reduction of (100%-90.4% = 9.6%). Note that additional improvements may occur between 2020 and 

2025. However, since current research only projected the impact of changes through 2020, only those 

improvements could be applied to this analysis. 318 When applying mass reduction, NHSTA capped the maximum amount of mass reduction to 20 percent for any 

individual vehicle class. The 20 percent cap is the maximum amount of mass reduction the agencies believe to be 

feasible in MYs 2017-2025 time frame. 
 

 

424 

passenger cars and midsize passenger cars as shown in Table V-109. Specifically, the maximum 

amount of mass reduction for compact passenger cars and compact performance passenger cars 

is reduced in the agencies’ respective models from 2% as used in the NPRM to 0% in the final 

rule analysis, while for midsize passenger cars and midsize performance passenger cars, it is 

reduced from 5% as used in the NPRM to 3.5% in the final rule analysis. 

Table V-109 Mass Reduction Levels to Achieve Safety Neutral Results in the Final Rule 

Analysis 

Absolute 

% 

Subcompact 

and 

Subcompact 

Perf. PC 

Compact 

and 

Compact 

Perf. PC 

Midsize PC 

and Midsize 

Perf. PC 

Large PC 

and Large 

Perf. PC 

Minivan LT 

Small, 

Midsize and 

Large LT 

MR1* 

MR2 

MR3 

MR4 

MR5 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.5% 

3.5% 

0.0% 

0.0% 

0.0% 

1.5% 

7.5% 

10.0% 

0.0% 

0.0% 

1.5% 

7.5% 

10.0% 

15.0% 

20.0% 

1.5% 

7.5% 

10.0% 

15.0% 

20.0% 

Notes:
 

*MR1-MR5: different levels of mass reduction used in CAFE model
 

For the CAFE model, these percentages apply to a vehicle’s total weight, including the 

powertrain. Table V-110 shows the amount of mass reduction in pounds for these percentage 

mass reduction levels for a typical vehicle weight in each subclass. 

Table V-110 Examples of Mass Reduction (in Pounds) for Different Vehicle Subclasses 

Using the Percentage Information As Defined in Table V-109 for Final Rule Analysis 

Mass 

Reduction 

(lbs) 

Subcompact and 

Subcomp 

act Perf. 

PC 

Compact 

and 

Compact 

Perf. PC 

Midsize 

PC and 

Midsize 

Perf. 

PC 

Large 

PC and 

Large 

Perf. PC 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Typical 

Vehicle 2795 3359 3725 4110 4250 3702 4260 5366 

Weight (lbs) 

MR1 (lbs) 0 0 56 62 64 56 64 80 

MR2 (lbs) 0 0 130 308 319 278 320 402 

MR3 (lbs) 0 0 0 411 425 370 426 537 

MR4 (lbs) 0 0 0 0 638 555 639 805 

MR5 (lbs) 0 0 0 0 850 740 852 1073 
                                                      

425 

The amounts of mass reduction shown in Table V-109 are for conventional vehicles. The 

agencies assume that vehicles with hybrid and electric powertrain are heavier than conventional 

vehicles because of the mass of battery systems. In comparing anecdotal data for HEVs, EPA 

and NHTSA assume a slight weight increase of 4-5% for HEVs as compared to baseline nonhybridized vehicles. The added weight of the Li-ion pack, motor and other electric hardware 

were offset partially by the reduced size of the base engine as stated in TSD section 3.4.3.8. We 

believe that this assumption accurately reflects real-world HEV, PHEV and EV construction. As 

an example, for a subcompact PHEV with 20 mile range operating on electricity, the agencies 

assume that to achieve no change in total vehicle mass, it would be necessary to reduce the mass 

of the glider by 6 percent because of the additional weight of the electrification system. The 

mass reduction for P/H/EVs can be found Section 3.3.3.9 in the joint TSD and elsewhere in this 

chapter. 

These maximum amounts of mass reduction discussed above were applied in the technology 

input files for the CAFE model. Within some of the light truck classes, additional limitations 

were placed on the maximum amount of mass reduction for some of the vehicles based on which 

Kahane study safety class the vehicles were in, as is explained below. By way of background, 

NHTSA divides vehicles into classes for purposes of applying technology in the CAFE model in 

a way that differs from the Kahane study which divides vehicles into classes for purposes of 

determining safety coefficients. These differences require that the “safety class” coefficients be 

applied to the appropriate vehicles in the CAFE “technology subclasses.” For the reader’s 

reference, for purposes of this final rule, the safety classes and the technology subclasses relate319 

as shown in Table V-111. 

Table V-111 Mapping between Safety Classes and Technology Classes 

Safety Class Tech Class 

PC (Passenger Car) 

Subcompact PC 

Subcompact Perf. 

PC 

Compact PC 

Compact Perf. PC 

Midsize PC 

Midsize Perf. PC 

Large PC 

Large Perf. PC 

LT (Light Truck) 

Small LT 

Midsize LT 

Large LT 

319 This is not to say that all vehicles within a technology subclass will necessarily fall within a single safety class – 

as the chart shows, some technology subclasses are divided among safety classes. 
426 

CM (CUV and 

Minivan)
 

Subcompact PC 

Subcompact Perf. 

PC 

Large PC 

Large Perf. PC 

Minivan 

Small LT 

Midsize LT 

Large LT 

In the NPRM analysis, the maximum amount of mass reduction for vehicles that would fall into 

the light truck safety class and would also fall into the small and midsize light truck technology 

subclasses was limited to 10%, as shown in Table V-112. In the final rule analysis, in order to 

find a safety-neutral compliance path using the new safety coefficients, for vehicles in the light 

truck safety class that also fall into the Small LT technology subclass, mass reduction was 

limited to a maximum of 1.5%, as shown in Table V-113. For vehicles in the light truck safety 

class that also fall into the Midsize LT technology subclass, the amount of mass reduction 

applied depends on vehicle mass: if the vehicle curb weight is greater than or equal to 4,000 

pounds, the maximum amount of mass reduction allowed is 7.5%; if the vehicle curb weight is 

less than 4,000 pounds, the maximum amount is 1.5%. Small and midsize light truck (Small LT 

and Midsize LT) that fall in the CUV and Minivan (CM) safety class are allowed up to 20% 

mass reduction. These changes from the NPRM analysis were incorporated in order to maximize 

the amount of overall fleet mass reduction in a way that achieved a safety neutral result with the 

updated coefficients from the Kahane 2012 study. 

Table V-112. Maximum Amount of Mass Reduction Limits for Light Truck Safety Vehicle 

Class for the NPRM CAFE Model Analysis 

NRPM - 2008 

Market Input File Tech Class 

Safety Class Small LT Midsize LT 

LT Apply MR3 at 10% Apply MR3 at 10% 

CM* MR5 (20%) MR5 (20%) 

*CM = CUV and MiniVan 

Table V-113. Maximum Amount of Mass Reduction Limits for Light Truck Safety Vehicle 

Class for the Final Rule CAFE Model Analysis 

Final Rule -2008 

& 2010 Market 

Input File 

Tech Class 

Safety Class Small LT Midsize LT 
 

 

 

                                                      

 

427 

LT Apply MR1 at 1.5% Vehicle Weight ≥ 4000, apply MR2 at 7.5%; 

Vehicle Weight < 4000, apply MR1 at 1.5%. 

CM MR5 (20%) MR5 (20%) 

Table V-114 shows CAFE model results for societal safety for each model year based on the 

application of the above mass reduction limits.320 These are the estimated increases or decreases 

in fatalities over the lifetime of the model year fleet. A positive number means that fatalities are 

projected to increase, a negative number (indicated by parentheses) means that fatalities are 

projected to decrease. The results are significantly affected by the mass reduction limitations 

used in the CAFE model, which allow more mass reduction in the heavy LTVs, CUVs, and 

minivans than in other vehicles. As the negative coefficients only appear for LTVs greater than 

4,594 lbs, CUVs, and minivans, a statistically significant improvement in safety can only occur if 

more weight is taken out of these vehicles than out of passenger cars or smaller light trucks. 

Combining passenger car and light truck safety estimates for the final rule results in a decrease in 

fatalities over the lifetime of the nine model years of MY 2017-2025 of 8 fewer fatalities with 

the 2010 baseline and of 107 fewer fatalities with the 2008 baseline. Broken up into passenger 

car and light truck categories, there is an increase of 135 fatalities in passenger cars and a 

decrease of 143 fatalities in light trucks with the 2010 baseline, and there is an increase of 78 

fatalities in passenger cars and a decrease of 185 fatalities in light trucks with the 2010 baseline. 

NHTSA also analyzed the results for different regulatory alternatives in Chapter IX of this FRIA; 

the difference in the results by alternative depends upon how much mass reduction is used in that 

alternative and the types and sizes of vehicles that the mass reduction applies to. 

Table V-114 NHTSA Calculated Mass-Safety-Related Fatality Impacts of the Final Rule 

over the Lifetime of the Vehicles Produced in each Model Year Using 2008 and 2010 

Baseline 

Fatalities Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 3 - 2 7 - 5 13 - 13 12 -12 

18 -

13 

19 -

10 

23 -

11 

22 -

9 

19 -

1 

135 -

78 

Light 2010 (5) ­ (9) ­ 0 - (5) ­ (18) ­ (21) ­ (24) ­ (30) ­ (31) ­ (143) ­

Trucks 2008 (5) (13) (17) (29) (27) (27) (27) (29) (11) (185) 

Total 

2010 

2008 

(2) ­

(3) 

(3) ­

(8) 

13 -

(3) 

7 -

(17) 

(1) ­

(14) 

(2) ­

(17) 

(2) ­

(16) 

(8) ­

(20) 

(12) ­

(10) 

(8) ­

(107) 

In its comments, Volkswagen wrote that “Smaller cars and economy models have less potential 

for mass reduction than larger or more premium vehicles.” This is in agreement with the 

320 NHTSA has changed the definitions of a passenger car and light truck for fuel economy purposes between the 

time of the Kahane 2003 analysis and the NPRM (as well as this final rule). About 1.4 million 2-wheel-drive SUVs 

have been redefined as passenger cars instead of light trucks. The Kahane 2011 and 2012 analyses continue to use 

the definitions used in the Kahane 2003 analysis. 
                                                      

 

 

 

428 

agencies’ application of mass reduction in the final rule analysis. Volkswagen, furthermore, 

agreed with the agencies assessment of the weight increase due to HEVs. 

How much do the agencies estimate mass reduction will cost in the rulemaking timeframe? 

Automakers are currently utilizing various mass reduction techniques across the light-duty 

vehicle fleet, and will continue to use and in some cases expand these approaches for the 2017 to 

2025 time frame. These approaches may include optimized design, geometry, part 

consolidations, and materials substitution. Unlike the other technologies described in this 

chapter, mass reduction is potentially more complex in that we cannot define it as a single piece 

of equipment or hardware change to implement the technological improvement. Mass reduction, 

depending upon the level of reduction targeted, has the potential to impact nearly every system 

on the vehicle. Because of this complexity, there are unique challenges to estimating the cost for 

mass reduction and for demonstrating the feasibility of reducing vehicle mass by a given amount. 

This section describes the cost estimates used for the agencies’ analysis. 

In the analysis for the MYs 2012-2016 rulemaking, the agencies assumed a constant cost for 

mass reduction of $1.32 for each pound reduced up to a mass reduction level of 10 percent (or 

$1.48/lb using an ICM factor of 1.1 for a low-complexity technology). The $1.32/lb estimate was 

based on averaging three studies: the 2002 NAS Report, a 2008 study by Sierra Research, and a 

2007 study by MIT researchers.321 

Since the MYs 2012-2016 final rule, the agencies have given further consideration to the cost of 

mass reduction, and now believe that a cost that varies with the level of mass reduction provides 

a better estimate. The agencies believe that as the vehicle fleet progresses from lower to higher 

levels of mass reduction and becomes increasingly optimized for mass and other attributes, the 

cost for mass reduction will progressively increase. The higher levels of mass reduction may, for 

example, require applying more advanced materials and technologies than lower levels of mass 

reduction, which means that the cost of achieving those higher levels may increase accordingly. 

The unit cost of mass reduction versus the amount of mass reduction might be linear, parabolic, 

or some other higher order relationship. In the 2017-2025 Notice of Intent, 75 FR 62739 (Oct. 

13, 2010), CARB, EPA and NHTSA derived a second order curve based on a study with two 

vehicle redesigns conducted by Lotus Engineering completed in 2010, such that zero mass 

321 Specifically, the 2002 NAS Report estimated that vehicle weight could be reduced by 5 percent (without engine 

downsizing) at a cost of $210-$350, which translates into $1.50/lb assuming a 3,800 lb base vehicle and using the 

midpoint cost; Sierra Research estimated that a 10 percent reduction (with compounding) could be accomplished for 

$1.01/lb, and MIT researchers estimated that a 14 percent reduction (with no compounding) could be accomplished 

for $1.36/lb. References for these studies are available in endnotes to Chapter 3 of the TSD for the MYs 2012-2016 

final rule. 
                                                      

 

 

 

429 

reduction had zero cost, and the dollars per pound increased with greater levels of mass 

reduction. Since the publication of the TAR, the agencies have identified a number of additional 

studies in the literature relating to the costs of vehicle mass reduction, which are discussed 

below. The studies show that for low or high mass reduction, the costs can range from small cost 

savings to significant cost increases. The economic costs associated with mass reduction are 

difficult to determine conclusively due to the broad range of methods employed to achieve mass 

reduction. The costs on a specific vehicle or component depend on many factors, such as the 

design, materials selected, raw material price, appropriate manufacturing processes, production 

volume, component functionality, required engineering and development, etc. 

Cost data thus varies widely in the literature. Of the various studies reviewed by the agencies, 

not all are equal in their original intent, rigor, transparency, or applicability to this regulatory 

purpose. The individual studies range from complete vehicle redesign to advanced optimization 

of individual components, and were conducted by researchers with a wide range of experience 

and background. Some of the studies were literature reviews, while others developed new 

designs for lighter components or complete lighter vehicles, while yet others built physical 

components or systems, and conducted testing on those components and systems. Some of the 

studies focused only on a certain sub-system (which is a building block for the overall vehicle 

design), while some of them took a systematic approach and re-designed the whole vehicle to 

achieve the maximum mass reduction and cost reduction. The latter studies typically identified a 

specific baseline vehicle, and then utilized different engineering approaches and investigated a 

variety of mass-reduction concepts that could be applied to that vehicle. Some of the differences 

between studies emanate from the characteristics of the baseline vehicle and its adaptability to 

the new technology or method, and the cost assumptions relating to the original components and 

the redesigned components. Assumptions regarding the degree and cost of any associated mass 

de-compounding can also confound comparisons.322 Despite this variation in the literature, in 

actual practice, we believe manufacturers will choose a target mass reduction for a whole vehicle 

and for each sub-system, and work to find the lowest total cost method to achieve those targets. 

Such a process would consider numerous primary and secondary cost factors (including 

322 The concept of secondary weight savings or mass compounding (also called mass decompounding) derives from 

the qualitative understanding that as vehicle weight decreases, other vehicle systems can also decrease in mass while 

maintaining the original vehicle level of performance and function. For instance, following a primary weight 

reduction in the vehicle (e.g. Body in White), the designs of some of the other dependent vehicle subsystems (tires, 

suspensions, brakes, powertrain, body structure) may be redesigned and reduced in mass to account for the overall 

lighter vehicle. The lighter vehicle is also associated with lighter loads, less friction and drag, and may require less 

power to be accelerated, and the powertrain may therefore be scaled down in size with a potential for reduced mass, 

even while maintaining equivalent acceleration performance and functionality. The compounded or secondary mass 

savings from these additional systems may then drive further mass reductions in the original primary weight 

reduction (e.g. Body in White). Mass compounding factors found in literature are rough estimates of the secondary 

mass reduction amount. 
 

                                                      

 

 

430 

engineering, facilities, equipment, tooling, and retraining costs) as well as technological and 

manufacturing risks.323 

Regardless of the confidence in specific estimates, the agencies must select a curve that will be 

applied to the whole fleet that will define the average cost per kg of mass reduction as a function 

of total percentage of mass reduction. There are many significant challenges that make it 

difficult for the agencies to establish an estimated cost curve based on the literature, such as the 

differences in the baselines used in the studies, whether the studies considered platform sharing 

and powertrain sharing, and other considerations. 

The costs for mass reduction employed for the main analysis for this final rule are the same as 

those in the NPRM. The agencies considered updating cost estimates based on the studies that 

were underway when the NPRM was issued. Those studies included the EPA/ICCT funded 

Phase 2 Toyota Venza Low Development project and the NHTSA funded Honda Accord mass 

reduction project, which are described in the section titled “What additional studies are the 

agencies conducting to inform our estimates of mass reduction amounts, cost, and 

effectiveness?” However, these studies were in the middle of the peer review process and had 

not yet been finalized at the time when the inputs for the main analysis for this final rule were 

required. For the final rule, the agencies decided to continue to use the same costs for mass 

reduction that were used in the NRPM. 

The agencies examined all the studies in Table V-115 including information supplied by 

manufacturers (during meetings held subsequent to the TAR) when deciding the mass reduction 

cost estimate used for the proposal, which has been carried forward for this FRM.324 The 

agencies considered three major factors in examining these studies. First, whether a study was 

rigorous in terms of how it evaluates and validates mass reduction from technological and design 

perspectives. This includes consideration of a study’s comprehensiveness, the technical rigor of 

its methodology, the validation methods employed, and the relevance of the technologies 

evaluated in the study given our rulemaking time frame. Second, whether a study was rigorous 

in terms of its estimation of costs, including the completeness and rigor of the methodology, such 

as whether the study includes data for all categories of direct manufacturing costs, and whether 

the study presents detailed cost information for both the baseline and the light-weighted design. 

323 We also note that the cost of mass reduction in the CAFE model is quantified on a per pound basis that is a 

function of the percentage decrease in vehicle mass. We assume that OEMs would find the most cost-effective 

approach to achieve such a mass reduction. Realistically, this would depend heavily on the baseline vehicle as well 

as the size and adaptability of the initial design to the new technology. Thus, the CAFE model strives to be realistic 

in the aggregate while recognizing that the figures proposed for any specific model may be debatable. 324 The agencies considered confidential cost information provided by OEMs that covered a range of components, 

systems, designs and materials. Some of these cost estimates are higher than some of the literature studies, and 

manufacturers provided varying levels of detail on the basis for the costs such as whether mass compounding is 

included, or whether the costs include markup factors. 
431 

And third, the degree of peer review, including if the study is peer-reviewed, and whether it has 

effectively addressed any critical technical, methodological, and cost issues raised by the peerreview, if this information is available. 

Some of the variation may be attributed to the complexity of mass reduction as it is not one 

single discrete technology and can have direct as well as indirect effects on other systems and 

components. The 2010 NAS study speaks to this point when it states on page 7-1 that “[t]he 

term material substitution oversimplifies the complexity of introducing advanced materials, 

because seldom does one part change without changing others around it.” These variations 

underscore that there is not a unique mass reduction solution as there are many different methods 

with varying costs for taking mass out of vehicles, and every manufacturer, even every vehicle, 

could have a different approach depending on the specific vehicle, assembly plant and model 

year of implementation. The agencies recognize that there are challenges to characterizing the 

mass reduction plans for the entire future fleet due to the complexity and variety of methods 

available. So far the agencies have not found any study that addresses how to generalize the 

mass reduction that is achievable on a single vehicle to the whole fleet. 

Table V-115 contains a summary of the data contained in the studies, and the OEM CBI data, 

which the agencies reviewed. There is a degree of uncertainty associated with comparing the 

costs from the range of studies in the literature when trying to summarize them in a single table, 

and we encourage interested stakeholders to carefully review the information in the 

literature. For some of the cost estimates presented in the papers there are unknowns such as: 

what year the costs are estimated for, whether mass decompounding (and potential resultant cost 

savings) was taken into account, and whether mark-ups or indirect costs were included. The 

agencies tried to normalize the cost estimations from all these studies by converting them to 

2009 year dollars, applying mass compounding factor of 1.35 for mass reduction amount more 

than 10 percent if it has not been applied in the study, and factoring out the RPE specified in the 

study to derive direct manufacturing costs for comparison. There are some papers that give cost 

for only component mass reduction, others that have more general subsystem costs and others 

yet that estimate total vehicle mass reduction costs (which often include and present data at the 

subsystem level). Other studies have multiple scenarios for different materials, different vehicle 

structures and mass reduction strategies. Thus, a single study which contains more than one 

vehicle can be broken down into a range of vehicle types, or at the subsystem level, or even at 

the component level. While Table V-115 is inclusive of all of the information reviewed by the 

agencies for the NPRM, for the reasons described above the technical staff for the two agencies 

applied various different approaches in evaluating the information. The linear mass-cost 

relationship developed for the proposal is carried forward to this final rule and presented below 

is the consensus assessment from the two agencies of the appropriate mass cost for this final rule. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

432 

Table V-115 Mass Reduction Studies Considered for Estimating Mass Reduction Cost for this FRM 

Studies 

Cost Year 

Cost Information from Studies 

Mass Reduction [lb] Compounding Factor Mass Reduction withCompounding [lb] Baseline Vehicle Weight [lb]Mass Reduction w/Compounding [%]Cost [$]RPEDollar Multiplier to 20092009 Direct Manufacturing Cost [$]Unit Cost of Mass Reduction[$/lb] 

Individual Cost Data Points 

AISI, 1998 (ULSAB) 1998 103 1 103 2977 3.5% -$32 1.0 1.28 -$41 -$0.40 

AISI, 2000 (ULSAC) 2000 6 1 6 2977 0.2% $15 1.0 1.24 $18 $2.99 

Austin et al, 2008 (Sierra Research) - ULS 

Unibody 2008 320 1 320 3200 10.0% $209 1.61 1.01 $131 $0.41 

Austin et al, 2008 (Sierra Research) - AL 

Unibody 2008 573 1 573 3200 17.9% $1,805 1.61 1.01 $1,134 $1.98 

Austin et al, 2008 (Sierra Research) - ULS BoF 2008 176 1 176 4500 3.9% $171 1.61 1.01 $107 $0.61 

Austin et al, 2008 (Sierra Research) - AL BoF 2008 298 1 298 4500 6.6% $1,411 1.61 1.01 $887 $2.98 

Bull et al, 2008 (Alum Assoc.) - AL BIW 2008 279 1 279 3378 8.3% $455 1.0 1.01 $460 $1.65 

Bull et al, 2008 (Alum Assoc.) - AL Closure 2008 70 1 70 3378 2.1% $151 1.0 1.01 $153 $2.17 

Bull et al, 2008 (Alum Assoc.) - Whole Vehicle 2008 573 1 573 3378 17.0% $122 1.0 1.03 $126 $0.22 

Cheah et al, 2007 (MIT) - 20% 2007 712 1 712 3560 20.0% $646 1.0 1.03 $667 $0.94 

Das, 2008 (ORNL) - AL Body & Panel 2008 637 1 637 3363 19.0% $180 1.5 1.01 $121 $0.19 

Das, 2008 (ORNL) – FRPMC 2008 536 1.0 536 3363 15.9% -$280 1.5 1.01 -$189 -$0.35 

Das, 2009 (ORNL) - CF Body & Panel, AL 

Chassis 2009 933 1 933 3363 27.7% $1,490 1.5 1.00 $993 $1.06 

Das, 2010 (ORNL) - CF Body & Panel, Mg 

Chassis 2010 1173 1 1173 3363 34.9% $373 1.5 1.00 $248 $0.21 

EEA, 2007 - Midsize Car - Adv Steel 2007 236 1 236 3350 7.0% $179 1.0 1.03 $185 $0.78 

EEA, 2007 - Midsize Car - Plast/Comp 2007 254 1 254 3350 7.6% $239 1.0 1.03 $247 $0.97 

EEA, 2007 - Midsize Car – Al 2007 586 1.35 791 3350 23.6% $1,388 1.0 1.03 $1,434 $1.81 

EEA, 2007 - Midsize Car – Mg 2007 712 1.35 961 3350 28.7% $1,508 1.0 1.03 $1,558 $1.62 

EEA, 2007 - Light Truck - Adv Steel 2007 422 1 422 4750 8.9% $291 1.0 1.03 $301 $0.71 

EEA, 2007 - Light Truck - Plast/Comp 2007 456 1 456 4750 9.6% $398 1.0 1.03 $411 $0.90 

EEA, 2007 - Light Truck - Al 2007 873 1.35 1179 4750 24.8% $1,830 1.0 1.03 $1,891 $1.60 

EEA, 2007 - Light Truck - Mg 2007 1026 1.35 1385 4750 29.2% $1,976 1.0 1.03 $2,042 $1.47 

Geck et al, 2008 (Ford) 2008 1310 1 1310 5250 25.0% $500 1.0 1.01 $506 $0.39 

Lotus, 2010 – LD 2010 660 1 660 3740 17.6% -$121 1.0 1.00 -$120 -$0.18 

Lotus, 2010 – HD 2010 1217 1 1217 3740 32.5% $362 1.0 1.00 $360 $0.30 

Montalbo et al, 2008 (GM/MIT) - Closure ­

HSS 2008 25 1 25 4000 0.6% $10 1.0 1.01 $10 $0.41 

Montalbo et al, 2008 (GM/MIT) - Closure - AL 2008 120 1 120 4000 3.0% $110 1.0 1.01 $111 $0.92 

Montalbo et al, 2008 (GM/MIT) - Closure ­

Mg/AL 2008 139 1 139 4000 3.5% $110 1.0 1.01 $111 $0.80 

Plotkin et al, 2009 (Argonne) 2009 683 1 683 3250 21.0% $1,300 1.0 1.00 $1,300 $1.90 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

433 

Table V-115(... Continued) Mass Reduction Studies Considered for Estimating Mass 

Reduction Cost for this FRM 

Studies 

Cost Year 

Cost Information from Studies 

Mass Reduction [lb] 

Compounding Factor 

Mass Reduction with Compounding 

[lb]

Baseline Vehicle Weight [lb]

Mass Reduction w/Compounding 

[%]

Cost [$]

RPE

Dollar Multiplier to 2009

2009 Direct Manufacturing Cost [$] 

Unit Cost of Mass Reduction [$/lb] 

Cost Curves 

NAS, 2010 

2010 1.0% $ 1.41 

2010 2.0% $ 1.46 

2010 5.0% $ 1.65 

2010 10.0% $ 1.52 

2010 20.0% $ 1.88 

OEM1 

2010 8.0% $ 6.00 

2010 9.0% $ 7.00 

2010 9.5% $ 8.00 

2010 10.0% $ 12.00 

2010 11.0% $ 25.00 

OEM2 

2010 0.4% 

$ 

-

2010 0.9% $ 0.10 

2010 1.9% $ 0.20 

2010 2.3% $ 0.33 

2010 2.4% $ 0.38 

2010 3.1% $ 0.60 

2010 3.6% $ 0.76 

2010 4.0% $ 0.85 

2010 4.1% $ 0.88 

2010 4.5% $ 0.98 

2010 4.8% $ 1.09 

2010 5.0% $ 1.17 

OEM3 

2010 4.0% $ 0.57 

2010 7.5% $ 1.01 

2010 10.0% $ 1.51 

OEM4 

2011 6.9% $ 0.97 

2011 8.1% $ 1.02 

2011 16.4% $ 1.95 
 

     

   

434 

EPA and NHTSA scrutinized the various available studies in the literature as well as confidential 

information provided by several auto firms based on the kinds of factors described above for 

purposes of estimating the cost of mass-reduction in the 2017-2025 timeframe. We determined 

that there was wide variation across the studies with respect to costs estimates, applicability to 

the 2017-2025 time frame, and technical rigor. The mass cost curve that was developed is 

defined by the following equation and is shown in Figure V-44: 

Mass Reduction Direct Manufacturing Cost (DMC) ($/lb) 

= $4.36/(%-lb) x Percentage of Mass Reduction Level (%) (2010$) 

$0.00

$0.10

$0.20

$0.30

$0.40

$0.50

$0.60

$0.70

$0.80

$0.90

$1.00

0% 5% 10% 15% 20% 25%

Unit Cost [$/lb]

Percent of Mass Reduction

Mass Reduction Cost

Slope = 4.36

Figure V-44 Mass Reduction Direct Manufacturing Cost ($/lb) 

For example, this results in an estimated $175 cost increase for a 10% mass reduction of a 

4,000lb vehicle (or $0.44/lb), and a $394 cost increase for 15% reduction on the same vehicle (or 

$0.66/lb). 

As mentioned in the NPRM, due to the wide variation in data used to select this estimated cost 

curve, the agencies have also conducted cost sensitivity studies in their respective RIAs in both 

the proposal and final rule using values of +/-40%. The wide variability in the applicability and 

rigor of the studies also provides justification for continued research in this field. 
                                                      

435 

The agencies consider this DMC to be applicable to the MY2017 and consider mass reduction 

technology to be on the flat portion of the learning curve in the MY2017-2025 timeframe. To 

estimate indirect costs for applied mass reduction of up to 15%, the agencies have applied a low 

complexity ICM of 1.24 through 2018 and 1.19 thereafter. To estimate indirect costs for applied 

mass reduction of 15% to 25%, the agencies have applied a medium complexity ICM of 1.39 

through 2024 and 1.29 thereafter. To estimate indirect costs for applied mass reduction greater 

than 25%, the agencies believe it is appropriate to apply a high1 complexity ICM of 1.56 through 

2024 and 1.35 thereafter. 

The agencies sought comment in the draft Joint TSD for the NPRM (p. 210) regarding options 

for realistically and appropriately assessing the degree of feasible mass reduction for vehicles in 

the rulemaking timeframe and the total costs to achieve that mass reduction, but got no specific 

response. The agencies also sought comments on what practical limiting factors need to be 

considered when considering maximum feasible amount of mass reduction; the degree to which 

these limiting factors will impact the amount of feasible mass reduction (in terms of the percent 

of mass reduction); the best method(s) to assess an appropriate and feasible fleet-wide amount 

mass reduction amount (because each study mainly focuses on a single vehicle); etc. In its 

comments, VW stated that it “projects full vehicle weight reductions during the time period of 

this regulation on average in the order of 7-10%.” VW noted that this was lower than the 

agencies’ estimates in the NPRM of upwards of 20% mass reduction for large cars and some 

trucks, which VW stated may exceed cost effective limits. As stated later in this section, the 

detailed studies sponsored by the agencies suggest that 20% mass reduction is likely feasible for 

the rulemaking period without using exotic materials or highly advanced technologies. The 

accompanying detailed cost analysis indicates that the cost of reducing mass by 20% can 

potentially be economical. The agencies also noted in the NPRM that we expected to refine our 

estimate of both the amount and the cost of mass reduction between the NPRM and the final rule 

based on the agencies’ ongoing work described a later section, below. As stated before, due to 

the limited time and the extensive scope of these studies, the agencies did not finish them in time 

for inclusion in the final rule analysis. 

How effective do the agencies estimate that mass reduction will be? 

A rule of thumb used by researchers and industry, based on testing and simulation, is that 10 

percent reduction in vehicle mass can be expected to generate a 6 to 8 percent increase in fuel 

economy if the vehicle powertrain and other components are also downsized accordingly.325 In 

the analysis for the MYs 2012-2016 final rule, NHTSA and EPA estimated that a 10 percent 

mass reduction with engine downsizing would result in a 6.5 percent reduction in fuel 

325 NAS 2010, “Assessment of Fuel Economy Technologies for Light-Duty Vehicles.” June 2010, page 7-14 
 

436 

consumption while maintaining equivalent vehicle performance (i.e., 0-60 mph time, towing 

capacity, etc.), consistent with estimates in the 2002 NAS report. For small amounts of mass 

reduction, such as the 1.5 percent used at vehicle refresh in NHTSA’s modeling, no engine 

downsizing was used, so a 10 percent mass reduction without engine downsizing was assumed to 

result in a 3.5 percent reduction in fuel consumption. In this FRM, both agencies have chosen to 

use the effectiveness value for mass reduction from EPA’s lumped parameter model to maintain 

consistency. EPA’s lumped parameter model-estimated mass reduction effectiveness is based on 

a simulation model developed by Ricardo, Inc. under contract to EPA. The 2011 Ricardo 

simulation results show an effectiveness of 5.1 percent for every 10 percent reduction in 

mass. NHTSA has assumed that for mass reduction amounts less than 10 percent, the 

effectiveness is 3.5 percent. For mass reduction greater than 10 percent, NHTSA estimates the 

effectiveness is 5.1 percent in order to avoid double counting benefits – because the effectiveness 

of engine downsizing is included in the effectiveness of the engine decision tree when applying 

engine downsizing, it should appropriately be removed from the mass reduction effectiveness 

value in the mass reduction decision tree. EPA applies an effectiveness of 5.1 percent for every 

10 percent mass reduction, and this scales linearly from 0 percent mass reduction up to the 

maximum applied mass reduction for any given vehicle, which in this final rule is never larger 

than 20 percent. 

What additional studies are the agencies conducting to inform our estimates of mass reduction 

amounts, cost, and effectiveness? 

In the MYs 2012-2016 final rule, the agencies stated that there are several areas concerning 

vehicle mass reduction and vehicle safety on which the agencies will focus their research efforts 

and undertake further study. The following vehicle level projects focus on the goals stated in the 

MYs 2012-2016 final rule, which include determining the maximum potential for mass reduction 

in the MY 2017-2025 timeframe by using advanced materials and improved designs while 

continuing to meeting safety regulations and voluntary guidelines and while maintaining all 

aspects of vehicle functionality. The fourth study investigates the effects of resultant study 

designs on fleet safety by evaluating crash performance with objects and other vehicles of 

different size and mass. 

1.	 NHTSA sponsored mass reduction study on a Honda Accord 

2.	 EPA sponsored mass reduction study on a Toyota Venza (Phase 2 Low Development) 

3.	 California Air Resources Board mass reduction study on a Toyota Venza (Phase 2 

High Development) 

4.	 NHTSA fleet-wide simulation study: crash analysis using the resultant designs from 

the studies 1-3 with objects and the design models of other vehicles with different 

size and mass. 
437 

Due to the extensive scope of work for these studies and tight time schedule, some of the studies 

were finished, but peer reviews and response to peer reviews were not completed in time to 

enable the results to inform the final rule. We note, however, that the intermediate results from 

the mass reduction studies would corroborate the level of feasible amount of mass reduction the 

agencies chose to apply in the NPRM and FRM analyses. Rulemaking modeling results show 

that the costs for mass reduction are not sensitive to the cost curve of the rulemaking. In the 

NPRM, EPA found that a +/- 40% change in the cost of mass reduction had very little impact on 

the cost of the program. This is largely because of safety restraints imposed in the amount of 

mass reduction selected for the various vehicle classes primarily drive the penetration rates of the 

technology, rather than the relative cost-effectiveness of the technology itself. 

The following sections describe the status and results of the studies sponsored by the agencies. 

NHTSA Sponsored Mass Reduction Study 

BACKGROUND: NHTSA awarded a contract in December 2010 to Electricore, with EDAG 

and George Washington University (GWU) as subcontractors, to study the maximum feasible 

amount of mass reduction for a mid-size car – specifically, a Honda Accord - while keeping the 

vehicle functionality the same as the baseline vehicle. The Electricore/EDAG/GWU project 

team was charged with maximizing the amount of mass reduction using technologies that are 

considered feasible for production of 200,000 units per year during the time frame of this 

rulemaking while maintaining retail price in parity (within ±10%) with the baseline vehicle. In 

addition, all designs, materials, technologies and manufacturing processes must be realistically 

projected to be feasible for industry-wide application in MYs 2017-2025. The project focused on 

mass reduction and allowed powertrain downsizing, however alternative powertrains, such as 

diesels, HEVs and EVs, were not to be considered. 

MATERIAL AND TECHNOLOGY SELECTION: For vehicle redesigns, OEMs normally select 

technologies, materials and manufacturing processes that are currently in use on existing vehicle 

platforms or planned to be in use on future vehicle platforms. The use of the same or similar 

technologies, materials and manufacturing processes helps maintain or improve component and 

vehicle reliability, manufacturability and cost. New materials, technologies and processes are 

often introduced in low-volume, high price vehicles first and then migrate to high production 

volume vehicle lines over time. This significantly reduces the risk to OEMs associated with 

implementing new technologies. Recognizing this when selecting materials, technologies and 

manufacturing processes, the Electricore/EDAG/GWU team utilized, to the extent possible, only 

those materials, technologies and design which are currently used or planned to be introduced in 

the near term (MY 2012-2015) on low-volume production vehicles. The recommended materials 

(Advanced High Strength Steels, Aluminum, Magnesium and Plastics) manufacturing processes 

(Stamping, Hot Stamping, Die Casting, Extrusions, Roll Forming) and assembly methods (Spot 

welding, Laser welding and Adhesive Bonding) are at present used, some to a lesser degree than 
438 

others. These technologies can be fully developed within the normal product design cycle using 

the current design and development methods. The process parameters for manufacturing with 

Advanced High Strength Steels can be supported by computer simulation. This approach 

minimized those material and technology options which would likely be overly aggressive or 

unrealistic to implement in mass production in model years 2017-2025. 

ENGINEERING APPROACH: The Electricore/EDAG/GWU team took a “clean sheet of paper” 

approach and adopted collaborative design, engineering and CAE process with built-in feedback 

loops to incorporate results and outcomes from each of the design steps into the overall vehicle 

design and analysis. The team tore down and benchmarked a 2011 Honda Accord and then 

undertook a series of baselines, noting the designs, materials, technologies and overall design 

optimization level of the baseline vehicle. Vehicle performance, safety simulation and cost 

analyses were run in parallel to the design study to help ensure that the design decisions for the 

concept vehicle would be informed by a well-documented baseline, thus enabling the resultant 

design to meet the defined project criteria. 

While working within the constraint of maintaining the baseline Honda Accord’s exterior size 

and shape, the body structure was first redesigned using topology optimization with six load 

cases including bending stiffness, torsion stiffness, IIHS frontal impact, IIHS side impact, 

FMVSS pole impact, FMVSS rear impact and FMVSS roof crush cases. The load paths from 

topology optimization were analyzed and interpreted by technical experts and the results were 

then fed into low fidelity 3G (Gauge, Grade and Geometry) optimization programs to further 

optimize for material properties, material thicknesses and cross-sectional shapes while trying to 

achieve the maximum amount of mass reduction. The Electricore/EDAG/GWU team carefully 

reviewed the optimization results and built detailed CAD/CAE models for the body structure, 

closures, bumpers, suspension, and instrumentation panel. The vehicle designs were also 

carefully reviewed by manufacturing technical experts to ensure that they could be manufactured 

at high volume production rates. Detailed manufacturing layouts were created and were later 

used to estimate costs. 

Multiple materials were used for this study. The body structure was redesigned using a 

significant amount of advanced high strength steel (AHSS). The closure and suspension were 

designed using a significant amount of aluminum. Magnesium was used for the instrumentation 

cross-car beam. A limited amount of composite material was used for the seat structure. 

Electricore and its sub-contractors consulted industry leaders and experts for each component 

and sub-system when deciding which mass reduction technologies were feasible. 

DESIGN AND FUNCTION VALIDATION: In order to ensure that the light weighted vehicle 

had the same functionality as the baseline vehicle, Electricore and its sub-contractors used the 

CAD/CAE/powertrain models and conducted simulation modeling. This is the first mass 

reduction study that has been released publicly that includes such a broad array of vehicle 
                                                      

 

439 

simulation modeling analyses to assess vehicle functionality and performance relative to these 

critical attributes. These significant additional analyses provide greater confidence that the 

designs employed in this study are more feasible for production implementation than a study 

without these analyses, although the agency notes that significantly more testing and validation 

work is required to refine and finalize a design for production. 

Safety: Safety performance of the light-weighted design is compared to the safety rating 

of the baseline MY2011 Honda Accord for seven consumer information and federal 

safety crash tests using LS-DYNA326. These seven tests are NCAP frontal test, NCAP 

lateral MDB test, NCAP lateral pole test, IIHS roof crush, IIHS lateral MDB, IIHS front 

offset test, and FMVSS No. 301 rear impact tests. All tests achieved safety performance 

equivalent to MY 2011 Honda Accord when comparing crash pulse and passenger 

compartment intrusion levels, with no damage to the fuel tank. This study does not 

include restraint systems and dummy, which would be part of NHTSA’s fleet simulation 

study. 

Body Stiffness/ Ride and Handling/NVH: Vehicle body torsional and bending stiffness 

are signatures for the vehicle structure performance. Higher stiffness is generally 

associated with a refined ride and handling qualities. The baseline vehicle body structure 

underwent testing for normal modes of vibration, and torsion and bending stiffness. A 

detailed FEA model of the light-weighted structure was created and analyzed using the 

MSC/NASTRAN simulation. The torsional stiffness of the light-weighted design is 30% 

higher than the baseline vehicle while the bending stiffness is 40% higher. The normal 

mode frequency test results for the light-weighted body structure, which represents 

vehicle dynamic stiffness, also are within 2.3% of the targets. These stiffness and modes 

results show that the light-weighted design will have improved ride and handling and 

improved NVH performance comparing to a vehicle with lower stiffness. 

Vehicle Ride and Handling: In the light-weighted design, the front suspension is 

redesigned using a MacPherson strut instead of the heavier double wishbone used in the 

baseline vehicle. Vehicle ride and handling is evaluated using MSC/ADAMS327 modeling 

on five maneuvers, fish-hook test, double lane change maneuver, pothole test, 0.7G 

constant radius turn test and 0.8G forward braking test. The results from the fish-hook 

test show that the light-weighted vehicle can achieve a five-star rating for rollover, same 

as the baseline vehicle. The double lane change maneuver tests according to the ISO 

standard show that the chosen suspension geometry and vehicle parameters of the lightweighted design are within acceptable range for safe high speed maneuvers. These 

326 LS-DYNA is a software developed by Livermore Software Technologies Corporation used widely by industry
 

and researchers to perform highly non-linear transient finite element analysis. 327 MSC/ADAMS: Macneal-Schwendler Corporation/Automatic Dynamic Analysis of Mechanical Systems. 
                                                      

 

 

440 

simulations are performed to further validate the chosen light-weighted front suspension 

design. 

Durability: There are two types of durability, stress related and corrosion related. Stress 

related durability for the light-weighted vehicle is evaluated using strain-based analysis 

based on pot hole, 0.8G forward braking and 0.7G cornering road load cases using an 

ADAMS model. Results from the simulation show that the life of the light-weighted 

vehicle body structure exceeds the targets. Although timing and funding did not allow 

corrosion testing to be conducted, the Electricore/EDAG/GWU team considered the 

properties of materials used and the location and the functionality of the components to 

avoid potential issues with corrosion. 

Powertrain Performance: The powertrain of the light-weighted vehicle is downsized from 

a 2.4L naturally aspirated engine to a 1.8L naturally aspirated engine to maintain the 

same vehicle acceleration and towing compared to the baseline 2011 Honda Accord. The 

powertrain simulation tool PSAT328 is used to verify and validate the light-weighted 

vehicle for fuel economy and powertrain performance. The light-weighted vehicle with 

the 1.8L NA engine will have 32 mpg fuel economy with comparable 0-30 mph time, 0­

60 mph time, quarter mile time, gradability and maximum speed at grade. The only 

metrics that the light-weighted vehicle performs less than the baseline vehicle is vehicle 

maximum speed (127 mph for the baseline Accord and 112 mph for the light-weighted 

design), which the Electricore/EDAG/GWU team and NHTSA believe is acceptable. As 

a result of the improved fuel economy, the fuel tank for the light-weighted vehicle can be 

reduced from 18.5 gallons to 15.8 gallons with the same driving range, which further 

reduced vehicle weight both by reducing fuel tank mass and the mass of fuel carried by 

the vehicle. 

Manufacturability: The manufacturability of all proposed body structure panels were then 

assessed using simulation tools, which included HYPER-FORM for stamping parts, and 

other single step process simulation tools for parts manufactured using other methods, 

such as hot stamping for B-pillar. 

COST ANALYSIS; A detailed cost analysis for the light weighted design and cost estimates for 

alternative design options were also conducted. For OEM-manufactured parts, a detailed cost 

model was built based on a Technical Cost Modeling (TCM) approach developed by the 

328 PSAT is a plug-and-play architecture software that allows the user to build and evaluate a vehicle's fuel economy 

and powertrain performance under varying load conditions and drive cycles. It uses MATLAB in a Simulink 

environment to record data, calculate and input powertrain requirements based on driver demand and current 

powertrain values. The software is sponsored by the U.S. Department of Energy and developed by Argonne 

National Laboratory (ANL). http://www.transportation.anl.gov/modeling_simulation/PSAT/index.html 
                                                      

 

441 

Massachusetts Institute of Technology (MIT) Materials Systems Laboratory’s research329 for 

estimating the manufacturing costs of OEM parts. The costs were broken down into each of the 

operations involved in the manufacturing, such as for a sheet metal part production by starting 

from blanking the steel coil, until the final operation to fabricate the component. Total costs 

were then categorized into fixed cost, such as tooling, equipment, and facilities; and variable 

costs, such as labor, material, energy, and maintenance. These costs were assessed through an 

interactive process between the product designer, manufacturing engineers and cost analysts. 

For OEM-purchased parts, the costs were estimated by consultation with experienced cost 

analysts and Tier 1 suppliers. Forty-one concise spreadsheets are created for both the baseline 

vehicle and the light-weighted design in the cost model to calculate both the manufacturing and 

assembly costs. 

FINAL RESULTS: To achieve the same vehicle performance as the baseline vehicle, the size of 

the engine for the light-weighted vehicle was proportionally reduced from 2.4L-177 HP to 1.8L140HP. Overall the complete light weight vehicle achieved a total weight savings of 22 percent 

(332 kg) relative to the baseline vehicle (1480 kg) at an incremental cost increase of $319 or 

$0.96 per kg. Without the mass and cost reduction allowance for the powertrain (including 

engine, transmission, fuel system, exhaust system and fuel) the mass saving for the ‘glider’ is 24 

percent (264 kg) at mass saving cost premium of $1.63 per kg of mass saving. The 

Electricore/EDAG/GWU team also developed a cost curve to cover a range of mass reduction 

levels from 0% to 28% for both the full vehicle with engine downsizing and for the glider only. 

When developing the cost curves, the project team used data that were developed in the study to 

derive a mass compounding factor (secondary mass reduction/total mass reduction), which was 

determined to be 0.7. The cost curves are shown in Figure V-45 and Figure V-46. 

329 Frank Field, Randolph Kirchain and Richard Roth, Process cost modeling: Strategic engineering and economic 

evaluation of materials technologies, JOM Journal of the Minerals, Metals and Materials Society, Volume 59, 

Number 10, 21-32. Available at http://msl.mit.edu/publications/Field_KirchainCM_StratEvalMatls.pdf (last 

accessed Jun. 10, 2012). 
442 

Figure V-45 Mass Reduction Cost with Allowance for Powertrain Downsizing 

Figure V-46. Mass Reduction Cost for the Glider Only 
                                                      

443 

PEER REVIEW: The study has been peer reviewed by three technical experts from industry, 

academia and a DOE national lab. In the peer reviewer charge letter, the agency asked the peer 

reviewers to comment on the following five specific items as well as any other potential areas for 

comments. 

 Assumptions and data sources 

 Vehicle design and optimization methodology and its rigorousness 

 Vehicle functionality and crashworthiness testing methodological rigor 

 Vehicle manufacturing cost methodology and its rigorousness 

 Conclusions and findings 

Comments from peer reviewers were generally positive. The peer reviewers concurred with the 

methodologies employed in the study and the technologies applied to the light-weighted design, 

although one peer reviewer commented that not enough composite materials were used in the 

design. One peer reviewer stated in his comments that “the main findings appear to be based on 

sound economic and engineering principles.” The peer reviewers stated that the cost estimates 

developed in the study, particularly based on the TCM model, seem to be reasonable, with one 

peer reviewer commenting the final cost is on the lower side and another commenting it on the 

higher side. All three peer reviewers looked into the details of the CAE and cost modeling. One 

significant concern identified in the peer review was whether the light-weighted vehicle 

maintained the same performance level in the NCAP side MDB test. In response to that concern, 

the Electricore/EDAG/GWU team conducted simulation testing and revised the B-pillar design, 

increasing the gauge for the steel for better performance. Because NCAP only measures injuries 

to dummies and the crash performance of the light-weighted design is based on the vehicle 

center of gravity crash pulse level, B-pillar velocity and passenger compartment and intrusion, to 

assess correlation of the model performance to the baseline vehicle, NHTSA asked a contractor 

who performs NHTSA’s NCAP testing to take additional measurements of the interior intrusion 

for the 2011 baseline Honda Accord. The updated design and the Honda Accord test data showed 

similar intrusion results for both NCAP and IIHS side impact tests, and those results support that 

the light-weighted design could possibly achieve similar NCAP and IIHS ratings, especially 

when the structure design is fine-tuned with the restraint system design, which NHTSA will 

study in the fleet simulation study described later on in this section. For other peer review 

comments, the Electricore/EDAG/GWU team addressed the comments fully in the report and 

also composed a response to peer review comment document, which is included at the end of the 

report. The final report330, CAE model and cost model, and peer review comments331 are 

available in Docket No. NHTSA-2010-0131 and can also be found on NHTSA’s website332. 

330 Electricore/EDAG/GWU, “Mass Reduction for Light-Duty Vehicles for Model Years 2017-2025”, NHTSA 

Docket NHTSA-2010-0131. 

331 “Peer Review for ‘Mass Reduction for Light-Duty Vehicles for Model Year 2017-2025’”, NHTSA Docket 

NHTSA-2010-0131. 

332 http://www.nhtsa.gov/fuel-economy 
                                                      

 

444 

EPA Sponsored Mass Reduction Study 

EPA, along with ICCT, funded a contract with FEV, with subcontractors EDAG (CAE 

modeling) and Munro & Associates, Inc. (component technology research) to study the 

feasibility, safety and cost of 20% mass reduction on a 2017-2020 production ready mid-size 

crossover utility vehicle (CUV) specifically, a Toyota Venza while maintaining cost parity or 

reduction. The EPA report is entitled “Light-Duty Vehicle Mass-Reduction and Cost Analysis – 

Midsize Crossover Utility Vehicle”333 . This study is a Phase 2 study of the low development 

design in the 2010 Lotus Engineering study “An Assessment of Mass Reduction Opportunities 

for a 2017-2020 Model Year Vehicle Program”334, herein described as “Phase 1.” 

LOTUS PHASE 1 STUDY: The original 2009/2010 Phase 1 effort by Lotus Engineering was 

funded by Energy Foundation and ICCT to generate a technical paper which would identify 

potential mass reduction opportunities for a selected vehicle representing the crossover utility 

segment, a 2009 Toyota Venza. Lotus examined mass reduction for two scenarios – a low 

development (20% MR and 2017 production with technology readiness of 2014) and high 

development (40% MR and 2020 production with technology readiness of 2017). Lotus 

disassembled a 2009 Toyota Venza and created a bill of materials (BOM) with all components. 

Lotus then investigated emerging/current technologies and opportunities for mass reduction. The 

report included the BOM for full vehicle, systems, sub-systems and components as well as 

recommendations for next steps. The potential mass reduction for the low development design 

includes material changes to portions of the body in white (underfloor and body, roof, body side, 

etc.), seats, console, trim, brakes, etc. The original powertrain was changed to a hybrid 

configuration. The Phase 1 project achieved 19% (without the powertrain) at 99% of original 

cost at full phase-in after peer review comments taken into consideration.335 This was calculated 

to be -$0.45/kg utilizing information from Lotus. 

The Lotus Phase 1 study created a good foundation for the next step of analyses of CAE 

modeling for safety evaluations and in-depth costing (these steps were not within the scope of 

the Phase 1 study) as noted by the peer reviewer recommendations336. The study was peer 

reviewed. Mr. Sujit Das, of ORNL and an author of several reports on mass reduction, reported 

that the mass reduction opportunities were reasonable and likely to meet the stated objectives. 

Mr. Das also recommended using a consistent cost methodology. Dr. Malen, a professor at the 

333 FEV, “Light-Duty Vehicle Mass-Reduction and Cost Analysis – Midsize Crossover Utility Vehicle.“ July 2012, 

EPA Docket: EPA-HQ-OAR-2010-0799. 

334 Systems Research and Application Corporation, “Peer Review of Demonstrating the Safety and Crashworthiness 

of a 2020 Model-Year, Mass-Reduced Crossover Vehicle (Lotus Phase 2 Report)”, February 2012, EPA docket:
 

EPA-HQ-OAR-2010-0799. 

335 Cost estimates were given in percentages – no actual cost analysis was presented for it was outside the scope of 

the study, though costs were estimated by the agency based on the report. 

336 RTI International,“Peer Review of Lotus Engineering Vehicle Mass Reduction Study” EPA-HQ-OAR-2010­

0799-0710, November 2010. 
 

                                                      

445 

University of Michigan, reported the mass reduction opportunities were reasonable and likely to 

meet the stated objectives and also recommended a data driven methodology that can be 

examined at each step of the analysis337. 

OBJECTIVES OF EPA PHASE 2 STUDY: Objectives for the EPA Phase 2 study included the 

creation of CAE body in white (BIW) models which could be used to analyze body stiffness, 

NVH modal characteristics and crash (FMVSS and NCAP) performance and inclusion of a more 

rigorous cost analysis including tooling and piece cost. In addition, EPA expanded the scope of 

the work to include an updated look (2012) at all of the mass reduction technologies and 

techniques so that FEV was not limited to only the ideas originally generated by Lotus which 

were determined in 2009. As part of this EPA Phase 2 study, FEV/EDAG analyzed the BIW 

ideas from Lotus’s Phase 1 study through CAE modeling and FEV included the technologies for 

mass reduction with the information provided in the Phase 1 Lotus Engineering report for the 

low development scenario. 

Similar to Lotus Phase 1 study, the EPA Phase 2 study begins with vehicle tear down and BOM 

development. FEV and its subcontractors tore down a MY 2010 Toyota Venza in order to create 

a BOM as well as understand the production methods for each component. Each component and 

sub-system chosen for mass reduction was scaled to the dimensions of the baseline vehicle, 

trying to maximize the amount of mass reduction with cost effective technologies and techniques 

that are considered feasible and manufacturable in high volumes in MY2017. FEV, in 

coordination with EDAG, constructed detailed CAD/CAE vehicle models of the body structure 

to account for other vehicle components, to evaluate vehicle safety. In addition to simulating 

various FMVSS and IIHS crash tests with the CAE model, the BIW CAE was evaluated for 

overall torsion mode, overall lateral bending mode, rear end match boxing mode and overall 

vertical bending rear end mode in addition to overall and bending and torsional stiffness. An indepth cost analysis was also completed utilizing several cost models including the one described 

in the NHTSA project above. 

Results for the EPA Phase 2 study of the 1710kg 2010 Toyota Venza include a 18% mass 

reduction (with powertrain) at -$0.49/kg cost (cost savings). While the results for $/kg appear 

similar between the Phase 1 Lotus study (without powertrain, 19% mass reduction at -$0.44/kg), 

it should be noted that each study took slightly different approaches. The Phase 1 study included 

mass reduction of every system except the powertrain. The EPA Phase 2 study focused on the 

vehicle as a whole (including all systems), but also included the powertrain. 

337 RTI International,“Peer Review of Lotus Engineering Vehicle Mass Reduction Study” EPA-HQ-OAR-2010-0799­

0710, November 2010. 
                                                      

 

 

446 

VERIFICATION OF THE LOTUS BIW DESIGN FOR NVH: The study started with a 

teardown of the 2010 Toyota Venza whose parts were then scanned for finite element analysis 

(FEA). Over 140 coupons from the BIW and several from the closures were also sent out to 

laboratories for verification of material properties for the model. The model’s results for static 

bending, static torsion, and modal frequency simulations (NVH) were obtained and compared to 

actual results from a Toyota Venza vehicle338. After confirming that the results were within 

acceptable limits,339 this model was then modified to create a light-weighted vehicle model based 

on the Lotus (phase 1) design and then the tests for NVH were compared. The results revealed 

that the original Lotus design required additional development to meet the acceptability criteria. 

EPA working with EDAG developed a new BIW using a similar material substitution 

methodology as Lotus, which was to exchange materials in parts of the existing design and not 

redesign the entire vehicle from scratch. After several iterations, the new EPA phase 2 design 

fell within the project’s design criteria, i.e.it had NVH results similar to the baseline vehicle. 

UPDATE RESEARCH ON MASS REDUCTION TECHNOLOGIES: FEV and Munro created 

a BOM based on the teardown analysis. Mass reduction technology review was conducted at the 

system and sub-system level. The staff at FEV and Munro consists of experts from the 

automotive industry and discussion also included outside venders of mass reduction 

technologies. Forty of the 150 Lotus Phase 1 concepts were included in the final mass reduction 

technology selection. 

SAFETY FEASIBILITY: Two models, the baseline vehicle and the light-weighted design, were 

developed and analyzed for safety employing a number of FMVSS and EURO NCAP 

protocols.340 Once EDAG confirmed the crash performance of the CAE baseline model was 

comparable to the NHTSA 2009 Toyota Venza vehicle crash results, the light weighted CAE 

model design was developed. The light-weighted CAE model was developed by applying mass 

reduction ideas developed by EDAG (for BIW and closures) and FEV/Munro (remaining vehicle 

systems341). Potential compliance with safety and performance of the light weighted CAE model 

in FMVSS and IIHS tests was inferred using quantitative measurements of vehicle delta velocity 

and intrusion. 

COST ANALYSIS: The development of a bill of materials (BOM), on systems and sub-systems 

by FEV and Munro, was the basis for the cost analysis. This methodology is consistent with the 

peer reviewed approach described earlier in this chapter. The cost for the mass reduced 

338 Note that the actual vehicle had a panoramic roof in its design and so the model was modified for this design and 

results were compared. The model was then re-fit with the full roof and the analysis continued.
 339 The goals for the Phase 1 report include the maintenance of utility/performance including NVH and this was 

interpreted as being within 5% of the modeled baseline value for static bending, static torsion, and modal frequency. 

340 FMVSS includes 208 Flat Frontal, 214 Side Impact, 301 Rear Impact, 216a Roof Crush and EURO NCAP 

includes ODB frontal crash -Euro NCAP/IIHS 40% offset.

341 – for which a center of gravity (CG) was determined to represent all other components.
 
                                                      

 

447 

technologies were developed by determining the difference in cost for those new components 

compared to the old, and under the assumption of production scales of 200,000 units (appropriate 

for the Venza global production). FEV and Munro developed several thousand cost spreadsheets 

as the basis for the cost analyses for the mass reduction technologies and the BIW and closures. 

Costs include manufacturing (material, labor, burden) and markup (end item scrap, Sales, 

General and Administrative (SG&A), Profit, Engineering, Development and Testing (ED&T) 

and Research and Development (R&D)). A separate tooling cost analysis was also performed 

and at 18% mass reduction calculated a $0.05/kg for tooling. The cost analysis of the BIW and 

closures were done by EDAG and were based on a Technical Cost Modeling (TCM) approach 

developed by the Massachusetts Institute of Technology (MIT) Materials Systems Laboratory’s 

research342. 

RESULTS: The light-weighting effort achieved an 18% mass reduction (with downsized 

powertrain343) on the base 1710 kg Toyota Venza at a cost of $-0.49/kg (a cost savings) which 

includes tooling (cost increase of $0.05/kg). A cost curve was developed to show the estimated 

$/kg over a variety of mass reduction levels utilizing the subset of technologies and techniques 

developed throughout the study (see Figure V-47). The two curves represent non-compounded 

mass reduction technologies (“primary”) and compounded mass reduction scenario (a total of 

“primary” and “secondary”). These curves were determined by reviewing the BOM part by part 

and identifying the parts within systems that would benefit from mass reduction and be able to 

utilize mass compounding. It is important to note that the potential for secondary mass reduction 

was evaluated by applying the mass compounding ratio at many points along the whole cost 

curve. The cost curve was used to determine a value for the average cost per kilogram of 

cumulative mass reduction (in terms of $/kg for mass reduction at a specific mass reduction 

level). 

342 Frank Field, Randolph Kirchain and Richard Roth, Process cost modeling: Strategic engineering and economic 

evaluation of materials technologies, JOM Journal of the Minerals, Metals and Materials Society, Volume 59,
 

Number 10, 21-32. Available at http://msl.mit.edu/pubs/docs/Field_KirchainCM_StratEvalMatls.pdf (last accessed 

Aug. 22, 2011). 

343 The engine was downsized and dowweighted, however the number of cylinders remained the same and it
 

remained naturally aspirated.
 
   

Average Cost/Kilogram of Cumulative

Mass Reduction

6.00

4.00

2.00

0.00
 

0%
 5% 10% 15% 20% 25% ‐2.00

‐4.00 w/ Compounding

‐6.00

w/o Compounding
 

‐8.00
 

‐10.00

‐12.00

% Vehicle Mass‐Reduction

448 

Figure V-47 Cost Curve for the 2010 Toyota Venza – EPA Study (FEV/EDAG/Munro) 

PEER REVIEW: The peer review comments for this study were generally positive and 

concurred with the ideas and methodology of the EPA study. The documents for the peer review 

can be found in EPA docket EPA-HQ-OAR-2010-0799. After accounting for peer review 

comments to the draft report, mass reduction decreased by 0.5% and though some of the 

adjustments resulted in a cost savings, the overall cost increased slightly. Changes to the BIW 

CAE models resulted in minimal differences. 

There were many positive comments about the report. While the report included mass reduction 

and cost analyses for several hundred items, there were some concerns identified in the peer 

review comments that influenced the overall amount of mass reduction and the cost. These 

included: 1) engine magnesium block cost, 2) the (brake) rotor design, 3) aluminum hollow 

suspension stabilizer bar, 4) the closure aluminum material cost. 

There were several areas where peer reviewers suggested changes that did not impact percent 

mass reduction or cost. First, more information was included to better describe the wheel mass 

technology. Second the BIW models were updated to eliminate the inconsistencies in material 

assignments - revising the number of through thickness integration points for the shell elements 

and correcting the asymmetrical thickness assignments. Finally, the baseline and optimized BIW 

models were further refined to include definitions of welding properties, transverse shear scale 

factor, element type, element formulation and material failure criteria. Based on these updates 

the crash models were rerun and the results included in the final report. 
449 

California Air Resources Board Sponsored Mass Reduction Study 

The California Air Resources Board (CARB) funded a study with Lotus Engineering to further 

develop the high development design from Lotus’ 2010 Toyota Venza work (“Phase 1”). The 

CARB-sponsored Lotus “Phase 2” study provides the updated design, crash simulation results, 

detailed costing, and analysis of the manufacturing feasibility of the BIW and closures. Based 

on the findings of the safety validation work, Lotus made revisions to strengthen the vehicle 

structure through the use of a more aluminum-intensive BIW (and with less magnesium). In 

addition to the increased use of advanced materials, the new design by Lotus included a number 

of instances in which multiple parts were integrated, resulting in a reduction in the number of 

manufactured parts in the lightweight BIW. The Phase 2 study reports that the number of parts 

in the BIW was reduced from greater than 400 to less than 170. The BIW was analyzed for 

torsional stiffness and crash test safety with Computer-Aided Engineering (CAE). The new 

design’s torsional stiffness was 32.9 kNm/deg, which is higher than the baseline vehicle and 

comparable to more performance-oriented models. The analysis included validation of the 

lightweight vehicle design for standard FMVSS/IIHS front, side, rear, offset, roof, intrusion, and 

seatbelt safety tests. Crash tests simulated in CAE showed results that were listed as acceptable 

for all crash tests analyzed. 

The cost analysis for the Phase 2 lightweight design involved new piece, tooling, and assembly 

work on the BIW and closures, and the technologies and costs for the non-BIW components 

were carried over from the Phase 1 work. The Lotus design achieved a 37% (141 kg) mass 

reduction in the body structure, a 38% (484kg) mass reduction in the vehicle excluding the 

powertrain, and a 32% (537 kg) mass reduction in the entire vehicle including the powertrain. 

The Phase 2 report included an investigation into the manufacturing and assembly processes to 

assess whether the low mass aluminum BIW design can feasibly and cost-effectively be 

constructed for 60,000 units. Lotus found that the assembly and tooling cost savings, due to the 

lower number of BIW parts, relative to the baseline Venza partially offset the 60% increase in 

piece costs for the BIW for a resulting BIW cost increase of $239. Accounting for all of the 

other systems (excluding the powertrain) using the results from Phase I study, the impact is a 

cost savings of $476 for 484 kg reduced, or -$0.98/kg. For the complete vehicle with powertrain 

(hybrid powertrain), the overall cost savings for the whole vehicle including powertrain is $318 

for 537 kg reduced, or -$0.59/kg. The hybrid engine was downsized from 120hp to 100hp and 

the corresponding hybrid system related components were removed or exchanged for a minimal 

change in overall mass. The report was peer reviewed by a cross section of experts, from 

academia, a DOE lab, DOE and an aluminum industry representative and the peer review 

comments are currently being addressed by Lotus and will be available by the final rulemaking. 

The documents will be found in EPA docket EPA-HQ-OAR-2010-0799. The final report is 

also located in this docket and will be available upon approval of the CAFE GHG rulemaking. 

NHTSA Fleet Simulation Study 
                                                      

450 

NHTSA has contracted with GWU to build a fleet simulation model to study the impact and 

relationship of light-weighted vehicle design with injuries and fatalities. This study will also 

include an evaluation of potential countermeasures to reduce any safety concerns associated with 

lightweight vehicles in the second phase. NHTSA has included three light-weighted vehicle 

designs in this study: the one from Electricore/EDAG/GWU mentioned above, one from Lotus 

Engineering funded by California Air Resource Board for the second phase of the study, 

evaluating mass reduction levels around 35 percent of total vehicle mass, and one funded by 

EPA and the International Council on Clean Transportation (ICCT). In addition to the 

lightweight vehicle models, these projects also created CAE models of the baseline vehicles. To 

estimate the fleet safety implications of light-weighting, CAE crash simulation modeling was 

conducted to generate crash pulse and intrusion data for the baseline and three light-weighted 

vehicles when they crash with objects (barriers and poles) and with four other vehicle models 

(Chevy Silverado, Ford Taurus, Toyota Yaris and Ford Explorer) that represent a range of 

current vehicles. The simulated acceleration and intrusion data were used as inputs to 

MADYMO occupant models to estimate driver injury. The crashes were conducted at a range of 

speeds and the occupant injury risks were combined based on the frequency of the crash 

occurring in real world data. The change in driver injury risk between the baseline and lightweighted vehicles will provide insight into the safety performance these light-weighting design 

concepts. This is a large and ambitious project involves several stages over several years. 

NHTSA and GWU have completed the first stage of this study. The frontal crash simulation part 

of the study is being finished and will be peer reviewed. The report for this study will be 

available in NHTSA-2010-0131. Information for this study can also be found at NHTSA’s 

website344. 

The countermeasures section of the study is expected to be finished in early 2013. This phase of 

the study is expected to provide information about the relationship of light-weighted vehicle 

design with injuries and fatalities and to provide the capability to evaluate the potential 

countermeasures to safety concerns associated with light-weighted vehicles. NHTSA plans to 

include the following items in future phases of the study to help better understanding the impact 

of mass reduction on safety. 

 Vehicle crash simulation between two light-weighted concept vehicles; 

 Additional crash configurations, such as side impact, oblique and rear impact 

tests; 

 Risk analysis for elderly and vulnerable occupants; 

 Safety of light-weighted concept vehicles for different size occupants. 

 Partner vehicle protection in crashes with other light-weighted concept vehicles. 

344 Website for fleet study can be found at http://www.nhtsa.gov/fuel-economy. 
451 

While this study is expected to provide information about the relationship of light-weighted 

vehicle design with injuries and fatalities and to provide meaningful information to NHTSA on 

potential countermeasures to reduce any safety concerns associated with lightweight vehicles, 

because this study cannot incorporate all of the variations in vehicle crashes that occur in the real 

world, it is expected to provide trend information on the effect of potential future designs on 

highway safety, but is not expected to provide information that can be used to modify the 

coefficients derived by Kahane that relate mass reduction to highway crash fatalities. Because 

the coefficients from the Kahane study are used in the agencies’ assessment of the amount of 

mass reduction that may be implemented with a neutral effect on highway safety, the fact that the 

fleet simulation modeling study is not complete does not affect the agencies’ assessment of the 

amount of mass reduction that may be implemented with a neutral effect on safety. 

Safety considerations in establishing CAFE/GHG standards along with discussion of NHTSA’s 

February 25, 2011, mass-size-safety workshop at DOT headquarters can be found in Section II.G 

of the preamble for this final rule. NHTSA intends to host additional workshops when the 

studies have reached a sufficient level of completion, to share the results with the public and 

continue the fruitful ongoing public dialogue on these issues. 

Low Drag Brake (LDB) 

Low drag brakes reduce the sliding friction of disc brake pads on rotors when the brakes are not 

engaged, because the brake pads are pulled away from the rotating disc either by mechanical or 

electric methods. 

The 2012-2016 final rule and TAR estimated the effectiveness of low drag brakes to be as high 

as 1 percent. NHTSA and EPA have slightly revised the effectiveness down to 0.8 percent based 

on the 2011 Ricardo study and the updated lumped parameter model. 

In the MYs 2012-2016 final rule, the agencies estimated the DMC at $57 (2007$). This DMC 

becomes $59 (updated to 2010$) for this analysis. The agencies consider low drag brake 

technology to be off the learning curve (i.e., fully learned out, so that the DMC does not change 

year-over-year) and have applied a low complexity ICM of 1.24 through 2018, switching to a 

long-term ICM of 1.19 thereafter. The resultant costs are shown Table V-116. 

Table V-116 Costs for Low Drag Brakes (2010$) 

Cost 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $59 $59 $59 $59 $59 $59 $59 $59 $59 

IC $14 $14 $11 $11 $11 $11 $11 $11 $11 
452 

TC $74 $74 $71 $71 $71 $71 $71 $71 $71 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Low Rolling Resistance Tires – Level 1and Level 2 (ROLL1 and ROLL2) 

Tire rolling resistance is the frictional loss associated mainly with the energy dissipated in the 

deformation of the tires under load and thus influences fuel economy. Other tire design 

characteristics (e.g., materials, construction, and tread design) influence durability, traction (both 

wet and dry grip), vehicle handling, and ride comfort in addition to rolling resistance. A typical 

low rolling resistance tire’s attributes could include increased specified tire inflation pressure, 

material changes, tire construction with less hysteresis, geometry changes (e.g., reduced aspect 

ratios), and reduction in sidewall and tread deflection. These changes would generally be 

accompanied with additional changes to vehicle suspension tuning and/or suspension design. 

The agencies expect that greater reductions in tire rolling resistance will be possible during the 

rulemaking timeframe than are currently available, as tire manufacturers continue to improve 

their products in order to meet increasing demand by auto OEMs for tires that contribute more to 

their vehicles’ fuel efficiency. Thus, for this final rule, consistent with the proposal, the agencies 

considered two “levels” of lower rolling resistance tires. The first level (“ROLL1”) is defined as 

a 10 percent reduction in rolling resistance from a base tire, which was estimated to be a 1 to 2 

percent fuel efficiency effectiveness improvement in MYs 2012-2016 final rule. Based on the 

2011 Ricardo study, the agencies are now using 1.9 percent fuel efficiency effectiveness 

improvement for ROLL1 for all vehicle classes. ROLL1 tires are widely available today, and 

appear to comprise a larger and larger portion of tire manufacturers’ product lines as the 

technology continues to improve and mature. The second level (“ROLL2”) is defined as a 20 

percent reduction in rolling resistance from a base tire, yielding an estimated 3.9 percent 

effectiveness improvement. In the CAFE model this results in a 2.0 percent incremental 

effectiveness increase from ROLL1. ROLL2 represents an additional level of rolling resistance 

improvement beyond what the agencies considered in the MYs 2012-2016 rulemaking analysis. 

NHTSA assumed that the increased traction requirements for braking and handling for 

performance vehicles could not be fully met with the ROLL2 designs in the MYs 2017-2025 

timeframe. For this reason the CAFE model did not apply ROLL2 to performance vehicle 

classifications. However, the agency did assume that tractions requirement for ROLL1 could be 

met in this timeframe and thus allowed ROLL1 to be applied to performance vehicle 

classifications in the MYs 2017-2025 timeframe. 

In the MYs 2012-2016 final rule, the agencies estimated the incremental DMC as $5 (2007$) per 

vehicle. This included costs associated with five tires per vehicle, four primary and one spare 

tire. There is no learning applied to ROLL1 due to the commodity based nature of this 

technology. Looking forward from 2016, the agencies continue to apply this same estimated 
                                                      

 

453 

DMC, as adjusted for 2010 dollars.345 The agencies consider ROLL1 to be fully learned out or 

“off” the learning curve (i.e., the DMC does not change year-over-year) and have applied a low 

complexity ICM of 1.24 through 2018, and a long-term low complexity ICM of 1.19 thereafter, 

due to the fact that this technology is already well established in the marketplace. 

To analyze the feasibility and cost for a second level of rolling resistance improvement, EPA, 

NHTSA, and CARB met with a number of the largest tire suppliers in the United States. The 

suppliers were generally optimistic about the ability to reduce tire rolling resistance in the future 

without the need to sacrifice traction (safety) or tread life (durability). Suppliers all generally 

stated that rolling resistance levels could be reduced by 20 percent relative to today’s tires by 

MY 2017. As such, the agencies agreed, based on these discussions, to consider ROLL2 as 

initially available for purposes of this analysis in MY 2017, but not widespread in the 

marketplace until MYs 2022-2023. In alignment with introduction of new technology, the 

agencies limited the phase-in schedule to 15 percent of a manufacturer’s fleet starting in 2017, 

and did not allow complete application (100 percent of a manufacturer’s fleet) until 2023. The 

agencies believe that this schedule aligns with the necessary efforts for production 

implementation, such as system and electronic system calibration and verification. 

ROLL2 technology does not yet exist in the marketplace today, making cost estimation 

challenging without disclosing potentially confidential business information. To develop a 

transparent cost estimate, the agencies relied on ROLL1 history, costs, market implementation, 

and information provided by the 2010 NAS report. The agencies assumed low rolling resistance 

technology (“ROLL1”) first entered the marketplace in the 1993 time frame with more 

widespread adoption being achieved in recent years, yielding approximately 15 years to maturity 

and widespread adoption. 

Then, using MY 2017 as the starting point for market entry for ROLL2 and taking into account 

the advances in industry knowledge and an assumed increase in demand for improvements in this 

technology, the agencies interpolated DMC for ROLL2 at $10 (2010$) per tire, or $40 ($2010) 

per vehicle. This estimate is generally fairly consistent with CBI suggestions by tire suppliers. 

The agencies have not included a cost for the spare tire because we believe manufacturers are not 

likely to include a ROLL2 as a spare given the $10 DMC. In some cases and when possible 

pending any state-level requirements, manufacturers have removed spare tires replacing them 

with tire repair kits to reduce both cost and weight associated with a spare tire.346 The agencies 

345 As noted elsewhere in this chapter, we show dollar values to the nearest dollar. However, dollars and cents are 

carried through each agency’s respective analysis. Thus, while the cost for lower rolling resistance tires in the 2012­

2016 final rule was shown as $5, the specific value used in that rule was $5.15 (2007$) and is now $5.40 (2010$).
 

We show $5 for presentation simplicity. 

346 “The Disappearing Spare Tire” Edmunds.com, May 11, 2011; http://www.edmunds.com/car-buying/thedisappearing-spare-tire.html (last accessed 9/6/2011) 
                                                      

454 

consider this estimated cost for ROLL2 to be applicable in MY 2021. Further, the agencies 

consider ROLL2 technology to be on the steep portion of the learning curve where costs would 

be reduced quickly in a relative short period of time. The agencies have applied a low 

complexity ICM of 1.24 through 2024, and switching to a long-term ICM of 1.19 thereafter. The 

ICM timing for ROLL2 is different from that for ROLL1 because ROLL2 is brand-new for this 

rulemaking and is not yet being implemented in the fleet. The resultant costs are shown in Table 

V-117. Note that both ROLL1 and ROLL2 are incremental to the baseline system, so ROLL2 is 

not incremental to ROLL1. 

Table V-117 Costs for Lower Rolling Resistance Tires Levels 1 & 2 (2010$) 

Cost 

type 

Lower 

Rolling 

Resistance 

Tire 

Technology 

2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Level 1 $5 $5 $5 $5 $5 $5 $5 $5 $5 

DMC Level 2 $63 $63 $51 $51 $40 $39 $38 $37 $35 

IC Level 1 $1 $1 $1 $1 $1 $1 $1 $1 $1 

IC Level 2 $10 $10 $10 $10 $10 $10 $10 $10 $8 

TC Level 1 $7 $7 $6 $6 $6 $6 $6 $6 $6 

TC Level 2 $73 $73 $60 $60 $50 $49 $48 $47 $43 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Note that both levels of lower rolling resistance tires are incremental to today’s baseline tires. 

Given that the final standards cover such a long timeframe, the agencies also considered 

introducing a third level of rolling resistance reduction (“ROLL3”), defined as a 30 percent 

reduction in rolling resistance. The agencies evaluated the potential of ROLL3 entering the 

marketplace during this proposed rulemaking timeframe. 

Tire technologies that enable improvements of 10 and 20 percent have been in existence for 

many years. Achieving improvements up to 20 percent involves optimizing and integrating 

multiple technologies, with a primary contributor being the adoption of a silica tread 

technology.347 This approach was based on the use of a new silica along with a specific polymer 

and coupling agent combination. The use of the polymer, coupling agent and silica was known 

to reduce tire rolling resistance at the expense of tread wear, but new approach using novel silica 

reduced the tread wear tradeoff. 

Tire suppliers have indicated there are one or more innovations/inventions that they expect to 

occur in order to move the industry to the next quantum reduction of rolling resistance. 

However, based on the historical development and integration of tire technologies, there appears 

347 see U.S Patent 5,227,425, Rauline to Michelin, July 13, 1993 
455 

to be little evidence supporting improvements beyond ROLL2 by 2025. Therefore, the agencies 

decided not to incorporate ROLL3 at this time. 

NHTSA sought comment on whether we should consider application of a 30 percent reduction 

from today’s rolling resistance levels being available for mass production implementation by 

MY 2025 or sooner. We also sought comment on the viability of this technology, maturity by 

MY 2025, as well as market introduction timing and the technological ways that this level of 

rolling resistance improvement will be achieved without any tradeoffs in terms of vehicle 

handling capability and tire life from what consumers expect today. Finally, we sought cost 

information regarding the potential incorporation of ROLL3 relative to today’s costs as well as 

during the timeframe covered by this final rule. No comments were submitted on any of these 

topics. 

Front or secondary axle disconnect for four-wheel drive systems (SAX) 

Energy is required to continually drive the front, or secondary, axle in a four-wheel drive system 

even when the system is not required during most operating conditions. This energy loss directly 

results in increased fuel consumption. Many part-time four-wheel drive systems use some type 

of front axle disconnect to provide shift-on-the-fly capabilities. The front axle disconnect is 

normally part of the front differential assembly. As part of a shift-on-the-fly four-wheel drive 

system, the front axles disconnect serves two basic purposes. First, in two-wheel drive mode, it 

disengages the front axle from the front driveline so the front wheels do not turn the front 

driveline at road speed, saving wear and tear. Second, when shifting from two- to four-wheel 

drive “on the fly” (while moving), the front axle disconnect couples the front axle to the front 

differential side gear only when the transfer case’s synchronizing mechanism has spun the front 

driveshaft up to the same speed as the rear driveshaft. Four-wheel drive systems that have a 

front axle disconnect typically do not have either manual- or automatic-locking hubs. To isolate 

the front wheels from the rest of the front driveline, front axle disconnects use a sliding sleeve to 

connect or disconnect an axle shaft from the front differential side gear. NHTSA and EPA are 

not aware of any manufacturer offering this technology in the U.S. today on unibody frame 

vehicles; however, it is possible this technology could be introduced by manufacturers within the 

MYs 2017-2025 time period. 

The MYs 2012-2016 final rule estimated an effectiveness improvement of 1.0 to 1.5 percent for 

axle disconnect. Based on the 2011 Ricardo report, NHTSA and EPA refined this range to 1.2 to 

1.4 percent for this analysis. 

In the MYs 2012-2016 final rule, the agencies estimated the DMC at $78 (2007$) which was 

considered applicable to MY 2015. This DMC becomes $82 (updated to 2010$) for this 

analysis. The agencies consider secondary axle disconnect technology to be on the flat portion 
456 

of the learning curve and have applied a low complexity ICM of 1.24 through 2018, and then a 

long-term ICM of 1.19 thereafter. The resultant costs are shown in 

Table V-118. 

Table V-118 Costs for Secondary Axle Disconnect (2010$) 

Cost 

type 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC $78 $76 $75 $73 $72 $70 $69 $68 $66 

IC $20 $20 $16 $16 $16 $16 $16 $16 $16 

TC $98 $96 $91 $89 $88 $86 $85 $83 $82 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Aerodynamic Drag Reduction Level 1 and Level 2 (AERO1 and AERO2) 

Many factors affect a vehicle’s aerodynamic drag and the resulting power required to move it 

through the air. The overall drag effect can be simplified as proportional to vehicle’s frontal 

area, vehicle’s drag coefficient, air density and the second order of vehicle’s velocity. Therefore 

reducing vehicle’s frontal area and drag coefficient can reduce fuel consumption. Although 

frontal areas tend to be relatively similar within a vehicle class (mostly due to marketcompetitive size requirements), significant variations in drag coefficient can be observed. 

Significant changes to a vehicle’s aerodynamic performance may need to be implemented during 

a redesign (e.g., changes in vehicle shape). However, shorter-term aerodynamic reductions, with 

a somewhat lower effectiveness, may be achieved through the use of revised exterior 

components (typically at a model refresh in mid-cycle) and add-on devices that are currently 

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 underbody panels, and lower aerodynamic 

drag exterior mirrors. 

In the MYs 2012-2016 final rule, we estimated that a fleet average of 10 to 20 percent total 

aerodynamic drag reduction is attainable which equates to incremental reductions in fuel 

consumption of 2 to 3 percent for both cars and trucks. These numbers are generally supported 

by the Ricardo study and public technical literature and therefore NHTSA and EPA are retaining 

these estimates, as confirmed by joint review, for the purposes of this final rule, consistent with 

the proposal. Importantly, the effectiveness values presented here represent two-cycle 

effectiveness. Because active aerodynamic technologies (i.e., aero level 2) provide additional 

off-cycle benefits, both agencies apply an off-cycle credit value to the technology. Off-cycle 

credits are discussed in Chapter 5 of the Joint TSD. 

For this final rule, consistent with the proposal, the agencies considered two levels of aero 

improvements. The first level is that discussed in MYs 2012-2016 final rule and the 2010 TAR 

and includes such body features as air dams, tire spats, and perhaps one underbody panel. In the 
 

 

 

 

 

 

 

457 

2012-2016 final rule, the agencies estimated the DMC of aero-level 1 at $39 (2007$). This DMC 

becomes $41 (updated to 2010$) for this analysis, applicable in MY 2015. The agencies 

consider aero-level 1 technology to be on the flat portion of the learning curve and have applied 

a low complexity ICM of 1.24 through 2018, and then a long-term ICM of 1.19 thereafter. 

The second level of aero—level 2, which includes such body features as active grille shutters, 

rear visors, larger under body panels or low-profile roof racks —was discussed in the 2010 TAR 

where the agencies estimated the DMC at $120 (2008$) incremental to the baseline vehicle. The 

agencies inadvertently used that cost as inclusive of aero-level 1 technologies when it should 

have been incremental to aero-1 technologies. As a result, the agencies now consider the TAR 

cost to more appropriately be incremental to aero-level 1, with a DMC for this analysis of $123 

(2010$). The agencies consider this cost to be applicable in MY 2015. Further, the agencies 

consider aero-level 2 technology to be on the flat portion of the learning curve. The agencies 

have applied a medium complexity ICM of 1.39 through 2024, and then a long-term ICM of 1.29 

thereafter. The timing of the aero-level 2 ICMs is different than that for the level 1 technology 

because the level 2 technology is newer and not yet being implemented in the fleet. The 

resultant costs are shown in Table V-119. 

Table V-119 Costs for Aerodynamic Drag Improvements – Levels 1 & 2 (2010$) 

Cost 

type 

Aero 

Technology 

Incremental 

to 2017 2018 2019 2020 2021 2022 2023 2024 2025 

DMC Level 1 Baseline $39 $38 $37 $37 $36 $35 $35 $34 $33 

DMC Level 2 Aero-level 1 $117 $115 $112 $110 $108 $106 $104 $102 $100 

IC Level 1 Baseline $10 $10 $8 $8 $8 $8 $8 $8 $8 

IC Level 2 Aero-level 1 $47 $47 $47 $47 $47 $47 $47 $47 $35 

TC Level 1 Baseline $49 $48 $45 $45 $44 $43 $42 $42 $41 

TC Level 2 Aero-level 1 $164 $162 $160 $157 $155 $153 $150 $148 $135 

TC Level 2 Baseline $213 $210 $205 $202 $199 $196 $193 $190 $176 

DMC=Direct manufacturing cost; IC=Indirect cost; TC=Total cost 

Because a large percent of the performance vehicles already have some level of aerodynamic 

treatments, the CAFE model only applies level 1 of aerodynamic treatment to these vehicles. 

Also for specific vehicles, such as Toyota Prius, which already have extensive aerodynamic 

treatment, the level of the aerodynamic that could be further applied by CAFE model is limited 

in the market input file. 
458 

Technologies considered but not included in the final rule analysis 

Lean-Burn Gasoline Direct Injection Technology 

Direct injection, especially with diesel-like “spray-guided” injection systems, enables operation 

with excess air in a stratified or partially-stratified fuel-air mixture, as a way of reducing the 

amount of intake throttling. Also, with higher-pressure fuel injection systems, the fuel may be 

added late enough during the compression stroke so as to delay the onset of auto-ignition, even 

with higher engine compression ratios or with boosted intake pressure. Taken together, an 

optimized “lean-burn” direct injection gasoline engine may achieve high engine thermal 

efficiency which approaches that of a diesel engine. European gasoline direct-injection engines 

have implemented stratified-charge lean-burn GDI, although at higher NOx emissions levels than 

are allowed at under U.S. Federal Tier 2 emissions standards. Fuel system improvements, 

changes in combustion chamber design and repositioning of the injectors have allowed for better 

air/fuel mixing and combustion efficiency. There is currently a shift from wall-guided injection 

to spray guided injection, which improves injection precision and targeting towards the spark 

plug, increasing lean combustion stability. Combined with advances in NOx after-treatment, 

lean-burn GDI engines may eventually be a possibility in North America. 

EPA and NHTSA’s current assessment is that the availability of ultra-low sulfur (ULS less than 

15 ppm sulfur) gasoline is a key technical requirement for lean-burn GDI engines to meet EPA’s 

Tier 2 NOx emissions standards. Since we do not believe that ULS gasoline will be available 

during the model years applicable to these rules, the technology was not applied in EPA or 

NHTSA analyses. 

Homogeneous Charge Compression Ignition 

Gasoline homogeneous charge compression ignition (HCCI), also referred to as controlled 

autoignition (CAI), is an alternate engine operating mode that does not rely on a spark event to 

initiate combustion. The principles are more closely aligned with a diesel combustion cycle, in 

which the compressed charge exceeds a temperature and pressure necessary for spontaneous 

autoignition although it differs from diesel by having a homogenous fuel/air charge rather than 

being a diffusion controlled combustion event. The subsequent combustion event is much 

shorter in duration with higher thermal efficiency. 

An HCCI engine has inherent advantages in its overall efficiency for two main reasons: 

 The engine is operated with a higher compression ratio, and with a shorter combustion 

duration, resulting in a higher thermodynamic efficiency, and 

 The engine can be operated virtually unthrottled, even at light loads. 
 

                                                      

459 

Combined, these effects have shown an increase in engine brake efficiency (typically 25-28 

percent) to greater than 35 percent at the high end of the HCCI operating range.348 

Criteria pollutant emissions are very favorable during HCCI operation. Lower peak in-cylinder 

temperatures (due to high dilution) keep engine-out NOx emissions to a minimum – realistically 

below Tier 2 levels without aftertreatment – and particulates are low due to the homogeneous 

nature of the premixed charge. 

Due to the inherent difficulty in maintaining combustion stability without encountering engine 

knock, HCCI is difficult to control, requiring feedback from in-cylinder pressure sensors and 

rapid engine control logic to optimize combustion timing, especially considering the transient 

nature of operating conditions seen in a vehicle. Due to the highly dilute conditions under which 

gasoline-HCCI combustion is stable, the range of engine loads achievable in a naturallyaspirated engine is somewhat limited. Because of this, it is likely that any commercial 

application would operate in a “dual-mode” strategy between HCCI and spark ignition 

combustion modes, in which HCCI would be utilized for best efficiency at light engine loads and 

spark ignition would be used at higher loads and at idle. This type of dual-mode strategy has 

already been employed in diesel HCCI engines in Europe and Asia (notably the Toyota Avensis 

D-Cat and the Nissan light-duty “MK” combustion diesels). 

Until recently, gasoline-HCCI technology was considered to still be in the research phase. 

However, most manufacturers have made public statements about the viability of incorporating 

HCCI into light-duty passenger vehicles, and have significant vehicle demonstration programs 

aimed at producing a viable product within the next 5-10 years. 

There is widespread opinion as to the fuel consumption reduction potential for HCCI in the 

literature. Based on confidential manufacturer information, EPA and NHTSA believe that a 

gasoline HCCI / GDI dual-mode engine might achieve 10-12% reduction in fuel consumption, 

compared to a comparable SI engine. Despite its promise, application of HCCI in light duty 

vehicles is not yet ready for the market. It is not anticipated to be seen in volume for at least the 

next 5-10 years, which is concurrent with many manufacturers’ public estimates. NHTSA also 

noted in its MY 2011 CAFE final rule that the technology will not be available within the time 

frame considered based on a review of confidential product plan information. 

Electric Assist Turbocharging 

The Alliance commented in prior rulemakings that global development of electric assist turbocharging has not demonstrated the fuel efficiency effectiveness of a 12V EAT up to 2kW power 

levels since the 2004 NESCCAF study, and stated that it saw remote probability of its 

348 “An HCCI Engine Power Plant for a Hybrid Vehicle,” Sun, R., R. Thomas and C. Gray, Jr., SAE Technical 

Paper No. 2004-01-0933, 2004. 
460 

application over the next decade. While hybrid vehicles lower the incremental hardware 

requirements for higher-voltage, higher-power EAT systems, NHTSA and EPA agree that 

significant developmental work is required to demonstrate effective systems and that 

implementation in significant volumes will not occur in the time frame considered in this 

rulemaking. Thus, this technology was not included in the FRM, consistent with the NPRM. 

Fuel cell electric vehicles 

Fuel cell electric vehicles (FCEVs) – utilize a full electric drive platform but consume electricity 

generated by an on-board fuel cell and hydrogen fuel. Fuel cells are electro-chemical devices 

that directly convert reactants (hydrogen and oxygen via air) into electricity, with the potential of 

achieving more than twice the efficiency of conventional internal combustion engines. High 

pressure gaseous hydrogen storage tanks are used by most automakers for FCEVs that are 

currently under development. The high pressure tanks are similar to those used for compressed 

gas storage in more than 10 million CNG vehicles worldwide, except that they are designed to 

operate at a higher pressure (350 bar or 700 bar vs. 250 bar for CNG). Due to the uncertainty of 

the future availability for this technology, FCEVs were not included in any OMEGA or CAFE 

model runs. 

Cost and effectiveness tables 

The following tables representing the CAFE model input files for MY 2017 incremental 

technology costs by vehicle subclass are presented below. The tables have been divided into 

passenger cars, performance passenger cars, and light trucks to make them easier to read. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

461 

Table V-120 Technology Incremental Cost Estimates, Passenger Cars, 2008 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE SUBCLASS 

- PASSENGER CARS 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $60.50 $60.50 $60.50 $60.50 

Low Friction Lubricants and Engine Friction Reduction - Level 2 

LUB2_EFR2 $62.84 $62.84 $62.84 $62.84 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $46.34 $46.34 $46.34 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $163.08 $163.08 $163.08 $163.08 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $46.34 $46.34 $46.34 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $44.26 $44.26 $44.26 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD $163.08 $163.08 $163.08 $163.08 

Continuously Variable Valve Lift (CVVL) CVVL $262.52 $262.52 $262.52 $262.52 

Cylinder Deactivation on DOHC DEACD $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $268.45 $268.45 $268.45 $268.45 

Cylinder Deactivation on OHV DEACO $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $51.93 $51.93 $51.93 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $268.45 $268.45 $268.45 $268.45 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium 

Displacement TRBDS1_MD $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium 

Displacement TRBDS2_MD $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Small Displacement CEGR1_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Medium Displacement CEGR1_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Large Displacement CEGR1_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Small Displacement CEGR2_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Medium Displacement CEGR2_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Large Displacement CEGR2_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement 

ADSL_SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement 

ADSL_MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement 

ADSL_LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 

High Efficiency Gearbox (Manual) HETRANSM $250.87 $250.87 $250.87 $250.87 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

462 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUTO -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT -$108.65 -$108.65 -$74.51 -$74.51 

8-Speed Trans (Auto or DCT) 8SPD $257.36 $257.36 $257.36 $257.36 

High Efficiency Gearbox (Auto or DCT) HETRANS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTOPT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $324.53 $351.07 $385.46 $414.00 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $1,910.10 $1,910.10 $2,290.00 $2,962.35 

Conversion from SHEV1 to SHEV2 

SHEV1_2 $1,222.53 $1,222.53 $1,222.53 $1,490.27 

Strong Hybrid - Level 2 SHEV2 $1,898.75 $1,898.75 $2,290.00 $2,962.35 

Plug-in Hybrid - 30 mi range PHEV1 $10,797.73 $10,797.73 $13,060.13 $17,995.66 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $2,292.75 $2,292.75 $3,577.34 $4,405.48 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $8,323.23 $8,323.23 $10,525.89 $9,581.94 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.00 $0.00 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.00 $0.00 $0.27 $0.48 

Mass Reduction - Level 3 MR3 $0.00 $0.00 $0.00 $0.94 

Mass Reduction - Level 4 MR4 $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 5 MR5 $0.00 $0.00 $0.00 $0.00 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

463 

Table V-121 Technology Incremental Cost Estimates, Passenger Cars, 2010 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE SUBCLASS 

- PASSENGER CARS 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $60.50 $60.50 $60.50 $60.50 

Low Friction Lubricants and Engine Friction Reduction - Level 2 

LUB2_EFR2 $62.84 $62.84 $62.84 $62.84 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $46.34 $46.34 $46.34 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $163.08 $163.08 $163.08 $163.08 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $46.34 $46.34 $46.34 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $44.26 $44.26 $44.26 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD $163.08 $163.08 $163.08 $163.08 

Continuously Variable Valve Lift (CVVL) CVVL $262.52 $262.52 $262.52 $262.52 

Cylinder Deactivation on DOHC DEACD $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $268.45 $268.45 $268.45 $268.45 

Cylinder Deactivation on OHV DEACO $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $51.93 $51.93 $51.93 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $268.45 $268.45 $268.45 $268.45 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Displacement TRBDS1_MD $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Displacement TRBDS2_MD $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Small Displacement CEGR1_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Medium Displacement CEGR1_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Large Displacement CEGR1_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Small Displacement CEGR2_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Medium Displacement CEGR2_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Large Displacement CEGR2_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement 

ADSL_SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement 

ADSL_MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement 

ADSL_LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 
 

 

464 

High Efficiency Gearbox (Manual) HETRANSM $250.87 $250.87 $250.87 $250.87 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUTO -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT -$108.65 -$108.65 -$74.51 -$74.51 

8-Speed Trans (Auto or DCT) 8SPD $257.36 $257.36 $257.36 $257.36 

High Efficiency Gearbox (Auto or DCT) HETRANS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTOPT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $324.53 $351.07 $385.46 $414.00 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $1,932.10 $1,932.10 $2,333.75 $3,053.73 

Conversion from SHEV1 to SHEV2 

SHEV1_2 $1,222.53 $1,222.53 $1,222.53 $1,490.27 

Strong Hybrid - Level 2 SHEV2 $1,920.65 $1,920.65 $2,333.75 $3,053.73 

Plug-in Hybrid - 30 mi range PHEV1 $11,042.77 $11,042.77 $13,448.66 $18,538.03 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $2,416.11 $2,416.11 $3,711.27 $4,614.46 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $8,646.39 $8,646.39 $10,648.50 $9,894.33 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.00 $0.00 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.00 $0.00 $0.27 $0.48 

Mass Reduction - Level 3 MR3 $0.00 $0.00 $0.00 $0.94 

Mass Reduction - Level 4 MR4 $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 5 MR5 $0.00 $0.00 $0.00 $0.00 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

465 

Table V-122 Technology Incremental Cost Estimates, Performance Passenger Cars, 

2008 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE SUBCLASS 

- PERFORMANCE PASSENGER CARS 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $60.50 $90.75 $90.75 $121.00 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_ 

EFR2 $62.84 $94.26 $94.26 $125.68 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $46.34 $92.69 $92.69 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $163.08 $244.61 $244.61 $326.15 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $46.34 $92.69 $92.69 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $44.26 $88.52 $88.52 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVL 

D $163.08 $244.61 $244.61 $326.15 

Continuously Variable Valve Lift (CVVL) CVVL $262.52 $393.78 $393.78 $525.04 

Cylinder Deactivation on DOHC DEAC 

D $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $268.45 $402.68 $402.68 $536.91 

Cylinder Deactivation on OHV DEAC 

O $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $51.93 $103.86 $103.86 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $268.45 $402.68 $402.68 $536.91 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS 

1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium 

Displacement TRBDS 

1_MD $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS 

1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS 

2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium 

Displacement TRBDS 

2_MD $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS 

2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Small Displacement CEGR1 

_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Medium Displacement CEGR1 

_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Large Displacement CEGR1 

_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Small Displacement CEGR2 

_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Medium Displacement CEGR2 

_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Large Displacement CEGR2 

_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement ADSL_ 

SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement ADSL_ 

MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement ADSL_ 

LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

466 

High Efficiency Gearbox (Manual) HETRA 

NSM $250.87 $250.87 $250.87 $250.87 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUT 

O -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT -$74.51 -$74.51 -$74.51 -$74.51 

8-Speed Trans (Auto or DCT) 8SPD $257.36 $257.36 $257.36 $257.36 

High Efficiency Gearbox (Auto or DCT) HETRA 

NS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTO 

PT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $324.53 $351.07 $385.46 $414.00 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $1,910.10 $1,910.10 $2,290.00 $2,962.35 

Conversion from SHEV1 to SHEV2 SHEV1 

_2 $1,222.53 $1,490.27 $1,490.27 $876.90 

Strong Hybrid - Level 2 SHEV2 $1,898.75 $1,898.75 $2,290.00 $2,962.35 

Plug-in Hybrid - 30 mi range PHEV1 $10,797.73 $10,797.73 $13,060.13 $17,995.66 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $2,292.75 $2,292.75 $3,577.34 $4,405.48 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $8,323.23 $8,323.23 $10,525.89 $9,581.94 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.00 $0.00 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.00 $0.00 $0.27 $0.48 

Mass Reduction - Level 3 MR3 $0.00 $0.00 $0.00 $0.94 

Mass Reduction - Level 4 MR4 $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 5 MR5 $0.00 $0.00 $0.00 $0.00 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

467 

Table V-123 Technology Incremental Cost Estimates, Performance Passenger Cars, 

2010 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE SUBCLASS 

- PERFORMANCE PASSENGER CARS 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $60.50 $90.75 $90.75 $121.00 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_ 

EFR2 $62.84 $94.26 $94.26 $125.68 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $46.34 $92.69 $92.69 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $163.08 $244.61 $244.61 $326.15 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $46.34 $92.69 $92.69 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $44.26 $88.52 $88.52 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVL 

D $163.08 $244.61 $244.61 $326.15 

Continuously Variable Valve Lift (CVVL) CVVL $262.52 $393.78 $393.78 $525.04 

Cylinder Deactivation on DOHC DEACD $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $268.45 $402.68 $402.68 $536.91 

Cylinder Deactivation on OHV DEACO $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $51.93 $103.86 $103.86 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $268.45 $402.68 $402.68 $536.91 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS 

1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium 

Displacement TRBDS 

1_MD $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS 

1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS 

2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium 

Displacement TRBDS 

2_MD $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS 

2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Small Displacement CEGR1 

_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Medium Displacement CEGR1 

_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Large Displacement CEGR1 

_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Small Displacement CEGR2 

_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Medium Displacement CEGR2 

_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Large Displacement CEGR2 

_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement ADSL_ 

SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement ADSL_ 

MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement ADSL_ 

LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

468 

High Efficiency Gearbox (Manual) HETRA 

NSM $250.87 $250.87 $250.87 $250.87 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUT 

O -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT -$74.51 -$74.51 -$74.51 -$74.51 

8-Speed Trans (Auto or DCT) 8SPD $257.36 $257.36 $257.36 $257.36 

High Efficiency Gearbox (Auto or DCT) HETRA 

NS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTO 

PT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $324.53 $351.07 $385.46 $414.00 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $1,932.10 $1,932.10 $2,333.75 $3,053.73 

Conversion from SHEV1 to SHEV2 SHEV1 

_2 $1,222.53 $1,490.27 $1,490.27 $876.90 

Strong Hybrid - Level 2 SHEV2 $1,920.65 $1,920.65 $2,333.75 $3,053.73 

Plug-in Hybrid - 30 mi range PHEV1 $11,042.77 $11,042.77 $13,448.66 $18,538.03 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $2,416.11 $2,416.11 $3,711.27 $4,614.46 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $8,646.39 $8,646.39 $10,648.50 $9,894.33 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.00 $0.00 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.00 $0.00 $0.27 $0.48 

Mass Reduction - Level 3 MR3 $0.00 $0.00 $0.00 $0.94 

Mass Reduction - Level 4 MR4 $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 5 MR5 $0.00 $0.00 $0.00 $0.00 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

469 

Table V-124 Technology Incremental Cost Estimates, Light Trucks, 2008 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE SUBCLASS 

- LIGHT TRUCKS 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $90.75 $60.50 $90.75 $121.00 

Low Friction Lubricants and Engine Friction Reduction - Level 2 

LUB2_EFR2 $94.26 $62.84 $94.26 $125.68 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $92.69 $46.34 $92.69 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $244.61 $163.08 $244.61 $326.15 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $92.69 $46.34 $92.69 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $88.52 $44.26 $88.52 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD $244.61 $163.08 $244.61 $326.15 

Continuously Variable Valve Lift (CVVL) CVVL $393.78 $262.52 $393.78 $525.04 

Cylinder Deactivation on DOHC DEACD $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $402.68 $268.45 $402.68 $536.91 

Cylinder Deactivation on OHV DEACO $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $103.86 $51.93 $103.86 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $402.68 $268.45 $402.68 $536.91 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium 

Displacement TRBDS1_M 

D $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium 

Displacement TRBDS2_M 

D $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Small Displacement CEGR1_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Medium Displacement CEGR1_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Large Displacement CEGR1_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Small Displacement CEGR2_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Medium Displacement CEGR2_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Large Displacement CEGR2_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement 

ADSL_SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement 

ADSL_MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement 

ADSL_LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

470 

High Efficiency Gearbox (Manual) HETRANSM $250.87 $250.87 $250.87 $250.87 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUTO -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT $0.00 -$74.51 $0.00 $0.00 

8-Speed Trans (Auto or DCT) 8SPD $80.32 $257.36 $80.32 $80.32 

High Efficiency Gearbox (Auto or DCT) HETRANS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTOPT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $414.00 $366.17 $424.17 $479.57 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $2,689.41 $2,141.46 $2,689.41 $3,069.02 

Conversion from SHEV1 to SHEV2 

SHEV1_2 $1,490.27 $1,222.53 $1,490.27 $876.90 

Strong Hybrid - Level 2 SHEV2 $2,689.41 $2,141.46 $2,689.41 $3,069.02 

Plug-in Hybrid - 30 mi range PHEV1 $0.00 $12,373.67 $0.00 $0.00 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $0.00 $2,288.55 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $0.00 $11,602.07 $0.00 $0.00 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.08 $0.08 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.48 $0.48 $0.48 $0.48 

Mass Reduction - Level 3 MR3 $0.94 $0.94 $0.94 $0.94 

Mass Reduction - Level 4 MR4 $1.50 $1.50 $1.50 $1.50 

Mass Reduction - Level 5 MR5 $2.10 $2.10 $2.10 $2.10 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

471 

Table V-125 Technology Incremental Cost Estimates, Light Trucks, 2010 Baseline 

VEHICLE TECHNOLOGY ICM COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE 

SUBCLASS 

- LIGHT TRUCKS 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Low Friction Lubricants - Level 1 LUB1 $4.02 $4.02 $4.02 $4.02 

Engine Friction Reduction - Level 1 EFR1 $90.75 $60.50 $90.75 $121.00 

Low Friction Lubricants and Engine Friction Reduction - Level 2 

LUB2_EFR2 $94.26 $62.84 $94.26 $125.68 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on 

SOHC CCPS $92.69 $46.34 $92.69 $92.69 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS $244.61 $163.08 $244.61 $326.15 

Cylinder Deactivation on SOHC DEACS $32.47 $32.47 $32.47 $32.47 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP $92.69 $46.34 $92.69 $92.69 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP $88.52 $44.26 $88.52 $88.52 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD $244.61 $163.08 $244.61 $326.15 

Continuously Variable Valve Lift (CVVL) CVVL $393.78 $262.52 $393.78 $525.04 

Cylinder Deactivation on DOHC DEACD $32.47 $32.47 $32.47 $32.47 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $402.68 $268.45 $402.68 $536.91 

Cylinder Deactivation on OHV DEACO $207.75 $207.75 $207.75 $207.75 

Variable Valve Actuation - CCP and DVVL on OHV VVA $103.86 $51.93 $103.86 $103.86 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO $402.68 $268.45 $402.68 $536.91 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small 

Displacement TRBDS1_SD $493.60 $493.60 $493.60 $493.60 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium 

Displacement TRBDS1_M 

D $19.39 $19.39 $19.39 $19.39 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large 

Displacement TRBDS1_LD $620.79 $620.79 $620.79 $620.79 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small 

Displacement TRBDS2_SD $26.06 $26.06 $26.06 $26.06 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium 

Displacement TRBDS2_M 

D $262.37 $262.37 $262.37 $262.37 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large 

Displacement TRBDS2_LD $442.27 $442.27 $442.27 $442.27 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Small Displacement CEGR1_SD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Medium Displacement CEGR1_MD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) ­

Large Displacement CEGR1_LD $302.18 $302.18 $302.18 $302.18 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Small Displacement CEGR2_SD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Medium Displacement CEGR2_MD $524.75 $524.75 $524.75 $524.75 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) ­

Large Displacement CEGR2_LD -$299.93 -$299.93 -$299.93 -$299.93 

Advanced Diesel - Small Displacement 

ADSL_SD $888.62 $888.62 $888.62 $888.62 

Advanced Diesel - Medium Displacement 

ADSL_MD $854.97 $854.97 $854.97 $854.97 

Advanced Diesel - Large Displacement 

ADSL_LD $1,709.99 $1,709.99 $1,709.99 $1,709.99 

6-Speed Manual/Improved Internals 6MAN $279.19 $279.19 $279.19 $279.19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

472 

High Efficiency Gearbox (Manual) HETRANSM $250.87 $250.87 $250.87 $250.87 

Improved Auto. Trans. Controls/Externals IATC $62.25 $62.25 $62.25 $62.25 

6-Speed Trans with Improved Internals (Auto) NAUTO -$39.06 -$39.06 -$39.06 -$39.06 

6-speed DCT DCT $0.00 -$74.51 $0.00 $0.00 

8-Speed Trans (Auto or DCT) 8SPD $80.32 $257.36 $80.32 $80.32 

High Efficiency Gearbox (Auto or DCT) HETRANS $250.87 $250.87 $250.87 $250.87 

Shift Optimizer SHFTOPT $1.67 $1.67 $1.67 $1.67 

Electric Power Steering EPS $109.42 $109.42 $109.42 $109.42 

Improved Accessories - Level 1 IACC1 $88.99 $88.99 $88.99 $88.99 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% 

efficient alternator) IACC2 $54.17 $54.17 $54.17 $54.17 

12V Micro-Hybrid (Stop-Start) MHEV $414.00 $366.17 $424.17 $479.57 

Integrated Starter Generator ISG $975.85 $975.85 $975.85 $975.85 

Strong Hybrid - Level 1 SHEV1 $2,723.05 $2,204.77 $2,723.05 $3,110.95 

Conversion from SHEV1 to SHEV2 

SHEV1_2 $1,490.27 $1,222.53 $1,490.27 $876.90 

Strong Hybrid - Level 2 SHEV2 $2,723.05 $2,204.77 $2,723.05 $3,110.95 

Plug-in Hybrid - 30 mi range PHEV1 $0.00 $12,828.40 $0.00 $0.00 

Plug-in Hybrid PHEV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $0.00 $2,207.55 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 100 mile range EV2 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Early Adopter) - 150 mile range EV3 $0.00 $0.00 $0.00 $0.00 

Electric Vehicle (Broad Market) - 150 mile range EV4 $0.00 $11,739.32 $0.00 $0.00 

Fuel Cell Vehicle FCV $0.00 $0.00 $0.00 $0.00 

Mass Reduction - Level 1 MR1 $0.08 $0.08 $0.08 $0.08 

Mass Reduction - Level 2 MR2 $0.48 $0.48 $0.48 $0.48 

Mass Reduction - Level 3 MR3 $0.94 $0.94 $0.94 $0.94 

Mass Reduction - Level 4 MR4 $1.50 $1.50 $1.50 $1.50 

Mass Reduction - Level 5 MR5 $2.10 $2.10 $2.10 $2.10 

Low Rolling Resistance Tires - Level 1 ROLL1 $6.71 $6.71 $6.71 $6.71 

Low Rolling Resistance Tires - Level 2 ROLL2 $73.16 $73.16 $73.16 $73.16 

Low Rolling Resistance Tires - Level 3 ROLL3 $0.00 $0.00 $0.00 $0.00 

Low Drag Brakes LDB $73.77 $73.77 $73.77 $73.77 

Secondary Axle Disconnect SAX $97.67 $97.67 $97.67 $97.67 

Aero Drag Reduction, Level 1 AERO1 $48.92 $48.92 $48.92 $48.92 

Aero Drag Reduction, Level 2 AERO2 $164.44 $164.44 $164.44 $164.44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

473 

The tables representing the CAFE model input files for incremental technology effectiveness 

values by vehicle subclass are presented below. The tables have been divided into passenger 

cars, performance passenger cars, and light trucks to make them easier to read. 

Table V-126 Technology Incremental Effectiveness Estimates, Passenger Cars 

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) BY VEHICLE SUBCLASS 

- PASSENGER CARS 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Low Friction Lubricants - Level 1 LUB1 0.50% 0.50% 0.70% 0.80% 

Engine Friction Reduction - Level 1 EFR1 2.00% 2.00% 2.60% 2.70% 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_EFR2 1.04% 1.04% 1.26% 1.37% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC CCPS 4.15% 4.15% 5.03% 5.36% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 2.81% 2.81% 3.64% 3.88% 

Cylinder Deactivation on SOHC DEACS 0.44% 0.44% 0.69% 0.69% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2.18% 2.18% 2.62% 2.73% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 2.01% 2.01% 2.47% 2.70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 2.81% 2.81% 3.64% 3.88% 

Continuously Variable Valve Lift (CVVL) CVVL 3.57% 3.57% 4.63% 4.88% 

Cylinder Deactivation on DOHC DEACD 0.44% 0.44% 0.69% 0.69% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 1.56% 1.56% 1.50% 1.51% 

Cylinder Deactivation on OHV DEACO 4.66% 4.66% 5.86% 6.30% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 2.72% 2.72% 3.45% 3.59% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1.56% 1.56% 1.50% 1.51% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – Small Disp. TRBDS1_SD 7.20% 7.20% 8.29% 8.61% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Disp. TRBDS1_MD 6.70% 6.70% 7.49% 7.79% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Disp. TRBDS1_LD 6.70% 6.70% 7.49% 7.79% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Disp. TRBDS2_SD 2.92% 2.92% 3.54% 3.71% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Disp. TRBDS2_MD 2.92% 2.92% 3.54% 3.71% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displ. TRBDS2_LD 2.92% 2.92% 3.54% 3.71% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 1.04% 1.04% 1.36% 1.38% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1.04% 1.04% 1.36% 1.38% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1.04% 1.04% 1.36% 1.38% 

Advanced Diesel - Small Displacement ADSL_SD 5.53% 5.53% 2.75% 2.89% 

Advanced Diesel - Medium Displacement ADSL_MD 5.53% 5.53% 2.75% 2.89% 

Advanced Diesel - Large Displacement ADSL_LD 5.53% 5.53% 2.75% 2.89% 

6-Speed Manual/Improved Internals 6MAN 2.02% 2.02% 2.39% 2.34% 

High Efficiency Gearbox (Manual) HETRANSM 3.44% 3.44% 4.08% 3.85% 

Improved Auto. Trans. Controls/Externals IATC 2.30% 2.30% 3.00% 3.10% 

6-Speed Trans with Improved Internals (Auto) NAUTO 1.89% 1.89% 2.04% 2.04% 

6-speed DCT DCT 4.01% 4.01% 4.06% 3.75% 

8-Speed Trans (Auto or DCT) 8SPD 3.85% 3.85% 4.57% 4.56% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2.17% 2.17% 2.68% 2.56% 

Shift Optimizer SHFTOPT 3.27% 3.27% 4.08% 4.31% 

Electric Power Steering EPS 1.50% 1.50% 1.30% 1.10% 

Improved Accessories - Level 1 IACC1 1.22% 1.22% 1.22% 1.01% 

Improved Accessories - Level 2 IACC2 1.85% 1.85% 2.36% 2.55% 

12V Micro-Hybrid (Stop-Start) MHEV 1.68% 1.68% 2.10% 2.20% 

Integrated Starter Generator ISG 7.45% 7.45% 6.55% 6.43% 

Strong Hybrid - Level 1 SHEV1 7.82% 7.82% 5.30% 6.14% 

Conversion from SHEV1 to SHEV2 SHEV1_2 10.05% 10.05% 12.46% 12.63% 

Strong Hybrid - Level 2 SHEV2 3.01% 3.01% 0.11% 0.63% 

Plug-in Hybrid - 30 mi range PHEV1 40.65% 40.65% 40.65% 40.65% 

Plug-in Hybrid PHEV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 68.54% 68.54% 68.54% 68.54% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0.00% 0.00% 0.00% 0.00% 
 

474 

Fuel Cell Vehicle FCV 0.00% 0.00% 0.00% 0.00% 

Mass Reduction - Level 1 MR1 0.00% 0.00% 0.53% 0.53% 

Mass Reduction - Level 2 MR2 0.00% 0.00% 0.70% 3.32% 

Mass Reduction - Level 3 MR3 0.00% 0.00% 0.00% 1.33% 

Mass Reduction - Level 4 MR4 0.00% 0.00% 0.00% 0.00% 

Mass Reduction - Level 5 MR5 0.00% 0.00% 0.00% 0.00% 

Low Rolling Resistance Tires - Level 1 ROLL1 1.90% 1.90% 1.90% 1.90% 

Low Rolling Resistance Tires - Level 2 ROLL2 2.04% 2.04% 2.04% 2.04% 

Low Rolling Resistance Tires - Level 3 ROLL3 0.00% 0.00% 0.00% 0.00% 

Low Drag Brakes LDB 0.80% 0.80% 0.80% 0.80% 

Secondary Axle Disconnect SAX 1.40% 1.40% 1.40% 1.30% 

Aero Drag Reduction, Level 1 AERO1 2.30% 2.30% 2.30% 2.30% 

Aero Drag Reduction, Level 2 AERO2 2.46% 2.46% 2.46% 2.46% 
 

 

 

 

 

 

 

 

475 

Table V-127 Technology Incremental Effectiveness Estimates, Performance Cars 

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) BY VEHICLE SUBCLASS 

- PERFORMANCE PASSENGER CARS 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Low Friction Lubricants - Level 1 LUB1 0.50% 0.50% 0.70% 0.80% 

Engine Friction Reduction - Level 1 EFR1 2.00% 2.00% 2.60% 2.70% 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_EFR2 1.04% 1.04% 1.26% 1.37% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC CCPS 4.15% 4.15% 5.03% 5.36% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 2.81% 2.81% 3.64% 3.88% 

Cylinder Deactivation on SOHC DEACS 0.44% 0.44% 0.69% 0.69% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2.18% 2.18% 2.62% 2.73% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 2.01% 2.01% 2.47% 2.70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 2.81% 2.81% 3.64% 3.88% 

Continuously Variable Valve Lift (CVVL) CVVL 3.57% 3.57% 4.63% 4.88% 

Cylinder Deactivation on DOHC DEACD 0.44% 0.44% 0.69% 0.69% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 1.56% 1.56% 1.50% 1.51% 

Cylinder Deactivation on OHV DEACO 4.66% 4.66% 5.86% 6.30% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 2.72% 2.72% 3.45% 3.59% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1.56% 1.56% 1.50% 1.51% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – Small Disp. TRBDS1_SD 7.20% 7.20% 8.29% 8.61% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Disp. TRBDS1_MD 6.70% 6.70% 7.49% 7.79% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Disp. TRBDS1_LD 6.70% 6.70% 7.49% 7.79% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Disp. TRBDS2_SD 2.92% 2.92% 3.54% 3.71% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Disp. TRBDS2_MD 2.92% 2.92% 3.54% 3.71% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displ. TRBDS2_LD 2.92% 2.92% 3.54% 3.71% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 3.63% 3.63% 3.54% 3.46% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 1.04% 1.04% 1.36% 1.38% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1.04% 1.04% 1.36% 1.38% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1.04% 1.04% 1.36% 1.38% 

Advanced Diesel - Small Displacement ADSL_SD 5.53% 5.53% 2.75% 2.89% 

Advanced Diesel - Medium Displacement ADSL_MD 5.53% 5.53% 2.75% 2.89% 

Advanced Diesel - Large Displacement ADSL_LD 5.53% 5.53% 2.75% 2.89% 

6-Speed Manual/Improved Internals 6MAN 2.02% 2.02% 2.39% 2.34% 

High Efficiency Gearbox (Manual) HETRANSM 3.44% 3.44% 4.08% 3.85% 

Improved Auto. Trans. Controls/Externals IATC 2.30% 2.30% 3.00% 3.10% 

6-Speed Trans with Improved Internals (Auto) NAUTO 1.89% 1.89% 2.04% 2.04% 

6-speed DCT DCT 3.38% 3.38% 4.06% 3.75% 

8-Speed Trans (Auto or DCT) 8SPD 4.48% 4.48% 4.57% 4.56% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2.17% 2.17% 2.68% 2.56% 

Shift Optimizer SHFTOPT 3.27% 3.27% 4.08% 4.31% 

Electric Power Steering EPS 1.50% 1.50% 1.30% 1.10% 

Improved Accessories - Level 1 IACC1 1.22% 1.22% 1.22% 1.01% 

Improved Accessories - Level 2 IACC2 1.85% 1.85% 2.36% 2.55% 

12V Micro-Hybrid (Stop-Start) MHEV 1.68% 1.68% 2.10% 2.20% 

Integrated Starter Generator ISG 7.45% 7.45% 6.55% 6.43% 

Strong Hybrid - Level 1 SHEV1 7.82% 7.82% 5.30% 6.14% 

Conversion from SHEV1 to SHEV2 SHEV1_2 10.05% 10.05% 12.46% 12.63% 

Strong Hybrid - Level 2 SHEV2 3.01% 3.01% 0.11% 0.63% 

Plug-in Hybrid - 30 mi range PHEV1 40.65% 40.65% 40.65% 40.65% 

Plug-in Hybrid PHEV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 68.54% 68.54% 68.54% 68.54% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0.00% 0.00% 0.00% 0.00% 

Fuel Cell Vehicle FCV 0.00% 0.00% 0.00% 0.00% 

Mass Reduction - Level 1 MR1 0.00% 0.00% 0.53% 0.53% 

Mass Reduction - Level 2 MR2 0.00% 0.00% 0.70% 3.32% 
476 

Mass Reduction - Level 3 MR3 0.00% 0.00% 0.00% 1.33% 

Mass Reduction - Level 4 MR4 0.00% 0.00% 0.00% 0.00% 

Mass Reduction - Level 5 MR5 0.00% 0.00% 0.00% 0.00% 

Low Rolling Resistance Tires - Level 1 ROLL1 1.90% 1.90% 1.90% 1.90% 

Low Rolling Resistance Tires - Level 2 ROLL2 2.04% 2.04% 2.04% 2.04% 

Low Rolling Resistance Tires - Level 3 ROLL3 0.00% 0.00% 0.00% 0.00% 

Low Drag Brakes LDB 0.80% 0.80% 0.80% 0.80% 

Secondary Axle Disconnect SAX 1.40% 1.40% 1.40% 1.30% 

Aero Drag Reduction, Level 1 AERO1 2.30% 2.30% 2.30% 2.30% 

Aero Drag Reduction, Level 2 AERO2 2.46% 2.46% 2.46% 2.46% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

477 

Table V-128 Technology Incremental Effectiveness Estimates, Light Trucks 

VEHICLE TECHNOLOGY INCREMENTAL FUEL CONSUMPTION REDUCTION (-%) BY VEHICLE SUBCLASS 

- LIGHT TRUCKS 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Low Friction Lubricants - Level 1 LUB1 0.70% 0.60% 0.70% 0.70% 

Engine Friction Reduction - Level 1 EFR1 2.60% 2.00% 2.60% 2.40% 

Low Friction Lubricants and Engine Friction Reduction - Level 2 LUB2_EFR2 1.26% 0.83% 1.26% 1.15% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC CCPS 5.03% 4.14% 5.03% 4.80% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 3.53% 2.81% 3.53% 3.40% 

Cylinder Deactivation on SOHC DEACS 0.69% 0.44% 0.69% 0.57% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2.51% 2.17% 2.51% 2.51% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 2.58% 2.01% 2.58% 2.36% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 3.53% 2.81% 3.53% 3.40% 

Continuously Variable Valve Lift (CVVL) CVVL 4.52% 3.56% 4.52% 4.28% 

Cylinder Deactivation on DOHC DEACD 0.69% 0.44% 0.69% 0.57% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 1.50% 1.56% 1.50% 1.48% 

Cylinder Deactivation on OHV DEACO 5.86% 4.66% 5.86% 5.53% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3.34% 2.71% 3.34% 3.20% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1.50% 1.56% 1.50% 1.48% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – Small Disp. TRBDS1_SD 8.74% 7.08% 8.74% 7.96% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Disp. TRBDS1_MD 7.94% 6.58% 7.94% 7.30% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Disp. TRBDS1_LD 7.94% 6.58% 7.94% 7.30% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Disp. TRBDS2_SD 3.43% 2.91% 3.43% 3.38% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Disp. TRBDS2_MD 3.43% 2.91% 3.43% 3.38% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Disp. TRBDS2_LD 3.43% 2.91% 3.43% 3.38% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3.55% 3.63% 3.55% 3.62% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3.55% 3.63% 3.55% 3.62% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 3.55% 3.63% 3.55% 3.62% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 1.09% 1.04% 1.09% 1.21% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1.09% 1.04% 1.09% 1.21% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1.09% 1.04% 1.09% 1.21% 

Advanced Diesel - Small Displacement ADSL_SD 3.44% 5.31% 3.44% 3.48% 

Advanced Diesel - Medium Displacement ADSL_MD 3.44% 5.31% 3.44% 3.48% 

Advanced Diesel - Large Displacement ADSL_LD 3.44% 5.31% 3.44% 3.48% 

6-Speed Manual/Improved Internals 6MAN 2.24% 2.21% 2.24% 2.52% 

High Efficiency Gearbox (Manual) HETRANSM 3.71% 3.90% 3.71% 4.45% 

Improved Auto. Trans. Controls/Externals IATC 2.90% 2.40% 2.90% 2.90% 

6-Speed Trans with Improved Internals (Auto) NAUTO 2.03% 2.00% 2.03% 2.13% 

6-speed DCT DCT 0.00% 3.81% 0.00% 0.00% 

8-Speed Trans (Auto or DCT) 8SPD 4.90% 4.18% 4.90% 5.34% 

High Efficiency Gearbox (Auto or DCT) HETRANS 3.14% 2.52% 3.14% 3.72% 

Shift Optimizer SHFTOPT 4.05% 3.29% 4.05% 3.86% 

Electric Power Steering EPS 1.00% 1.20% 1.00% 0.80% 

Improved Accessories - Level 1 IACC1 0.91% 1.01% 0.91% 1.61% 

Improved Accessories - Level 2 IACC2 2.34% 1.74% 2.34% 2.15% 

12V Micro-Hybrid (Stop-Start) MHEV 2.09% 1.77% 2.09% 2.09% 

Integrated Starter Generator ISG 5.65% 6.14% 5.65% 2.99% 

Strong Hybrid - Level 1 SHEV1 -0.33% 8.24% -0.33% 1.06% 

Conversion from SHEV1 to SHEV2 SHEV1_2 17.13% 10.93% 17.13% 17.87% 

Strong Hybrid - Level 2 SHEV2 -0.33% 4.25% -0.33% 1.59% 

Plug-in Hybrid - 30 mi range PHEV1 40.65% 40.65% 40.65% 40.65% 

Plug-in Hybrid PHEV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 68.54% 68.54% 68.54% 68.54% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0.00% 0.00% 0.00% 0.00% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0.00% 0.00% 0.00% 0.00% 

Fuel Cell Vehicle FCV 0.00% 0.00% 0.00% 0.00% 

Mass Reduction - Level 1 MR1 0.53% 0.53% 0.53% 0.53% 

Mass Reduction - Level 2 MR2 3.32% 3.32% 3.32% 3.32% 

Mass Reduction - Level 3 MR3 1.33% 1.33% 1.33% 1.33% 
 

478 

Mass Reduction - Level 4 MR4 2.69% 2.69% 2.69% 2.69% 

Mass Reduction - Level 5 MR5 2.76% 2.76% 2.76% 2.76% 

Low Rolling Resistance Tires - Level 1 ROLL1 1.90% 1.90% 1.90% 1.90% 

Low Rolling Resistance Tires - Level 2 ROLL2 2.04% 2.04% 2.04% 2.04% 

Low Rolling Resistance Tires - Level 3 ROLL3 0.00% 0.00% 0.00% 0.00% 

Low Drag Brakes LDB 0.80% 0.80% 0.80% 0.80% 

Secondary Axle Disconnect SAX 1.30% 1.40% 1.30% 1.60% 

Aero Drag Reduction, Level 1 AERO1 2.30% 2.30% 2.30% 2.30% 

Aero Drag Reduction, Level 2 AERO2 2.46% 2.46% 2.46% 2.46% 
 

 

 

 

 

 

 

 

 

 

 

 

 

479 

The following tables representing the CAFE model input files for MY 2017, MY 2021 and MY 

2025 approximate net (accumulated) technology costs by vehicle subclass are presented below. 

The tables have been divided into passenger cars, performance passenger cars, and light trucks to 

make them easier to read. 

Table V-129 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $638 $638 $638 $961 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $1,131 $1,131 $1,131 $981 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,157 $1,157 $1,157 $1,243 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,460 $1,460 $1,460 $1,545 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,984 $1,984 $1,984 $2,070 

Advanced Diesel ADSL $2,873 $2,873 $2,873 $2,925 

6-speed DCT DCT ($85) ($85) ($51) ($51) 

8-Speed Trans (Auto or DCT) 8SPD $172 $172 $206 $206 

Shift Optimizer SHFTOPT $424 $424 $459 $459 

12V Micro-Hybrid (Stop-Start) MHEV $577 $604 $638 $667 

Mild Hybrid (Integrated Starter Generator) ISG $1,553 $1,579 $1,614 $1,642 

Strong Hybrid - Level 2 SHEV2 $5,860 $5,887 $6,347 $7,134 

Plug-in Hybrid - 30 mi range PHEV1 $16,658 $16,685 $19,407 $25,129 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $18,951 $18,977 $22,984 $29,535 

Electric Vehicle (Broad Market) - 150 mile range EV4 $27,274 $27,301 $33,510 $39,117 

Table V-130 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE 

SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $638 $638 $638 $961 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $1,131 $1,131 $1,131 $981 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,157 $1,157 $1,157 $1,243 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,460 $1,460 $1,460 $1,545 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,984 $1,984 $1,984 $2,070 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

480 

Advanced Diesel ADSL $2,873 $2,873 $2,873 $2,925 

6-speed DCT DCT ($85) ($85) ($51) ($51) 

8-Speed Trans (Auto or DCT) 8SPD $172 $172 $206 $206 

Shift Optimizer SHFTOPT $424 $424 $459 $459 

12V Micro-Hybrid (Stop-Start) MHEV $577 $604 $638 $667 

Mild Hybrid (Integrated Starter Generator) ISG $1,553 $1,579 $1,614 $1,642 

Strong Hybrid - Level 2 SHEV2 $5,882 $5,909 $6,391 $7,225 

Plug-in Hybrid - 30 mi range PHEV1 $16,925 $16,952 $19,839 $25,763 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $19,341 $19,368 $23,550 $30,377 

Electric Vehicle (Broad Market) - 150 mile range EV4 $27,988 $28,014 $34,199 $40,272 

Table V-131 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE 

SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $638 $961 $961 $1,239 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $1,131 $981 $981 $1,860 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,157 $1,243 $1,243 $2,302 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,460 $1,545 $1,545 $2,604 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,984 $2,070 $2,070 $2,304 

Advanced Diesel ADSL $2,873 $2,925 $2,925 $4,014 

6-speed DCT DCT ($51) ($51) ($51) ($51) 

8-Speed Trans (Auto or DCT) 8SPD $206 $206 $206 $206 

Shift Optimizer SHFTOP 

T $459 $459 $459 $459 

12V Micro-Hybrid (Stop-Start) MHEV $577 $604 $638 $667 

Mild Hybrid (Integrated Starter Generator) ISG $1,553 $1,579 $1,614 $1,642 

Strong Hybrid - Level 2 SHEV2 $5,895 $6,007 $6,433 $7,368 

Plug-in Hybrid - 30 mi range PHEV1 $16,692 $16,805 $19,493 $25,363 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $18,985 $19,097 $23,070 $29,769 

Electric Vehicle (Broad Market) - 150 mile range EV4 $27,308 $27,421 $33,596 $39,351 
 

 

 

 

 

 

 

 

 

 

 

 

 

481 

Table V-132 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY VEHICLE 

SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $638 $961 $961 $1,239 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $1,131 $981 $981 $1,860 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,157 $1,243 $1,243 $2,302 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,460 $1,545 $1,545 $2,604 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,984 $2,070 $2,070 $2,304 

Advanced Diesel ADSL $2,873 $2,925 $2,925 $4,014 

6-speed DCT DCT ($51) ($51) ($51) ($51) 

8-Speed Trans (Auto or DCT) 8SPD $206 $206 $206 $206 

Shift Optimizer SHFTOP 

T $459 $459 $459 $459 

12V Micro-Hybrid (Stop-Start) MHEV $577 $604 $638 $667 

Mild Hybrid (Integrated Starter Generator) ISG $1,553 $1,579 $1,614 $1,642 

Strong Hybrid - Level 2 SHEV2 $5,916 $6,029 $6,476 $7,459 

Plug-in Hybrid - 30 mi range PHEV1 $16,959 $17,072 $19,925 $25,997 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $19,375 $19,488 $23,636 $30,611 

Electric Vehicle (Broad Market) - 150 mile range EV4 $28,022 $28,134 $34,285 $40,506 

Table V-133 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $961 $638 $961 $1,239 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $981 $1,131 $981 $1,860 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,243 $1,157 $1,243 $2,302 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,545 $1,460 $1,545 $2,604 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $2,070 $1,984 $2,070 $2,304 

Advanced Diesel ADSL $2,925 $2,873 $2,925 $4,014 

6-speed DCT DCT $23 ($51) $23 $23 

8-Speed Trans (Auto or DCT) 8SPD $104 $206 $104 $104 
 

 

 

 

 

 

 

 

482 

Shift Optimizer SHFTOPT $356 $459 $356 $356 

12V Micro-Hybrid (Stop-Start) MHEV $667 $619 $677 $732 

Mild Hybrid (Integrated Starter Generator) ISG $1,642 $1,595 $1,653 $1,708 

Strong Hybrid - Level 2 SHEV2 $6,758 $6,179 $6,768 $7,437 

Plug-in Hybrid - 30 mi range PHEV1 - $18,553 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $20,841 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $32,443 - -

Table V-134 MY 2017 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2017 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $961 $638 $961 $1,239 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $981 $1,131 $981 $1,860 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,243 $1,157 $1,243 $2,302 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,545 $1,460 $1,545 $2,604 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $2,070 $1,984 $2,070 $2,304 

Advanced Diesel ADSL $2,925 $2,873 $2,925 $4,014 

6-speed DCT DCT $23 ($51) $23 $23 

8-Speed Trans (Auto or DCT) 8SPD $104 $206 $104 $104 

Shift Optimizer SHFTOP 

T $356 $459 $356 $356 

12V Micro-Hybrid (Stop-Start) MHEV $667 $619 $677 $732 

Mild Hybrid (Integrated Starter Generator) ISG $1,642 $1,595 $1,653 $1,708 

Strong Hybrid - Level 2 SHEV2 $6,792 $6,242 $6,802 $7,479 

Plug-in Hybrid - 30 mi range PHEV1 - $19,071 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $21,278 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $33,018 - -

Table V-135 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to 

technology application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

483 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $569 $569 $569 $859 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) TRBDS1 $989 $989 $989 $830 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) TRBDS2 $1,009 $1,009 $1,009 $1,077 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 

(24 bar BMEP) CEGR1 $1,295 $1,295 $1,295 $1,362 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 

(27 bar BMEP) CEGR2 $1,790 $1,790 $1,790 $1,858 

Advanced Diesel ADSL $2,701 $2,701 $2,701 $2,785 

6-speed DCT DCT ($98) ($98) ($61) ($61) 

8-Speed Trans (Auto or DCT) 8SPD $126 $126 $162 $162 

Shift Optimizer SHFTOPT $355 $355 $391 $391 

12V Micro-Hybrid (Stop-Start) MHEV $502 $525 $554 $578 

Mild Hybrid (Integrated Starter Generator) ISG $1,397 $1,419 $1,448 $1,472 

Strong Hybrid - Level 2 SHEV2 $5,042 $5,065 $5,459 $6,115 

Plug-in Hybrid - 30 mi range PHEV1 $13,090 $13,113 $15,185 $19,528 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $14,594 $14,616 $17,841 $22,958 

Electric Vehicle (Broad Market) - 150 mile range EV4 $20,668 $20,691 $25,522 $29,950 

Table V-136 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to 

technology application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $569 $569 $569 $859 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) TRBDS1 $989 $989 $989 $830 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) TRBDS2 $1,009 $1,009 $1,009 $1,077 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 

(24 bar BMEP) CEGR1 $1,295 $1,295 $1,295 $1,362 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 

(27 bar BMEP) CEGR2 $1,790 $1,790 $1,790 $1,858 

Advanced Diesel ADSL $2,701 $2,701 $2,701 $2,785 

6-speed DCT DCT ($98) ($98) ($61) ($61) 

8-Speed Trans (Auto or DCT) 8SPD $126 $126 $162 $162 

Shift Optimizer SHFTOPT $355 $355 $391 $391 

12V Micro-Hybrid (Stop-Start) MHEV $502 $525 $554 $578 

Mild Hybrid (Integrated Starter Generator) ISG $1,397 $1,419 $1,448 $1,472 

Strong Hybrid - Level 2 SHEV2 $5,061 $5,083 $5,496 $6,191 

Plug-in Hybrid - 30 mi range PHEV1 $13,292 $13,315 $15,515 $20,013 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $14,899 $14,921 $18,293 $23,628 
 

 

 

 

 

 

 

 

 

 

484 

Electric Vehicle (Broad Market) - 150 mile range EV4 $21,209 $21,231 $26,064 $30,848 

Table V-137 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY VEHICLE 

SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to 

technology application) 

Performance 

Subcompact 

Car 

Performance 

Compact 

Car 

Performance 

Midsize 

Car 

Performance 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $569 $859 $859 $1,107 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) TRBDS1 $989 $830 $830 $1,630 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) TRBDS2 $1,009 $1,077 $1,077 $2,048 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 

(24 bar BMEP) CEGR1 $1,295 $1,362 $1,362 $2,333 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 

(27 bar BMEP) CEGR2 $1,790 $1,858 $1,858 $2,036 

Advanced Diesel ADSL $2,701 $2,785 $2,785 $3,848 

6-speed DCT DCT ($61) ($61) ($61) ($61) 

8-Speed Trans (Auto or DCT) 8SPD $162 $162 $162 $162 

Shift Optimizer SHFTOPT $391 $391 $391 $391 

12V Micro-Hybrid (Stop-Start) MHEV $502 $525 $554 $578 

Mild Hybrid (Integrated Starter Generator) ISG $1,397 $1,419 $1,448 $1,472 

Strong Hybrid - Level 2 SHEV2 $5,078 $5,169 $5,527 $6,294 

Plug-in Hybrid - 30 mi range PHEV1 $13,126 $13,217 $15,253 $19,707 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $14,630 $14,720 $17,909 $23,136 

Electric Vehicle (Broad Market) - 150 mile range EV4 $20,705 $20,795 $25,590 $30,129 

Table V-138 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Performan 

ce 

Subcompa 

ct Car 

Performan 

ce 

Compact 

Car 

Performan 

ce 

Midsize 

Car 

Performan 

ce 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $569 $859 $859 $1,107 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $989 $830 $830 $1,630 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,009 $1,077 $1,077 $2,048 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,295 $1,362 $1,362 $2,333 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,790 $1,858 $1,858 $2,036 
 

 

 

 

 

 

 

 

 

485 

Advanced Diesel ADSL $2,701 $2,785 $2,785 $3,848 

6-speed DCT DCT ($61) ($61) ($61) ($61) 

8-Speed Trans (Auto or DCT) 8SPD $162 $162 $162 $162 

Shift Optimizer SHFTOP 

T $391 $391 $391 $391 

12V Micro-Hybrid (Stop-Start) MHEV $502 $525 $554 $578 

Mild Hybrid (Integrated Starter Generator) ISG $1,397 $1,419 $1,448 $1,472 

Strong Hybrid - Level 2 SHEV2 $5,097 $5,188 $5,563 $6,370 

Plug-in Hybrid - 30 mi range PHEV1 $13,329 $13,419 $15,583 $20,192 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $14,935 $15,025 $18,361 $23,807 

Electric Vehicle (Broad Market) - 150 mile range EV4 $21,245 $21,335 $26,132 $31,027 

Table V-139 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to 

technology application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $859 $569 $859 $1,107 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) TRBDS1 $830 $989 $830 $1,630 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) TRBDS2 $1,077 $1,009 $1,077 $2,048 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 

(24 bar BMEP) CEGR1 $1,362 $1,295 $1,362 $2,333 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 

(27 bar BMEP) CEGR2 $1,858 $1,790 $1,858 $2,036 

Advanced Diesel ADSL $2,785 $2,701 $2,785 $3,848 

6-speed DCT DCT $18 ($61) $18 $18 

8-Speed Trans (Auto or DCT) 8SPD $88 $162 $88 $88 

Shift Optimizer SHFTOPT $317 $391 $317 $317 

12V Micro-Hybrid (Stop-Start) MHEV $578 $538 $587 $633 

Mild Hybrid (Integrated Starter Generator) ISG $1,472 $1,432 $1,481 $1,528 

Strong Hybrid - Level 2 SHEV2 $5,811 $5,320 $5,819 $6,374 

Plug-in Hybrid - 30 mi range PHEV1 - $14,527 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $15,864 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $24,331 - -

Table V-140 MY 2021 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2021 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

486 

Final technology (as compared to baseline vehicle prior to technology application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $859 $569 $859 $1,107 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $830 $989 $830 $1,630 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,077 $1,009 $1,077 $2,048 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) CEGR1 $1,362 $1,295 $1,362 $2,333 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) CEGR2 $1,858 $1,790 $1,858 $2,036 

Advanced Diesel ADSL $2,785 $2,701 $2,785 $3,848 

6-speed DCT DCT $18 ($61) $18 $18 

8-Speed Trans (Auto or DCT) 8SPD $88 $162 $88 $88 

Shift Optimizer SHFTOPT $317 $391 $317 $317 

12V Micro-Hybrid (Stop-Start) MHEV $578 $538 $587 $633 

Mild Hybrid (Integrated Starter Generator) ISG $1,472 $1,432 $1,481 $1,528 

Strong Hybrid - Level 2 SHEV2 $5,838 $5,372 $5,847 $6,409 

Plug-in Hybrid - 30 mi range PHEV1 - $14,922 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $16,230 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $24,797 - -

Table V-141 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $540 $540 $540 $815 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $938 $938 $938 $797 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $943 $943 $943 $1,011 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) CEGR1 $1,190 $1,190 $1,190 $1,258 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) CEGR2 $1,618 $1,618 $1,618 $1,686 

Advanced Diesel ADSL $2,320 $2,320 $2,320 $2,415 

6-speed DCT DCT ($84) ($84) ($52) ($52) 

8-Speed Trans (Auto or DCT) 8SPD $126 $126 $158 $158 

Shift Optimizer SHFTOPT $330 $330 $362 $362 

12V Micro-Hybrid (Stop-Start) MHEV $461 $482 $508 $530 

Mild Hybrid (Integrated Starter Generator) ISG $1,186 $1,206 $1,233 $1,255 

Strong Hybrid - Level 2 SHEV2 $4,512 $4,532 $4,882 $5,472 

Plug-in Hybrid - 30 mi range PHEV1 $10,933 $10,954 $12,654 $16,240 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $11,374 $11,394 $13,842 $17,701 

Electric Vehicle (Broad Market) - 150 mile range EV4 $15,834 $15,854 $19,482 $22,835 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

487 

Table V-142 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology application) Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $540 $540 $540 $815 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $938 $938 $938 $797 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $943 $943 $943 $1,011 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) CEGR1 $1,190 $1,190 $1,190 $1,258 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) CEGR2 $1,618 $1,618 $1,618 $1,686 

Advanced Diesel ADSL $2,320 $2,320 $2,320 $2,415 

6-speed DCT DCT ($84) ($84) ($52) ($52) 

8-Speed Trans (Auto or DCT) 8SPD $126 $126 $158 $158 

Shift Optimizer SHFTOPT $330 $330 $362 $362 

12V Micro-Hybrid (Stop-Start) MHEV $461 $482 $508 $530 

Mild Hybrid (Integrated Starter Generator) ISG $1,186 $1,206 $1,233 $1,255 

Strong Hybrid - Level 2 SHEV2 $4,528 $4,549 $4,914 $5,540 

Plug-in Hybrid - 30 mi range PHEV1 $11,099 $11,120 $12,929 $16,648 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $11,603 $11,623 $14,184 $18,206 

Electric Vehicle (Broad Market) - 150 mile range EV4 $16,235 $16,256 $19,889 $23,508 

Table V-143 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Perf. 

Subcompact 

Car 

Perf. 

Compact 

Car 

Perf. 

Midsize 

Car 

Perf. 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $540 $815 $815 $1,050 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $938 $797 $797 $1,543 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $943 $1,011 $1,011 $1,904 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) CEGR1 $1,190 $1,258 $1,258 $2,151 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) CEGR2 $1,618 $1,686 $1,686 $1,862 

Advanced Diesel ADSL $2,320 $2,415 $2,415 $3,364 

6-speed DCT DCT ($52) ($52) ($52) ($52) 

8-Speed Trans (Auto or DCT) 8SPD $158 $158 $158 $158 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

488 

Shift Optimizer SHFTOPT $362 $362 $362 $362 

12V Micro-Hybrid (Stop-Start) MHEV $461 $482 $508 $530 

Mild Hybrid (Integrated Starter Generator) ISG $1,186 $1,206 $1,233 $1,255 

Strong Hybrid - Level 2 SHEV2 $4,544 $4,633 $4,950 $5,647 

Plug-in Hybrid - 30 mi range PHEV1 $10,965 $11,054 $12,722 $16,416 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $11,406 $11,495 $13,910 $17,876 

Electric Vehicle (Broad Market) - 150 mile range EV4 $15,866 $15,955 $19,550 $23,011 

Table V-144 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Performance Passenger Cars, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Perf. 

Subcompact 

Car 

Perf. 

Compact 

Car 

Perf. 

Midsize 

Car 

Perf. 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $540 $815 $815 $1,050 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $938 $797 $797 $1,543 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $943 $1,011 $1,011 $1,904 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) CEGR1 $1,190 $1,258 $1,258 $2,151 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) CEGR2 $1,618 $1,686 $1,686 $1,862 

Advanced Diesel ADSL $2,320 $2,415 $2,415 $3,364 

6-speed DCT DCT ($52) ($52) ($52) ($52) 

8-Speed Trans (Auto or DCT) 8SPD $158 $158 $158 $158 

Shift Optimizer SHFTOP 

T $362 $362 $362 $362 

12V Micro-Hybrid (Stop-Start) MHEV $461 $482 $508 $530 

Mild Hybrid (Integrated Starter Generator) ISG $1,186 $1,206 $1,233 $1,255 

Strong Hybrid - Level 2 SHEV2 $4,560 $4,649 $4,982 $5,716 

Plug-in Hybrid - 30 mi range PHEV1 $11,132 $11,220 $12,997 $16,824 

Electric Vehicle (Early Adopter) - 75 mile range EV1 $11,635 $11,723 $14,252 $18,382 

Electric Vehicle (Broad Market) - 150 mile range EV4 $16,267 $16,356 $19,957 $23,683 

Table V-145 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2008 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $815 $540 $815 $1,050 
 

 

 

 

 

 

 

 

 

 

 

 

489 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $797 $938 $797 $1,543 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,011 $943 $1,011 $1,904 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 $1,258 $1,190 $1,258 $2,151 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 $1,686 $1,618 $1,686 $1,862 

Advanced Diesel ADSL $2,415 $2,320 $2,415 $3,364 

6-speed DCT DCT $18 ($52) $18 $18 

8-Speed Trans (Auto or DCT) 8SPD $84 $158 $84 $84 

Shift Optimizer SHFTOPT $287 $362 $287 $287 

12V Micro-Hybrid (Stop-Start) MHEV $530 $493 $538 $581 

Mild Hybrid (Integrated Starter Generator) ISG $1,255 $1,218 $1,263 $1,305 

Strong Hybrid - Level 2 SHEV2 $5,195 $4,756 $5,202 $5,699 

Plug-in Hybrid - 30 mi range PHEV1 - $12,092 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $12,285 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $18,501 - -

Table V-146 MY 2025 Approximate Net (Accumulated) Technology Costs, 

Light Trucks, 2010 Baseline 

APPROXIMATE ICM NET COSTS PER VEHICLE (for MY 2025 in 2010 dollars) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI $815 $540 $815 $1,050 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 $797 $938 $797 $1,543 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 $1,011 $943 $1,011 $1,904 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) CEGR1 $1,258 $1,190 $1,258 $2,151 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) CEGR2 $1,686 $1,618 $1,686 $1,862 

Advanced Diesel ADSL $2,415 $2,320 $2,415 $3,364 

6-speed DCT DCT $18 ($52) $18 $18 

8-Speed Trans (Auto or DCT) 8SPD $84 $158 $84 $84 

Shift Optimizer SHFTOPT $287 $362 $287 $287 

12V Micro-Hybrid (Stop-Start) MHEV $530 $493 $538 $581 

Mild Hybrid (Integrated Starter Generator) ISG $1,255 $1,218 $1,263 $1,305 

Strong Hybrid - Level 2 SHEV2 $5,220 $4,803 $5,228 $5,731 

Plug-in Hybrid - 30 mi range PHEV1 - $12,420 - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - $12,568 - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - $18,858 - -
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

490 

The following tables representing the CAFE model input files for approximate net (accumulated) 

technology effectiveness values by vehicle subclass are presented below. The tables have been 

divided into passenger cars, performance passenger cars, and light trucks to make them easier to 

read. 

Table V-147 Approximate Net Technology Effectiveness, Passenger Cars 

APPROXIMATE NET EFFECTIVENESS ESTIMATES (FC REDUCTION) PER VEHILCE (-%) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Subcompact 

Car 

Compact 

Car 

Midsize 

Car 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 Inline 4 Inline 4 V6 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 11.9% 11.9% 14.5% 15.3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 17.8% 17.8% 20.9% 21.9% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 20.2% 20.2% 23.7% 24.8% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 23.1% 23.1% 26.4% 27.4% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 23.9% 23.9% 27.4% 28.4% 

Advanced Diesel ADSL 28.1% 28.1% 29.4% 30.5% 

6-speed DCT DCT 8.0% 8.0% 8.8% 8.6% 

8-Speed Trans (Auto or DCT) 8SPD 11.5% 11.5% 13.0% 12.8% 

Shift Optimizer SHFTOPT 16.3% 16.3% 18.8% 18.7% 

12V Micro-Hybrid (Stop-Start) MHEV 6.1% 6.1% 6.8% 6.7% 

Mild Hybrid (Integrated Starter Generator) ISG 13.1% 13.1% 12.9% 12.7% 

Strong Hybrid - Level 2 SHEV2 46.3% 46.3% 48.7% 49.5% 

Plug-in Hybrid - 30 mi range PHEV1 68.1% 68.1% 69.6% 70.0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 90.0% 90.0% 90.4% 90.6% 

Electric Vehicle (Broad Market) - 150 mile range EV4 90.0% 90.0% 90.4% 90.6% 

Table V-148 Approximate Net Technology Effectiveness, Performance Passenger Cars 

APPROXIMATE NET EFFECTIVENESS ESTIMATES (FC REDUCTION) PER VEHILCE (-%) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Perf. 

Subcompact 

Car 

Perf. 

Compact 

Car 

Perf. 

Midsize 

Car 

Perf. 

Large 

Car 

Nominal Baseline Engine (For Cost Basis) Inline 4 V6 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 11.9% 11.9% 14.5% 15.3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 17.8% 17.8% 20.9% 21.9% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 20.2% 20.2% 23.7% 24.8% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 23.1% 23.1% 26.4% 27.4% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 23.9% 23.9% 27.4% 28.4% 

Advanced Diesel ADSL 28.1% 28.1% 29.4% 30.5% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

491 

6-speed DCT DCT 7.4% 7.4% 8.8% 8.6% 

8-Speed Trans (Auto or DCT) 8SPD 11.5% 11.5% 13.0% 12.8% 

Shift Optimizer SHFTOP 

T 16.3% 16.3% 18.8% 18.7% 

12V Micro-Hybrid (Stop-Start) MHEV 6.1% 6.1% 6.8% 6.7% 

Mild Hybrid (Integrated Starter Generator) ISG 13.1% 13.1% 12.9% 12.7% 

Strong Hybrid - Level 2 SHEV2 46.3% 46.3% 48.7% 49.5% 

Plug-in Hybrid - 30 mi range PHEV1 68.1% 68.1% 69.6% 70.0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 90.0% 90.0% 90.4% 90.6% 

Electric Vehicle (Broad Market) - 150 mile range EV4 90.0% 90.0% 90.4% 90.6% 

Table V-149 Approximate Net Technology Effectiveness, Light Trucks 

APPROXIMATE NET EFFECTIVENESS ESTIMATES (FC REDUCTION) PER VEHILCE (-%) BY 

VEHICLE SUBCLASS TO KEY TECHNOLOGIES 

Final technology (as compared to baseline vehicle prior to technology 

application) 

Minivan 

LT 

Small 

LT 

Midsize 

LT 

Large 

LT 

Nominal Baseline Engine (For Cost Basis) V6 Inline 4 V6 V8 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 14.4% 11.8% 14.4% 13.7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) TRBDS1 21.2% 17.6% 21.2% 20.0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) TRBDS2 23.9% 20.0% 23.9% 22.7% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) CEGR1 26.6% 22.9% 26.6% 25.5% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) CEGR2 27.4% 23.7% 27.4% 26.4% 

Advanced Diesel ADSL 29.9% 27.8% 29.9% 29.0% 

6-speed DCT DCT 4.9% 8.0% 4.9% 5.0% 

8-Speed Trans (Auto or DCT) 8SPD 9.5% 11.8% 9.5% 10.0% 

Shift Optimizer SHFTOPT 15.9% 16.9% 15.9% 16.7% 

12V Micro-Hybrid (Stop-Start) MHEV 6.2% 5.6% 6.2% 6.5% 

Mild Hybrid (Integrated Starter Generator) ISG 11.5% 11.4% 11.5% 9.3% 

Strong Hybrid - Level 2 SHEV2 45.8% 46.2% 45.8% 45.3% 

Plug-in Hybrid - 30 mi range PHEV1 - 68.1% - -

Electric Vehicle (Early Adopter) - 75 mile range EV1 - 90.0% - -

Electric Vehicle (Broad Market) - 150 mile range EV4 - 90.0% - -
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

492 

Penetration of Technologies by Alternative 

Preferred Alternative - Passenger Cars - 2008 Baseline shows the penetration of technologies by 

alternative for passenger cars, Table V-151 shows the penetration of technologies for light trucks 

for the alternatives and Table V-152 shows the penetration of technologies by alternative for the 

combined passenger car and light truck fleet. These tables are for the whole fleet combined, not 

by specific manufacturers. The application rate only includes technologies that the model 

applied. The penetration rate includes technologies that the model applies and technologies that 

were already present in the base fleet/base vehicle. They allow the reader to see the progression 

of technologies used as the alternatives get stricter. 

Table V-150 Penetration Rate of New Technologies to Passenger Cars, by Baseline Model 

Year and Alternative, 

Preferred Alternative - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 89% 89% 89% 89% 88% 87% 

Engine Friction Reduction - Level 1 EFR1 77% 80% 87% 88% 88% 88% 88% 88% 87% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 16% 26% 40% 44% 48% 51% 57% 59% 61% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) 

on SOHC CCPS 4% 5% 11% 10% 11% 11% 10% 11% 10% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 5% 4% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 73% 73% 74% 75% 75% 75% 75% 74% 74% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 51% 54% 54% 56% 57% 57% 56% 56% 56% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 12% 15% 16% 16% 16% 17% 17% 17% 

Cylinder Deactivation on DOHC DEACD 5% 4% 4% 4% 4% 5% 4% 4% 4% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 44% 51% 57% 61% 70% 75% 75% 84% 83% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 3% 4% 5% 5% 5% 5% 5% 5% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 1% 2% 4% 5% 5% 5% 5% 5% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 23% 26% 27% 25% 34% 31% 28% 33% 29% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 11% 16% 16% 18% 15% 14% 10% 9% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 4% 3% 3% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 1% 2% 2% 2% 2% 2% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 1% 1% 1% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement 

CEGR1_SD 1% 1% 4% 8% 8% 15% 18% 21% 26% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement 

CEGR1_MD 3% 3% 5% 6% 8% 9% 13% 14% 16% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement 

CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

493 

CEGR - Level 2 (27 bar BMEP) - Small Displacement 

CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement 

CEGR2_MD 0% 0% 0% 0% 3% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement 

CEGR2_LD 0% 1% 1% 1% 2% 2% 3% 3% 2% 

Advanced Diesel - Small Displacement 

ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement 

ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement 

ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 9% 7% 4% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 13% 7% 5% 2% 1% 0% 0% 0% 0% 

6-speed DCT DCT 30% 24% 18% 12% 5% 3% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 26% 29% 28% 21% 12% 8% 3% 2% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 17% 29% 43% 57% 66% 72% 74% 73% 

Shift Optimizer SHFTOPT 7% 20% 34% 45% 56% 72% 81% 84% 83% 

Electric Power Steering EPS 80% 84% 93% 94% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 61% 64% 68% 77% 80% 82% 85% 92% 92% 

Improved Accessories - Level 2 IACC2 19% 26% 39% 46% 54% 63% 65% 76% 78% 

12V Micro-Hybrid (Stop-Start) MHEV 6% 6% 9% 12% 14% 14% 15% 13% 12% 

Integrated Starter Generator ISG 1% 2% 2% 7% 7% 10% 11% 17% 24% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 2% 2% 

Conversion from SHEV1 to SHEV2 

SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 1% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 45% 49% 52% 53% 53% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 26% 32% 44% 47% 47% 47% 49% 49% 49% 

Mass Reduction - Level 3 MR3 10% 12% 13% 15% 15% 15% 16% 17% 18% 

Mass Reduction - Level 4 MR4 4% 4% 5% 5% 5% 5% 6% 7% 9% 

Mass Reduction - Level 5 MR5 1% 1% 2% 3% 3% 4% 4% 5% 8% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 20% 33% 53% 66% 75% 83% 86% 87% 88% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

494 

Preferred Alternative - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Engine Friction Reduction - Level 1 EFR1 75% 79% 81% 80% 81% 81% 81% 80% 80% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 9% 12% 15% 19% 24% 31% 37% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 15% 15% 15% 15% 15% 15% 15% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 15% 16% 16% 16% 16% 16% 15% 

Cylinder Deactivation on SOHC DEACS 5% 4% 4% 3% 2% 2% 2% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 68% 68% 68% 68% 68% 68% 68% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 36% 37% 38% 38% 39% 40% 40% 40% 40% 

Continuously Variable Valve Lift (CVVL) CVVL 24% 25% 27% 27% 27% 27% 27% 27% 27% 

Cylinder Deactivation on DOHC DEACD 7% 7% 5% 4% 3% 3% 3% 2% 2% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 46% 56% 69% 73% 82% 86% 86% 89% 89% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 3% 3% 3% 3% 3% 3% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 28% 35% 40% 42% 46% 46% 41% 39% 34% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 12% 16% 19% 20% 19% 19% 19% 18% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 3% 3% 3% 3% 3% 2% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 2% 2% 2% 3% 3% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 2% 2% 2% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement 

CEGR1_SD 0% 1% 3% 4% 7% 10% 16% 21% 25% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement 

CEGR1_MD 1% 2% 2% 2% 2% 3% 3% 5% 8% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement 

CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement 

CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement 

CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement 

CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 3% 4% 

Advanced Diesel - Small Displacement 

ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Advanced Diesel - Medium Displacement 

ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement 

ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 3% 2% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 24% 22% 12% 6% 4% 2% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 25% 24% 15% 9% 7% 6% 1% 0% 0% 

6-speed DCT DCT 35% 35% 29% 19% 21% 15% 11% 8% 7% 

8-Speed Trans (Auto or DCT) 8SPD 11% 15% 24% 24% 21% 19% 16% 5% 5% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

495 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 3% 12% 24% 31% 40% 49% 59% 61% 

Shift Optimizer SHFTOPT 0% 0% 8% 17% 30% 36% 54% 62% 65% 

Electric Power Steering EPS 76% 82% 90% 92% 93% 93% 95% 97% 97% 

Improved Accessories - Level 1 IACC1 53% 62% 74% 80% 81% 82% 85% 89% 94% 

Improved Accessories - Level 2 IACC2 5% 13% 19% 29% 38% 44% 51% 65% 68% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 6% 5% 6% 6% 7% 7% 7% 

Integrated Starter Generator ISG 1% 2% 2% 4% 5% 6% 6% 10% 12% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 

SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 46% 50% 59% 59% 60% 60% 61% 60% 61% 

Mass Reduction - Level 2 MR2 16% 27% 37% 41% 46% 48% 51% 58% 59% 

Mass Reduction - Level 3 MR3 7% 8% 8% 10% 12% 12% 15% 18% 19% 

Mass Reduction - Level 4 MR4 2% 2% 3% 3% 3% 3% 3% 4% 5% 

Mass Reduction - Level 5 MR5 0% 0% 1% 1% 1% 1% 1% 2% 3% 

Low Rolling Resistance Tires - Level 1 

ROLL1 91% 97% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 21% 29% 52% 62% 72% 79% 83% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 93% 93% 93% 93% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 91% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 80% 87% 88% 88% 90% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

496 

2% Annual Increase - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Engine Friction Reduction - Level 1 EFR1 83% 88% 88% 88% 88% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 12% 26% 39% 47% 53% 56% 61% 63% 67% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 4% 4% 4% 4% 4% 4% 4% 4% 4% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 14% 9% 7% 5% 5% 5% 5% 5% 5% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 63% 68% 71% 73% 73% 73% 73% 73% 73% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 46% 49% 50% 52% 53% 53% 52% 52% 53% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 13% 16% 20% 20% 20% 20% 20% 20% 

Cylinder Deactivation on DOHC DEACD 4% 5% 5% 5% 5% 5% 5% 5% 4% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 40% 42% 43% 45% 46% 46% 48% 52% 53% 

Cylinder Deactivation on OHV DEACO 3% 2% 2% 3% 2% 2% 1% 1% 1% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 3% 3% 4% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 0% 0% 0% 0% 0% 1% 1% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 20% 20% 21% 21% 22% 21% 23% 26% 25% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 11% 12% 13% 13% 13% 12% 14% 13% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 2% 2% 3% 3% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 1% 1% 1% 1% 1% 2% 2% 3% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 3% 3% 4% 4% 5% 5% 6% 6% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 15% 9% 5% 3% 3% 1% 3% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 10% 11% 12% 12% 11% 10% 9% 1% 0% 

6-speed DCT DCT 36% 32% 27% 22% 16% 13% 10% 19% 17% 

8-Speed Trans (Auto or DCT) 8SPD 15% 17% 21% 16% 14% 17% 15% 12% 12% 

High Efficiency Gearbox (Auto or DCT) HETRANS 3% 12% 17% 26% 35% 39% 47% 52% 54% 

Shift Optimizer SHFTOPT 5% 9% 18% 24% 28% 31% 37% 37% 37% 

Electric Power Steering EPS 79% 85% 90% 91% 91% 91% 91% 95% 95% 

Improved Accessories - Level 1 IACC1 55% 56% 56% 60% 63% 68% 73% 84% 87% 

Improved Accessories - Level 2 IACC2 11% 15% 17% 23% 29% 33% 39% 56% 60% 

12V Micro-Hybrid (Stop-Start) MHEV 6% 6% 6% 6% 6% 6% 6% 6% 6% 

Integrated Starter Generator ISG 1% 2% 2% 3% 3% 3% 3% 5% 6% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

497 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 45% 49% 52% 53% 52% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 24% 29% 40% 42% 42% 44% 49% 51% 51% 

Mass Reduction - Level 3 MR3 10% 10% 11% 13% 13% 13% 15% 16% 16% 

Mass Reduction - Level 4 MR4 3% 4% 4% 4% 4% 5% 5% 5% 5% 

Mass Reduction - Level 5 MR5 0% 1% 1% 1% 1% 1% 1% 1% 3% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 20% 33% 48% 60% 72% 81% 84% 87% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 88% 88% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

498 

2% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Engine Friction Reduction - Level 1 EFR1 76% 80% 80% 81% 81% 81% 81% 80% 80% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 9% 21% 25% 27% 31% 42% 45% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 15% 15% 15% 15% 15% 15% 15% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 15% 16% 16% 16% 16% 16% 16% 

Cylinder Deactivation on SOHC DEACS 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 7% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 69% 69% 69% 69% 69% 69% 69% 69% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 32% 33% 34% 36% 39% 40% 40% 40% 40% 

Continuously Variable Valve Lift (CVVL) CVVL 19% 20% 26% 26% 29% 28% 28% 28% 28% 

Cylinder Deactivation on DOHC DEACD 7% 8% 10% 11% 11% 11% 12% 12% 12% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 31% 40% 41% 44% 50% 51% 51% 55% 56% 

Cylinder Deactivation on OHV DEACO 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 1% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 15% 22% 23% 25% 31% 32% 32% 36% 37% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 6% 7% 7% 9% 9% 9% 9% 8% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 2% 2% 2% 2% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 1% 1% 1% 1% 1% 2% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 1% 2% 2% 2% 2% 2% 2% 3% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 0% 0% 1% 1% 1% 1% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 2% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 25% 22% 20% 15% 15% 15% 16% 19% 18% 

6-Speed Trans with Improved Internals (Auto) NAUTO 27% 21% 18% 12% 18% 19% 23% 25% 25% 

6-speed DCT DCT 31% 32% 24% 14% 13% 9% 4% 5% 5% 

8-Speed Trans (Auto or DCT) 8SPD 9% 13% 14% 18% 15% 14% 18% 19% 19% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 3% 10% 17% 23% 25% 28% 28% 28% 

Shift Optimizer SHFTOPT 0% 0% 11% 17% 19% 24% 26% 27% 27% 

Electric Power Steering EPS 72% 79% 85% 86% 90% 92% 92% 92% 92% 

Improved Accessories - Level 1 IACC1 38% 40% 42% 45% 53% 58% 63% 75% 75% 

Improved Accessories - Level 2 IACC2 2% 3% 7% 9% 14% 16% 24% 33% 34% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 5% 5% 5% 5% 4% 4% 4% 

Integrated Starter Generator ISG 1% 2% 2% 2% 2% 2% 2% 4% 4% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

499 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 40% 47% 57% 59% 59% 59% 61% 60% 61% 

Mass Reduction - Level 2 MR2 15% 22% 29% 32% 37% 39% 46% 56% 57% 

Mass Reduction - Level 3 MR3 7% 7% 8% 8% 10% 10% 12% 15% 16% 

Mass Reduction - Level 4 MR4 1% 1% 1% 1% 1% 1% 2% 4% 5% 

Mass Reduction - Level 5 MR5 0% 0% 0% 0% 1% 1% 1% 4% 4% 

Low Rolling Resistance Tires - Level 1 

ROLL1 91% 96% 98% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 37% 45% 58% 71% 82% 83% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 91% 92% 92% 93% 93% 93% 93% 93% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 90% 96% 98% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 80% 87% 88% 88% 90% 90% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

500 

3% Annual Increase - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 89% 89% 89% 89% 88% 88% 

Engine Friction Reduction - Level 1 EFR1 83% 87% 87% 88% 88% 88% 88% 88% 87% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 13% 27% 38% 46% 53% 61% 64% 66% 67% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) 

on SOHC CCPS 4% 4% 4% 4% 6% 6% 6% 10% 10% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 8% 6% 6% 5% 5% 4% 4% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 69% 72% 72% 73% 73% 74% 74% 75% 74% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 49% 52% 53% 55% 56% 56% 56% 56% 56% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 12% 15% 17% 17% 17% 17% 17% 17% 

Cylinder Deactivation on DOHC DEACD 4% 4% 3% 4% 4% 4% 3% 2% 2% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 42% 45% 51% 56% 57% 62% 64% 65% 65% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 3% 3% 5% 4% 4% 4% 5% 5% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 1% 1% 3% 4% 3% 4% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_S 

D 21% 23% 27% 27% 28% 29% 28% 26% 24% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_M 

D 11% 15% 15% 18% 16% 14% 16% 16% 16% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_L 

D 3% 2% 2% 3% 2% 2% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_S 

D 0% 0% 0% 1% 1% 2% 3% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_M 

D 0% 0% 1% 1% 1% 2% 2% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 1% 1% 1% 3% 3% 6% 6% 8% 10% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 3% 3% 4% 7% 8% 8% 11% 11% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 10% 8% 4% 1% 2% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 14% 9% 6% 3% 0% 0% 0% 0% 0% 

6-speed DCT DCT 31% 24% 19% 13% 10% 6% 6% 6% 6% 

8-Speed Trans (Auto or DCT) 8SPD 24% 25% 25% 18% 8% 7% 6% 6% 6% 

High Efficiency Gearbox (Auto or DCT) HETRANS 3% 19% 30% 44% 55% 61% 63% 63% 62% 

Shift Optimizer SHFTOPT 7% 21% 35% 47% 55% 60% 70% 75% 74% 

Electric Power Steering EPS 79% 85% 90% 91% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 54% 56% 60% 64% 71% 73% 76% 76% 76% 

Improved Accessories - Level 2 IACC2 14% 24% 28% 32% 34% 41% 46% 51% 54% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 5% 6% 6% 6% 6% 6% 6% 

Integrated Starter Generator ISG 1% 2% 2% 4% 4% 5% 5% 6% 10% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

501 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 45% 49% 52% 53% 52% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 26% 33% 44% 47% 46% 47% 50% 51% 51% 

Mass Reduction - Level 3 MR3 10% 12% 13% 15% 15% 15% 15% 15% 17% 

Mass Reduction - Level 4 MR4 4% 4% 5% 5% 5% 6% 5% 6% 8% 

Mass Reduction - Level 5 MR5 0% 1% 2% 3% 3% 4% 4% 4% 6% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 99% 99% 99% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 20% 35% 52% 64% 74% 82% 85% 85% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 88% 88% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

502 

3% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Engine Friction Reduction - Level 1 EFR1 75% 79% 81% 81% 81% 81% 81% 80% 80% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 5% 9% 11% 12% 14% 20% 22% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 15% 15% 15% 15% 15% 15% 15% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 15% 16% 16% 16% 16% 16% 16% 

Cylinder Deactivation on SOHC DEACS 5% 5% 4% 3% 3% 3% 2% 3% 3% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 68% 68% 68% 68% 68% 68% 68% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 35% 36% 37% 38% 38% 39% 39% 39% 39% 

Continuously Variable Valve Lift (CVVL) CVVL 24% 25% 27% 28% 28% 29% 29% 29% 29% 

Cylinder Deactivation on DOHC DEACD 8% 9% 9% 5% 5% 5% 4% 2% 2% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 38% 47% 63% 67% 70% 76% 78% 81% 82% 

Cylinder Deactivation on OHV DEACO 3% 3% 3% 2% 2% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 1% 1% 1% 1% 1% 3% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 19% 22% 27% 29% 32% 36% 40% 44% 41% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 9% 10% 13% 17% 16% 16% 19% 18% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 3% 3% 3% 2% 2% 2% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 1% 1% 2% 2% 5% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 2% 2% 2% 2% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 4% 4% 4% 4% 4% 4% 6% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 1% 2% 2% 2% 2% 2% 3% 4% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 0% 1% 1% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 3% 2% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 25% 22% 13% 11% 6% 4% 3% 1% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 26% 21% 13% 6% 4% 5% 4% 2% 4% 

6-speed DCT DCT 36% 37% 34% 25% 29% 26% 23% 18% 17% 

8-Speed Trans (Auto or DCT) 8SPD 11% 18% 27% 32% 28% 29% 23% 15% 11% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 3% 8% 16% 23% 26% 34% 49% 55% 

Shift Optimizer SHFTOPT 0% 0% 3% 14% 21% 23% 32% 45% 51% 

Electric Power Steering EPS 73% 79% 89% 92% 92% 92% 92% 93% 93% 

Improved Accessories - Level 1 IACC1 50% 56% 66% 74% 74% 75% 76% 76% 77% 

Improved Accessories - Level 2 IACC2 3% 4% 8% 12% 16% 24% 24% 28% 29% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 4% 5% 5% 5% 5% 5% 5% 

Integrated Starter Generator ISG 2% 2% 2% 2% 2% 3% 3% 4% 5% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 1% 1% 
 

 

 

 

 

 

 

503 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 46% 50% 59% 60% 61% 60% 61% 60% 61% 

Mass Reduction - Level 2 MR2 16% 27% 38% 42% 47% 49% 50% 56% 58% 

Mass Reduction - Level 3 MR3 7% 7% 8% 10% 11% 11% 12% 15% 17% 

Mass Reduction - Level 4 MR4 1% 1% 2% 2% 2% 3% 3% 4% 7% 

Mass Reduction - Level 5 MR5 0% 0% 0% 0% 1% 1% 1% 2% 5% 

Low Rolling Resistance Tires - Level 1 

ROLL1 91% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 37% 44% 56% 74% 82% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 93% 93% 93% 93% 93% 93% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 90% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 80% 87% 88% 88% 90% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

504 

4% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 78% 77% 77% 76% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction 

Reduction - Level 2 LUB2_EFR2 11% 23% 38% 52% 66% 72% 77% 82% 84% 

Variable Valve Timing (VVT) - Coupled Cam 

Phasing (CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing 

(ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing 

(DCP) DCP 58% 58% 58% 59% 60% 61% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 41% 42% 43% 43% 44% 44% 44% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 7% 7% 6% 6% 5% 4% 1% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 68% 69% 70% 70% 74% 76% 79% 81% 81% 

Cylinder Deactivation on OHV DEACO 12% 12% 3% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 19% 17% 17% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on 

OHV SGDIO 11% 12% 15% 20% 19% 18% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) – Small Disp. TRBDS1_SD 10% 10% 9% 7% 7% 4% 4% 2% 1% 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) - Medium Disp. TRBDS1_MD 50% 50% 50% 45% 39% 35% 32% 26% 22% 

Turbocharging and Downsizing - Level 1 (18 bar 

BMEP) - Large Disp. TRBDS1_LD 9% 9% 17% 18% 14% 11% 13% 13% 13% 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) - Small Disp. TRBDS2_SD 0% 0% 1% 1% 1% 1% 1% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) - Medium Disp. TRBDS2_MD 0% 0% 2% 9% 9% 10% 12% 13% 16% 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) - Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small 

Displacement CEGR1_SD 0% 0% 0% 1% 1% 4% 4% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium 

Displacement CEGR1_MD 3% 5% 6% 8% 15% 19% 21% 25% 27% 

CEGR - Level 1 (24 bar BMEP) - Large 

Displacement CEGR1_LD 1% 1% 0% 0% 3% 3% 3% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Small 

Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium 

Displacement CEGR2_MD 0% 0% 0% 0% 1% 1% 1% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large 

Displacement CEGR2_LD 0% 0% 1% 1% 4% 7% 7% 7% 7% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 13% 6% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 32% 24% 12% 6% 3% 3% 1% 1% 1% 

6-speed DCT DCT 5% 5% 4% 2% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 34% 40% 40% 34% 17% 14% 9% 5% 5% 
 

 

 

 

 

 

 

 

 

 

 

505 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 15% 31% 45% 60% 64% 71% 75% 75% 

Shift Optimizer SHFTOPT 11% 19% 34% 49% 66% 74% 81% 93% 94% 

Electric Power Steering EPS 79% 83% 92% 92% 92% 92% 92% 93% 93% 

Improved Accessories - Level 1 IACC1 51% 53% 56% 63% 69% 71% 75% 85% 87% 

Improved Accessories - Level 2 IACC2 7% 8% 11% 15% 24% 28% 32% 35% 43% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 3% 3% 3% 6% 7% 7% 7% 7% 

Integrated Starter Generator ISG 0% 0% 0% 1% 1% 2% 2% 4% 9% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 2% 2% 2% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 87% 88% 93% 98% 99% 

100 

% 

100 

% 

100 

% 100% 

Mass Reduction - Level 2 MR2 30% 39% 54% 64% 77% 82% 84% 87% 88% 

Mass Reduction - Level 3 MR3 16% 18% 22% 29% 34% 38% 44% 49% 52% 

Mass Reduction - Level 4 MR4 9% 10% 12% 17% 25% 28% 33% 41% 46% 

Mass Reduction - Level 5 MR5 0% 0% 2% 5% 8% 9% 11% 17% 21% 

Low Rolling Resistance Tires - Level 1 ROLL1 100% 

100 

% 100% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 13% 28% 48% 66% 71% 76% 85% 89% 90% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 81% 82% 83% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 34% 38% 39% 44% 43% 43% 43% 43% 43% 

Aero Drag Reduction, Level 1 AERO1 100% 

100 

% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 61% 69% 86% 93% 95% 98% 

100 

% 

100 

% 100% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

506 

4% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 

100 

% 100% 

100 

% 

100 

% 

100 

% 99% 

Engine Friction Reduction - Level 1 EFR1 75% 79% 81% 81% 81% 81% 81% 80% 80% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 4% 10% 11% 13% 18% 29% 30% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 14% 14% 14% 15% 15% 15% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 14% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on SOHC DEACS 5% 5% 5% 3% 2% 2% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 68% 68% 68% 68% 68% 68% 68% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 34% 37% 37% 39% 39% 39% 39% 39% 39% 

Continuously Variable Valve Lift (CVVL) CVVL 25% 26% 28% 28% 28% 28% 28% 28% 28% 

Cylinder Deactivation on DOHC DEACD 9% 9% 7% 3% 2% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 52% 59% 73% 77% 86% 87% 90% 92% 92% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 0% 2% 2% 3% 3% 3% 3% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 33% 38% 47% 47% 51% 48% 44% 37% 32% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 8% 11% 14% 19% 20% 20% 21% 20% 16% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 3% 3% 3% 3% 3% 3% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 2% 2% 2% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 1% 1% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 2% 3% 7% 11% 14% 22% 28% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 4% 4% 4% 6% 6% 6% 8% 10% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 2% 2% 2% 3% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 3% 2% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 27% 21% 11% 8% 3% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 29% 25% 15% 8% 3% 1% 0% 0% 0% 

6-speed DCT DCT 33% 35% 30% 20% 19% 15% 7% 2% 2% 

8-Speed Trans (Auto or DCT) 8SPD 11% 15% 22% 24% 23% 23% 25% 18% 16% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 4% 16% 24% 30% 35% 37% 47% 46% 

Shift Optimizer SHFTOPT 0% 0% 8% 23% 40% 46% 52% 54% 60% 

Electric Power Steering EPS 77% 84% 92% 94% 96% 96% 96% 96% 97% 

Improved Accessories - Level 1 IACC1 54% 64% 76% 82% 86% 90% 91% 91% 94% 

Improved Accessories - Level 2 IACC2 5% 14% 22% 30% 38% 43% 54% 62% 65% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 7% 7% 8% 10% 11% 11% 10% 

Integrated Starter Generator ISG 1% 2% 3% 7% 7% 8% 9% 11% 18% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 
 

 

 

 

 

 

 

507 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 46% 50% 59% 61% 61% 61% 61% 61% 61% 

Mass Reduction - Level 2 MR2 16% 25% 36% 40% 45% 47% 51% 53% 53% 

Mass Reduction - Level 3 MR3 7% 8% 10% 13% 15% 15% 18% 19% 20% 

Mass Reduction - Level 4 MR4 2% 2% 3% 3% 4% 4% 4% 5% 9% 

Mass Reduction - Level 5 MR5 0% 0% 1% 1% 2% 3% 3% 3% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 92% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 21% 37% 54% 61% 71% 78% 84% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 93% 93% 93% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 91% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 79% 85% 86% 87% 89% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

508 

5% Annual Increase - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 88% 88% 88% 88% 87% 85% 

Engine Friction Reduction - Level 1 EFR1 83% 87% 87% 87% 87% 87% 87% 86% 85% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 15% 27% 36% 40% 43% 47% 49% 51% 51% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 6% 7% 11% 10% 10% 10% 10% 10% 10% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 6% 6% 5% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 72% 72% 73% 74% 75% 72% 70% 68% 66% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 52% 55% 55% 57% 57% 57% 56% 54% 52% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 15% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on DOHC DEACD 5% 3% 2% 2% 2% 2% 2% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 52% 62% 70% 75% 84% 82% 82% 83% 81% 

Cylinder Deactivation on OHV DEACO 2% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 3% 4% 5% 5% 5% 5% 4% 4% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 3% 4% 5% 5% 5% 5% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 30% 36% 37% 35% 35% 26% 21% 9% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 14% 18% 21% 18% 16% 14% 10% 5% 5% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 3% 3% 2% 2% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 3% 3% 5% 5% 5% 3% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 2% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 1% 1% 2% 8% 11% 19% 22% 33% 35% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 3% 4% 8% 8% 10% 13% 17% 18% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 4% 4% 4% 4% 4% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 1% 4% 5% 7% 9% 9% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 2% 2% 3% 3% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 3% 5% 6% 7% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 4% 3% 3% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 5% 2% 2% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 8% 5% 4% 1% 0% 0% 0% 0% 0% 

6-speed DCT DCT 42% 31% 22% 12% 3% 1% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 20% 20% 19% 12% 8% 6% 5% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 9% 24% 38% 51% 58% 61% 62% 61% 60% 

Shift Optimizer SHFTOPT 12% 31% 47% 60% 79% 86% 87% 83% 80% 

Electric Power Steering EPS 85% 89% 93% 94% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 60% 62% 66% 75% 88% 89% 95% 95% 95% 

Improved Accessories - Level 2 IACC2 15% 28% 34% 42% 53% 63% 70% 79% 82% 

12V Micro-Hybrid (Stop-Start) MHEV 8% 8% 11% 18% 23% 29% 33% 31% 27% 

Integrated Starter Generator ISG 2% 3% 5% 11% 15% 19% 24% 32% 40% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 4% 5% 
 

 

 

 

 

 

 

 

 

509 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 1% 1% 1% 1% 2% 4% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 47% 52% 52% 53% 53% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 26% 32% 44% 48% 47% 48% 52% 52% 51% 

Mass Reduction - Level 3 MR3 10% 13% 14% 18% 18% 18% 18% 19% 19% 

Mass Reduction - Level 4 MR4 4% 4% 6% 9% 9% 9% 9% 9% 9% 

Mass Reduction - Level 5 MR5 1% 2% 3% 8% 8% 8% 8% 9% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 18% 33% 53% 66% 74% 83% 88% 88% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

510 

5% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 99% 99% 99% 99% 99% 95% 

Engine Friction Reduction - Level 1 EFR1 76% 79% 81% 81% 81% 80% 80% 80% 77% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 2% 6% 6% 7% 7% 14% 19% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 14% 14% 14% 14% 14% 14% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 14% 14% 14% 14% 14% 14% 14% 

Cylinder Deactivation on SOHC DEACS 4% 4% 4% 3% 2% 2% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 68% 68% 68% 65% 64% 64% 61% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 35% 38% 38% 38% 38% 36% 36% 36% 35% 

Continuously Variable Valve Lift (CVVL) CVVL 25% 26% 27% 27% 28% 27% 28% 27% 27% 

Cylinder Deactivation on DOHC DEACD 5% 5% 3% 2% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 57% 67% 78% 82% 87% 85% 85% 88% 85% 

Cylinder Deactivation on OHV DEACO 2% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 2% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 3% 3% 3% 3% 3% 3% 3% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_S 

D 38% 43% 50% 48% 47% 40% 32% 20% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_M 

D 12% 16% 18% 19% 17% 16% 16% 15% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_L 

D 2% 3% 3% 4% 3% 3% 3% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_S 

D 0% 0% 0% 2% 2% 2% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_M 

D 2% 2% 2% 2% 2% 2% 2% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 3% 6% 10% 14% 18% 32% 34% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 1% 2% 2% 4% 6% 8% 8% 11% 13% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 2% 2% 2% 2% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 3% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 1% 1% 4% 5% 5% 5% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 3% 2% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 25% 19% 8% 3% 2% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 27% 23% 12% 6% 2% 1% 0% 0% 0% 

6-speed DCT DCT 37% 33% 24% 13% 9% 4% 3% 1% 0% 

8-Speed Trans (Auto or DCT) 8SPD 13% 22% 22% 22% 17% 13% 6% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 6% 23% 35% 42% 47% 51% 55% 52% 

Shift Optimizer SHFTOPT 0% 0% 24% 40% 63% 75% 83% 86% 84% 

Electric Power Steering EPS 78% 85% 93% 94% 97% 97% 97% 97% 97% 

Improved Accessories - Level 1 IACC1 55% 66% 79% 84% 92% 95% 95% 97% 97% 

Improved Accessories - Level 2 IACC2 6% 18% 22% 31% 43% 51% 59% 77% 80% 

12V Micro-Hybrid (Stop-Start) MHEV 10% 11% 14% 16% 20% 20% 24% 24% 24% 

Integrated Starter Generator ISG 2% 3% 5% 11% 12% 13% 19% 28% 29% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

511 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 2% 3% 5% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 1% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 1% 1% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 46% 50% 59% 61% 61% 61% 61% 61% 61% 

Mass Reduction - Level 2 MR2 16% 28% 45% 49% 55% 56% 59% 60% 60% 

Mass Reduction - Level 3 MR3 7% 8% 9% 12% 15% 15% 18% 20% 22% 

Mass Reduction - Level 4 MR4 2% 2% 3% 4% 4% 4% 5% 7% 10% 

Mass Reduction - Level 5 MR5 0% 0% 2% 2% 3% 4% 4% 6% 10% 

Low Rolling Resistance Tires - Level 1 

ROLL1 92% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 22% 41% 52% 62% 69% 80% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 93% 93% 94% 94% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 91% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 79% 86% 87% 87% 89% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

512 

6% Annual Increase - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 89% 88% 86% 84% 82% 78% 

Engine Friction Reduction - Level 1 EFR1 83% 87% 87% 88% 86% 83% 82% 80% 75% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 18% 30% 40% 46% 46% 46% 48% 56% 55% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 9% 10% 11% 10% 10% 10% 10% 10% 9% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 10% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 4% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 73% 74% 74% 74% 71% 67% 66% 63% 60% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 55% 56% 56% 56% 54% 53% 51% 47% 46% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 14% 15% 15% 15% 15% 15% 14% 

Cylinder Deactivation on DOHC DEACD 3% 1% 0% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 60% 70% 76% 80% 83% 81% 81% 77% 73% 

Cylinder Deactivation on OHV DEACO 2% 1% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 4% 4% 5% 5% 5% 5% 5% 5% 4% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 2% 4% 4% 5% 5% 5% 5% 5% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 33% 39% 40% 35% 34% 27% 23% 11% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_M 

D 17% 21% 24% 21% 17% 15% 14% 7% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 3% 2% 2% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 2% 2% 3% 3% 3% 1% 1% 1% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 1% 1% 3% 12% 15% 17% 17% 23% 21% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 4% 4% 6% 10% 10% 11% 12% 11% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 1% 1% 2% 6% 9% 14% 14% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 3% 3% 5% 6% 9% 8% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 3% 3% 3% 4% 4% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 1% 2% 2% 3% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 1% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 4% 3% 3% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 5% 2% 2% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 8% 6% 4% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 38% 28% 19% 11% 2% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 23% 23% 22% 14% 8% 5% 4% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 9% 25% 38% 49% 54% 56% 57% 56% 49% 

Shift Optimizer SHFTOPT 12% 34% 53% 68% 79% 81% 81% 78% 69% 

Electric Power Steering EPS 82% 87% 93% 95% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 65% 68% 75% 84% 87% 87% 93% 96% 96% 

Improved Accessories - Level 2 IACC2 20% 30% 40% 52% 64% 69% 80% 86% 87% 

12V Micro-Hybrid (Stop-Start) MHEV 13% 18% 25% 31% 42% 40% 39% 38% 31% 

Integrated Starter Generator ISG 4% 7% 10% 16% 19% 24% 28% 39% 39% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 3% 3% 3% 3% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 1% 1% 1% 1% 5% 
 

 

 

 

 

 

 

513 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 2% 5% 6% 7% 9% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 1% 1% 2% 5% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 47% 52% 52% 53% 53% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 26% 33% 45% 49% 49% 49% 52% 52% 51% 

Mass Reduction - Level 3 MR3 10% 12% 14% 17% 17% 17% 17% 19% 19% 

Mass Reduction - Level 4 MR4 4% 4% 6% 6% 6% 6% 6% 8% 8% 

Mass Reduction - Level 5 MR5 1% 1% 3% 5% 6% 6% 6% 7% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 18% 35% 52% 67% 74% 83% 86% 89% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

514 

6% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 100% 99% 98% 98% 96% 94% 92% 

Engine Friction Reduction - Level 1 EFR1 77% 79% 80% 80% 79% 79% 77% 76% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 3% 5% 5% 6% 10% 15% 17% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 14% 14% 14% 14% 14% 14% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 14% 14% 14% 14% 14% 14% 14% 

Cylinder Deactivation on SOHC DEACS 4% 3% 2% 2% 1% 1% 1% 1% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 67% 66% 65% 63% 61% 60% 58% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 34% 38% 37% 36% 36% 35% 34% 32% 31% 

Continuously Variable Valve Lift (CVVL) CVVL 25% 26% 27% 27% 27% 27% 25% 25% 24% 

Cylinder Deactivation on DOHC DEACD 4% 4% 3% 2% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 51% 63% 78% 77% 84% 83% 81% 78% 77% 

Cylinder Deactivation on OHV DEACO 2% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 3% 3% 3% 2% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 27% 33% 40% 38% 39% 35% 28% 16% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 14% 19% 22% 21% 19% 18% 16% 12% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 2% 2% 2% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 1% 1% 1% 1% 1% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3% 4% 8% 10% 16% 18% 23% 29% 31% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 2% 3% 3% 6% 7% 7% 9% 12% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 1% 1% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 3% 3% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 2% 3% 4% 5% 5% 7% 7% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 4% 3% 2% 2% 1% 1% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 18% 16% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 25% 17% 7% 2% 1% 0% 0% 0% 0% 

6-speed DCT DCT 39% 35% 27% 15% 7% 5% 3% 1% 0% 

8-Speed Trans (Auto or DCT) 8SPD 21% 29% 29% 29% 19% 12% 5% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 7% 25% 36% 41% 46% 46% 42% 40% 

Shift Optimizer SHFTOPT 0% 0% 21% 37% 59% 72% 83% 80% 78% 

Electric Power Steering EPS 80% 88% 97% 97% 97% 97% 97% 97% 97% 

Improved Accessories - Level 1 IACC1 60% 67% 80% 81% 89% 91% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 9% 20% 34% 39% 51% 57% 69% 69% 71% 

12V Micro-Hybrid (Stop-Start) MHEV 11% 17% 31% 37% 47% 48% 45% 41% 37% 

Integrated Starter Generator ISG 4% 6% 8% 14% 21% 26% 32% 39% 40% 
 

 

 

 

 

 

 

 

515 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 1% 1% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 1% 3% 6% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 2% 2% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 1% 1% 1% 2% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 1% 1% 2% 3% 4% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 47% 51% 59% 60% 61% 60% 61% 60% 61% 

Mass Reduction - Level 2 MR2 17% 28% 45% 49% 54% 55% 58% 59% 60% 

Mass Reduction - Level 3 MR3 7% 8% 10% 11% 14% 15% 17% 19% 22% 

Mass Reduction - Level 4 MR4 2% 2% 4% 4% 4% 4% 5% 5% 9% 

Mass Reduction - Level 5 MR5 0% 0% 2% 3% 4% 4% 5% 5% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 93% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 38% 50% 59% 71% 77% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 93% 93% 94% 94% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 79% 86% 87% 87% 89% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

516 

7% Annual Increase - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 89% 88% 88% 84% 84% 80% 78% 

Engine Friction Reduction - Level 1 EFR1 87% 87% 87% 87% 85% 82% 81% 77% 75% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 18% 30% 40% 42% 43% 42% 45% 50% 50% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 9% 10% 10% 10% 8% 8% 8% 8% 8% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 9% 9% 9% 9% 8% 

Cylinder Deactivation on SOHC DEACS 2% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 4% 3% 3% 1% 1% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 73% 73% 73% 71% 64% 61% 60% 58% 57% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 55% 56% 55% 54% 49% 45% 45% 42% 42% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 14% 15% 14% 14% 14% 14% 13% 

Cylinder Deactivation on DOHC DEACD 5% 2% 1% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 67% 78% 83% 84% 76% 72% 72% 69% 68% 

Cylinder Deactivation on OHV DEACO 1% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 4% 4% 5% 5% 4% 4% 4% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 3% 4% 5% 5% 5% 4% 4% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 38% 45% 42% 37% 29% 24% 19% 15% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 19% 24% 26% 22% 19% 16% 13% 8% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 3% 2% 2% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 2% 2% 2% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 2% 3% 5% 11% 13% 15% 16% 18% 19% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 3% 4% 6% 7% 8% 9% 9% 10% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 3% 3% 4% 4% 8% 8% 7% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 2% 3% 4% 5% 5% 5% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 3% 3% 3% 4% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 2% 6% 7% 7% 7% 7% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 3% 5% 5% 5% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 4% 3% 3% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 7% 6% 2% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 10% 4% 2% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 39% 28% 19% 10% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 23% 23% 22% 13% 7% 5% 4% 4% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 11% 26% 37% 50% 56% 57% 57% 53% 51% 

Shift Optimizer SHFTOPT 12% 34% 56% 73% 82% 80% 79% 72% 68% 

Electric Power Steering EPS 87% 91% 94% 95% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 63% 74% 86% 93% 93% 95% 96% 96% 96% 

Improved Accessories - Level 2 IACC2 23% 41% 50% 61% 72% 81% 84% 84% 85% 

12V Micro-Hybrid (Stop-Start) MHEV 20% 28% 37% 41% 44% 40% 39% 34% 31% 

Integrated Starter Generator ISG 6% 10% 13% 20% 29% 34% 38% 36% 39% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 0% 0% 0% 0% 
 

 

 

 

 

 

 

517 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 1% 1% 4% 6% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 3% 7% 7% 8% 9% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 1% 1% 1% 1% 2% 3% 6% 7% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 49% 53% 53% 53% 53% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 27% 36% 49% 52% 52% 51% 52% 51% 51% 

Mass Reduction - Level 3 MR3 10% 12% 14% 16% 16% 17% 17% 17% 19% 

Mass Reduction - Level 4 MR4 4% 4% 6% 6% 6% 7% 6% 7% 9% 

Mass Reduction - Level 5 MR5 2% 2% 4% 6% 6% 6% 6% 7% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 18% 33% 52% 66% 75% 84% 88% 88% 88% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

518 

7% Annual Increase - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 99% 99% 98% 95% 92% 90% 88% 

Engine Friction Reduction - Level 1 EFR1 78% 79% 80% 80% 80% 79% 77% 75% 73% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 3% 6% 6% 6% 9% 15% 17% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 15% 15% 15% 15% 15% 14% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 15% 14% 14% 14% 14% 14% 13% 

Cylinder Deactivation on SOHC DEACS 4% 3% 2% 2% 1% 1% 1% 1% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 68% 67% 66% 65% 61% 54% 53% 51% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 35% 38% 37% 37% 37% 35% 30% 29% 27% 

Continuously Variable Valve Lift (CVVL) CVVL 25% 26% 27% 26% 26% 26% 25% 24% 24% 

Cylinder Deactivation on DOHC DEACD 6% 5% 3% 2% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 63% 74% 85% 83% 84% 82% 76% 73% 71% 

Cylinder Deactivation on OHV DEACO 2% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 2% 2% 2% 2% 2% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 2% 3% 3% 3% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 41% 46% 51% 48% 46% 42% 34% 22% 15% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 12% 17% 21% 20% 18% 18% 17% 12% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 3% 3% 3% 2% 2% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 1% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3% 4% 5% 8% 8% 9% 8% 15% 17% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 4% 5% 8% 8% 9% 10% 14% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 3% 4% 4% 4% 4% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 2% 3% 5% 9% 10% 10% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 4% 3% 2% 2% 1% 1% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 18% 16% 6% 1% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 25% 17% 6% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 40% 34% 25% 13% 5% 3% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 22% 31% 31% 31% 21% 14% 6% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 7% 25% 34% 40% 43% 44% 42% 38% 

Shift Optimizer SHFTOPT 0% 0% 24% 44% 64% 72% 81% 76% 71% 

Electric Power Steering EPS 79% 88% 96% 97% 97% 97% 97% 97% 97% 

Improved Accessories - Level 1 IACC1 60% 71% 86% 92% 95% 97% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 13% 27% 41% 44% 53% 57% 58% 60% 61% 

12V Micro-Hybrid (Stop-Start) MHEV 27% 38% 53% 53% 53% 49% 45% 36% 32% 

Integrated Starter Generator ISG 6% 11% 13% 17% 30% 35% 36% 37% 37% 
 

 

 

 

 

 

 

 

 

519 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 2% 8% 11% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 1% 1% 2% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 1% 1% 1% 5% 6% 7% 9% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 48% 52% 59% 61% 61% 61% 61% 61% 61% 

Mass Reduction - Level 2 MR2 17% 29% 47% 50% 55% 56% 58% 59% 60% 

Mass Reduction - Level 3 MR3 8% 8% 10% 12% 15% 15% 17% 19% 22% 

Mass Reduction - Level 4 MR4 2% 3% 4% 4% 4% 4% 4% 7% 10% 

Mass Reduction - Level 5 MR5 0% 0% 2% 2% 3% 4% 4% 6% 10% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 21% 38% 48% 58% 69% 79% 86% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 91% 92% 93% 94% 94% 94% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 97% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 56% 70% 79% 86% 87% 87% 89% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

520 

Max Net Benefits - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 89% 89% 88% 87% 87% 87% 87% 87% 86% 

Engine Friction Reduction - Level 1 EFR1 87% 87% 86% 86% 86% 86% 86% 86% 85% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 20% 23% 29% 38% 55% 57% 67% 74% 75% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 10% 10% 10% 10% 10% 10% 10% 10% 10% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 1% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 4% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 71% 71% 70% 70% 71% 71% 70% 70% 70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 55% 55% 54% 55% 55% 55% 55% 55% 55% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 14% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on DOHC DEACD 4% 3% 2% 1% 1% 1% 1% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 70% 75% 75% 78% 82% 83% 83% 84% 84% 

Cylinder Deactivation on OHV DEACO 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 5% 5% 5% 5% 5% 5% 5% 4% 4% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 5% 5% 5% 5% 5% 5% 5% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 38% 41% 38% 38% 31% 28% 23% 9% 5% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_MD 20% 22% 21% 22% 22% 22% 20% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 3% 3% 3% 4% 4% 3% 3% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 3% 9% 9% 11% 19% 18% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_MD 1% 1% 1% 1% 1% 1% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 4% 4% 6% 8% 12% 16% 18% 23% 26% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 5% 5% 6% 7% 8% 8% 10% 12% 12% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 0% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 2% 2% 3% 3% 3% 3% 3% 3% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 5% 4% 3% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 8% 

Improved Auto. Trans. Controls/Externals IATC 6% 2% 2% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 7% 5% 2% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 38% 26% 15% 6% 2% 1% 1% 1% 1% 

8-Speed Trans (Auto or DCT) 8SPD 31% 31% 30% 22% 11% 8% 6% 6% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 7% 24% 36% 50% 57% 59% 61% 59% 58% 

Shift Optimizer SHFTOPT 15% 27% 39% 53% 78% 81% 82% 79% 77% 

Electric Power Steering EPS 94% 94% 94% 94% 95% 95% 95% 95% 95% 

Improved Accessories - Level 1 IACC1 76% 76% 76% 78% 82% 82% 83% 87% 90% 

Improved Accessories - Level 2 IACC2 38% 42% 43% 48% 51% 52% 55% 59% 61% 

12V Micro-Hybrid (Stop-Start) MHEV 24% 26% 27% 26% 24% 24% 24% 22% 18% 

Integrated Starter Generator ISG 6% 8% 10% 14% 17% 18% 19% 25% 30% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 3% 3% 
 

 

 

 

 

 

 

521 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 3% 4% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 1% 2% 2% 2% 2% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 53% 53% 53% 53% 52% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 27% 32% 43% 46% 46% 46% 50% 51% 51% 

Mass Reduction - Level 3 MR3 11% 13% 14% 16% 16% 15% 16% 17% 18% 

Mass Reduction - Level 4 MR4 5% 5% 6% 6% 6% 6% 6% 7% 7% 

Mass Reduction - Level 5 MR5 3% 3% 4% 6% 6% 5% 5% 6% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 22% 33% 46% 58% 78% 85% 86% 87% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

522 

Max Net Benefits - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 98% 98% 98% 98% 98% 98% 97% 

Engine Friction Reduction - Level 1 EFR1 79% 80% 78% 78% 79% 78% 78% 78% 77% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 1% 7% 12% 13% 16% 23% 27% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 15% 14% 14% 14% 14% 14% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 14% 13% 14% 14% 14% 14% 13% 

Cylinder Deactivation on SOHC DEACS 4% 3% 2% 2% 1% 1% 1% 1% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 67% 67% 66% 66% 66% 66% 66% 66% 65% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 34% 36% 34% 35% 35% 35% 35% 35% 35% 

Continuously Variable Valve Lift (CVVL) CVVL 27% 26% 25% 24% 24% 24% 24% 24% 24% 

Cylinder Deactivation on DOHC DEACD 4% 3% 1% 0% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 70% 76% 83% 83% 84% 85% 85% 85% 85% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 2% 2% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 1% 3% 2% 3% 3% 3% 2% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 44% 45% 50% 47% 45% 43% 34% 21% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 15% 20% 23% 24% 22% 21% 20% 19% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 2% 2% 2% 2% 2% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 4% 5% 5% 6% 10% 12% 17% 31% 34% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 4% 4% 6% 7% 8% 9% 13% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 3% 3% 4% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 3% 4% 4% 4% 4% 4% 5% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 4% 4% 3% 2% 2% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 20% 18% 8% 3% 1% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 21% 17% 8% 2% 0% 0% 0% 0% 0% 

6-speed DCT DCT 43% 34% 23% 12% 9% 6% 5% 2% 1% 

8-Speed Trans (Auto or DCT) 8SPD 21% 28% 33% 34% 31% 24% 18% 12% 13% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 8% 22% 32% 37% 41% 50% 56% 56% 

Shift Optimizer SHFTOPT 0% 0% 15% 32% 45% 55% 63% 65% 65% 

Electric Power Steering EPS 92% 96% 97% 97% 97% 97% 97% 97% 97% 

Improved Accessories - Level 1 IACC1 73% 77% 86% 90% 94% 94% 95% 95% 95% 

Improved Accessories - Level 2 IACC2 12% 16% 26% 28% 43% 48% 53% 56% 58% 

12V Micro-Hybrid (Stop-Start) MHEV 27% 27% 27% 27% 29% 28% 26% 27% 24% 

Integrated Starter Generator ISG 7% 9% 10% 11% 12% 15% 18% 21% 27% 
 

 

 

 

 

 

 

 

523 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 1% 1% 1% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 2% 2% 2% 2% 2% 2% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 55% 57% 59% 60% 61% 60% 61% 60% 61% 

Mass Reduction - Level 2 MR2 18% 26% 44% 47% 52% 52% 59% 59% 60% 

Mass Reduction - Level 3 MR3 8% 8% 12% 14% 16% 16% 18% 19% 22% 

Mass Reduction - Level 4 MR4 2% 3% 4% 4% 4% 4% 4% 7% 7% 

Mass Reduction - Level 5 MR5 0% 0% 2% 3% 3% 4% 4% 4% 4% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 34% 51% 61% 71% 82% 88% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 93% 93% 93% 94% 94% 94% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 55% 69% 78% 85% 86% 86% 89% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

524 

Total Cost = Total Benefits - Passenger Cars - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

201 

8 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 87% 87% 87% 86% 86% 86% 86% 85% 84% 

Engine Friction Reduction - Level 1 EFR1 85% 85% 84% 85% 85% 85% 84% 84% 83% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 18% 21% 26% 33% 52% 57% 66% 75% 77% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 10% 10% 10% 10% 10% 10% 10% 10% 10% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 1% 1% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 4% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 71% 70% 70% 69% 69% 69% 69% 69% 68% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 55% 55% 54% 55% 56% 56% 56% 55% 55% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 14% 14% 14% 14% 14% 14% 14% 

Cylinder Deactivation on DOHC DEACD 3% 2% 1% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 78% 80% 81% 81% 82% 84% 84% 84% 83% 

Cylinder Deactivation on OHV DEACO 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 5% 5% 5% 5% 5% 4% 4% 4% 4% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 5% 5% 5% 5% 5% 4% 4% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Small Displacement TRBDS1_SD 46% 46% 43% 41% 30% 25% 20% 6% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Displacement 

TRBDS1_M 

D 21% 23% 22% 21% 20% 19% 15% 11% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Displacement TRBDS1_LD 3% 3% 3% 3% 3% 3% 2% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Displacement TRBDS2_SD 3% 3% 3% 5% 5% 4% 3% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Displacement 

TRBDS2_M 

D 1% 1% 1% 1% 0% 0% 0% 2% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Displacement TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Small Displacement CEGR1_SD 2% 3% 4% 6% 16% 23% 27% 38% 40% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Medium Displacement CEGR1_MD 5% 5% 5% 7% 8% 11% 11% 12% 12% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 0% 1% 1% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 1% 3% 3% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 2% 2% 2% 4% 4% 4% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 2% 2% 3% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Medium Displacement ADSL_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 5% 4% 3% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 2% 3% 4% 6% 8% 8% 8% 8% 9% 

Improved Auto. Trans. Controls/Externals IATC 4% 2% 2% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 7% 2% 2% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 41% 29% 14% 6% 2% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 29% 29% 27% 18% 10% 8% 6% 6% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 7% 23% 38% 55% 60% 64% 64% 62% 60% 

Shift Optimizer SHFTOPT 14% 25% 40% 56% 78% 83% 82% 78% 75% 

Electric Power Steering EPS 94% 94% 94% 94% 95% 95% 95% 95% 95% 
 

 

 

 

 

 

 

 

 

 

 

 

 

525 

Improved Accessories - Level 1 IACC1 76% 79% 82% 83% 85% 85% 91% 95% 96% 

Improved Accessories - Level 2 (w/ Alternator Regen and 

70% efficient alternator) IACC2 38% 43% 48% 55% 64% 65% 70% 73% 75% 

12V Micro-Hybrid (Stop-Start) MHEV 29% 30% 33% 32% 32% 33% 33% 30% 28% 

Integrated Starter Generator ISG 11% 13% 15% 18% 19% 24% 24% 26% 29% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 2% 5% 7% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 2% 2% 3% 3% 3% 4% 4% 4% 5% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 53% 53% 53% 53% 53% 52% 53% 52% 52% 

Mass Reduction - Level 2 MR2 27% 33% 44% 47% 47% 47% 51% 51% 51% 

Mass Reduction - Level 3 MR3 11% 13% 13% 16% 17% 16% 16% 19% 19% 

Mass Reduction - Level 4 MR4 5% 5% 5% 8% 7% 7% 7% 7% 7% 

Mass Reduction - Level 5 MR5 3% 3% 3% 7% 7% 7% 6% 7% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 22% 27% 39% 53% 76% 83% 85% 86% 88% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 92% 92% 92% 92% 92% 92% 92% 92% 92% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 96% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 47% 59% 71% 81% 88% 89% 89% 89% 89% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

526 

Total Cost = Total Benefits - Passenger Cars - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 98% 98% 98% 98% 96% 96% 96% 

Engine Friction Reduction - Level 1 EFR1 80% 80% 79% 79% 78% 78% 77% 76% 76% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 1% 6% 12% 13% 14% 22% 25% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 15% 14% 14% 14% 14% 14% 14% 14% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 14% 14% 14% 14% 14% 14% 14% 14% 14% 

Cylinder Deactivation on SOHC DEACS 4% 3% 2% 2% 1% 1% 1% 1% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 67% 67% 67% 66% 65% 65% 64% 63% 63% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 34% 35% 34% 34% 34% 35% 35% 35% 34% 

Continuously Variable Valve Lift (CVVL) CVVL 27% 26% 25% 25% 25% 25% 24% 24% 24% 

Cylinder Deactivation on DOHC DEACD 4% 4% 2% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 68% 74% 81% 82% 83% 84% 84% 84% 84% 

Cylinder Deactivation on OHV DEACO 3% 1% 1% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 3% 2% 3% 3% 3% 3% 3% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 1% 1% 2% 2% 2% 2% 3% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Small Displacement TRBDS1_SD 42% 44% 48% 48% 45% 39% 31% 18% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Displacement 

TRBDS1_M 

D 14% 19% 22% 21% 21% 20% 20% 17% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Displacement TRBDS1_LD 2% 2% 2% 3% 2% 2% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Displacement TRBDS2_SD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Displacement 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Displacement TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Small Displacement CEGR1_SD 5% 5% 5% 7% 11% 17% 22% 32% 34% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Medium Displacement CEGR1_MD 4% 4% 4% 4% 6% 7% 7% 8% 10% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar 

BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Medium Displacement CEGR2_MD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar 

BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 3% 3% 4% 4% 4% 4% 4% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 4% 4% 3% 2% 2% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 0% 2% 3% 4% 4% 4% 4% 

Improved Auto. Trans. Controls/Externals IATC 18% 15% 6% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 20% 15% 6% 1% 0% 0% 0% 0% 0% 

6-speed DCT DCT 47% 37% 25% 13% 5% 3% 1% 1% 0% 

8-Speed Trans (Auto or DCT) 8SPD 23% 31% 31% 31% 23% 14% 8% 5% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 8% 26% 39% 44% 45% 54% 56% 56% 

Shift Optimizer SHFTOPT 0% 0% 18% 35% 53% 68% 73% 79% 80% 

Electric Power Steering EPS 92% 97% 97% 97% 97% 97% 97% 97% 97% 
 

 

 

 

 

 

 

 

 

 

 

 

527 

Improved Accessories - Level 1 IACC1 76% 82% 90% 94% 94% 96% 96% 97% 97% 

Improved Accessories - Level 2 (w/ Alternator Regen and 

70% efficient alternator) IACC2 16% 26% 36% 37% 49% 54% 56% 60% 63% 

12V Micro-Hybrid (Stop-Start) MHEV 29% 30% 35% 34% 35% 33% 30% 25% 24% 

Integrated Starter Generator ISG 8% 10% 11% 13% 16% 20% 22% 26% 28% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 2% 6% 7% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 1% 1% 1% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 2% 2% 2% 2% 3% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 55% 57% 59% 61% 61% 61% 61% 61% 61% 

Mass Reduction - Level 2 MR2 18% 30% 48% 51% 56% 56% 59% 59% 59% 

Mass Reduction - Level 3 MR3 8% 8% 11% 13% 16% 16% 18% 19% 21% 

Mass Reduction - Level 4 MR4 2% 2% 4% 4% 4% 4% 5% 6% 9% 

Mass Reduction - Level 5 MR5 0% 0% 1% 2% 3% 4% 4% 6% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 97% 99% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 35% 46% 58% 68% 84% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 93% 93% 93% 94% 94% 94% 94% 94% 94% 

Secondary Axle Disconnect SAX 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Aero Drag Reduction, Level 1 

AERO1 92% 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 

Aero Drag Reduction, Level 2 AERO2 42% 55% 69% 78% 85% 86% 86% 89% 91% 

* DOT has not yet been able to modify the CAFE model to explicitly estimate the extent to 

which manufacturers might respond to the proposed technology incentives by building greater 

numbers of HEVs, PHEVs, and/or EVs. Increased application of such technologies could result 

in reduced estimated application of some other technologies (e.g., diesel engines). 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

528 

Table V-151 Penetration Rate of New Technologies to Light Trucks, by Baseline Model 

Year and Alternative 

Preferred Alternative - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 78% 77% 77% 77% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 11% 19% 41% 49% 68% 74% 77% 83% 90% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 5% 5% 3% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 59% 60% 61% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 41% 41% 43% 43% 44% 44% 44% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 28% 26% 24% 20% 17% 16% 16% 10% 9% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 42% 45% 49% 54% 61% 63% 64% 70% 72% 

Cylinder Deactivation on OHV DEACO 14% 14% 13% 11% 10% 9% 7% 7% 7% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 19% 17% 17% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 9% 10% 12% 12% 11% 12% 12% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 10% 10% 9% 8% 8% 7% 7% 8% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 27% 30% 34% 42% 44% 42% 43% 46% 43% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 7% 6% 6% 6% 8% 7% 7% 7% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 1% 2% 2% 3% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 1% 2% 2% 2% 2% 2% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 0% 0% 2% 2% 3% 5% 6% 8% 9% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 0% 1% 3% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 1% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 1% 1% 2% 2% 2% 2% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

529 

Improved Auto. Trans. Controls/Externals IATC 30% 23% 23% 16% 4% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 35% 28% 18% 11% 9% 5% 2% 0% 0% 

6-speed DCT DCT 2% 2% 3% 2% 2% 1% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 14% 18% 19% 18% 16% 15% 14% 9% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 13% 28% 42% 63% 74% 78% 85% 92% 

Shift Optimizer SHFTOPT 10% 15% 30% 40% 54% 58% 66% 85% 92% 

Electric Power Steering EPS 74% 78% 80% 83% 86% 87% 88% 89% 96% 

Improved Accessories - Level 1 IACC1 46% 49% 51% 53% 60% 61% 65% 77% 81% 

Improved Accessories - Level 2 IACC2 7% 7% 9% 16% 24% 29% 36% 51% 71% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 3% 3% 3% 3% 3% 3% 3% 2% 

Integrated Starter Generator ISG 0% 0% 0% 0% 0% 0% 0% 0% 4% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 1% 1% 1% 1% 1% 0% 

Conversion from SHEV1 to SHEV2 

SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 82% 84% 93% 96% 99% 

100 

% 

100 

% 100% 100% 

Mass Reduction - Level 2 MR2 35% 44% 56% 67% 76% 81% 83% 85% 88% 

Mass Reduction - Level 3 MR3 14% 14% 17% 23% 36% 41% 46% 52% 59% 

Mass Reduction - Level 4 MR4 7% 7% 8% 11% 21% 24% 25% 29% 42% 

Mass Reduction - Level 5 MR5 0% 0% 0% 1% 1% 3% 3% 5% 18% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 

100 

% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 12% 24% 48% 63% 79% 85% 90% 94% 98% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 76% 77% 80% 81% 82% 82% 82% 82% 82% 

Secondary Axle Disconnect SAX 27% 33% 34% 38% 38% 38% 38% 38% 37% 

Aero Drag Reduction, Level 1 

AERO1 99% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 

100 

% 100% 100% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

530 

Preferred Alternative - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 73% 73% 73% 75% 75% 75% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 13% 25% 26% 35% 43% 44% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 26% 26% 26% 26% 24% 24% 24% 24% 24% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 22% 23% 23% 23% 23% 23% 24% 24% 23% 

Cylinder Deactivation on SOHC DEACS 19% 19% 17% 16% 5% 4% 3% 3% 3% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 46% 46% 48% 48% 48% 48% 48% 48% 48% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 17% 18% 20% 20% 20% 20% 20% 20% 20% 

Continuously Variable Valve Lift (CVVL) CVVL 11% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on DOHC DEACD 15% 20% 15% 15% 13% 12% 12% 10% 8% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 28% 31% 41% 42% 54% 56% 58% 61% 62% 

Cylinder Deactivation on OHV DEACO 11% 11% 9% 3% 3% 3% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 3% 3% 10% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 11% 12% 13% 13% 12% 13% 13% 12% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_M 

D 18% 19% 27% 28% 30% 32% 32% 32% 33% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 1% 1% 9% 15% 26% 26% 29% 29% 29% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement 

CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 1% 1% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement 

CEGR1_MD 4% 5% 5% 6% 4% 4% 5% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement 

CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement 

CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement 

CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement 

CEGR2_LD 1% 1% 1% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement 

ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement 

ADSL_MD 0% 0% 0% 0% 2% 2% 1% 1% 1% 

Advanced Diesel - Large Displacement 

ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 52% 49% 36% 19% 5% 3% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 71% 68% 53% 32% 18% 13% 5% 0% 0% 

6-speed DCT DCT 5% 7% 6% 3% 3% 3% 3% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 7% 10% 13% 19% 16% 15% 13% 9% 9% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

531 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 2% 13% 24% 45% 54% 64% 71% 73% 

Shift Optimizer SHFTOPT 0% 0% 14% 27% 33% 38% 48% 62% 67% 

Electric Power Steering EPS 69% 73% 81% 86% 88% 90% 91% 92% 92% 

Improved Accessories - Level 1 IACC1 57% 61% 66% 70% 79% 83% 84% 89% 90% 

Improved Accessories - Level 2 IACC2 8% 10% 15% 16% 32% 36% 40% 47% 50% 

12V Micro-Hybrid (Stop-Start) MHEV 9% 9% 10% 13% 13% 12% 12% 12% 12% 

Integrated Starter Generator ISG 3% 3% 3% 4% 4% 4% 4% 4% 4% 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 

SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 69% 76% 83% 91% 94% 95% 95% 99% 99% 

Mass Reduction - Level 2 MR2 30% 36% 45% 48% 61% 64% 64% 68% 68% 

Mass Reduction - Level 3 MR3 14% 14% 15% 17% 21% 23% 26% 30% 30% 

Mass Reduction - Level 4 MR4 6% 7% 7% 8% 11% 12% 12% 15% 15% 

Mass Reduction - Level 5 MR5 0% 0% 1% 2% 5% 6% 7% 9% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 98% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 19% 26% 41% 49% 57% 76% 77% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 74% 76% 80% 82% 82% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 27% 29% 32% 33% 34% 36% 37% 37% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 

100 

% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 49% 56% 70% 84% 87% 89% 92% 95% 96% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

532 

2% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 78% 77% 77% 77% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 12% 20% 35% 47% 59% 64% 65% 69% 73% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 3% 3% 3% 3% 1% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 59% 60% 61% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 40% 40% 40% 41% 42% 43% 44% 44% 44% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 10% 10% 10% 10% 11% 11% 9% 9% 9% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 63% 63% 63% 64% 67% 68% 71% 71% 71% 

Cylinder Deactivation on OHV DEACO 13% 13% 13% 13% 12% 11% 10% 10% 10% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 18% 17% 16% 16% 15% 15% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 9% 9% 10% 9% 9% 9% 9% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 10% 10% 9% 9% 9% 9% 9% 9% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. TRBDS1_M 

D 50% 49% 50% 51% 51% 51% 54% 54% 54% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_L 

D 6% 6% 6% 6% 7% 8% 8% 8% 8% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. TRBDS2_M 

D 0% 1% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 0% 0% 0% 0% 1% 1% 1% 1% 1% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 1% 1% 1% 1% 1% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 16% 12% 9% 3% 3% 3% 4% 6% 5% 

6-Speed Trans with Improved Internals (Auto) NAUTO 47% 41% 29% 22% 17% 11% 10% 17% 17% 

6-speed DCT DCT 4% 4% 5% 3% 3% 1% 1% 1% 1% 

8-Speed Trans (Auto or DCT) 8SPD 16% 18% 21% 22% 19% 22% 21% 15% 11% 

High Efficiency Gearbox (Auto or DCT) HETRANS 3% 9% 19% 29% 42% 48% 52% 57% 62% 

Shift Optimizer SHFTOPT 8% 10% 23% 25% 26% 28% 28% 29% 29% 

Electric Power Steering EPS 70% 73% 74% 75% 76% 77% 78% 78% 84% 

Improved Accessories - Level 1 IACC1 48% 50% 52% 55% 56% 56% 56% 56% 56% 

Improved Accessories - Level 2 IACC2 4% 5% 5% 5% 8% 9% 10% 13% 13% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Integrated Starter Generator ISG 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

533 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 78% 79% 85% 88% 88% 90% 91% 91% 91% 

Mass Reduction - Level 2 MR2 34% 43% 54% 64% 70% 71% 74% 74% 78% 

Mass Reduction - Level 3 MR3 16% 16% 19% 23% 23% 26% 32% 36% 37% 

Mass Reduction - Level 4 MR4 8% 8% 9% 9% 10% 13% 13% 18% 18% 

Mass Reduction - Level 5 MR5 0% 0% 0% 0% 0% 2% 2% 4% 4% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 

100 

% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 12% 24% 41% 62% 79% 82% 83% 89% 91% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 74% 75% 77% 77% 78% 78% 78% 77% 77% 

Secondary Axle Disconnect SAX 26% 29% 32% 32% 33% 35% 35% 37% 37% 

Aero Drag Reduction, Level 1 

AERO1 99% 99% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 

100 

% 100% 100% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

534 

2% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 72% 72% 72% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 7% 9% 13% 17% 22% 25% 25% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 24% 24% 24% 24% 24% 24% 24% 24% 24% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 22% 23% 23% 23% 23% 23% 23% 22% 22% 

Cylinder Deactivation on SOHC DEACS 8% 8% 7% 7% 7% 7% 7% 5% 5% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 46% 46% 48% 48% 48% 48% 48% 48% 48% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 18% 18% 20% 20% 20% 20% 20% 20% 20% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on DOHC DEACD 12% 12% 9% 9% 8% 7% 6% 6% 6% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 50% 51% 56% 56% 57% 58% 59% 61% 61% 

Cylinder Deactivation on OHV DEACO 9% 9% 9% 9% 9% 9% 9% 9% 9% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 10% 10% 10% 10% 10% 10% 10% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 9% 11% 12% 11% 11% 11% 11% 11% 11% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 33% 34% 37% 37% 38% 38% 39% 41% 41% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 14% 15% 16% 16% 16% 16% 16% 16% 16% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 5% 5% 5% 5% 4% 4% 4% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 55% 52% 40% 24% 16% 14% 14% 19% 19% 

6-Speed Trans with Improved Internals (Auto) NAUTO 64% 62% 54% 35% 27% 25% 19% 19% 19% 

6-speed DCT DCT 7% 7% 5% 5% 5% 7% 7% 6% 6% 

8-Speed Trans (Auto or DCT) 8SPD 6% 8% 8% 13% 20% 19% 20% 21% 21% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 2% 10% 21% 25% 28% 33% 33% 33% 

Shift Optimizer SHFTOPT 0% 0% 12% 18% 20% 21% 28% 28% 28% 

Electric Power Steering EPS 67% 69% 73% 74% 84% 88% 90% 90% 90% 

Improved Accessories - Level 1 IACC1 55% 56% 58% 61% 65% 67% 73% 82% 81% 

Improved Accessories - Level 2 IACC2 8% 10% 12% 12% 16% 16% 19% 24% 30% 

12V Micro-Hybrid (Stop-Start) MHEV 12% 12% 12% 13% 12% 12% 12% 12% 12% 

Integrated Starter Generator ISG 2% 2% 2% 3% 4% 4% 4% 4% 4% 
 

 

 

 

 

 

 

 

 

 

 

535 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 69% 69% 75% 77% 83% 84% 84% 84% 84% 

Mass Reduction - Level 2 MR2 30% 37% 44% 47% 57% 59% 59% 64% 63% 

Mass Reduction - Level 3 MR3 15% 15% 15% 16% 16% 18% 21% 23% 24% 

Mass Reduction - Level 4 MR4 6% 6% 7% 7% 7% 7% 8% 10% 11% 

Mass Reduction - Level 5 MR5 0% 0% 1% 1% 1% 1% 1% 4% 4% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 98% 98% 98% 98% 98% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 30% 39% 49% 60% 73% 74% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 70% 71% 74% 74% 82% 81% 81% 81% 81% 

Secondary Axle Disconnect SAX 27% 30% 32% 33% 33% 35% 35% 35% 35% 

Aero Drag Reduction, Level 1 

AERO1 94% 94% 94% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 AERO2 49% 56% 70% 80% 83% 85% 88% 91% 91% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

536 

3% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 78% 77% 77% 77% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 12% 20% 35% 49% 61% 65% 69% 76% 83% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 3% 3% 3% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 59% 60% 61% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 41% 42% 43% 43% 44% 44% 44% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 9% 9% 9% 9% 8% 7% 6% 5% 4% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 64% 65% 66% 67% 71% 73% 74% 76% 77% 

Cylinder Deactivation on OHV DEACO 13% 13% 8% 6% 6% 6% 4% 4% 4% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 19% 17% 17% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 9% 11% 15% 15% 14% 15% 15% 15% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 10% 10% 9% 9% 9% 9% 9% 9% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 48% 48% 51% 55% 52% 51% 51% 50% 47% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 7% 6% 10% 11% 12% 12% 12% 12% 12% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 1% 1% 1% 2% 5% 5% 5% 5% 7% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 2% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 1% 2% 2% 2% 5% 6% 7% 10% 11% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 1% 1% 1% 3% 3% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 14% 10% 8% 3% 4% 3% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 38% 33% 22% 17% 8% 7% 2% 1% 0% 

6-speed DCT DCT 8% 10% 10% 7% 7% 3% 3% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 27% 28% 32% 27% 16% 14% 15% 10% 7% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 13% 24% 38% 54% 60% 66% 75% 79% 

Shift Optimizer SHFTOPT 11% 18% 33% 45% 60% 62% 63% 67% 73% 

Electric Power Steering EPS 69% 73% 74% 76% 79% 79% 80% 82% 84% 

Improved Accessories - Level 1 IACC1 48% 50% 55% 57% 57% 58% 58% 59% 59% 

Improved Accessories - Level 2 IACC2 4% 5% 6% 5% 8% 11% 11% 17% 19% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Integrated Starter Generator ISG 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 2% 2% 2% 1% 1% 1% 
 

 

 

 

 

 

 

 

 

 

 

537 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 88% 89% 94% 97% 98% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 35% 44% 56% 67% 76% 81% 84% 84% 85% 

Mass Reduction - Level 3 MR3 16% 16% 19% 24% 29% 32% 39% 44% 48% 

Mass Reduction - Level 4 MR4 8% 9% 9% 14% 16% 19% 19% 23% 27% 

Mass Reduction - Level 5 MR5 0% 0% 0% 3% 3% 3% 3% 5% 9% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 13% 24% 43% 60% 75% 84% 89% 95% 97% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 74% 75% 77% 78% 81% 81% 81% 82% 84% 

Secondary Axle Disconnect SAX 27% 33% 34% 38% 38% 38% 38% 38% 42% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 100% 

100 

% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

538 

3% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 17% 23% 27% 38% 41% 43% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 26% 26% 26% 26% 26% 25% 25% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 22% 23% 23% 23% 23% 23% 24% 24% 23% 

Cylinder Deactivation on SOHC DEACS 8% 8% 5% 5% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 48% 47% 47% 47% 47% 48% 48% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 18% 17% 18% 18% 18% 18% 18% 18% 18% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 11% 11% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on DOHC DEACD 8% 7% 6% 7% 6% 4% 4% 4% 4% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 54% 56% 62% 62% 67% 69% 70% 71% 71% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 12% 12% 13% 12% 12% 12% 12% 12% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 36% 38% 41% 42% 42% 43% 43% 43% 42% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 15% 15% 17% 22% 26% 27% 30% 30% 30% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 5% 5% 5% 5% 6% 6% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 1% 1% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 55% 52% 38% 22% 8% 5% 1% 1% 1% 

6-Speed Trans with Improved Internals (Auto) NAUTO 70% 68% 50% 30% 15% 10% 2% 2% 2% 

6-speed DCT DCT 8% 9% 9% 7% 7% 5% 5% 3% 2% 

8-Speed Trans (Auto or DCT) 8SPD 5% 8% 19% 27% 23% 23% 23% 16% 9% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 2% 14% 19% 42% 44% 50% 59% 66% 

Shift Optimizer SHFTOPT 0% 0% 6% 18% 22% 31% 39% 44% 47% 

Electric Power Steering EPS 72% 75% 81% 84% 85% 85% 85% 85% 85% 

Improved Accessories - Level 1 IACC1 66% 70% 74% 77% 78% 78% 78% 80% 80% 

Improved Accessories - Level 2 IACC2 8% 9% 10% 10% 10% 12% 12% 13% 14% 

12V Micro-Hybrid (Stop-Start) MHEV 13% 12% 13% 13% 12% 12% 12% 12% 12% 

Integrated Starter Generator ISG 2% 2% 2% 3% 4% 4% 4% 4% 4% 
 

 

 

 

 

 

 

 

 

 

 

539 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 71% 75% 82% 90% 96% 97% 97% 97% 

100 

% 

Mass Reduction - Level 2 MR2 30% 37% 50% 57% 63% 66% 66% 73% 78% 

Mass Reduction - Level 3 MR3 15% 15% 16% 17% 25% 27% 32% 37% 42% 

Mass Reduction - Level 4 MR4 6% 6% 7% 14% 16% 18% 19% 20% 25% 

Mass Reduction - Level 5 MR5 0% 0% 1% 2% 2% 3% 3% 3% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 33% 47% 55% 71% 82% 84% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 76% 77% 80% 83% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 29% 31% 35% 37% 37% 38% 38% 38% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 68% 84% 87% 89% 92% 97% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

540 

4% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 78% 77% 77% 76% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 

LUB2_EF 

R2 11% 23% 38% 52% 66% 72% 77% 82% 84% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 59% 60% 61% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 41% 42% 43% 43% 44% 44% 44% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 7% 7% 6% 6% 5% 4% 1% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 68% 69% 70% 70% 74% 76% 79% 81% 81% 

Cylinder Deactivation on OHV DEACO 12% 12% 3% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 19% 17% 17% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 11% 12% 15% 20% 19% 18% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_ 

SD 10% 10% 9% 7% 7% 4% 4% 2% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_ 

MD 50% 50% 50% 45% 39% 35% 32% 26% 22% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_ 

LD 9% 9% 17% 18% 14% 11% 13% 13% 13% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_ 

SD 0% 0% 1% 1% 1% 1% 1% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_ 

MD 0% 0% 2% 9% 9% 10% 12% 13% 16% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_ 

LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_S 

D 0% 0% 0% 1% 1% 4% 4% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_M 

D 3% 5% 6% 8% 15% 19% 21% 25% 27% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_L 

D 1% 1% 0% 0% 3% 3% 3% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_M 

D 0% 0% 0% 0% 1% 1% 1% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_L 

D 0% 0% 1% 1% 4% 7% 7% 7% 7% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 13% 6% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 32% 24% 12% 6% 3% 3% 1% 1% 1% 

6-speed DCT DCT 5% 5% 4% 2% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 34% 40% 40% 34% 17% 14% 9% 5% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 15% 31% 45% 60% 64% 71% 75% 75% 

Shift Optimizer SHFTOPT 11% 19% 34% 49% 66% 74% 81% 93% 94% 

Electric Power Steering EPS 79% 83% 92% 92% 92% 92% 92% 93% 93% 

Improved Accessories - Level 1 IACC1 51% 53% 56% 63% 69% 71% 75% 85% 87% 

Improved Accessories - Level 2 IACC2 7% 8% 11% 15% 24% 28% 32% 35% 43% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 3% 3% 3% 6% 7% 7% 7% 7% 
 

 

 

 

 

 

 

 

 

 

 

 

541 

Integrated Starter Generator ISG 0% 0% 0% 1% 1% 2% 2% 4% 9% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 2% 2% 2% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 87% 88% 93% 98% 99% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 30% 39% 54% 64% 77% 82% 84% 87% 88% 

Mass Reduction - Level 3 MR3 16% 18% 22% 29% 34% 38% 44% 49% 52% 

Mass Reduction - Level 4 MR4 9% 10% 12% 17% 25% 28% 33% 41% 46% 

Mass Reduction - Level 5 MR5 0% 0% 2% 5% 8% 9% 11% 17% 21% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 13% 28% 48% 66% 71% 76% 85% 89% 90% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 81% 82% 83% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 34% 38% 39% 44% 43% 43% 43% 43% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 100% 

100 

% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

542 

4% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 100% 100% 100% 100% 

100 

% 99% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 73% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 17% 20% 21% 26% 32% 39% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 26% 26% 26% 26% 26% 25% 24% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 24% 24% 24% 24% 24% 24% 24% 23% 

Cylinder Deactivation on SOHC DEACS 7% 7% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 48% 47% 47% 47% 47% 48% 48% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 19% 18% 18% 18% 19% 19% 19% 19% 19% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 11% 10% 10% 10% 10% 10% 10% 10% 

Cylinder Deactivation on DOHC DEACD 10% 6% 2% 2% 2% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 53% 58% 66% 65% 70% 72% 74% 74% 74% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 12% 12% 12% 11% 11% 9% 9% 5% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 34% 36% 41% 37% 36% 36% 33% 22% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 16% 19% 21% 24% 29% 29% 30% 29% 27% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 1% 2% 2% 9% 10% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 3% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 1% 1% 3% 3% 6% 10% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 5% 10% 10% 11% 13% 18% 24% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 2% 3% 3% 6% 7% 7% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 50% 44% 30% 14% 5% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 66% 61% 46% 25% 10% 7% 3% 0% 0% 

6-speed DCT DCT 7% 9% 9% 6% 6% 4% 3% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 9% 14% 18% 18% 14% 14% 10% 5% 4% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2% 3% 14% 25% 43% 46% 50% 57% 57% 

Shift Optimizer SHFTOPT 0% 0% 12% 28% 53% 57% 71% 83% 89% 

Electric Power Steering EPS 72% 77% 82% 86% 88% 90% 90% 92% 92% 

Improved Accessories - Level 1 IACC1 61% 63% 63% 65% 70% 74% 77% 82% 85% 

Improved Accessories - Level 2 IACC2 8% 10% 14% 22% 26% 31% 32% 49% 59% 

12V Micro-Hybrid (Stop-Start) MHEV 12% 13% 13% 14% 12% 12% 13% 13% 10% 

Integrated Starter Generator ISG 3% 3% 3% 3% 5% 5% 5% 5% 6% 
 

 

 

 

 

 

 

 

 

 

 

 

543 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 73% 80% 87% 92% 96% 97% 98% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 31% 37% 57% 64% 74% 76% 78% 81% 87% 

Mass Reduction - Level 3 MR3 16% 17% 22% 27% 34% 35% 42% 47% 59% 

Mass Reduction - Level 4 MR4 7% 7% 11% 21% 22% 25% 29% 31% 31% 

Mass Reduction - Level 5 MR5 0% 1% 1% 4% 5% 8% 8% 10% 11% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 31% 48% 55% 66% 79% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 76% 76% 81% 82% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 29% 31% 34% 35% 36% 36% 36% 37% 37% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 70% 85% 88% 90% 93% 96% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

544 

5% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 78% 77% 77% 77% 74% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 89% 89% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 

LUB2_EF 

R2 11% 23% 37% 53% 59% 65% 70% 76% 76% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 12% 12% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 59% 60% 58% 59% 59% 57% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 41% 40% 41% 39% 40% 39% 38% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 5% 4% 3% 3% 3% 3% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 70% 71% 72% 72% 74% 73% 76% 76% 74% 

Cylinder Deactivation on OHV DEACO 12% 12% 3% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 19% 17% 17% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 12% 14% 17% 20% 19% 18% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_ 

SD 10% 10% 8% 6% 6% 3% 3% 0% 0% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_ 

MD 53% 55% 53% 43% 33% 28% 25% 12% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_ 

LD 9% 9% 9% 9% 7% 5% 3% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_ 

SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_ 

MD 0% 0% 0% 2% 2% 2% 2% 4% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_ 

LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_S 

D 0% 0% 2% 3% 3% 3% 3% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_M 

D 4% 4% 9% 19% 26% 29% 33% 41% 42% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_L 

D 1% 1% 4% 4% 4% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_M 

D 0% 0% 0% 1% 4% 5% 6% 8% 8% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_L 

D 1% 1% 5% 7% 10% 11% 15% 15% 15% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 4% 4% 4% 4% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 1% 1% 1% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 16% 9% 7% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 33% 25% 14% 5% 1% 0% 0% 0% 0% 

6-speed DCT DCT 3% 3% 3% 2% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 33% 33% 31% 26% 8% 6% 5% 5% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 10% 23% 38% 50% 65% 70% 71% 69% 67% 

Shift Optimizer SHFTOPT 11% 24% 45% 67% 83% 89% 93% 92% 90% 

Electric Power Steering EPS 80% 84% 94% 96% 97% 97% 98% 98% 98% 

Improved Accessories - Level 1 IACC1 61% 66% 68% 76% 82% 86% 87% 97% 98% 

Improved Accessories - Level 2 IACC2 18% 26% 41% 58% 68% 72% 82% 89% 96% 

12V Micro-Hybrid (Stop-Start) MHEV 3% 4% 5% 13% 23% 27% 30% 27% 26% 
 

 

 

 

 

 

 

 

 

 

 

 

 

545 

Integrated Starter Generator ISG 0% 2% 2% 6% 11% 15% 17% 27% 28% 

Strong Hybrid - Level 1 SHEV1 2% 1% 1% 1% 1% 1% 1% 1% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 1% 1% 3% 3% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 87% 89% 95% 99% 99% 99% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 35% 44% 61% 72% 81% 86% 88% 88% 89% 

Mass Reduction - Level 3 MR3 16% 19% 23% 32% 37% 40% 46% 51% 51% 

Mass Reduction - Level 4 MR4 12% 14% 17% 29% 31% 34% 37% 41% 42% 

Mass Reduction - Level 5 MR5 1% 3% 4% 16% 20% 23% 25% 30% 31% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 12% 28% 50% 66% 75% 80% 85% 89% 90% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 82% 82% 83% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 34% 38% 39% 44% 44% 43% 44% 44% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 100% 

100 

% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

546 

5% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 7% 14% 19% 23% 26% 32% 40% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 25% 25% 25% 25% 25% 25% 25% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 24% 23% 23% 22% 22% 22% 21% 21% 

Cylinder Deactivation on SOHC DEACS 8% 8% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 48% 43% 43% 41% 41% 41% 41% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 20% 18% 18% 18% 19% 17% 17% 17% 17% 

Continuously Variable Valve Lift (CVVL) CVVL 10% 11% 10% 10% 10% 10% 10% 10% 10% 

Cylinder Deactivation on DOHC DEACD 8% 5% 2% 1% 1% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 56% 59% 66% 63% 66% 64% 66% 66% 66% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 12% 12% 12% 11% 11% 9% 9% 5% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 37% 38% 41% 37% 35% 32% 29% 18% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 15% 18% 20% 24% 18% 16% 15% 14% 12% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 2% 2% 2% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 4% 6% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 7% 9% 9% 10% 13% 22% 26% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 7% 7% 7% 7% 9% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 1% 1% 1% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 3% 6% 7% 10% 10% 11% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 3% 3% 3% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 4% 4% 4% 4% 4% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 2% 2% 2% 2% 2% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 48% 43% 29% 13% 3% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 68% 63% 45% 25% 8% 4% 0% 0% 0% 

6-speed DCT DCT 8% 10% 8% 4% 4% 2% 2% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 11% 15% 16% 16% 11% 8% 4% 2% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2% 5% 20% 32% 50% 52% 51% 53% 51% 

Shift Optimizer SHFTOPT 0% 0% 21% 37% 57% 72% 86% 90% 89% 

Electric Power Steering EPS 77% 82% 90% 91% 92% 92% 92% 93% 93% 

Improved Accessories - Level 1 IACC1 70% 75% 87% 90% 91% 93% 93% 96% 97% 

Improved Accessories - Level 2 IACC2 9% 12% 25% 32% 39% 45% 55% 80% 83% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

547 

12V Micro-Hybrid (Stop-Start) MHEV 12% 13% 21% 30% 45% 47% 45% 51% 49% 

Integrated Starter Generator ISG 3% 5% 9% 16% 18% 20% 21% 28% 30% 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 3% 4% 6% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 73% 80% 87% 95% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 31% 38% 58% 67% 77% 81% 82% 84% 84% 

Mass Reduction - Level 3 MR3 16% 17% 22% 31% 43% 45% 54% 58% 66% 

Mass Reduction - Level 4 MR4 7% 8% 10% 20% 21% 24% 28% 33% 46% 

Mass Reduction - Level 5 MR5 0% 1% 1% 5% 6% 11% 15% 21% 34% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 34% 50% 56% 73% 84% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 76% 77% 82% 82% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 29% 32% 34% 35% 36% 36% 36% 37% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 AERO2 49% 56% 70% 85% 88% 90% 93% 96% 97% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

548 

6% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 76% 76% 76% 75% 74% 73% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 89% 89% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 

LUB2_EFR 

2 11% 23% 37% 46% 59% 67% 67% 75% 75% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 12% 12% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 55% 57% 54% 54% 52% 52% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 40% 38% 39% 37% 37% 35% 35% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on DOHC DEACD 2% 1% 1% 1% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 73% 74% 75% 70% 73% 72% 72% 69% 69% 

Cylinder Deactivation on OHV DEACO 9% 10% 2% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 18% 17% 16% 15% 15% 15% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 15% 16% 18% 20% 18% 18% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 10% 10% 8% 6% 6% 3% 3% 1% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_ 

MD 56% 56% 53% 41% 29% 24% 22% 7% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 11% 11% 12% 12% 13% 12% 7% 7% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_ 

MD 0% 0% 1% 1% 2% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_S 

D 0% 0% 2% 2% 2% 2% 2% 1% 1% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_M 

D 4% 5% 9% 18% 26% 29% 29% 32% 32% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_L 

D 1% 1% 1% 1% 1% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_S 

D 0% 0% 0% 0% 0% 0% 0% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_M 

D 0% 0% 0% 0% 4% 5% 6% 14% 16% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_L 

D 1% 1% 8% 10% 10% 10% 13% 13% 8% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 2% 2% 4% 4% 4% 4% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 2% 2% 3% 4% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 14% 7% 6% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 33% 24% 11% 4% 1% 0% 0% 0% 0% 

6-speed DCT DCT 4% 5% 4% 1% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 34% 34% 32% 25% 7% 5% 5% 3% 0% 

High Efficiency Gearbox (Auto or DCT) HETRANS 11% 24% 39% 52% 65% 68% 69% 66% 60% 

Shift Optimizer SHFTOPT 11% 24% 45% 65% 87% 91% 89% 85% 76% 

Electric Power Steering EPS 80% 85% 94% 97% 97% 97% 98% 98% 98% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

549 

Improved Accessories - Level 1 IACC1 61% 66% 76% 86% 90% 96% 96% 98% 98% 

Improved Accessories - Level 2 IACC2 19% 31% 51% 69% 78% 87% 93% 95% 95% 

12V Micro-Hybrid (Stop-Start) MHEV 13% 14% 15% 25% 33% 36% 38% 36% 35% 

Integrated Starter Generator ISG 2% 5% 11% 18% 23% 25% 27% 33% 34% 

Strong Hybrid - Level 1 SHEV1 2% 1% 1% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 2% 4% 8% 17% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 2% 2% 2% 2% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 87% 90% 95% 100% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 35% 44% 61% 72% 81% 86% 88% 88% 89% 

Mass Reduction - Level 3 MR3 17% 19% 23% 34% 39% 45% 50% 55% 62% 

Mass Reduction - Level 4 MR4 12% 14% 17% 27% 29% 35% 38% 43% 52% 

Mass Reduction - Level 5 MR5 1% 3% 4% 15% 17% 24% 26% 31% 44% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 12% 27% 45% 66% 83% 91% 93% 96% 99% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 82% 82% 84% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 34% 39% 40% 44% 44% 44% 44% 44% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 100% 

100 

% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

550 

6% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 100% 100% 100% 100% 100% 98% 96% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 17% 19% 25% 28% 33% 39% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 25% 25% 24% 24% 24% 24% 24% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 24% 23% 23% 21% 21% 21% 20% 20% 

Cylinder Deactivation on SOHC DEACS 5% 5% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 48% 43% 43% 43% 42% 41% 38% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 19% 18% 18% 18% 18% 18% 17% 15% 15% 

Continuously Variable Valve Lift (CVVL) CVVL 11% 11% 11% 11% 10% 10% 10% 10% 9% 

Cylinder Deactivation on DOHC DEACD 6% 3% 3% 2% 2% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 59% 64% 66% 62% 64% 65% 66% 62% 59% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 12% 12% 12% 9% 9% 8% 8% 3% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 41% 42% 41% 37% 33% 29% 26% 13% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 16% 18% 20% 23% 17% 16% 16% 15% 8% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 1% 2% 2% 4% 4% 7% 7% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 5% 7% 10% 14% 16% 21% 22% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 7% 7% 7% 7% 9% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 3% 3% 4% 6% 6% 5% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 1% 2% 2% 2% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 4% 5% 5% 6% 8% 9% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 2% 2% 2% 2% 2% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 45% 40% 28% 12% 3% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 62% 57% 41% 22% 6% 5% 0% 0% 0% 

6-speed DCT DCT 8% 9% 6% 2% 2% 2% 2% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 14% 18% 18% 16% 8% 5% 1% 0% 0% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 7% 21% 32% 44% 47% 45% 43% 40% 

Shift Optimizer SHFTOPT 0% 0% 20% 39% 58% 69% 83% 81% 74% 

Electric Power Steering EPS 78% 83% 90% 93% 93% 93% 93% 93% 93% 

Improved Accessories - Level 1 IACC1 72% 77% 89% 91% 93% 95% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 11% 19% 34% 43% 53% 60% 62% 62% 63% 

12V Micro-Hybrid (Stop-Start) MHEV 15% 18% 35% 45% 56% 59% 59% 50% 44% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

551 

Integrated Starter Generator ISG 3% 5% 12% 19% 21% 25% 25% 26% 25% 

Strong Hybrid - Level 1 SHEV1 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 3% 4% 7% 13% 21% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 2% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 74% 82% 91% 95% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 31% 38% 58% 67% 76% 80% 81% 84% 87% 

Mass Reduction - Level 3 MR3 16% 17% 23% 28% 42% 44% 52% 56% 72% 

Mass Reduction - Level 4 MR4 7% 8% 12% 22% 30% 32% 37% 44% 61% 

Mass Reduction - Level 5 MR5 0% 1% 3% 7% 11% 16% 21% 28% 45% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 32% 49% 60% 73% 86% 96% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 77% 77% 83% 83% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 29% 31% 36% 37% 37% 38% 38% 38% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 70% 86% 89% 91% 94% 97% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

552 

7% Annual Increase - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 78% 77% 77% 76% 75% 73% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 89% 89% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 

LUB2_EFR 

2 11% 23% 39% 49% 54% 61% 62% 69% 69% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 14% 13% 13% 13% 13% 13% 12% 12% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 58% 58% 58% 54% 55% 52% 51% 50% 48% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 41% 40% 40% 36% 36% 33% 32% 31% 29% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 6% 2% 1% 1% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 69% 74% 74% 69% 72% 69% 68% 67% 64% 

Cylinder Deactivation on OHV DEACO 8% 8% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 18% 17% 16% 15% 15% 15% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 16% 17% 19% 20% 18% 18% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 10% 10% 8% 5% 5% 2% 2% 0% 0% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_ 

MD 56% 56% 46% 30% 20% 16% 14% 6% 5% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 8% 11% 18% 17% 15% 13% 9% 9% 7% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_ 

MD 1% 1% 1% 2% 2% 2% 2% 1% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_S 

D 0% 0% 2% 3% 2% 2% 2% 1% 1% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_M 

D 3% 6% 14% 23% 24% 27% 26% 27% 25% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_L 

D 1% 1% 1% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_S 

D 0% 0% 0% 0% 0% 0% 0% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_M 

D 0% 0% 2% 4% 12% 13% 13% 13% 12% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_L 

D 1% 1% 2% 3% 3% 4% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 4% 4% 6% 6% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 5% 5% 7% 7% 7% 7% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 16% 7% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 37% 27% 9% 3% 1% 0% 0% 0% 0% 

6-speed DCT DCT 4% 5% 4% 1% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 39% 39% 34% 24% 6% 6% 6% 4% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 9% 23% 38% 54% 60% 65% 61% 58% 54% 

Shift Optimizer SHFTOPT 16% 34% 52% 74% 88% 88% 81% 75% 69% 

Electric Power Steering EPS 81% 86% 95% 98% 98% 98% 98% 98% 98% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

553 

Improved Accessories - Level 1 IACC1 68% 75% 81% 93% 93% 97% 98% 98% 98% 

Improved Accessories - Level 2 IACC2 21% 35% 56% 69% 78% 85% 86% 86% 86% 

12V Micro-Hybrid (Stop-Start) MHEV 15% 19% 34% 46% 48% 50% 47% 38% 32% 

Integrated Starter Generator ISG 3% 6% 13% 20% 25% 28% 29% 31% 31% 

Strong Hybrid - Level 1 SHEV1 2% 1% 1% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 1% 5% 6% 12% 19% 23% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 1% 1% 1% 4% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 87% 90% 95% 99% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 35% 44% 61% 72% 81% 86% 88% 88% 89% 

Mass Reduction - Level 3 MR3 17% 19% 23% 34% 43% 49% 55% 59% 67% 

Mass Reduction - Level 4 MR4 12% 14% 17% 30% 40% 47% 53% 59% 67% 

Mass Reduction - Level 5 MR5 2% 4% 5% 22% 30% 36% 42% 48% 57% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 12% 28% 47% 68% 86% 90% 94% 96% 99% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 83% 83% 84% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 45% 45% 44% 44% 44% 43% 44% 44% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 61% 69% 86% 93% 95% 98% 100% 

100 

% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

554 

7% Annual Increase - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 100% 99% 99% 99% 98% 97% 97% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 73% 73% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 14% 17% 20% 23% 25% 26% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 25% 25% 22% 22% 22% 22% 22% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 23% 23% 23% 20% 20% 20% 20% 20% 

Cylinder Deactivation on SOHC DEACS 5% 5% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 48% 40% 40% 40% 40% 37% 37% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 19% 18% 18% 18% 18% 18% 17% 16% 16% 

Continuously Variable Valve Lift (CVVL) CVVL 11% 11% 11% 11% 10% 10% 10% 10% 10% 

Cylinder Deactivation on DOHC DEACD 6% 3% 2% 1% 1% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 59% 64% 66% 59% 61% 61% 63% 60% 60% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 12% 12% 12% 7% 7% 5% 5% 1% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 41% 42% 39% 32% 26% 23% 20% 16% 10% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 16% 18% 14% 17% 13% 12% 12% 12% 10% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 2% 2% 2% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 1% 2% 2% 4% 4% 6% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 7% 9% 12% 14% 15% 16% 20% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 2% 2% 1% 1% 1% 2% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 4% 4% 4% 4% 4% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 6% 8% 15% 16% 18% 18% 12% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 3% 3% 3% 3% 4% 4% 

Advanced Diesel - Medium Displacement ADSL_MD 1% 1% 1% 5% 5% 5% 5% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 3% 3% 3% 3% 3% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 45% 40% 26% 11% 1% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 64% 58% 39% 20% 5% 4% 0% 0% 0% 

6-speed DCT DCT 7% 8% 7% 3% 3% 3% 3% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 15% 16% 15% 14% 6% 3% 2% 2% 0% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 11% 27% 36% 41% 41% 39% 35% 34% 

Shift Optimizer SHFTOPT 0% 0% 20% 37% 65% 71% 87% 85% 79% 

Electric Power Steering EPS 77% 84% 90% 93% 93% 93% 93% 93% 93% 

Improved Accessories - Level 1 IACC1 72% 78% 91% 96% 96% 96% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 20% 26% 35% 43% 49% 50% 50% 52% 53% 

12V Micro-Hybrid (Stop-Start) MHEV 31% 34% 49% 58% 63% 62% 62% 54% 47% 
 

 

 

 

 

 

 

 

 

 

 

 

 

555 

Integrated Starter Generator ISG 5% 7% 14% 19% 21% 24% 23% 26% 26% 

Strong Hybrid - Level 1 SHEV1 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 3% 5% 9% 17% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 1% 1% 1% 1% 2% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 1% 2% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 77% 86% 91% 95% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 32% 39% 59% 70% 84% 86% 87% 90% 91% 

Mass Reduction - Level 3 MR3 17% 18% 24% 32% 43% 44% 52% 56% 69% 

Mass Reduction - Level 4 MR4 8% 9% 12% 25% 31% 33% 38% 45% 59% 

Mass Reduction - Level 5 MR5 0% 1% 3% 10% 14% 20% 25% 32% 47% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 19% 36% 47% 60% 75% 87% 94% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 79% 80% 83% 83% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 29% 31% 36% 37% 37% 38% 38% 38% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 70% 82% 85% 87% 90% 93% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

556 

Max Net Benefits - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 75% 74% 74% 74% 74% 73% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 88% 88% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 14% 20% 33% 45% 59% 65% 66% 73% 77% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 13% 13% 12% 12% 12% 12% 12% 12% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing 

(ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 57% 57% 57% 55% 57% 58% 58% 58% 58% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 40% 40% 40% 38% 39% 39% 40% 39% 39% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 1% 1% 1% 1% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 74% 73% 73% 70% 73% 74% 75% 74% 74% 

Cylinder Deactivation on OHV DEACO 2% 2% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 18% 17% 16% 15% 14% 14% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 17% 18% 20% 20% 18% 18% 17% 16% 16% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

– Small Disp. TRBDS1_SD 10% 10% 8% 5% 5% 3% 3% 1% 1% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Medium Disp. 

TRBDS1_M 

D 53% 53% 49% 39% 29% 27% 24% 14% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Large Disp. 

TRBDS1_L 

D 18% 18% 19% 17% 18% 16% 12% 11% 11% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 2% 3% 3% 3% 3% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 7% 9% 13% 17% 27% 28% 30% 38% 40% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 2% 2% 2% 3% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 5% 5% 5% 7% 6% 6% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 3% 3% 5% 8% 8% 8% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 1% 1% 1% 1% 1% 1% 2% 3% 3% 

Advanced Diesel - Large Displacement ADSL_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 0% 0% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 1% 2% 2% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 14% 7% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 33% 23% 10% 4% 1% 1% 0% 0% 0% 

6-speed DCT DCT 6% 3% 3% 0% 0% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 42% 41% 33% 24% 5% 5% 4% 3% 1% 

High Efficiency Gearbox (Auto or DCT) HETRANS 10% 23% 44% 57% 68% 69% 71% 69% 72% 

Shift Optimizer SHFTOPT 16% 27% 50% 66% 88% 90% 91% 88% 88% 

Electric Power Steering EPS 82% 86% 94% 97% 98% 98% 98% 98% 98% 

Improved Accessories - Level 1 IACC1 94% 94% 94% 97% 97% 97% 97% 98% 98% 

Improved Accessories - Level 2 IACC2 42% 49% 62% 70% 72% 78% 81% 85% 86% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

557 

12V Micro-Hybrid (Stop-Start) MHEV 38% 38% 42% 37% 36% 36% 35% 31% 32% 

Integrated Starter Generator ISG 11% 13% 14% 16% 16% 19% 20% 23% 25% 

Strong Hybrid - Level 1 SHEV1 2% 1% 1% 1% 1% 1% 1% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 1% 1% 1% 1% 1% 1% 2% 5% 5% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 3% 3% 3% 3% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 90% 90% 95% 98% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 40% 48% 60% 71% 80% 81% 83% 85% 89% 

Mass Reduction - Level 3 MR3 22% 23% 28% 32% 40% 41% 48% 51% 63% 

Mass Reduction - Level 4 MR4 16% 17% 21% 26% 31% 36% 39% 43% 56% 

Mass Reduction - Level 5 MR5 3% 3% 6% 16% 21% 22% 25% 29% 39% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 16% 24% 46% 58% 78% 87% 89% 96% 97% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 83% 83% 84% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 46% 45% 45% 44% 44% 44% 44% 44% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 AERO2 61% 69% 85% 93% 94% 98% 99% 99% 99% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

558 

Max Net Benefits - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 10% 22% 30% 32% 35% 38% 47% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 25% 25% 25% 25% 25% 25% 25% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 24% 23% 23% 23% 23% 23% 23% 23% 

Cylinder Deactivation on SOHC DEACS 8% 8% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing 

(ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 47% 43% 43% 43% 43% 43% 43% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 18% 18% 18% 18% 18% 18% 18% 18% 18% 

Continuously Variable Valve Lift (CVVL) CVVL 11% 11% 11% 10% 10% 10% 10% 10% 10% 

Cylinder Deactivation on DOHC DEACD 6% 3% 3% 2% 2% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 57% 62% 65% 62% 67% 68% 70% 70% 70% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

– Small Disp. TRBDS1_SD 12% 12% 13% 10% 10% 8% 8% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Medium Disp. TRBDS1_MD 38% 39% 38% 34% 30% 28% 25% 20% 15% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Large Disp. TRBDS1_LD 16% 18% 20% 24% 22% 21% 19% 19% 11% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Medium Disp. TRBDS2_MD 0% 0% 0% 0% 0% 0% 0% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Large Disp. TRBDS2_LD 0% 0% 1% 1% 1% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 2% 2% 3% 3% 4% 5% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 8% 9% 13% 16% 19% 21% 24% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 7% 7% 8% 7% 14% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 2% 2% 4% 4% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 2% 3% 4% 7% 7% 7% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 2% 5% 5% 5% 5% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 48% 43% 27% 12% 2% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 69% 61% 40% 21% 5% 4% 0% 0% 0% 

6-speed DCT DCT 6% 8% 7% 3% 2% 2% 2% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 15% 17% 14% 13% 7% 5% 4% 2% 1% 

High Efficiency Gearbox (Auto or DCT) HETRANS 4% 9% 23% 31% 43% 44% 43% 42% 42% 

Shift Optimizer SHFTOPT 0% 0% 20% 41% 67% 71% 79% 88% 90% 

Electric Power Steering EPS 85% 89% 92% 93% 93% 93% 93% 93% 93% 

Improved Accessories - Level 1 IACC1 70% 73% 85% 91% 91% 91% 91% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

559 

Improved Accessories - Level 2 IACC2 18% 22% 27% 31% 34% 36% 36% 42% 53% 

12V Micro-Hybrid (Stop-Start) MHEV 39% 38% 43% 48% 50% 52% 49% 49% 46% 

Integrated Starter Generator ISG 7% 9% 13% 13% 16% 17% 18% 19% 20% 

Strong Hybrid - Level 1 SHEV1 1% 1% 1% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 1% 1% 1% 1% 4% 5% 7% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 77% 79% 85% 94% 98% 99% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 32% 39% 57% 65% 77% 78% 81% 85% 88% 

Mass Reduction - Level 3 MR3 17% 18% 22% 26% 39% 39% 48% 52% 65% 

Mass Reduction - Level 4 MR4 8% 9% 12% 23% 27% 29% 34% 36% 49% 

Mass Reduction - Level 5 MR5 0% 1% 3% 7% 10% 15% 19% 20% 21% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 98% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 35% 52% 57% 72% 85% 92% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 83% 83% 82% 83% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 31% 33% 36% 37% 37% 37% 37% 38% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 72% 87% 90% 92% 95% 96% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

560 

Total Cost = Total Benefits - Light Trucks - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

202 

5 

Low Friction Lubricants - Level 1 LUB1 82% 80% 79% 75% 74% 74% 74% 74% 73% 

Engine Friction Reduction - Level 1 EFR1 89% 89% 89% 88% 88% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 15% 19% 34% 42% 60% 62% 62% 69% 69% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 14% 13% 13% 13% 13% 13% 13% 13% 13% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 13% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing 

(ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 57% 57% 57% 51% 52% 53% 53% 53% 53% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 40% 40% 40% 34% 34% 35% 35% 34% 35% 

Continuously Variable Valve Lift (CVVL) CVVL 15% 15% 15% 15% 15% 15% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 1% 1% 1% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 74% 74% 74% 67% 69% 70% 71% 70% 70% 

Cylinder Deactivation on OHV DEACO 2% 2% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 17% 18% 18% 17% 16% 16% 15% 15% 15% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 17% 18% 20% 19% 18% 17% 17% 17% 17% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Small Displacement TRBDS1_SD 9% 9% 7% 5% 5% 2% 2% 0% 0% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Medium Displacement 

TRBDS1_M 

D 53% 53% 48% 38% 28% 24% 21% 10% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Large Displacement TRBDS1_LD 18% 18% 19% 17% 18% 17% 12% 12% 11% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Small Displacement TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Medium Displacement 

TRBDS2_M 

D 0% 0% 0% 1% 1% 1% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Large Displacement TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Small Displacement CEGR1_SD 1% 1% 2% 3% 3% 5% 5% 8% 7% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Medium Displacement CEGR1_MD 8% 9% 15% 18% 28% 28% 29% 36% 36% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Large Displacement CEGR1_LD 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 1% 1% 4% 4% 5% 5% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 3% 3% 4% 8% 7% 8% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 1% 1% 1% 5% 6% 6% 7% 7% 7% 

Advanced Diesel - Large Displacement ADSL_LD 1% 1% 1% 1% 1% 1% 1% 1% 1% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 0% 0% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 1% 2% 2% 2% 2% 2% 2% 2% 

Improved Auto. Trans. Controls/Externals IATC 12% 6% 5% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 31% 21% 9% 3% 0% 0% 0% 0% 0% 

6-speed DCT DCT 8% 5% 3% 0% 0% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 43% 43% 34% 24% 9% 8% 8% 7% 5% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

561 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 25% 41% 54% 66% 67% 68% 67% 68% 

Shift Optimizer SHFTOPT 18% 29% 54% 69% 87% 91% 88% 86% 85% 

Electric Power Steering EPS 82% 83% 91% 94% 98% 98% 98% 98% 98% 

Improved Accessories - Level 1 IACC1 96% 96% 96% 98% 98% 98% 98% 98% 98% 

Improved Accessories - Level 2 (w/ Alternator Regen and 

70% efficient alternator) IACC2 42% 47% 58% 67% 70% 70% 75% 79% 81% 

12V Micro-Hybrid (Stop-Start) MHEV 39% 40% 46% 41% 43% 44% 42% 37% 35% 

Integrated Starter Generator ISG 13% 14% 16% 17% 18% 22% 22% 22% 23% 

Strong Hybrid - Level 1 SHEV1 2% 1% 1% 1% 1% 1% 1% 1% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 1% 1% 1% 1% 1% 1% 4% 7% 8% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 3% 3% 3% 3% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 90% 90% 95% 98% 100% 100% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 40% 48% 60% 71% 80% 81% 83% 85% 89% 

Mass Reduction - Level 3 MR3 22% 23% 28% 32% 40% 41% 48% 51% 63% 

Mass Reduction - Level 4 MR4 20% 20% 24% 28% 30% 32% 38% 43% 55% 

Mass Reduction - Level 5 MR5 6% 6% 7% 18% 21% 24% 26% 30% 41% 

Low Rolling Resistance Tires - Level 1 

ROLL1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 16% 25% 47% 61% 80% 87% 90% 93% 96% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 83% 83% 84% 84% 84% 84% 84% 84% 84% 

Secondary Axle Disconnect SAX 46% 45% 45% 44% 44% 44% 44% 44% 43% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 99% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 AERO2 61% 69% 85% 93% 94% 98% 99% 99% 99% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

562 

Total Cost = Total Benefits - Light Trucks - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 100% 100% 100% 99% 99% 99% 99% 

Engine Friction Reduction - Level 1 EFR1 71% 72% 72% 74% 74% 74% 74% 74% 74% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 10% 22% 26% 26% 29% 33% 42% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 25% 25% 25% 25% 25% 25% 25% 25% 25% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 23% 24% 23% 23% 23% 23% 23% 23% 23% 

Cylinder Deactivation on SOHC DEACS 6% 6% 5% 6% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing 

(ICP) ICP 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 48% 48% 47% 41% 41% 41% 41% 42% 41% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 18% 18% 18% 18% 18% 18% 18% 18% 19% 

Continuously Variable Valve Lift (CVVL) CVVL 11% 11% 11% 10% 10% 10% 10% 10% 10% 

Cylinder Deactivation on DOHC DEACD 6% 3% 3% 2% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 58% 62% 63% 58% 65% 65% 66% 67% 66% 

Cylinder Deactivation on OHV DEACO 9% 9% 7% 3% 3% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 16% 16% 16% 16% 16% 16% 16% 16% 16% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 10% 10% 11% 16% 16% 16% 18% 18% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Small Displacement TRBDS1_SD 11% 10% 11% 6% 6% 6% 6% 2% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Medium Displacement 

TRBDS1_M 

D 40% 41% 40% 33% 28% 25% 23% 12% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) 

- Large Displacement TRBDS1_LD 16% 18% 20% 24% 26% 26% 27% 26% 23% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Small Displacement TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Medium Displacement 

TRBDS2_M 

D 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) 

- Large Displacement TRBDS2_LD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Small Displacement CEGR1_SD 2% 2% 2% 5% 5% 5% 5% 9% 9% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Medium Displacement CEGR1_MD 4% 5% 5% 9% 15% 18% 20% 30% 30% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 

bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 1% 1% 1% 2% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 

bar BMEP) - Large Displacement CEGR2_LD 1% 1% 1% 3% 3% 4% 4% 4% 5% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 2% 5% 5% 5% 5% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 1% 1% 1% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Improved Auto. Trans. Controls/Externals IATC 51% 46% 30% 15% 2% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 67% 60% 42% 23% 5% 4% 0% 0% 0% 

6-speed DCT DCT 8% 9% 7% 3% 2% 2% 2% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 12% 14% 14% 12% 8% 4% 3% 2% 2% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

563 

High Efficiency Gearbox (Auto or DCT) HETRANS 3% 8% 22% 32% 36% 40% 38% 37% 33% 

Shift Optimizer SHFTOPT 0% 0% 21% 41% 67% 71% 79% 86% 85% 

Electric Power Steering EPS 86% 90% 90% 93% 93% 93% 93% 93% 93% 

Improved Accessories - Level 1 IACC1 83% 84% 89% 93% 94% 94% 95% 95% 95% 

Improved Accessories - Level 2 (w/ Alternator Regen and 

70% efficient alternator) IACC2 21% 25% 34% 42% 47% 49% 54% 54% 61% 

12V Micro-Hybrid (Stop-Start) MHEV 39% 38% 47% 51% 48% 50% 47% 46% 44% 

Integrated Starter Generator ISG 7% 9% 12% 17% 19% 20% 21% 21% 18% 

Strong Hybrid - Level 1 SHEV1 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 3% 3% 5% 7% 11% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 

MR1 79% 81% 85% 94% 98% 98% 100% 

100 

% 

100 

% 

Mass Reduction - Level 2 MR2 32% 39% 57% 68% 77% 78% 81% 85% 87% 

Mass Reduction - Level 3 MR3 17% 18% 22% 29% 37% 37% 45% 50% 63% 

Mass Reduction - Level 4 MR4 8% 9% 10% 23% 25% 27% 35% 38% 52% 

Mass Reduction - Level 5 MR5 0% 1% 1% 8% 8% 12% 18% 19% 21% 

Low Rolling Resistance Tires - Level 1 

ROLL1 98% 98% 98% 100% 100% 100% 100% 

100 

% 

100 

% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 37% 47% 49% 64% 76% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 83% 83% 82% 83% 83% 83% 83% 83% 83% 

Secondary Axle Disconnect SAX 36% 36% 36% 37% 37% 38% 38% 38% 38% 

Aero Drag Reduction, Level 1 

AERO1 100% 100% 100% 100% 100% 100% 100% 

100 

% 

100 

% 

Aero Drag Reduction, Level 2 

AERO2 49% 56% 72% 87% 90% 92% 95% 96% 

100 

% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

564 

Table V-152 Penetration Rate of New Technologies to Combined Fleet, by Baseline Model 

Year and Alternative 

Preferred Alternative - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 85% 85% 85% 85% 85% 84% 

Engine Friction Reduction - Level 1 EFR1 81% 83% 88% 88% 88% 88% 88% 88% 87% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 14% 23% 40% 46% 55% 59% 63% 67% 70% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 8% 8% 12% 11% 11% 11% 11% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 12% 12% 12% 12% 12% 11% 

Cylinder Deactivation on SOHC DEACS 3% 3% 3% 2% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 67% 67% 68% 69% 70% 70% 70% 70% 70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 47% 49% 49% 51% 52% 52% 52% 52% 52% 

Continuously Variable Valve Lift (CVVL) CVVL 12% 13% 15% 16% 16% 16% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 13% 12% 11% 10% 9% 9% 8% 6% 5% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 43% 49% 54% 59% 67% 71% 72% 80% 80% 

Cylinder Deactivation on OHV DEACO 7% 6% 5% 4% 4% 3% 2% 2% 2% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 8% 9% 9% 10% 9% 9% 9% 8% 8% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 3% 4% 5% 7% 7% 7% 7% 7% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 18% 20% 21% 19% 25% 23% 21% 24% 22% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 17% 21% 22% 26% 25% 24% 21% 21% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 4% 4% 4% 4% 5% 4% 4% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 1% 1% 1% 2% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 2% 6% 6% 11% 13% 15% 18% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 2% 4% 5% 6% 7% 11% 12% 14% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 2% 2% 2% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 1% 1% 2% 3% 3% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 2% 2% 1% 1% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 4% 6% 6% 6% 6% 6% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

565 

Improved Auto. Trans. Controls/Externals IATC 17% 13% 10% 6% 1% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 21% 15% 9% 5% 4% 2% 1% 0% 0% 

6-speed DCT DCT 20% 16% 13% 8% 4% 2% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 22% 25% 25% 20% 13% 10% 7% 5% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 5% 15% 29% 42% 59% 69% 74% 78% 79% 

Shift Optimizer SHFTOPT 8% 18% 32% 43% 55% 67% 76% 85% 85% 

Electric Power Steering EPS 78% 82% 88% 90% 92% 92% 92% 93% 95% 

Improved Accessories - Level 1 IACC1 56% 58% 62% 68% 73% 75% 78% 87% 89% 

Improved Accessories - Level 2 IACC2 15% 19% 28% 36% 44% 51% 55% 68% 76% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 7% 9% 10% 10% 11% 10% 8% 

Integrated Starter Generator ISG 1% 1% 1% 4% 5% 7% 7% 11% 17% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 

SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 59% 62% 66% 68% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 29% 36% 48% 54% 57% 59% 60% 61% 62% 

Mass Reduction - Level 3 MR3 11% 13% 14% 18% 23% 24% 26% 28% 32% 

Mass Reduction - Level 4 MR4 5% 5% 6% 7% 11% 12% 12% 14% 20% 

Mass Reduction - Level 5 MR5 1% 1% 1% 2% 2% 3% 4% 5% 11% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 17% 30% 51% 65% 77% 84% 88% 89% 91% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 86% 86% 88% 88% 89% 89% 89% 89% 89% 

Secondary Axle Disconnect SAX 11% 13% 13% 14% 14% 14% 14% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

566 

Preferred Alternative - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 

100 

% 

100 

% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Engine Friction Reduction - Level 1 EFR1 74% 77% 77% 78% 78% 78% 79% 79% 79% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 12% 18% 21% 28% 35% 39% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 19% 19% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 17% 17% 18% 18% 18% 18% 18% 18% 

Cylinder Deactivation on SOHC DEACS 10% 10% 8% 7% 3% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 60% 61% 61% 61% 61% 61% 61% 61% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 29% 30% 31% 32% 32% 33% 33% 33% 33% 

Continuously Variable Valve Lift (CVVL) CVVL 20% 20% 21% 21% 21% 21% 22% 22% 22% 

Cylinder Deactivation on DOHC DEACD 10% 12% 8% 8% 6% 6% 6% 5% 4% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 39% 47% 59% 62% 72% 76% 77% 80% 80% 

Cylinder Deactivation on OHV DEACO 5% 4% 4% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 2% 3% 5% 7% 8% 8% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 22% 27% 31% 32% 35% 34% 31% 30% 26% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 14% 17% 22% 23% 23% 24% 24% 23% 20% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 2% 2% 5% 7% 11% 11% 11% 11% 10% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 1% 1% 1% 2% 2% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 2% 2% 2% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 2% 3% 5% 7% 10% 14% 17% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 3% 4% 3% 3% 4% 5% 7% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 2% 2% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 1% 1% 1% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 34% 32% 20% 10% 4% 2% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 41% 39% 28% 17% 11% 9% 2% 0% 0% 

6-speed DCT DCT 24% 25% 21% 14% 15% 11% 8% 5% 5% 

8-Speed Trans (Auto or DCT) 8SPD 9% 13% 20% 22% 19% 18% 15% 6% 6% 

High Efficiency Gearbox (Auto or DCT) HETRANS 0% 2% 12% 24% 36% 45% 54% 63% 65% 

Shift Optimizer SHFTOPT 0% 0% 10% 21% 31% 37% 52% 62% 66% 

Electric Power Steering EPS 73% 79% 87% 90% 91% 92% 93% 95% 95% 

Improved Accessories - Level 1 IACC1 54% 62% 71% 76% 80% 83% 85% 89% 92% 

Improved Accessories - Level 2 IACC2 6% 12% 18% 24% 36% 41% 48% 59% 62% 
 

 

 

 

 

 

 

 

 

 

567 

12V Micro-Hybrid (Stop-Start) MHEV 6% 7% 7% 8% 8% 8% 9% 9% 9% 

Integrated Starter Generator ISG 2% 2% 3% 4% 5% 5% 6% 8% 10% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 54% 59% 68% 70% 72% 72% 72% 73% 73% 

Mass Reduction - Level 2 MR2 21% 30% 40% 43% 51% 53% 56% 61% 62% 

Mass Reduction - Level 3 MR3 10% 10% 11% 12% 15% 16% 19% 22% 23% 

Mass Reduction - Level 4 MR4 3% 4% 4% 5% 6% 6% 6% 8% 8% 

Mass Reduction - Level 5 MR5 0% 0% 1% 1% 2% 3% 3% 5% 5% 

Low Rolling Resistance Tires - Level 1 

ROLL1 93% 97% 98% 99% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 28% 49% 58% 67% 78% 81% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 85% 86% 88% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 10% 11% 12% 12% 12% 13% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 81% 87% 88% 89% 91% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

568 

2% Annual Increase - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 85% 85% 85% 85% 85% 85% 

Engine Friction Reduction - Level 1 EFR1 85% 88% 88% 88% 88% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 12% 24% 37% 47% 55% 59% 63% 65% 69% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 8% 7% 7% 7% 7% 7% 7% 7% 7% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 3% 3% 3% 2% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 9% 6% 4% 3% 3% 3% 3% 3% 3% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 61% 65% 66% 68% 68% 69% 69% 69% 69% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 44% 46% 46% 48% 49% 49% 50% 50% 50% 

Continuously Variable Valve Lift (CVVL) CVVL 12% 13% 16% 18% 18% 19% 19% 19% 19% 

Cylinder Deactivation on DOHC DEACD 6% 7% 6% 7% 7% 7% 6% 6% 6% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 48% 49% 51% 52% 53% 54% 56% 58% 59% 

Cylinder Deactivation on OHV DEACO 6% 6% 6% 6% 6% 5% 4% 4% 4% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 8% 9% 9% 9% 8% 8% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 3% 3% 3% 4% 3% 3% 4% 3% 3% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 16% 16% 17% 17% 18% 17% 18% 21% 20% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 25% 25% 26% 26% 26% 26% 27% 27% 27% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 4% 4% 4% 4% 4% 4% 4% 4% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 1% 0% 0% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 1% 1% 2% 2% 2% 3% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 2% 2% 3% 3% 4% 4% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 1% 2% 1% 1% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 4% 5% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 15% 10% 7% 3% 3% 2% 3% 2% 2% 

6-Speed Trans with Improved Internals (Auto) NAUTO 24% 22% 18% 15% 13% 10% 9% 6% 6% 

6-speed DCT DCT 24% 22% 20% 15% 11% 9% 7% 13% 12% 

8-Speed Trans (Auto or DCT) 8SPD 16% 17% 21% 18% 16% 19% 17% 13% 12% 

High Efficiency Gearbox (Auto or DCT) HETRANS 3% 11% 18% 27% 37% 42% 48% 54% 56% 

Shift Optimizer SHFTOPT 6% 10% 19% 24% 27% 30% 34% 34% 34% 

Electric Power Steering EPS 76% 81% 84% 86% 86% 86% 87% 89% 91% 

Improved Accessories - Level 1 IACC1 52% 54% 54% 58% 61% 64% 67% 75% 77% 

Improved Accessories - Level 2 IACC2 8% 11% 13% 17% 21% 25% 29% 41% 44% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 5% 5% 5% 5% 5% 5% 5% 
 

 

 

 

 

 

 

 

 

 

569 

Integrated Starter Generator ISG 1% 1% 1% 2% 2% 2% 2% 3% 4% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 3% 3% 3% 3% 3% 3% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 57% 60% 64% 65% 65% 65% 66% 65% 65% 

Mass Reduction - Level 2 MR2 28% 34% 45% 50% 52% 53% 58% 59% 60% 

Mass Reduction - Level 3 MR3 12% 13% 14% 16% 17% 18% 21% 23% 23% 

Mass Reduction - Level 4 MR4 5% 5% 6% 6% 6% 8% 7% 9% 9% 

Mass Reduction - Level 5 MR5 0% 0% 1% 1% 1% 1% 1% 2% 3% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 97% 99% 99% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 17% 29% 46% 60% 74% 81% 84% 87% 88% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 85% 86% 87% 87% 87% 87% 87% 87% 87% 

Secondary Axle Disconnect SAX 10% 11% 12% 12% 12% 13% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 100% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 85% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

570 

2% Annual Increase - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Engine Friction Reduction - Level 1 EFR1 74% 77% 77% 78% 78% 78% 78% 78% 78% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 8% 17% 21% 23% 28% 36% 38% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 18% 18% 18% 18% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 17% 17% 18% 18% 18% 18% 18% 18% 

Cylinder Deactivation on SOHC DEACS 6% 6% 6% 6% 6% 6% 6% 5% 5% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 61% 62% 62% 62% 62% 62% 62% 62% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 27% 28% 29% 30% 32% 33% 33% 33% 33% 

Continuously Variable Valve Lift (CVVL) CVVL 16% 17% 20% 21% 22% 22% 23% 22% 23% 

Cylinder Deactivation on DOHC DEACD 9% 10% 9% 10% 10% 10% 10% 10% 10% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 38% 44% 46% 48% 52% 53% 54% 57% 58% 

Cylinder Deactivation on OHV DEACO 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 4% 4% 4% 4% 4% 4% 4% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 13% 18% 19% 20% 24% 25% 25% 27% 28% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 16% 17% 18% 19% 19% 19% 19% 19% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 6% 6% 7% 7% 7% 7% 6% 6% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 1% 1% 1% 0% 0% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 1% 1% 1% 1% 1% 1% 
 

 

 

 

 

 

 

 

 

 

571 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 3% 3% 3% 3% 3% 4% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 0% 1% 1% 1% 1% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 1% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 36% 33% 27% 18% 15% 15% 15% 19% 19% 

6-Speed Trans with Improved Internals (Auto) NAUTO 40% 35% 30% 20% 21% 21% 21% 23% 23% 

6-speed DCT DCT 22% 23% 18% 11% 10% 8% 5% 5% 5% 

8-Speed Trans (Auto or DCT) 8SPD 8% 11% 12% 17% 16% 15% 19% 19% 19% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 3% 10% 19% 24% 26% 30% 29% 30% 

Shift Optimizer SHFTOPT 0% 0% 11% 17% 20% 23% 26% 27% 27% 

Electric Power Steering EPS 70% 75% 81% 82% 88% 90% 91% 91% 91% 

Improved Accessories - Level 1 IACC1 44% 45% 48% 50% 57% 61% 67% 77% 77% 

Improved Accessories - Level 2 IACC2 4% 5% 9% 10% 15% 16% 22% 30% 33% 

12V Micro-Hybrid (Stop-Start) MHEV 7% 7% 7% 8% 7% 7% 7% 7% 7% 

Integrated Starter Generator ISG 2% 2% 2% 2% 2% 3% 3% 4% 4% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

572 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 50% 55% 63% 65% 67% 68% 69% 68% 68% 

Mass Reduction - Level 2 MR2 21% 27% 34% 37% 44% 46% 51% 58% 59% 

Mass Reduction - Level 3 MR3 10% 10% 10% 10% 12% 13% 15% 18% 19% 

Mass Reduction - Level 4 MR4 3% 3% 3% 3% 3% 3% 4% 6% 7% 

Mass Reduction - Level 5 MR5 0% 0% 0% 1% 1% 1% 1% 4% 4% 

Low Rolling Resistance Tires - Level 1 ROLL1 93% 97% 98% 99% 99% 99% 99% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 34% 43% 55% 67% 79% 80% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 84% 84% 86% 86% 89% 89% 89% 89% 89% 

Secondary Axle Disconnect SAX 10% 11% 12% 12% 12% 13% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 91% 95% 97% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 80% 86% 87% 88% 90% 90% 
 

 

 

 

 

 

 

 

 

 

 

 

573 

3% Annual Increase - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 85% 85% 85% 85% 85% 84% 

Engine Friction Reduction - Level 1 EFR1 85% 88% 88% 88% 88% 88% 88% 88% 88% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 13% 25% 37% 47% 56% 62% 66% 69% 73% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 8% 7% 7% 7% 9% 9% 9% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 12% 12% 12% 12% 12% 12% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 5% 4% 4% 3% 3% 3% 3% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 65% 67% 67% 68% 69% 69% 70% 70% 70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 46% 48% 48% 50% 51% 52% 52% 52% 52% 

Continuously Variable Valve Lift (CVVL) CVVL 12% 13% 15% 16% 16% 17% 17% 17% 17% 

Cylinder Deactivation on DOHC DEACD 6% 6% 5% 6% 5% 5% 4% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 50% 52% 56% 60% 62% 66% 67% 69% 69% 

Cylinder Deactivation on OHV DEACO 6% 6% 4% 3% 2% 2% 2% 1% 1% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 8% 9% 9% 9% 9% 8% 8% 8% 8% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 3% 4% 4% 8% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 17% 18% 21% 21% 22% 22% 21% 20% 18% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 25% 27% 28% 31% 28% 27% 28% 27% 26% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 4% 4% 5% 6% 6% 6% 5% 5% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 1% 1% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 1% 1% 1% 2% 2% 3% 3% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 2% 2% 4% 4% 6% 7% 
 

 

 

 

 

 

 

 

 

 

 

 

574 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 3% 3% 6% 7% 8% 11% 11% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 1% 2% 2% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 11% 8% 6% 2% 2% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 23% 17% 12% 8% 3% 3% 1% 0% 0% 

6-speed DCT DCT 22% 19% 16% 11% 9% 5% 5% 4% 4% 

8-Speed Trans (Auto or DCT) 8SPD 25% 26% 27% 21% 11% 10% 9% 7% 6% 

High Efficiency Gearbox (Auto or DCT) HETRANS 4% 17% 28% 42% 55% 60% 64% 67% 68% 

Shift Optimizer SHFTOPT 8% 20% 35% 47% 56% 61% 68% 72% 74% 

Electric Power Steering EPS 76% 81% 85% 86% 89% 89% 90% 90% 91% 

Improved Accessories - Level 1 IACC1 52% 54% 58% 61% 66% 68% 70% 70% 71% 

Improved Accessories - Level 2 IACC2 10% 17% 20% 23% 25% 30% 34% 39% 42% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 5% 5% 5% 5% 5% 5% 5% 

Integrated Starter Generator ISG 1% 1% 1% 3% 3% 3% 3% 4% 7% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

575 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 61% 64% 67% 68% 68% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 29% 37% 48% 54% 57% 59% 61% 62% 62% 

Mass Reduction - Level 3 MR3 12% 14% 15% 18% 20% 21% 23% 25% 27% 

Mass Reduction - Level 4 MR4 5% 6% 6% 8% 9% 10% 10% 11% 14% 

Mass Reduction - Level 5 MR5 0% 1% 1% 3% 3% 4% 3% 4% 7% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 98% 99% 99% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 17% 31% 49% 63% 74% 82% 86% 89% 90% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 85% 86% 86% 87% 88% 88% 89% 89% 90% 

Secondary Axle Disconnect SAX 11% 13% 13% 14% 14% 14% 14% 13% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

576 

3% Annual Increase - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Engine Friction Reduction - Level 1 EFR1 74% 77% 77% 78% 78% 78% 78% 78% 78% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 6% 12% 15% 17% 22% 27% 29% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 19% 19% 19% 19% 19% 19% 19% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 17% 17% 18% 18% 18% 19% 18% 18% 

Cylinder Deactivation on SOHC DEACS 6% 6% 4% 3% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 2% 2% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 61% 61% 61% 61% 61% 61% 61% 61% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 29% 30% 30% 31% 31% 31% 32% 32% 32% 

Continuously Variable Valve Lift (CVVL) CVVL 19% 20% 21% 22% 22% 23% 23% 23% 23% 

Cylinder Deactivation on DOHC DEACD 8% 9% 8% 6% 5% 5% 4% 3% 3% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 44% 51% 63% 65% 69% 74% 75% 78% 78% 

Cylinder Deactivation on OHV DEACO 5% 5% 4% 3% 2% 2% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 4% 4% 6% 6% 6% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 17% 18% 22% 23% 25% 28% 31% 33% 31% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 19% 20% 23% 26% 25% 25% 27% 27% 23% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 7% 7% 8% 9% 11% 11% 12% 12% 12% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 1% 1% 1% 1% 4% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 1% 1% 1% 1% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 3% 3% 3% 3% 3% 3% 4% 
 

 

 

 

 

 

 

 

 

 

 

 

 

577 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 3% 3% 3% 3% 4% 5% 5% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 1% 1% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 35% 33% 22% 15% 7% 4% 2% 1% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 42% 38% 26% 14% 8% 7% 3% 2% 3% 

6-speed DCT DCT 26% 27% 25% 18% 21% 19% 17% 13% 12% 

8-Speed Trans (Auto or DCT) 8SPD 9% 15% 24% 30% 27% 27% 23% 16% 10% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 2% 10% 17% 30% 32% 39% 53% 59% 

Shift Optimizer SHFTOPT 0% 0% 4% 15% 21% 26% 34% 44% 50% 

Electric Power Steering EPS 72% 78% 86% 89% 90% 90% 90% 90% 90% 

Improved Accessories - Level 1 IACC1 56% 61% 69% 75% 75% 76% 76% 77% 78% 

Improved Accessories - Level 2 IACC2 5% 6% 9% 11% 14% 19% 20% 23% 24% 

12V Micro-Hybrid (Stop-Start) MHEV 7% 7% 7% 8% 8% 8% 7% 7% 7% 

Integrated Starter Generator ISG 2% 2% 2% 2% 3% 3% 3% 4% 5% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

578 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 55% 59% 67% 71% 73% 73% 73% 73% 74% 

Mass Reduction - Level 2 MR2 21% 31% 43% 47% 53% 55% 55% 62% 65% 

Mass Reduction - Level 3 MR3 10% 10% 11% 12% 16% 17% 19% 22% 25% 

Mass Reduction - Level 4 MR4 3% 3% 4% 6% 7% 8% 8% 9% 13% 

Mass Reduction - Level 5 MR5 0% 0% 0% 1% 1% 1% 1% 2% 5% 

Low Rolling Resistance Tires - Level 1 

ROLL1 93% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 19% 35% 45% 55% 73% 82% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 86% 86% 88% 89% 89% 89% 89% 89% 89% 

Secondary Axle Disconnect SAX 11% 12% 13% 14% 14% 14% 14% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 82% 87% 88% 89% 92% 94% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

579 

4% Annual Increase - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 85% 85% 85% 85% 85% 84% 

Engine Friction Reduction - Level 1 EFR1 85% 88% 88% 88% 88% 88% 88% 88% 87% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 15% 27% 38% 46% 55% 60% 64% 68% 70% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 11% 11% 12% 11% 11% 11% 11% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 12% 12% 12% 12% 12% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 1% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 3% 3% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 67% 67% 67% 68% 69% 70% 70% 70% 70% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 48% 50% 50% 51% 52% 52% 52% 52% 52% 

Continuously Variable Valve Lift (CVVL) CVVL 13% 15% 15% 16% 16% 16% 16% 16% 16% 

Cylinder Deactivation on DOHC DEACD 5% 4% 4% 5% 4% 4% 2% 1% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 56% 61% 66% 68% 75% 77% 80% 85% 86% 

Cylinder Deactivation on OHV DEACO 6% 5% 2% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 8% 9% 9% 10% 9% 9% 9% 8% 8% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 5% 7% 10% 10% 9% 9% 9% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 20% 23% 25% 24% 28% 23% 20% 18% 16% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 26% 29% 29% 28% 24% 22% 19% 15% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 5% 5% 8% 8% 6% 5% 5% 5% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 1% 2% 2% 2% 4% 5% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 1% 4% 4% 4% 5% 6% 7% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 5% 5% 10% 12% 16% 19% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

580 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 4% 5% 7% 12% 14% 17% 21% 22% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 1% 1% 1% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 3% 4% 5% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 8% 4% 4% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 18% 12% 7% 2% 1% 1% 0% 0% 0% 

6-speed DCT DCT 26% 21% 16% 10% 4% 2% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 25% 28% 28% 21% 12% 8% 5% 3% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 20% 32% 47% 59% 63% 67% 71% 70% 

Shift Optimizer SHFTOPT 11% 23% 39% 52% 69% 77% 81% 86% 87% 

Electric Power Steering EPS 81% 85% 91% 92% 94% 94% 94% 94% 94% 

Improved Accessories - Level 1 IACC1 53% 55% 60% 67% 75% 79% 82% 89% 91% 

Improved Accessories - Level 2 IACC2 13% 20% 23% 29% 33% 37% 42% 48% 57% 

12V Micro-Hybrid (Stop-Start) MHEV 5% 5% 6% 10% 12% 13% 13% 13% 12% 

Integrated Starter Generator ISG 1% 1% 2% 4% 5% 8% 10% 13% 16% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

 

581 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 62% 65% 67% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 27% 35% 48% 54% 58% 60% 63% 63% 64% 

Mass Reduction - Level 3 MR3 12% 14% 16% 21% 23% 24% 26% 29% 30% 

Mass Reduction - Level 4 MR4 6% 7% 7% 9% 12% 13% 15% 19% 22% 

Mass Reduction - Level 5 MR5 1% 1% 2% 4% 6% 7% 7% 11% 13% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 16% 32% 49% 66% 75% 82% 86% 88% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 88% 88% 89% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 13% 14% 15% 16% 16% 16% 15% 15% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

582 

4% Annual Increase - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 

100 

% 

100 

% 

100 

% 

100 

% 100% 99% 

Engine Friction Reduction - Level 1 EFR1 74% 77% 77% 78% 78% 78% 78% 78% 78% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 6% 13% 14% 16% 21% 30% 33% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 18% 18% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 18% 17% 18% 18% 18% 18% 18% 18% 

Cylinder Deactivation on SOHC DEACS 6% 6% 5% 4% 2% 2% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 2% 2% 2% 2% 2% 2% 2% 1% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 61% 61% 61% 61% 61% 61% 61% 61% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 29% 30% 31% 32% 32% 32% 32% 32% 32% 

Continuously Variable Valve Lift (CVVL) CVVL 20% 21% 21% 22% 22% 22% 22% 22% 22% 

Cylinder Deactivation on DOHC DEACD 9% 8% 5% 3% 2% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 52% 59% 70% 73% 80% 82% 85% 86% 86% 

Cylinder Deactivation on OHV DEACO 5% 4% 3% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 5% 5% 7% 8% 8% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 26% 29% 34% 34% 37% 34% 32% 26% 22% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 17% 19% 24% 26% 25% 25% 25% 21% 15% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 7% 8% 9% 11% 12% 12% 12% 11% 10% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 1% 1% 4% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 1% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 1% 3% 5% 8% 10% 17% 22% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

583 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 4% 6% 7% 8% 9% 11% 15% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 2% 2% 2% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 35% 30% 18% 10% 3% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 42% 38% 26% 14% 6% 3% 1% 0% 0% 

6-speed DCT DCT 24% 26% 22% 15% 15% 11% 5% 2% 1% 

8-Speed Trans (Auto or DCT) 8SPD 10% 15% 21% 22% 20% 20% 20% 14% 12% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 4% 15% 25% 35% 38% 41% 50% 50% 

Shift Optimizer SHFTOPT 0% 0% 9% 25% 44% 50% 59% 64% 70% 

Electric Power Steering EPS 75% 82% 88% 91% 93% 94% 94% 95% 95% 

Improved Accessories - Level 1 IACC1 56% 64% 71% 76% 81% 85% 86% 88% 91% 

Improved Accessories - Level 2 IACC2 6% 12% 19% 27% 34% 39% 47% 57% 63% 

12V Micro-Hybrid (Stop-Start) MHEV 8% 8% 9% 10% 9% 11% 12% 12% 10% 

Integrated Starter Generator ISG 2% 2% 3% 5% 6% 7% 8% 9% 14% 

Strong Hybrid - Level 1 SHEV1 2% 2% 2% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

584 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 56% 61% 69% 72% 73% 73% 74% 74% 74% 

Mass Reduction - Level 2 MR2 21% 30% 43% 49% 55% 57% 60% 62% 65% 

Mass Reduction - Level 3 MR3 10% 11% 14% 18% 21% 22% 26% 28% 33% 

Mass Reduction - Level 4 MR4 4% 4% 6% 10% 10% 11% 13% 14% 16% 

Mass Reduction - Level 5 MR5 0% 0% 1% 2% 3% 4% 5% 5% 8% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 35% 52% 59% 69% 78% 85% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 86% 86% 88% 89% 90% 90% 90% 90% 90% 

Secondary Axle Disconnect SAX 11% 12% 13% 13% 13% 13% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 81% 86% 88% 89% 91% 94% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

585 

5% Annual Increase - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 85% 84% 84% 84% 84% 82% 

Engine Friction Reduction - Level 1 EFR1 85% 88% 88% 88% 88% 88% 88% 87% 86% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 14% 25% 36% 44% 48% 53% 56% 59% 59% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 9% 9% 12% 11% 11% 11% 11% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 2% 2% 2% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 3% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 67% 67% 67% 69% 70% 67% 67% 65% 63% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 48% 50% 50% 51% 52% 51% 50% 49% 47% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 15% 15% 15% 15% 15% 16% 15% 

Cylinder Deactivation on DOHC DEACD 5% 4% 3% 2% 2% 2% 1% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 58% 66% 71% 74% 81% 79% 80% 80% 78% 

Cylinder Deactivation on OHV DEACO 6% 5% 1% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 8% 9% 9% 10% 9% 9% 9% 8% 8% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 5% 7% 8% 10% 10% 9% 9% 9% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 22% 26% 27% 25% 25% 18% 15% 6% 5% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 28% 31% 32% 27% 22% 19% 15% 8% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 5% 5% 5% 5% 4% 4% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 2% 2% 3% 3% 3% 2% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 2% 2% 2% 2% 2% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 2% 6% 8% 13% 16% 24% 25% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

586 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 4% 6% 11% 14% 17% 20% 25% 26% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 2% 1% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 3% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 1% 4% 5% 7% 9% 8% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 3% 4% 5% 5% 7% 7% 6% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 1% 1% 3% 4% 5% 6% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 2% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 9% 5% 4% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 17% 13% 7% 3% 0% 0% 0% 0% 0% 

6-speed DCT DCT 27% 21% 15% 9% 2% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 25% 25% 23% 16% 8% 6% 5% 5% 4% 

High Efficiency Gearbox (Auto or DCT) HETRANS 9% 24% 38% 50% 61% 64% 65% 64% 62% 

Shift Optimizer SHFTOPT 11% 28% 46% 62% 80% 87% 89% 86% 83% 

Electric Power Steering EPS 84% 87% 93% 95% 95% 95% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 60% 63% 67% 76% 86% 88% 92% 96% 96% 

Improved Accessories - Level 2 IACC2 16% 27% 36% 48% 58% 66% 74% 82% 86% 

12V Micro-Hybrid (Stop-Start) MHEV 6% 6% 9% 16% 23% 28% 32% 30% 27% 

Integrated Starter Generator ISG 1% 2% 4% 9% 13% 17% 22% 30% 36% 

Strong Hybrid - Level 1 SHEV1 3% 3% 3% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 1% 4% 4% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 1% 1% 1% 1% 1% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

 

587 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 62% 65% 67% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 29% 36% 50% 56% 59% 61% 64% 64% 64% 

Mass Reduction - Level 3 MR3 12% 15% 17% 23% 25% 26% 27% 29% 29% 

Mass Reduction - Level 4 MR4 7% 8% 10% 16% 16% 17% 18% 20% 20% 

Mass Reduction - Level 5 MR5 1% 2% 4% 11% 12% 13% 14% 16% 16% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 16% 31% 52% 66% 74% 82% 87% 89% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 88% 88% 89% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 13% 15% 15% 16% 16% 16% 16% 15% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

588 

5% Annual Increase - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 

LUB1 100% 100% 100% 

100 

% 99% 99% 99% 99% 97% 

Engine Friction Reduction - Level 1 EFR1 74% 77% 77% 78% 78% 78% 78% 78% 76% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 4% 9% 10% 12% 14% 20% 26% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 18% 18% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 18% 17% 17% 17% 17% 17% 17% 16% 

Cylinder Deactivation on SOHC DEACS 6% 5% 4% 4% 2% 2% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 2% 1% 1% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 61% 61% 59% 59% 57% 56% 56% 55% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 29% 31% 31% 31% 32% 30% 30% 30% 29% 

Continuously Variable Valve Lift (CVVL) CVVL 20% 20% 21% 21% 22% 22% 22% 21% 21% 

Cylinder Deactivation on DOHC DEACD 6% 5% 3% 2% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 57% 64% 74% 75% 79% 78% 79% 80% 78% 

Cylinder Deactivation on OHV DEACO 5% 3% 3% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 5% 6% 7% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 29% 32% 37% 35% 35% 30% 24% 15% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 21% 24% 26% 25% 23% 22% 20% 16% 10% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 7% 8% 9% 11% 8% 7% 7% 6% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 0% 0% 0% 1% 1% 1% 1% 1% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 1% 1% 1% 1% 1% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 1% 2% 4% 6% 9% 12% 23% 25% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

589 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 4% 6% 7% 8% 10% 14% 18% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 3% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 1% 2% 2% 2% 2% 3% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 2% 3% 4% 5% 5% 5% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 1% 1% 3% 4% 4% 4% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 1% 1% 1% 1% 1% 

6-Speed Manual/Improved Internals 6MAN 2% 2% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANS 

M 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 33% 27% 16% 6% 2% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 41% 37% 24% 13% 4% 2% 0% 0% 0% 

6-speed DCT DCT 27% 25% 19% 10% 7% 4% 2% 1% 0% 

8-Speed Trans (Auto or DCT) 8SPD 12% 19% 20% 20% 15% 12% 5% 4% 3% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 6% 22% 34% 45% 49% 51% 54% 52% 

Shift Optimizer SHFTOPT 0% 0% 23% 39% 61% 74% 84% 88% 85% 

Electric Power Steering EPS 77% 84% 92% 93% 95% 95% 95% 96% 96% 

Improved Accessories - Level 1 IACC1 61% 69% 82% 86% 91% 94% 94% 97% 97% 

Improved Accessories - Level 2 IACC2 7% 15% 23% 31% 41% 49% 57% 78% 81% 

12V Micro-Hybrid (Stop-Start) MHEV 11% 12% 16% 21% 28% 29% 31% 33% 32% 

Integrated Starter Generator ISG 2% 4% 6% 13% 14% 16% 19% 28% 30% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 0% 3% 3% 5% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 
 

 

 

 

 

 

 

 

 

 

 

 

590 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 56% 60% 69% 73% 74% 74% 74% 74% 74% 

Mass Reduction - Level 2 MR2 22% 32% 49% 56% 62% 64% 67% 68% 68% 

Mass Reduction - Level 3 MR3 10% 11% 13% 19% 25% 26% 30% 33% 37% 

Mass Reduction - Level 4 MR4 4% 4% 6% 9% 10% 11% 13% 15% 22% 

Mass Reduction - Level 5 MR5 0% 0% 1% 3% 4% 6% 8% 11% 18% 

Low Rolling Resistance Tires - Level 1 

ROLL1 94% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 21% 38% 51% 60% 70% 81% 87% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 86% 87% 89% 89% 90% 90% 90% 90% 90% 

Secondary Axle Disconnect SAX 11% 12% 13% 13% 13% 13% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 94% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 81% 86% 88% 89% 91% 93% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

591 

6% Annual Increase - Combined - 2008 Baseline 

Low Friction Lubricants - Level 1 

LUB1 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Engine Friction Reduction - Level 1 EFR1 86% 86% 85% 84% 84% 82% 81% 80% 76% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 85% 88% 88% 88% 87% 85% 84% 82% 79% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 15% 27% 39% 46% 51% 53% 55% 62% 62% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 11% 12% 11% 11% 11% 11% 11% 11% 10% 

Cylinder Deactivation on SOHC DEACS 12% 12% 12% 11% 11% 11% 11% 11% 11% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 2% 1% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 3% 2% 3% 2% 2% 2% 2% 2% 2% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 68% 68% 68% 67% 66% 63% 62% 59% 57% 

Continuously Variable Valve Lift (CVVL) CVVL 50% 50% 50% 50% 48% 47% 47% 43% 42% 

Cylinder Deactivation on DOHC DEACD 14% 14% 15% 15% 15% 15% 15% 15% 14% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 3% 1% 1% 1% 0% 0% 0% 0% 0% 

Cylinder Deactivation on OHV DEACO 65% 71% 76% 77% 80% 78% 78% 74% 71% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 5% 4% 1% 0% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 9% 9% 10% 9% 9% 8% 8% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 7% 8% 9% 10% 10% 9% 9% 9% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 25% 29% 28% 25% 24% 19% 16% 8% 6% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 31% 34% 34% 28% 21% 18% 16% 7% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 6% 6% 6% 6% 6% 5% 3% 3% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 1% 1% 2% 2% 2% 1% 1% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 1% 1% 1% 1% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 1% 1% 3% 9% 10% 12% 12% 16% 14% 
 

 

 

 

 

 

 

 

 

 

 

 

 

592 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 3% 4% 5% 10% 15% 17% 17% 19% 18% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 1% 4% 6% 9% 10% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 2% 4% 5% 6% 11% 10% 

Advanced Diesel - Small Displacement ADSL_SD 1% 1% 4% 5% 5% 5% 7% 7% 5% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 1% 1% 3% 3% 4% 4% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 2% 2% 2% 2% 3% 3% 

6-Speed Manual/Improved Internals 6MAN 0% 0% 0% 0% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 3% 2% 2% 1% 0% 0% 0% 0% 0% 

Improved Auto. Trans. Controls/Externals IATC 1% 2% 3% 5% 6% 6% 6% 6% 6% 

6-Speed Trans with Improved Internals (Auto) NAUTO 8% 4% 3% 0% 0% 0% 0% 0% 0% 

6-speed DCT DCT 17% 12% 6% 1% 0% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 26% 19% 14% 8% 2% 0% 0% 0% 0% 

High Efficiency Gearbox (Auto or DCT) HETRANS 27% 27% 25% 18% 8% 5% 4% 4% 2% 

Shift Optimizer SHFTOPT 10% 24% 39% 50% 58% 61% 61% 59% 52% 

Electric Power Steering EPS 12% 30% 51% 67% 82% 85% 84% 80% 71% 

Improved Accessories - Level 1 IACC1 82% 86% 94% 96% 96% 96% 96% 96% 96% 

Improved Accessories - Level 2 IACC2 64% 67% 75% 85% 88% 90% 94% 97% 97% 

12V Micro-Hybrid (Stop-Start) MHEV 20% 30% 44% 58% 69% 75% 85% 89% 89% 

Integrated Starter Generator ISG 13% 17% 22% 29% 39% 38% 38% 37% 32% 

Strong Hybrid - Level 1 SHEV1 3% 6% 10% 17% 20% 25% 28% 37% 38% 

Conversion from SHEV1 to SHEV2 SHEV1_2 3% 3% 2% 1% 1% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 1% 1% 1% 2% 2% 2% 2% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 1% 1% 2% 4% 9% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 1% 2% 4% 4% 6% 7% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 1% 2% 3% 
 

 

 

 

 

 

 

 

 

 

 

 

593 

Mass Reduction - Level 1 MR1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 2 MR2 62% 65% 67% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 3 MR3 29% 37% 51% 57% 60% 62% 64% 64% 64% 

Mass Reduction - Level 4 MR4 13% 15% 17% 23% 25% 27% 28% 31% 33% 

Mass Reduction - Level 5 MR5 7% 8% 10% 13% 14% 16% 17% 19% 22% 

Low Rolling Resistance Tires - Level 1 ROLL1 1% 2% 4% 8% 10% 12% 13% 15% 20% 

Low Rolling Resistance Tires - Level 2 

ROLL2 96% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 3 ROLL3 16% 32% 49% 67% 77% 86% 88% 91% 92% 

Low Drag Brakes LDB 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Secondary Axle Disconnect SAX 88% 88% 89% 89% 89% 89% 90% 90% 90% 

Aero Drag Reduction, Level 1 AERO1 13% 15% 15% 16% 16% 16% 16% 15% 15% 

Aero Drag Reduction, Level 2 

AERO2 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

594 

6% Annual Increase - Combined - 2010 Baseline 

Low Friction Lubricants - Level 1 

LUB1 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Engine Friction Reduction - Level 1 

EFR1 100% 100% 100% 

100 

% 99% 99% 98% 95% 94% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 75% 77% 77% 78% 78% 78% 76% 75% 74% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 0% 0% 5% 9% 10% 13% 16% 21% 24% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 19% 19% 18% 18% 18% 18% 18% 17% 17% 

Cylinder Deactivation on SOHC DEACS 17% 18% 17% 17% 16% 16% 16% 16% 16% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 4% 4% 3% 3% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 3% 2% 1% 1% 1% 1% 1% 1% 1% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 59% 61% 61% 58% 57% 56% 55% 53% 52% 

Continuously Variable Valve Lift (CVVL) CVVL 29% 31% 30% 30% 30% 29% 29% 26% 26% 

Cylinder Deactivation on DOHC DEACD 20% 21% 22% 21% 21% 21% 20% 20% 19% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 5% 4% 3% 2% 1% 1% 0% 0% 0% 

Cylinder Deactivation on OHV DEACO 54% 63% 74% 72% 77% 77% 76% 73% 71% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 4% 3% 3% 1% 1% 1% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. 

TRBDS1_S 

D 4% 5% 6% 7% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 22% 26% 30% 28% 29% 26% 21% 12% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. 

TRBDS1_L 

D 23% 27% 29% 27% 24% 22% 19% 12% 6% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. 

TRBDS2_S 

D 7% 8% 9% 10% 7% 7% 6% 6% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 1% 1% 1% 1% 1% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. 

TRBDS2_L 

D 1% 1% 1% 1% 1% 1% 1% 1% 2% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 2% 3% 6% 7% 11% 13% 16% 21% 23% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

595 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 3% 3% 4% 4% 7% 9% 10% 13% 15% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 1% 1% 1% 0% 3% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 1% 1% 1% 1% 2% 2% 2% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 2% 2% 3% 4% 4% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 3% 3% 4% 4% 5% 5% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 2% 3% 3% 3% 4% 4% 

6-Speed Manual/Improved Internals 6MAN 0% 0% 0% 0% 1% 1% 1% 1% 1% 

High Efficiency Gearbox (Manual) HETRANS 

M 3% 3% 2% 1% 1% 1% 0% 0% 0% 

Improved Auto. Trans. Controls/Externals IATC 0% 0% 1% 2% 2% 3% 3% 3% 3% 

6-Speed Trans with Improved Internals (Auto) NAUTO 28% 25% 13% 4% 1% 1% 0% 0% 0% 

6-speed DCT DCT 38% 32% 19% 9% 3% 2% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 28% 26% 20% 11% 6% 4% 3% 1% 0% 

High Efficiency Gearbox (Auto or DCT) HETRANS 19% 25% 25% 25% 15% 10% 4% 3% 2% 

Shift Optimizer SHFTOPT 2% 7% 24% 35% 42% 46% 46% 42% 40% 

Electric Power Steering EPS 0% 0% 21% 38% 59% 71% 83% 80% 77% 

Improved Accessories - Level 1 IACC1 79% 87% 94% 95% 96% 96% 96% 96% 96% 

Improved Accessories - Level 2 IACC2 64% 71% 83% 85% 90% 93% 97% 97% 97% 

12V Micro-Hybrid (Stop-Start) MHEV 10% 20% 34% 41% 52% 58% 66% 67% 68% 

Integrated Starter Generator ISG 12% 18% 32% 40% 50% 52% 50% 44% 39% 

Strong Hybrid - Level 1 SHEV1 4% 6% 9% 15% 21% 25% 30% 35% 35% 

Conversion from SHEV1 to SHEV2 SHEV1_2 2% 2% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 1% 1% 0% 0% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 1% 1% 3% 7% 11% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 1% 1% 1% 2% 3% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 1% 2% 3% 
 

 

 

 

 

 

 

 

 

 

 

 

596 

Mass Reduction - Level 1 MR1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 2 MR2 57% 62% 70% 72% 74% 74% 74% 74% 74% 

Mass Reduction - Level 3 MR3 22% 32% 50% 55% 62% 64% 66% 67% 69% 

Mass Reduction - Level 4 MR4 10% 11% 15% 17% 23% 25% 29% 31% 39% 

Mass Reduction - Level 5 MR5 4% 4% 7% 10% 13% 14% 16% 18% 26% 

Low Rolling Resistance Tires - Level 1 ROLL1 0% 1% 2% 4% 6% 8% 10% 13% 21% 

Low Rolling Resistance Tires - Level 2 

ROLL2 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 20% 36% 50% 59% 72% 80% 89% 

Low Drag Brakes LDB 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Secondary Axle Disconnect SAX 86% 87% 89% 90% 90% 90% 90% 90% 90% 

Aero Drag Reduction, Level 1 AERO1 11% 12% 13% 14% 14% 14% 14% 13% 13% 

Aero Drag Reduction, Level 2 

AERO2 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 81% 87% 88% 89% 91% 94% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

597 

7% Annual Increase - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 87% 86% 85% 85% 84% 82% 81% 78% 76% 

Engine Friction Reduction - Level 1 EFR1 88% 88% 87% 88% 86% 84% 83% 81% 79% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 15% 27% 39% 45% 47% 48% 50% 56% 56% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 11% 12% 11% 11% 10% 10% 10% 9% 9% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 11% 11% 10% 10% 10% 10% 9% 

Cylinder Deactivation on SOHC DEACS 2% 2% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 2% 3% 2% 2% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 68% 68% 68% 65% 61% 58% 57% 55% 54% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 50% 50% 50% 48% 44% 41% 40% 38% 38% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 15% 15% 15% 14% 15% 15% 14% 

Cylinder Deactivation on DOHC DEACD 5% 2% 1% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 67% 76% 80% 79% 75% 71% 71% 68% 66% 

Cylinder Deactivation on OHV DEACO 4% 3% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 9% 9% 10% 9% 9% 8% 8% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 8% 9% 10% 10% 9% 9% 9% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 28% 32% 30% 26% 21% 16% 13% 10% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 33% 35% 33% 24% 19% 16% 13% 8% 7% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 5% 6% 8% 8% 7% 6% 4% 3% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 1% 1% 1% 1% 1% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 1% 1% 1% 1% 1% 0% 0% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 2% 2% 4% 8% 10% 11% 11% 13% 13% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

598 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 3% 4% 8% 12% 13% 15% 14% 15% 15% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 2% 2% 3% 3% 5% 6% 6% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 3% 6% 7% 8% 8% 7% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 1% 1% 2% 3% 3% 3% 4% 4% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 0% 2% 4% 6% 6% 6% 6% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 0% 3% 5% 5% 6% 6% 6% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 10% 6% 3% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 20% 12% 4% 1% 0% 0% 0% 0% 0% 

6-speed DCT DCT 26% 19% 14% 7% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 29% 29% 26% 17% 7% 5% 5% 4% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 10% 25% 38% 51% 57% 60% 58% 55% 52% 

Shift Optimizer SHFTOPT 14% 34% 54% 73% 84% 83% 80% 73% 69% 

Electric Power Steering EPS 85% 89% 95% 96% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 65% 75% 84% 93% 93% 96% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 22% 39% 52% 64% 74% 82% 85% 85% 85% 

12V Micro-Hybrid (Stop-Start) MHEV 18% 25% 36% 43% 45% 43% 42% 35% 31% 

Integrated Starter Generator ISG 4% 9% 13% 20% 28% 32% 35% 35% 36% 

Strong Hybrid - Level 1 SHEV1 3% 3% 2% 1% 1% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 2% 2% 5% 9% 12% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 0% 2% 5% 5% 6% 6% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 1% 1% 1% 2% 2% 4% 6% 
 

 

 

 

 

 

 

 

 

 

 

 

599 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 63% 66% 68% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 30% 39% 53% 59% 62% 63% 64% 64% 64% 

Mass Reduction - Level 3 MR3 13% 15% 17% 23% 26% 28% 30% 31% 35% 

Mass Reduction - Level 4 MR4 7% 8% 10% 15% 18% 20% 22% 24% 28% 

Mass Reduction - Level 5 MR5 2% 3% 4% 11% 14% 16% 18% 21% 25% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 16% 31% 50% 67% 79% 86% 90% 91% 92% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 88% 89% 89% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 17% 17% 16% 16% 16% 16% 16% 15% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 86% 91% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

600 

7% Annual Increase - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 99% 99% 98% 96% 94% 93% 91% 

Engine Friction Reduction - Level 1 EFR1 75% 77% 77% 78% 78% 77% 76% 74% 73% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 4% 9% 10% 11% 14% 18% 20% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 19% 18% 17% 17% 17% 17% 16% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 17% 17% 17% 16% 16% 16% 16% 15% 

Cylinder Deactivation on SOHC DEACS 4% 4% 3% 3% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 3% 2% 1% 1% 1% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 59% 61% 60% 57% 56% 54% 49% 47% 46% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 29% 31% 30% 31% 30% 29% 26% 25% 23% 

Continuously Variable Valve Lift (CVVL) CVVL 20% 21% 21% 21% 21% 21% 20% 19% 19% 

Cylinder Deactivation on DOHC DEACD 6% 4% 3% 2% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 62% 71% 78% 75% 77% 75% 71% 69% 67% 

Cylinder Deactivation on OHV DEACO 5% 4% 3% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 5% 6% 7% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 31% 34% 38% 34% 32% 29% 24% 15% 11% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 22% 26% 27% 24% 21% 20% 18% 13% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 7% 8% 7% 8% 6% 6% 5% 5% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 1% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 2% 2% 3% 6% 6% 7% 7% 12% 13% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

601 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 5% 6% 9% 10% 11% 12% 16% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 1% 0% 0% 0% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 2% 3% 3% 3% 3% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 1% 2% 2% 2% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 2% 3% 6% 7% 8% 8% 5% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 2% 3% 4% 7% 8% 8% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 3% 3% 3% 3% 3% 3% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 1% 1% 1% 1% 1% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 2% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 28% 24% 13% 4% 1% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 39% 31% 18% 7% 2% 1% 0% 0% 0% 

6-speed DCT DCT 28% 25% 19% 9% 5% 3% 1% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 19% 26% 26% 25% 16% 10% 5% 3% 2% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2% 9% 26% 35% 40% 43% 42% 39% 37% 

Shift Optimizer SHFTOPT 0% 0% 22% 42% 64% 72% 83% 79% 74% 

Electric Power Steering EPS 78% 87% 94% 96% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 64% 73% 87% 93% 95% 97% 97% 97% 97% 

Improved Accessories - Level 2 IACC2 15% 27% 39% 43% 51% 55% 55% 57% 59% 

12V Micro-Hybrid (Stop-Start) MHEV 28% 37% 52% 55% 56% 53% 50% 42% 37% 

Integrated Starter Generator ISG 6% 9% 13% 18% 27% 31% 32% 34% 33% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 1% 1% 0% 0% 0% 0% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 0% 1% 3% 8% 13% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 0% 1% 1% 1% 2% 3% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 1% 1% 1% 3% 4% 5% 7% 
 

 

 

 

 

 

 

 

 

 

 

 

602 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 58% 64% 70% 73% 74% 74% 74% 74% 74% 

Mass Reduction - Level 2 MR2 22% 33% 51% 57% 65% 66% 68% 69% 70% 

Mass Reduction - Level 3 MR3 11% 12% 15% 19% 24% 25% 29% 31% 38% 

Mass Reduction - Level 4 MR4 4% 5% 7% 11% 13% 14% 16% 20% 27% 

Mass Reduction - Level 5 MR5 0% 1% 2% 5% 7% 9% 11% 15% 22% 

Low Rolling Resistance Tires - Level 1 

ROLL1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 20% 37% 48% 59% 71% 81% 89% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 87% 88% 90% 90% 90% 90% 90% 90% 90% 

Secondary Axle Disconnect SAX 11% 12% 13% 14% 14% 14% 14% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 56% 70% 80% 85% 87% 88% 90% 94% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

603 

Max Net Benefits - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 86% 86% 85% 83% 83% 83% 83% 82% 82% 

Engine Friction Reduction - Level 1 EFR1 88% 88% 87% 87% 87% 87% 87% 86% 86% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 18% 22% 30% 41% 56% 60% 67% 73% 76% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 12% 11% 11% 11% 11% 11% 11% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 1% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 3% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 66% 66% 65% 66% 66% 66% 66% 66% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 50% 50% 49% 49% 50% 50% 50% 50% 50% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 15% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on DOHC DEACD 3% 2% 1% 1% 1% 1% 1% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 71% 74% 74% 75% 79% 80% 80% 81% 81% 

Cylinder Deactivation on OHV DEACO 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 9% 10% 10% 10% 9% 9% 8% 8% 8% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 10% 10% 10% 10% 9% 9% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 28% 30% 27% 27% 22% 19% 16% 6% 4% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 32% 33% 31% 28% 24% 24% 21% 16% 15% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 9% 8% 8% 8% 8% 8% 6% 5% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 1% 1% 1% 2% 6% 6% 7% 13% 12% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 1% 1% 1% 1% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3% 3% 5% 6% 9% 12% 13% 17% 19% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

604 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 6% 6% 9% 11% 14% 15% 17% 20% 21% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 2% 2% 2% 2% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 2% 3% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 1% 2% 2% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 9% 4% 3% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 17% 11% 5% 1% 0% 0% 0% 0% 0% 

6-speed DCT DCT 26% 18% 11% 4% 2% 1% 1% 1% 1% 

8-Speed Trans (Auto or DCT) 8SPD 35% 35% 31% 23% 9% 7% 6% 5% 4% 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 24% 39% 52% 60% 63% 65% 62% 62% 

Shift Optimizer SHFTOPT 15% 27% 43% 58% 81% 84% 85% 82% 81% 

Electric Power Steering EPS 90% 91% 94% 95% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 82% 83% 83% 84% 87% 87% 88% 91% 93% 

Improved Accessories - Level 2 IACC2 39% 44% 50% 56% 59% 61% 64% 67% 69% 

12V Micro-Hybrid (Stop-Start) MHEV 29% 30% 32% 29% 28% 28% 27% 25% 23% 

Integrated Starter Generator ISG 8% 10% 11% 15% 17% 18% 20% 24% 28% 

Strong Hybrid - Level 1 SHEV1 3% 3% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 1% 1% 1% 1% 1% 3% 4% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

 

605 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 66% 66% 68% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 31% 38% 49% 55% 58% 58% 62% 62% 63% 

Mass Reduction - Level 3 MR3 15% 16% 19% 22% 24% 24% 27% 29% 33% 

Mass Reduction - Level 4 MR4 9% 9% 12% 13% 15% 16% 17% 19% 23% 

Mass Reduction - Level 5 MR5 3% 3% 5% 9% 11% 11% 12% 14% 17% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 97% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 20% 30% 46% 58% 78% 85% 87% 90% 91% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 88% 89% 89% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 17% 17% 17% 16% 16% 16% 16% 15% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 85% 90% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

606 

Max Net Benefits - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 99% 99% 99% 99% 98% 98% 98% 

Engine Friction Reduction - Level 1 EFR1 76% 77% 76% 77% 77% 77% 77% 77% 76% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 4% 13% 18% 20% 22% 28% 34% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 18% 18% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 18% 17% 17% 17% 17% 17% 17% 17% 

Cylinder Deactivation on SOHC DEACS 6% 5% 3% 3% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 2% 1% 1% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 60% 60% 59% 58% 58% 58% 58% 58% 58% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 28% 29% 29% 29% 29% 29% 29% 29% 29% 

Continuously Variable Valve Lift (CVVL) CVVL 21% 21% 20% 19% 20% 20% 20% 20% 20% 

Cylinder Deactivation on DOHC DEACD 5% 3% 1% 1% 1% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 65% 71% 77% 76% 78% 79% 80% 80% 80% 

Cylinder Deactivation on OHV DEACO 5% 4% 3% 1% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 4% 6% 7% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 33% 34% 37% 34% 33% 31% 25% 15% 13% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 23% 27% 28% 27% 25% 24% 22% 19% 14% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 7% 8% 8% 10% 9% 8% 7% 7% 4% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 0% 0% 1% 1% 1% 1% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 3% 3% 3% 5% 7% 9% 12% 22% 24% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

607 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 5% 6% 9% 10% 12% 13% 17% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 3% 3% 3% 3% 5% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 1% 3% 4% 4% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 0% 0% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 2% 2% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 2% 3% 3% 3% 3% 3% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 30% 27% 15% 6% 1% 1% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 38% 33% 20% 9% 2% 2% 0% 0% 0% 

6-speed DCT DCT 30% 25% 17% 9% 7% 5% 4% 2% 1% 

8-Speed Trans (Auto or DCT) 8SPD 19% 24% 27% 27% 23% 17% 13% 9% 9% 

High Efficiency Gearbox (Auto or DCT) HETRANS 2% 8% 22% 31% 39% 42% 47% 51% 52% 

Shift Optimizer SHFTOPT 0% 0% 17% 35% 52% 60% 69% 73% 74% 

Electric Power Steering EPS 90% 94% 95% 96% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 72% 76% 86% 90% 93% 93% 93% 94% 94% 

Improved Accessories - Level 2 IACC2 14% 18% 27% 29% 40% 44% 47% 51% 56% 

12V Micro-Hybrid (Stop-Start) MHEV 31% 31% 33% 35% 37% 36% 34% 35% 31% 

Integrated Starter Generator ISG 7% 9% 11% 12% 13% 16% 18% 20% 24% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 1% 1% 1% 1% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 1% 1% 1% 2% 2% 3% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 1% 1% 1% 1% 1% 2% 2% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 0% 
 

 

 

 

 

 

 

 

 

 

 

608 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 63% 65% 68% 72% 74% 73% 74% 74% 74% 

Mass Reduction - Level 2 MR2 23% 31% 49% 53% 61% 61% 66% 67% 69% 

Mass Reduction - Level 3 MR3 11% 12% 15% 18% 24% 24% 28% 30% 36% 

Mass Reduction - Level 4 MR4 4% 5% 7% 11% 12% 13% 14% 16% 21% 

Mass Reduction - Level 5 MR5 0% 1% 2% 4% 6% 8% 9% 9% 10% 

Low Rolling Resistance Tires - Level 1 

ROLL1 95% 97% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 18% 34% 51% 60% 71% 83% 90% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 89% 90% 90% 90% 90% 90% 90% 90% 90% 

Secondary Axle Disconnect SAX 12% 13% 13% 14% 14% 14% 13% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 95% 97% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 55% 70% 81% 87% 88% 89% 91% 94% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

609 

Total Cost = Total Benefits - Combined - 2008 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 85% 84% 84% 82% 82% 82% 82% 81% 80% 

Engine Friction Reduction - Level 1 EFR1 86% 86% 86% 86% 86% 86% 85% 85% 84% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 17% 20% 29% 36% 55% 59% 65% 73% 74% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 12% 11% 11% 11% 11% 11% 11% 11% 11% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12% 12% 12% 11% 11% 11% 11% 11% 11% 

Cylinder Deactivation on SOHC DEACS 2% 1% 1% 1% 0% 0% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 3% 2% 2% 2% 2% 2% 2% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 66% 65% 65% 63% 64% 64% 64% 64% 63% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 49% 49% 49% 48% 48% 48% 48% 48% 48% 

Continuously Variable Valve Lift (CVVL) CVVL 14% 14% 14% 15% 15% 15% 15% 15% 15% 

Cylinder Deactivation on DOHC DEACD 2% 2% 1% 1% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 76% 77% 78% 76% 78% 79% 79% 79% 79% 

Cylinder Deactivation on OHV DEACO 1% 1% 0% 0% 0% 0% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 9% 10% 10% 9% 9% 8% 8% 8% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 9% 10% 10% 10% 9% 9% 9% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 33% 32% 31% 28% 21% 17% 14% 4% 2% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 33% 34% 31% 27% 23% 21% 17% 11% 9% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 9% 8% 8% 8% 8% 8% 6% 5% 5% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 2% 2% 2% 3% 4% 2% 2% 2% 2% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 1% 0% 0% 1% 2% 3% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 2% 2% 3% 5% 12% 17% 20% 28% 29% 
 

 

 

 

 

 

 

 

 

 

 

 

 

610 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 6% 6% 9% 11% 15% 17% 17% 20% 20% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 1% 1% 1% 1% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 1% 2% 2% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 1% 2% 2% 3% 4% 5% 4% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 1% 1% 2% 2% 3% 4% 4% 4% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 1% 1% 1% 1% 1% 1% 1% 

Advanced Diesel - Medium Displacement ADSL_MD 1% 1% 1% 2% 3% 3% 3% 3% 3% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 0% 0% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 1% 2% 3% 5% 6% 6% 6% 6% 6% 

Improved Auto. Trans. Controls/Externals IATC 7% 3% 3% 0% 0% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 16% 9% 4% 1% 0% 0% 0% 0% 0% 

6-speed DCT DCT 29% 20% 10% 4% 1% 0% 0% 0% 0% 

8-Speed Trans (Auto or DCT) 8SPD 34% 34% 29% 20% 9% 8% 7% 6% 5% 

High Efficiency Gearbox (Auto or DCT) HETRANS 8% 24% 39% 55% 62% 65% 66% 64% 62% 

Shift Optimizer SHFTOPT 15% 27% 45% 60% 81% 86% 84% 81% 78% 

Electric Power Steering EPS 90% 90% 93% 94% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 83% 85% 87% 89% 89% 89% 94% 96% 97% 

Improved Accessories - Level 2 IACC2 39% 44% 52% 59% 66% 67% 72% 75% 77% 

12V Micro-Hybrid (Stop-Start) MHEV 33% 33% 38% 35% 36% 37% 36% 33% 30% 

Integrated Starter Generator ISG 12% 13% 15% 17% 19% 23% 23% 25% 27% 

Strong Hybrid - Level 1 SHEV1 3% 3% 2% 2% 2% 2% 2% 2% 2% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 1% 1% 

Strong Hybrid - Level 2 SHEV2 0% 0% 1% 1% 1% 1% 3% 5% 7% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 1% 2% 2% 3% 3% 3% 4% 4% 4% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 0% 1% 
 

 

 

 

 

 

 

 

 

 

 

 

611 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 66% 66% 68% 69% 69% 69% 69% 68% 68% 

Mass Reduction - Level 2 MR2 31% 38% 50% 55% 58% 58% 62% 62% 63% 

Mass Reduction - Level 3 MR3 15% 16% 18% 22% 25% 25% 27% 30% 34% 

Mass Reduction - Level 4 MR4 10% 10% 12% 15% 15% 16% 17% 19% 23% 

Mass Reduction - Level 5 MR5 4% 4% 4% 11% 12% 12% 13% 14% 18% 

Low Rolling Resistance Tires - Level 1 

ROLL1 96% 97% 98% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 20% 26% 42% 56% 78% 84% 87% 89% 91% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 88% 89% 89% 89% 89% 89% 90% 90% 90% 

Secondary Axle Disconnect SAX 17% 17% 17% 16% 16% 16% 16% 15% 15% 

Aero Drag Reduction, Level 1 

AERO1 95% 98% 99% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 52% 62% 76% 85% 90% 92% 93% 92% 92% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

612 

Total Cost = Total Benefits - Combined - 2010 Baseline 

Technology Abbr. MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Low Friction Lubricants - Level 1 LUB1 100% 100% 99% 99% 98% 98% 97% 97% 97% 

Engine Friction Reduction - Level 1 EFR1 77% 77% 76% 77% 77% 77% 76% 76% 75% 

Low Friction Lubricants and Engine Friction Reduction ­

Level 2 LUB2_EFR2 0% 0% 4% 12% 17% 17% 19% 26% 31% 

Variable Valve Timing (VVT) - Coupled Cam Phasing 

(CCP) on SOHC CCPS 19% 19% 18% 18% 18% 18% 18% 18% 18% 

Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 17% 18% 17% 17% 17% 17% 17% 17% 17% 

Cylinder Deactivation on SOHC DEACS 5% 4% 3% 3% 1% 1% 0% 0% 0% 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 2% 2% 1% 1% 1% 1% 1% 1% 1% 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 60% 60% 60% 57% 57% 57% 56% 56% 56% 

Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 28% 29% 29% 29% 29% 29% 29% 29% 29% 

Continuously Variable Valve Lift (CVVL) CVVL 21% 21% 20% 20% 20% 20% 20% 20% 20% 

Cylinder Deactivation on DOHC DEACD 5% 4% 2% 2% 0% 0% 0% 0% 0% 

Stoichiometric Gasoline Direct Injection (GDI) SGDI 65% 70% 75% 74% 77% 78% 78% 78% 78% 

Cylinder Deactivation on OHV DEACO 5% 4% 3% 2% 1% 1% 0% 0% 0% 

Variable Valve Actuation - CCP and DVVL on OHV VVA 7% 7% 7% 7% 7% 7% 7% 7% 7% 

Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 4% 4% 5% 7% 7% 7% 8% 8% 8% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) – 

Small Disp. TRBDS1_SD 31% 32% 35% 33% 31% 27% 22% 12% 10% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Medium Disp. 

TRBDS1_M 

D 24% 26% 28% 26% 23% 22% 21% 16% 12% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) ­

Large Disp. TRBDS1_LD 7% 8% 9% 10% 10% 10% 10% 10% 9% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Small Disp. TRBDS2_SD 0% 1% 0% 1% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Medium Disp. 

TRBDS2_M 

D 0% 0% 0% 0% 0% 0% 0% 0% 1% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) ­

Large Disp. TRBDS2_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 1 (24 bar BMEP) - Small Displacement CEGR1_SD 4% 4% 4% 6% 9% 13% 16% 24% 25% 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

613 

CEGR - Level 1 (24 bar BMEP) - Medium Displacement CEGR1_MD 4% 4% 5% 6% 9% 10% 12% 15% 17% 

CEGR - Level 1 (24 bar BMEP) - Large Displacement CEGR1_LD 0% 0% 0% 0% 0% 0% 0% 0% 1% 

CEGR - Level 2 (27 bar BMEP) - Small Displacement CEGR2_SD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

CEGR - Level 2 (27 bar BMEP) - Medium Displacement CEGR2_MD 0% 0% 0% 0% 1% 1% 1% 1% 1% 

CEGR - Level 2 (27 bar BMEP) - Large Displacement CEGR2_LD 0% 0% 0% 1% 2% 2% 3% 3% 3% 

Advanced Diesel - Small Displacement ADSL_SD 0% 0% 2% 3% 3% 3% 3% 3% 3% 

Advanced Diesel - Medium Displacement ADSL_MD 0% 0% 1% 2% 2% 2% 2% 2% 2% 

Advanced Diesel - Large Displacement ADSL_LD 0% 0% 0% 0% 0% 0% 0% 0% 0% 

6-Speed Manual/Improved Internals 6MAN 3% 3% 2% 1% 1% 1% 0% 0% 0% 

High Efficiency Gearbox (Manual) HETRANSM 0% 0% 1% 2% 2% 3% 3% 3% 3% 

Improved Auto. Trans. Controls/Externals IATC 30% 26% 14% 5% 1% 0% 0% 0% 0% 

6-Speed Trans with Improved Internals (Auto) NAUTO 37% 31% 18% 8% 2% 1% 0% 0% 0% 

6-speed DCT DCT 33% 27% 19% 9% 4% 3% 2% 1% 0% 

8-Speed Trans (Auto or DCT) 8SPD 19% 25% 25% 25% 18% 11% 7% 4% 4% 

High Efficiency Gearbox (Auto or DCT) HETRANS 1% 8% 25% 37% 42% 43% 48% 49% 48% 

Shift Optimizer SHFTOPT 0% 0% 19% 37% 58% 69% 75% 81% 81% 

Electric Power Steering EPS 90% 94% 94% 96% 96% 96% 96% 96% 96% 

Improved Accessories - Level 1 IACC1 78% 83% 90% 93% 94% 95% 96% 96% 96% 

Improved Accessories - Level 2 IACC2 18% 26% 35% 39% 48% 52% 55% 58% 62% 

12V Micro-Hybrid (Stop-Start) MHEV 33% 33% 39% 40% 39% 39% 36% 32% 30% 

Integrated Starter Generator ISG 8% 9% 11% 14% 17% 20% 22% 24% 25% 

Strong Hybrid - Level 1 SHEV1 2% 2% 1% 1% 1% 1% 1% 1% 1% 

Conversion from SHEV1 to SHEV2 SHEV1_2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Strong Hybrid - Level 2 SHEV2 0% 0% 0% 0% 1% 1% 3% 6% 8% 

Plug-in Hybrid - 30 mi range PHEV1 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Plug-in Hybrid PHEV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 75 mile range EV1 0% 0% 1% 1% 1% 1% 2% 2% 3% 

Electric Vehicle (Early Adopter) - 100 mile range EV2 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Early Adopter) - 150 mile range EV3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Electric Vehicle (Broad Market) - 150 mile range EV4 0% 0% 0% 0% 0% 0% 0% 1% 1% 
 

 

 

 

 

 

 

 

 

 

 

 

614 

Fuel Cell Vehicle FCV 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Mass Reduction - Level 1 MR1 64% 65% 68% 72% 74% 74% 74% 74% 74% 

Mass Reduction - Level 2 MR2 23% 33% 51% 57% 63% 64% 66% 67% 68% 

Mass Reduction - Level 3 MR3 11% 12% 15% 19% 23% 23% 27% 30% 35% 

Mass Reduction - Level 4 MR4 4% 5% 6% 11% 11% 12% 15% 17% 23% 

Mass Reduction - Level 5 MR5 0% 0% 1% 4% 5% 7% 9% 10% 13% 

Low Rolling Resistance Tires - Level 1 

ROLL1 95% 97% 98% 

100 

% 

100 

% 

100 

% 

100 

% 100% 100% 

Low Rolling Resistance Tires - Level 2 ROLL2 0% 0% 17% 36% 46% 55% 66% 81% 86% 

Low Rolling Resistance Tires - Level 3 ROLL3 0% 0% 0% 0% 0% 0% 0% 0% 0% 

Low Drag Brakes LDB 89% 90% 90% 90% 90% 90% 90% 90% 90% 

Secondary Axle Disconnect SAX 13% 13% 14% 14% 14% 14% 14% 13% 13% 

Aero Drag Reduction, Level 1 

AERO1 95% 97% 99% 99% 

100 

% 

100 

% 

100 

% 100% 100% 

Aero Drag Reduction, Level 2 AERO2 45% 55% 70% 81% 87% 88% 89% 91% 94% 
 

                                                       

 

615 

VI. MANUFACTURER CAFE CAPABILITIES 

Table VI-1 shows the agencies’ forecast of where the manufacturers’ passenger car mpg would 

be, based on the MY 2008 and MY 2010 baseline vehicles extended into the future with no fuel 

economy improvements based on application of additional technology. These mpg estimates 

change for some of the model years, but usually to a minimal extent, and only based on changes 

in sales forecasts between passenger cars and light trucks. 

Table VI-2 shows the ADJUSTED BASELINES for passenger cars. Note that when we do cost 

and benefit analyses, we use the ADJUSTED BASELINES throughout the analysis. The 

adjusted baseline takes each manufacturer’s MY 2008 and 2010 fleet and adds fuel economyimproving technologies to each, making both meet the MY 2016 fuel economy standard. The 

adjusted baselines assume for the analysis that each manufacturer below the MY 2016 standard 

applicable to that manufacturer in MY 2008 or MY 2010 (except for manufacturers that have 

historically paid fines for not fully complying with standards, which include Aston Martin, 

BMW, Daimler, Geely (Volvo), Lotus, Porsche, Spyker, Tata (Jaguar Land Rover), and 

Volkswagen) would apply technology to achieve the MY 2016 standard. We adjust the baseline 

because we believe that doing so is appropriate since the costs and benefits of achieving MY 

2016 mpg levels have already been analyzed and estimated in the previous analysis used to 

establish CAFE standards for MYs 2012-2016. The costs of these technologies are therefore not 

considered part of this rule, and we estimate the costs and benefits of going from the adjusted 

baseline to the level of the alternatives.349 

The estimated required standard levels are shown in Table VI-3 for passenger cars for the 

preferred alternative. The estimated average required mpg levels for cars and trucks under the 

standards include the expected performance of the manufacturer’s fleet based on calculations 

using the 2-cycle test and also the use of A/C efficiency improvements, but do not reflect a 

number of flexibilities and credits that manufacturers could use for compliance that NHTSA 

cannot consider in establishing standards based on EPCA/EISA constraints. The flexibilities and 

credits that NHTSA cannot consider include the ability of manufacturers to pay civil penalties 

rather than achieving required CAFE levels, the ability to use statutory FFV credits, the ability to 

count electric vehicles for compliance, the operation of plug-in hybrid electric vehicles on 

electricity for compliance prior to MY 2020, and the ability to transfer and carry-forward credits. 

Table VI-4 provides the estimated achieved mpg levels for passenger cars for each of the 

alternatives. The estimated average achieved mpg levels do reflect the accounting for the 

349 If a manufacturer’s MY 2008 or MY 2010 fleet extended mpg levels are above those of the alternative, its mpg 

is assumed to remain at that level. Some manufacturers’ levels go slightly above the required mpg level since some 

technologies are applied to all models of a particular manufacturer so that the exact level for each manufacturer may 

be slightly higher than the level of the standard and costs and benefits are estimated to that level. 
616 

flexibilities and credits mentioned above, and are based on the projections of what each 

manufacturer’s fleet will comprise in each year of the program. Tables VI-5 through VI-8 

provide the same tables for light trucks as Tables VI-1 through VI-4 show for passenger cars. 

Note that not all manufacturers are assumed to attempt to “meet” the alternatives for purposes of 

this analysis. EPCA/EISA allows manufacturers to pay civil penalties for non-compliance; 

essentially, to pay civil penalties instead of complying with the CAFE standards. Some 

manufacturers have historically chosen to do this instead of applying technology to improve their 

fuel economy, whether because civil penalties are cheaper for them than improving fuel 

economy, or because they would rather invest their money in other vehicle attributes that they 

believe their customers value more highly than fuel economy, or for some other reason. Other 

manufacturers may have found it more cost-effective to pay civil penalties than to apply 

technology, but may have chosen to apply technology anyway for other reasons – the Detroit 3 

manufacturers, for example, have historically avoided paying civil penalties. We assume that 

Aston Martin, BMW, Daimler, Geely, Lotus, Porsche, Spyker, Tata, and Volkswagen would not 

meet these levels because these manufacturers have shown, in the past, willingness to pay 

penalties rather than spend more money to apply technologies to improve the fuel economy of 

their products. Because NHTSA is attempting to analyze the impacts of the CAFE standards, 

and because the EPCA/EISA provision allowing payment of civil penalties continues indefinitely 

into the future, we are assuming for purposes of this analysis that these manufacturers will 

continue to pay civil penalties when the cost of doing so becomes cheaper than applying 

additional fuel economy-improving technology. 

The agency has performed an analysis of how manufacturers could respond to changes in the 

alternative CAFE levels. The analysis uses a technology application algorithm to systematically 

apply consistent cost and performance assumptions to the entire industry, as well as consistent 

assumptions regarding economic decision-making by manufacturers. The resulting computer 

model (the CAFE Compliance and Effects Model, often referred to as the “CAFE Model” or the 

“Volpe model”), developed by technical staff of the DOT Volpe National Transportation 

Systems Center in consultation with NHTSA staff, is used to help estimate the overall economic 

impact of the alternative CAFE standards. The CAFE model analysis shows the economic 

impact of the standards in terms of increases in new vehicle prices on a manufacturer-wide, 

industry-wide, and average per-vehicle basis. Based on these estimates and corresponding 

estimates of net economic and other benefits, the agency is able to consider alternatives that are 

economically practicable and technologically feasible. 

We note that, as explained above in Chapter V, the CAFE model has been updated to account for 

manufacturers’ ability to apply “multi-year planning” in order to minimize compliance burdens 

over multiple model years, and to account for manufacturers’ use of CAFE credits (when 

specified as a model input). The model has been peer reviewed. The model documentation, 
 

                                                      

617 

including a description of the input assumptions and process, as well as peer review reports, was 

made available in the rulemaking docket for the August 2005 NPRM, and updated 

documentation is also available on NHTSA’s website.350 

Our analyses of the potential effects of alternative CAFE standards were founded on two major 

elements: (1) projections of the technical characteristics and sales volumes of future product 

offerings and (2) estimates of the applicability and incremental cost and fuel savings associated 

with different hardware changes—technologies—that might be utilized in response to alternative 

CAFE standards. 

350 See Docket Nos. NHTSA-2005-22223-0003, NHTSA-2005-22223-0004 and NHTSA-2005-22223-0005, as well 

as NHTSA’s website at http://www.nhtsa.gov/Laws+&+Regulations/CAFE+­

+Fuel+Economy/CAFE+Compliance+and+Effects+Modeling+System:+The+Volpe+Model. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

618 

Table VI-1
 

Estimated Fuel Economy (mpg), Without CAFE Standards 

Passenger Cars
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

19.0 -

18.8 

BMW 2010 

2008 

27.5 -

27.2 

27.4 -

27.2 

27.4 -

27.2 

27.3 -

27.2 

27.3 -

27.2 

27.3 -

27.2 

27.3 -

27.2 

27.3 -

27.2 

27.3 -

27.2 

Daimler 2010 

2008 

24.7 -

25.1 

24.7 -

25.0 

24.8 -

24.9 

24.8 -

25.0 

24.8 -

25.1 

24.8 -

25.1 

24.8 -

25.1 

24.9 -

24.9 

24.9 -

25.0 

Fiat 2010 

2008 

28.2 -

28.2 

28.1 -

28.2 

28.1 -

28.3 

28.1 -

28.2 

28.1 -

28.3 

28.1 -

28.4 

28.1 -

28.4 

28.2 -

28.5 

28.2 -

28.5 

Ford 2010 

2008 

30.2 -

28.0 

30.2 -

28.0 

30.2 -

28.0 

30.3 -

28.0 

30.3 -

28.0 

30.3 -

28.0 

30.3 -

28.0 

30.3 -

28.0 

30.3 -

28.0 

Geely 2010 

2008 

28.2 -

26.0 

28.1 -

26.0 

28.1 -

26.0 

28.0 -

26.1 

28.0 -

26.1 

28.0 -

26.1 

28.0 -

26.1 

27.9 -

26.1 

27.9 -

26.1 

General Motors 2010 

2008 

30.4 -

28.5 

30.3 -

28.4 

30.3 -

28.4 

30.2 -

28.5 

30.2 -

28.6 

30.2 -

28.6 

30.2 -

28.6 

30.2 -

28.6 

30.1 -

28.6 

Honda 2010 

2008 

34.6 -

34.2 

34.7 -

34.3 

34.5 -

34.4 

34.5 -

34.4 

34.5 -

34.4 

34.5 -

34.4 

34.5 -

34.4 

34.5 -

34.4 

34.5 -

34.4 

Hyundai 2010 

2008 

33.0 -

31.4 

33.0 -

31.4 

33.0 -

31.4 

33.0 -

31.5 

33.0 -

31.5 

33.1 -

31.5 

33.1 -

31.5 

33.1 -

31.5 

33.1 -

31.6 

Kia 2010 

2008 

35.2 -

31.8 

35.2 -

31.9 

35.2 -

31.9 

35.2 -

32.0 

35.2 -

32.0 

35.2 -

32.1 

35.2 -

32.0 

35.3 -

32.1 

35.3 -

32.1 

Lotus 2010 

2008 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

26.7 -

29.7 

Mazda 2010 

2008 

31.9 -

31.4 

31.9 -

31.4 

31.9 -

31.4 

31.9 -

31.5 

31.9 -

31.6 

31.9 -

31.6 

31.9 -

31.7 

31.9 -

31.6 

31.9 -

31.6 

Mitsubishi 2010 

2008 

32.4 -

28.0 

32.3 -

28.0 

32.3 -

28.1 

32.4 -

28.1 

32.4 -

28.2 

32.4 -

28.2 

32.4 -

28.2 

32.4 -

28.2 

32.4 -

28.3 

Nissan 2010 

2008 

32.6 -

31.6 

32.6 -

31.6 

32.5 -

31.6 

32.5 -

31.6 

32.4 -

31.6 

32.4 -

31.5 

32.4 -

31.5 

32.4 -

31.5 

32.4 -

31.5 

Porsche 2010 

2008 

25.4 -

26.2 

25.4 -

26.2 

25.4 -

26.2 

25.4 -

26.2 

25.3 -

26.2 

25.3 -

26.2 

25.3 -

26.2 

25.3 -

26.2 

25.3 -

26.2 
 

 

 

 

 

 

 

 

 

619 

Spyker 2010 

2008 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

- ­

26.6 

Subaru 2010 

2008 

29.7 -

29.5 

29.7 -

29.5 

29.8 -

29.5 

29.8 -

29.5 

29.8 -

29.5 

29.9 -

29.5 

29.9 -

29.5 

29.9 -

29.5 

29.9 -

29.5 

Suzuki 2010 

2008 

33.1 -

30.7 

33.1 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

33.0 -

30.8 

Tata 2010 

2008 

23.3 -

24.6 

23.3 -

24.6 

23.3 -

24.6 

23.4 -

24.6 

23.4 -

24.6 

23.4 -

24.6 

23.4 -

24.6 

23.4 -

24.6 

23.4 -

24.6 

Tesla 2010 

2008 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

- ­

244.0 

Toyota 2010 

2008 

35.4 -

35.2 

35.5 -

35.2 

35.3 -

35.3 

35.3 -

35.3 

35.3 -

35.3 

35.3 -

35.4 

35.3 -

35.4 

35.3 -

35.4 

35.3 -

35.4 

Volkswagen 2010 

2008 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

31.9 -

28.9 

Total/Average 2010 

2008 

31.6 -

30.6 

31.6 -

30.6 

31.5 -

30.6 

31.5 -

30.6 

31.5 -

30.6 

31.5 -

30.6 

31.5 -

30.6 

31.5 -

30.6 

31.5 -

30.7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

620 

Table VI-2
 

Estimated Fuel Economy (mpg), Adjusted Baseline 

Passenger Cars
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.6 -

28.7 

25.6 -

28.7 

25.6 -

28.7 

25.6 -

28.7 

27.6 -

31.0 

27.6 -

31.0 

30.6 -

31.1 

33.6 -

31.1 

34.5 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

36.7 -

37.7 

37.4 -

37.9 

37.5 -

37.9 

37.6 -

37.9 

37.8 -

37.9 

37.9 -

38.0 

37.9 -

38.0 

37.8 -

38.0 

Daimler 2010 

2008 

33.5 -

35.5 

33.6 -

35.8 

34.7 -

36.4 

36.1 -

36.5 

36.2 -

36.6 

36.3 -

36.7 

36.3 -

37.1 

36.4 -

36.9 

36.4 -

36.9 

Fiat 2010 

2008 

36.7 -

37.1 

37.0 -

37.1 

37.2 -

37.1 

37.4 -

37.3 

37.5 -

37.7 

37.5 -

37.8 

37.5 -

37.9 

37.5 -

37.9 

37.5 -

37.9 

Ford 2010 

2008 

37.3 -

36.9 

37.3 -

36.9 

37.5 -

37.0 

38.0 -

37.5 

38.1 -

37.7 

38.1 -

37.7 

38.1 -

37.7 

38.2 -

37.6 

38.2 -

37.6 

Geely 2010 

2008 

37.1 -

35.4 

37.7 -

36.9 

37.6 -

37.3 

37.5 -

37.3 

37.5 -

37.5 

37.4 -

37.5 

37.4 -

37.5 

37.3 -

37.5 

37.3 -

37.5 

General Motors 2010 

2008 

37.1 -

37.5 

37.7 -

37.7 

37.7 -

37.7 

37.8 -

37.9 

37.8 -

38.3 

37.9 -

38.3 

37.8 -

38.3 

37.9 -

38.3 

37.9 -

38.4 

Honda 2010 

2008 

37.1 -

37.1 

37.6 -

38.2 

38.1 -

38.9 

38.1 -

39.0 

38.6 -

39.0 

38.7 -

39.0 

38.7 -

39.0 

38.7 -

39.0 

38.7 -

39.1 

Hyundai 2010 

2008 

37.8 -

38.2 

38.2 -

38.2 

38.2 -

38.8 

38.3 -

38.9 

38.4 -

39.0 

38.4 -

39.0 

38.5 -

39.0 

38.5 -

39.0 

38.5 -

39.0 

Kia 2010 

2008 

38.1 -

38.2 

39.1 -

39.3 

39.1 -

39.6 

39.4 -

39.7 

39.5 -

39.7 

39.5 -

39.8 

39.5 -

39.8 

39.5 -

39.8 

39.5 -

39.9 

Lotus 2010 

2008 

33.1 -

37.0 

33.1 -

37.0 

35.5 -

39.6 

35.5 -

39.6 

35.5 -

39.6 

35.5 -

39.6 

39.3 -

41.5 

39.3 -

41.5 

39.3 -

41.5 

Mazda 2010 

2008 

38.2 -

39.2 

38.2 -

39.5 

38.2 -

39.6 

38.3 -

40.0 

38.2 -

40.1 

38.4 -

40.1 

38.4 -

40.2 

38.4 -

40.2 

38.5 -

40.2 

Mitsubishi 2010 

2008 

40.1 -

38.2 

40.1 -

38.3 

40.1 -

38.4 

40.1 -

38.5 

40.3 -

39.1 

40.3 -

39.1 

40.4 -

39.1 

40.4 -

39.1 

40.4 -

39.1 

Nissan 2010 

2008 

37.0 -

37.3 

37.1 -

37.6 

37.8 -

38.2 

38.1 -

38.3 

38.1 -

38.3 

38.1 -

38.3 

38.1 -

38.3 

38.1 -

38.3 

38.1 -

38.3 

Porsche 2010 

2008 

33.3 -

34.3 

34.8 -

35.3 

36.5 -

35.3 

36.5 -

35.4 

36.5 -

37.0 

36.5 -

40.0 

36.5 -

40.0 

36.5 -

41.4 

36.4 -

41.4 
 

 

 

 

 

 

 

 

 

621 

Spyker 2010 

2008 

- ­

36.3 

- ­

38.1 

- ­

39.6 

- ­

39.6 

- ­

39.6 

- ­

39.6 

- ­

39.6 

- ­

39.6 

- ­

39.6 

Subaru 2010 

2008 

39.4 -

40.1 

39.3 -

40.2 

39.4 -

40.2 

39.4 -

41.6 

39.4 -

41.6 

39.5 -

41.6 

39.5 -

41.6 

39.5 -

41.6 

39.5 -

41.5 

Suzuki 2010 

2008 

39.8 -

40.1 

39.8 -

40.2 

40.3 -

41.8 

40.6 -

42.0 

40.8 -

42.0 

40.8 -

42.1 

40.8 -

42.1 

40.8 -

42.1 

40.8 -

42.1 

Tata 2010 

2008 

30.3 -

35.0 

34.5 -

35.4 

34.3 -

35.4 

36.2 -

35.5 

36.9 -

35.6 

36.9 -

35.6 

36.9 -

35.6 

37.0 -

35.6 

37.0 -

35.6 

Tesla 2010 

2008 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

- ­

281.2 

Toyota 2010 

2008 

37.9 -

38.3 

38.4 -

38.4 

38.2 -

38.7 

38.4 -

39.1 

38.3 -

39.2 

38.4 -

39.2 

38.4 -

39.2 

38.4 -

39.3 

38.4 -

39.3 

Volkswagen 2010 

2008 

38.0 -

37.8 

38.6 -

38.6 

38.8 -

39.6 

39.0 -

39.9 

39.0 -

39.9 

39.0 -

39.9 

39.0 -

39.9 

39.1 -

39.8 

39.1 -

39.9 

Total/Average 2010 

2008 

37.2 -

37.5 

37.7 -

38.0 

37.9 -

38.3 

38.1 -

38.6 

38.2 -

38.7 

38.2 -

38.8 

38.2 -

38.8 

38.2 -

38.8 

38.2 -

38.8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

622 

Table VI-3
 

Estimated Required Fuel Economy Levels for Preferred Alternative 

Estimated mpg 

Passenger Cars
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

38.8 -

40.5 

40.2 -

41.9 

41.6 -

43.5 

43.3 -

45.2 

45.1 -

47.2 

47.3 -

49.4 

49.5 -

51.7 

51.8 -

54.1 

54.2 -

56.6 

BMW 2010 

2008 

39.4 -

39.4 

40.8 -

40.9 

42.3 -

42.4 

43.9 -

44.1 

45.8 -

46.0 

47.9 -

48.1 

50.1 -

50.4 

52.5 -

52.7 

55.0 -

55.2 

Daimler 2010 

2008 

38.0 -

38.6 

39.4 -

39.9 

40.9 -

41.4 

42.5 -

43.0 

44.3 -

44.9 

46.4 -

47.0 

48.5 -

49.2 

50.9 -

51.4 

53.2 -

53.9 

Fiat 2010 

2008 

38.7 -

39.1 

39.9 -

40.6 

41.4 -

42.1 

43.0 -

43.7 

44.9 -

45.7 

47.0 -

47.9 

49.2 -

50.2 

51.6 -

52.6 

54.0 -

55.1 

Ford 2010 

2008 

39.5 -

39.1 

41.0 -

40.6 

42.5 -

42.1 

44.1 -

43.7 

46.0 -

45.6 

48.2 -

47.7 

50.4 -

49.9 

52.8 -

52.3 

55.3 -

54.7 

Geely 2010 

2008 

40.1 -

38.8 

41.5 -

40.3 

43.0 -

41.7 

44.7 -

43.4 

46.6 -

45.3 

48.7 -

47.4 

50.9 -

49.6 

53.3 -

51.9 

55.8 -

54.4 

General Motors 2010 

2008 

39.3 -

39.6 

40.8 -

41.1 

42.2 -

42.6 

43.9 -

44.3 

45.7 -

46.2 

47.9 -

48.4 

50.1 -

50.7 

52.5 -

53.1 

54.9 -

55.6 

Honda 2010 

2008 

39.7 -

40.4 

41.1 -

41.9 

42.6 -

43.4 

44.2 -

45.2 

46.1 -

47.1 

48.3 -

49.3 

50.5 -

51.6 

52.9 -

54.0 

55.4 -

56.6 

Hyundai 2010 

2008 

39.8 -

40.4 

41.3 -

41.9 

42.7 -

43.4 

44.5 -

45.2 

46.4 -

47.1 

48.6 -

49.3 

50.8 -

51.6 

53.2 -

54.1 

55.7 -

56.6 

Kia 2010 

2008 

40.8 -

41.1 

42.3 -

42.6 

43.8 -

44.2 

45.6 -

46.0 

47.5 -

48.0 

49.8 -

50.3 

52.1 -

52.6 

54.5 -

55.1 

57.1 -

57.7 

Lotus 2010 

2008 

41.8 -

43.6 

43.3 -

45.2 

44.9 -

46.9 

46.7 -

48.7 

48.7 -

50.8 

51.0 -

53.2 

53.4 -

55.7 

55.9 -

58.3 

58.5 -

61.1 

Mazda 2010 

2008 

40.1 -

41.5 

41.6 -

43.0 

43.0 -

44.5 

44.7 -

46.3 

46.6 -

48.3 

48.8 -

50.6 

51.1 -

53.0 

53.5 -

55.5 

56.0 -

58.1 

Mitsubishi 2010 

2008 

41.8 -

40.5 

43.3 -

42.0 

44.9 -

43.6 

46.7 -

45.3 

48.7 -

47.3 

51.0 -

49.5 

53.4 -

51.8 

55.9 -

54.2 

58.6 -

56.8 

Nissan 2010 

2008 

39.6 -

39.8 

41.0 -

41.2 

42.5 -

42.8 

44.2 -

44.4 

46.0 -

46.3 

48.2 -

48.5 

50.4 -

50.7 

52.8 -

53.1 

55.2 -

55.6 

Porsche 2010 

2008 

39.1 -

43.6 

40.5 -

45.2 

42.0 -

46.9 

43.6 -

48.7 

45.4 -

50.8 

47.5 -

53.2 

49.7 -

55.7 

52.1 -

58.3 

54.5 -

61.1 
 

 

 

 

 

 

 

 

 

623 

Spyker 2010 

2008 

- ­

41.1 

- ­

42.6 

- ­

44.2 

- ­

46.0 

- ­

47.9 

- ­

50.2 

- ­

52.5 

- ­

55.0 

- ­

57.6 

Subaru 2010 

2008 

41.1 -

42.6 

42.6 -

44.2 

44.1 -

45.8 

45.8 -

47.6 

47.7 -

49.7 

49.9 -

52.0 

52.2 -

54.4 

54.7 -

57.0 

57.2 -

59.6 

Suzuki 2010 

2008 

42.1 -

43.3 

43.6 -

44.9 

45.2 -

46.5 

46.9 -

48.4 

48.9 -

50.5 

51.2 -

52.8 

53.6 -

55.3 

56.1 -

57.9 

58.7 -

60.6 

Tata 2010 

2008 

37.4 -

36.9 

38.8 -

38.3 

40.4 -

39.7 

41.9 -

41.2 

43.8 -

43.0 

45.9 -

45.0 

48.0 -

47.1 

50.3 -

49.3 

52.7 -

51.7 

Tesla 2010 

2008 

- ­

43.6 

- ­

45.2 

- ­

46.9 

- ­

48.7 

- ­

50.8 

- ­

53.2 

- ­

55.7 

- ­

58.3 

- ­

61.1 

Toyota 2010 

2008 

39.7 -

40.6 

41.2 -

42.1 

42.7 -

43.7 

44.3 -

45.4 

46.2 -

47.4 

48.4 -

49.6 

50.7 -

51.9 

53.0 -

54.3 

55.5 -

56.9 

Volkswagen 2010 

2008 

40.5 -

41.4 

41.9 -

43.0 

43.5 -

44.5 

45.2 -

46.3 

47.1 -

48.3 

49.3 -

50.6 

51.6 -

52.9 

54.1 -

55.4 

56.6 -

58.0 

Total/Average 2010 

2008 

39.6 -

40.1 

41.1 -

41.6 

42.5 -

43.1 

44.2 -

44.8 

46.1 -

46.8 

48.2 -

49.0 

50.5 -

51.2 

52.9 -

53.6 

55.3 -

56.2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

624 

Table VI-4
 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

Preferred Alternative
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

39.0 

36.4 -

39.4 

37.8 -

40.6 

40.9 -

42.9 

41.0 -

42.7 

43.1 -

45.7 

Fiat 2010 

2008 

38.6 -

38.9 

39.4 -

41.3 

42.3 -

41.6 

44.8 -

46.4 

47.7 -

47.1 

48.0 -

48.1 

50.3 -

51.1 

51.6 -

51.6 

51.6 -

53.7 

Ford 2010 

2008 

39.8 -

39.4 

39.9 -

39.7 

42.1 -

42.2 

46.1 -

45.0 

47.2 -

47.2 

48.7 -

49.5 

49.4 -

50.0 

51.3 -

49.9 

52.4 -

54.1 

Geely 2010 

2008 

37.2 -

36.4 

38.9 -

39.4 

43.5 -

42.2 

44.4 -

42.3 

44.7 -

43.5 

44.7 -

43.5 

45.7 -

44.4 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

39.6 -

38.9 

42.5 -

42.5 

43.1 -

43.8 

45.6 -

47.8 

47.2 -

49.3 

47.2 -

49.3 

50.3 -

50.5 

51.2 -

50.7 

52.8 -

51.4 

Honda 2010 

2008 

39.0 -

40.0 

43.3 -

44.1 

44.5 -

46.3 

44.6 -

46.8 

48.4 -

50.5 

48.9 -

51.9 

52.2 -

53.3 

53.1 -

54.1 

53.1 -

54.2 

Hyundai 2010 

2008 

41.6 -

41.6 

42.3 -

42.1 

44.9 -

47.7 

44.9 -

48.2 

48.2 -

50.2 

50.7 -

52.2 

51.5 -

52.7 

53.0 -

52.7 

53.7 -

52.8 

Kia 2010 

2008 

40.7 -

40.6 

41.6 -

40.9 

45.2 -

44.6 

48.0 -

50.0 

49.3 -

50.4 

52.3 -

51.8 

52.9 -

52.3 

52.9 -

52.3 

52.9 -

55.7 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

42.0 -

41.8 

42.7 -

43.7 

43.3 -

43.8 

47.2 -

47.5 

47.3 -

47.5 

51.1 -

52.8 

52.6 -

53.0 

52.9 -

53.3 

52.9 -

53.8 

Mitsubishi 2010 

2008 

42.5 -

39.4 

43.1 -

41.1 

43.1 -

41.2 

48.0 -

45.8 

54.1 -

51.6 

54.6 -

51.7 

54.6 -

51.7 

55.0 -

53.7 

55.1 -

53.7 

Nissan 2010 

2008 

40.6 -

38.9 

41.7 -

40.6 

45.5 -

45.6 

45.8 -

46.7 

47.0 -

47.3 

48.6 -

50.3 

49.4 -

51.2 

52.5 -

53.7 

53.2 -

54.0 
 

 

 

 

 

 

 

 

 

 

625 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

39.6 -

41.8 

39.6 -

43.1 

43.0 -

44.0 

49.4 -

50.0 

49.5 -

50.0 

49.5 -

50.0 

50.1 -

50.0 

54.5 -

50.4 

57.2 -

60.6 

Suzuki 2010 

2008 

44.3 -

41.9 

44.3 -

42.0 

47.5 -

50.3 

48.4 -

51.2 

50.5 -

52.7 

51.9 -

53.7 

52.9 -

53.7 

52.9 -

54.4 

57.2 -

58.2 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.3 

34.4 -

39.3 

36.3 -

40.5 

37.1 -

41.1 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.4 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

40.1 -

40.9 

41.4 -

42.9 

45.8 -

45.3 

46.6 -

47.6 

49.6 -

49.4 

50.1 -

50.1 

50.1 -

50.1 

53.0 -

54.9 

53.0 -

55.0 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.3 -

40.1 

44.2 -

44.1 

45.1 -

44.8 

45.7 -

45.6 

46.0 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

39.4 -

39.5 

41.1 -

41.5 

43.3 -

43.8 

45.1 -

46.3 

47.1 -

47.9 

48.1 -

49.3 

49.6 -

50.0 

51.3 -

51.5 

52.1 -

52.9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

626 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

2% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

45.6 

44.2 -

45.6 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

39.0 

36.4 -

39.4 

37.8 -

40.6 

40.9 -

42.9 

40.9 -

42.7 

43.0 -

44.2 

Fiat 2010 

2008 

38.4 -

38.2 

38.6 -

40.0 

39.7 -

40.1 

41.6 -

42.7 

42.4 -

42.9 

42.5 -

43.2 

43.6 -

44.6 

43.8 -

44.8 

43.9 -

44.8 

Ford 2010 

2008 

38.5 -

38.7 

38.6 -

38.8 

40.1 -

40.2 

43.3 -

42.1 

43.7 -

43.1 

44.6 -

43.6 

44.8 -

43.7 

45.4 -

44.0 

45.4 -

44.0 

Geely 2010 

2008 

37.2 -

36.4 

38.9 -

39.0 

43.0 -

41.4 

43.6 -

41.6 

43.7 -

42.2 

43.7 -

42.2 

44.7 -

43.6 

46.0 -

44.9 

46.4 -

45.0 

General Motors 2010 

2008 

37.1 -

38.5 

38.9 -

40.0 

39.1 -

40.7 

40.9 -

42.1 

42.7 -

43.0 

42.9 -

43.2 

43.3 -

45.0 

43.4 -

45.6 

43.6 -

46.3 

Honda 2010 

2008 

38.3 -

39.1 

41.0 -

41.7 

41.6 -

42.2 

41.8 -

42.4 

42.0 -

43.9 

42.5 -

44.2 

44.9 -

45.5 

45.2 -

46.1 

45.4 -

46.5 

Hyundai 2010 

2008 

39.4 -

40.5 

40.0 -

41.0 

40.4 -

43.1 

40.8 -

43.2 

43.2 -

44.4 

43.8 -

45.8 

44.3 -

46.2 

45.7 -

47.5 

45.8 -

47.6 

Kia 2010 

2008 

40.1 -

39.9 

41.2 -

40.9 

42.6 -

41.7 

44.0 -

43.4 

44.4 -

45.1 

44.8 -

45.8 

45.2 -

46.8 

45.3 -

46.9 

47.2 -

46.9 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

40.7 -

39.8 

41.0 -

41.5 

41.1 -

42.0 

42.4 -

44.7 

42.6 -

44.7 

44.7 -

46.7 

45.2 -

46.8 

45.3 -

46.7 

45.3 -

46.7 

Mitsubishi 2010 

2008 

41.2 -

39.3 

41.5 -

39.6 

41.5 -

39.7 

44.1 -

41.0 

46.5 -

44.7 

46.8 -

44.8 

46.8 -

44.8 

47.3 -

45.1 

47.4 -

45.3 

Nissan 2010 

2008 

38.7 -

38.6 

39.1 -

39.6 

42.1 -

42.4 

43.1 -

43.0 

43.1 -

43.2 

43.4 -

43.6 

43.9 -

43.9 

47.1 -

46.3 

47.1 -

46.7 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

627 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

46.7 

- ­

46.7 

Subaru 2010 

2008 

39.5 -

41.8 

39.4 -

42.2 

41.4 -

46.4 

45.3 -

46.8 

45.3 -

46.6 

45.7 -

46.5 

45.8 -

46.4 

46.2 -

46.6 

46.2 -

47.3 

Suzuki 2010 

2008 

42.4 -

41.2 

42.4 -

41.4 

43.8 -

46.3 

44.4 -

46.6 

45.6 -

47.3 

46.9 -

47.7 

47.0 -

47.7 

47.0 -

48.0 

48.3 -

49.8 

Tata 2010 

2008 

30.3 -

36.1 

34.5 -

38.8 

34.4 -

38.8 

36.3 -

39.1 

37.1 -

39.7 

37.1 -

41.3 

38.7 -

42.0 

38.7 -

42.0 

39.3 -

42.3 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

39.0 -

39.5 

40.0 -

40.8 

41.8 -

42.2 

42.2 -

43.6 

43.5 -

44.4 

43.8 -

45.1 

43.8 -

45.1 

45.3 -

46.5 

45.4 -

46.8 

Volkswagen 2010 

2008 

38.6 -

37.9 

41.3 -

38.7 

41.9 -

40.1 

43.3 -

43.7 

43.8 -

44.3 

44.2 -

45.0 

44.7 -

45.5 

45.7 -

45.6 

46.9 -

46.2 

Total/Average 2010 

2008 

38.2 -

38.8 

39.4 -

40.1 

40.5 -

41.4 

41.8 -

42.7 

42.8 -

43.6 

43.3 -

44.2 

44.0 -

44.9 

44.9 -

45.8 

45.2 -

46.2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

628 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

3% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

39.0 

36.4 -

39.4 

37.8 -

40.6 

40.9 -

42.9 

40.9 -

42.7 

43.0 -

45.7 

Fiat 2010 

2008 

38.7 -

38.8 

39.1 -

40.9 

41.3 -

41.0 

43.8 -

45.5 

45.0 -

46.0 

45.2 -

46.4 

46.8 -

47.6 

47.7 -

47.8 

47.7 -

47.8 

Ford 2010 

2008 

40.1 -

39.1 

40.3 -

40.0 

42.3 -

41.8 

45.3 -

43.9 

45.8 -

45.0 

46.6 -

46.4 

46.8 -

47.0 

47.5 -

47.6 

50.4 -

48.5 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.2 

42.9 -

41.7 

43.6 -

41.8 

44.9 -

43.4 

44.9 -

43.4 

45.7 -

44.3 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

37.6 -

38.9 

39.7 -

42.1 

40.1 -

42.9 

43.9 -

46.1 

45.6 -

47.4 

45.6 -

47.5 

46.7 -

47.7 

47.3 -

48.5 

47.6 -

48.5 

Honda 2010 

2008 

39.3 -

39.8 

43.1 -

43.2 

44.1 -

44.0 

44.2 -

44.4 

44.6 -

46.7 

45.3 -

48.1 

50.0 -

49.0 

50.8 -

50.1 

50.8 -

50.4 

Hyundai 2010 

2008 

41.1 -

41.2 

41.7 -

41.7 

43.2 -

45.9 

44.5 -

46.1 

45.8 -

47.3 

48.0 -

48.4 

48.7 -

48.5 

50.9 -

48.5 

51.0 -

48.5 

Kia 2010 

2008 

39.8 -

39.9 

41.0 -

40.0 

43.9 -

43.1 

46.3 -

47.3 

47.2 -

48.6 

49.2 -

49.4 

49.5 -

49.7 

49.5 -

49.8 

51.2 -

50.7 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

40.7 -

40.6 

41.3 -

42.4 

41.4 -

42.4 

44.1 -

45.5 

44.1 -

45.5 

48.0 -

50.1 

48.9 -

50.4 

49.1 -

50.6 

49.9 -

50.9 

Mitsubishi 2010 

2008 

41.7 -

39.6 

42.3 -

40.7 

42.3 -

40.8 

44.7 -

43.8 

49.7 -

47.9 

50.2 -

48.0 

50.2 -

48.0 

51.1 -

49.6 

51.1 -

49.6 

Nissan 2010 

2008 

38.6 -

38.8 

39.0 -

39.7 

43.7 -

44.2 

44.5 -

44.8 

44.9 -

45.4 

46.4 -

47.6 

47.7 -

48.9 

51.0 -

50.1 

51.6 -

50.3 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

629 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

39.5 -

40.9 

39.4 -

41.9 

42.2 -

42.8 

47.5 -

49.3 

47.6 -

49.2 

48.1 -

49.2 

48.2 -

49.2 

52.0 -

49.2 

52.0 -

61.1 

Suzuki 2010 

2008 

42.6 -

43.1 

42.7 -

43.3 

45.5 -

49.2 

47.4 -

49.7 

48.9 -

52.0 

49.8 -

52.0 

49.8 -

52.1 

50.0 -

52.0 

54.0 -

52.1 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.6 

34.4 -

39.6 

36.3 -

40.2 

37.1 -

40.8 

37.1 -

42.1 

38.7 -

44.3 

38.7 -

44.3 

39.3 -

44.7 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

40.0 -

40.3 

41.4 -

42.4 

43.7 -

44.7 

44.3 -

46.9 

45.8 -

47.7 

46.2 -

48.3 

46.4 -

48.6 

50.7 -

48.6 

50.7 -

48.7 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.5 -

38.7 

42.1 -

40.1 

44.0 -

44.0 

44.9 -

44.7 

45.4 -

45.5 

45.8 -

46.0 

47.8 -

46.2 

50.2 -

48.4 

Total/Average 2010 

2008 

38.9 -

39.2 

40.3 -

41.1 

42.1 -

42.9 

43.9 -

45.1 

44.9 -

46.1 

45.8 -

47.2 

47.0 -

47.7 

48.7 -

48.4 

49.5 -

49.1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

630 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

4% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

39.0 

36.4 -

39.4 

37.8 -

40.6 

40.9 -

42.9 

40.9 -

42.7 

43.0 -

45.7 

Fiat 2010 

2008 

39.6 -

39.1 

40.2 -

41.9 

42.9 -

42.1 

45.9 -

47.7 

47.8 -

48.4 

48.3 -

49.4 

51.0 -

52.4 

52.2 -

53.2 

53.4 -

53.2 

Ford 2010 

2008 

39.9 -

39.9 

40.1 -

40.8 

42.2 -

42.5 

47.4 -

46.1 

48.5 -

47.9 

50.4 -

49.5 

50.6 -

50.3 

51.3 -

51.0 

55.5 -

54.9 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.6 -

42.2 

44.5 -

42.3 

44.9 -

43.5 

44.9 -

43.5 

45.8 -

44.3 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

39.1 -

39.2 

41.4 -

42.9 

42.1 -

44.3 

46.9 -

48.1 

48.9 -

49.6 

48.9 -

49.8 

51.0 -

51.3 

51.8 -

51.3 

54.9 -

51.3 

Honda 2010 

2008 

39.4 -

40.6 

44.1 -

45.5 

45.5 -

46.8 

45.6 -

47.2 

49.5 -

51.8 

50.0 -

53.3 

53.0 -

54.6 

53.9 -

55.4 

54.2 -

56.9 

Hyundai 2010 

2008 

41.8 -

42.4 

42.5 -

43.0 

45.4 -

46.9 

46.5 -

47.2 

49.0 -

49.0 

51.4 -

50.3 

51.9 -

50.5 

53.7 -

55.2 

54.8 -

56.3 

Kia 2010 

2008 

41.9 -

41.4 

42.5 -

41.6 

46.6 -

45.7 

49.7 -

50.9 

50.7 -

51.8 

53.6 -

52.6 

54.0 -

53.8 

54.1 -

53.9 

54.1 -

56.2 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

42.3 -

42.7 

42.9 -

44.9 

43.3 -

44.9 

47.4 -

47.5 

47.4 -

47.5 

51.4 -

54.4 

53.2 -

55.5 

53.5 -

55.9 

53.5 -

56.0 

Mitsubishi 2010 

2008 

41.4 -

40.1 

41.8 -

41.3 

41.8 -

41.4 

49.9 -

45.3 

54.6 -

51.0 

55.0 -

51.0 

55.0 -

51.1 

55.1 -

52.1 

55.1 -

57.2 

Nissan 2010 

2008 

41.4 -

40.3 

42.1 -

41.7 

46.4 -

46.7 

46.8 -

47.6 

48.9 -

48.5 

50.0 -

49.5 

51.3 -

51.9 

53.1 -

54.3 

53.8 -

55.0 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

631 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

39.8 -

41.5 

39.7 -

43.2 

44.4 -

44.1 

50.0 -

50.4 

49.9 -

50.4 

49.9 -

50.3 

50.4 -

50.3 

51.5 -

50.9 

53.3 -

62.6 

Suzuki 2010 

2008 

42.5 -

43.8 

42.5 -

44.0 

48.2 -

50.7 

51.1 -

51.4 

54.2 -

54.3 

54.2 -

54.3 

54.4 -

54.3 

54.3 -

55.3 

54.3 -

58.8 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.7 

37.1 -

41.2 

37.1 -

42.3 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

40.2 -

41.2 

42.0 -

43.4 

46.5 -

46.3 

47.4 -

48.4 

50.9 -

50.2 

51.7 -

51.7 

51.7 -

51.7 

53.5 -

54.6 

54.0 -

55.0 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

39.6 -

39.9 

41.3 -

42.2 

43.6 -

44.3 

46.1 -

46.8 

48.1 -

48.5 

49.2 -

49.7 

50.5 -

50.7 

51.7 -

52.2 

53.3 -

53.6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

632 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

5% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

39.4 -

40.2 

40.4 -

42.2 

44.7 -

42.8 

49.1 -

49.9 

51.2 -

51.4 

52.3 -

52.7 

54.2 -

57.9 

54.6 -

58.6 

63.1 -

58.6 

Ford 2010 

2008 

41.1 -

39.9 

41.4 -

41.3 

44.1 -

43.3 

49.9 -

49.2 

51.5 -

51.7 

53.7 -

53.3 

54.4 -

53.4 

54.6 -

54.0 

60.0 -

54.5 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.2 

44.5 -

42.3 

44.9 -

43.5 

44.9 -

43.5 

45.8 -

44.3 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

39.9 -

40.1 

43.0 -

43.9 

43.7 -

45.4 

48.5 -

49.5 

50.4 -

52.5 

50.7 -

52.7 

53.5 -

54.3 

55.6 -

56.4 

60.7 -

58.7 

Honda 2010 

2008 

40.6 -

41.7 

46.5 -

46.5 

48.0 -

48.3 

48.1 -

49.0 

51.5 -

54.1 

52.1 -

55.0 

58.3 -

59.1 

60.0 -

60.9 

60.8 -

62.3 

Hyundai 2010 

2008 

42.6 -

42.1 

43.4 -

42.7 

47.2 -

49.3 

48.4 -

50.3 

51.3 -

52.0 

54.9 -

55.2 

55.4 -

55.5 

59.7 -

61.0 

60.1 -

61.4 

Kia 2010 

2008 

42.6 -

41.9 

43.4 -

42.0 

49.1 -

44.8 

52.6 -

52.3 

53.3 -

55.0 

58.1 -

57.3 

58.4 -

59.7 

58.7 -

59.8 

58.7 -

59.9 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

42.7 -

43.9 

43.6 -

46.5 

44.1 -

46.5 

48.4 -

50.0 

48.7 -

50.0 

54.9 -

57.3 

57.6 -

58.4 

58.2 -

60.8 

59.2 -

64.1 

Mitsubishi 2010 

2008 

42.6 -

40.6 

42.7 -

41.9 

42.8 -

42.0 

51.0 -

55.0 

54.9 -

61.0 

55.3 -

61.4 

55.3 -

61.7 

55.4 -

61.5 

76.4 -

61.7 

Nissan 2010 

2008 

41.9 -

40.7 

43.1 -

42.7 

48.8 -

48.9 

49.6 -

49.8 

50.0 -

51.0 

51.2 -

52.9 

52.4 -

54.3 

57.9 -

60.2 

61.3 -

61.2 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

633 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

40.6 -

42.5 

41.0 -

44.3 

45.7 -

45.2 

51.8 -

49.7 

51.8 -

49.7 

51.8 -

49.9 

52.6 -

49.9 

53.8 -

50.0 

55.3 -

69.6 

Suzuki 2010 

2008 

43.3 -

45.1 

43.3 -

45.4 

49.4 -

52.6 

53.4 -

53.1 

55.8 -

58.9 

56.2 -

59.0 

56.2 -

59.0 

56.4 -

59.0 

64.3 -

68.7 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.7 

37.1 -

41.2 

37.1 -

42.3 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

41.0 -

42.0 

42.5 -

44.7 

48.5 -

47.6 

49.7 -

50.8 

53.7 -

53.7 

54.7 -

54.9 

54.7 -

54.9 

58.5 -

58.4 

58.7 -

61.6 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

40.2 -

40.5 

42.3 -

42.9 

45.3 -

45.3 

48.0 -

48.6 

50.0 -

50.9 

51.4 -

52.3 

53.2 -

53.5 

55.4 -

55.8 

58.3 -

57.8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

634 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

6% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.5 

38.0 -

39.5 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

40.1 -

40.5 

41.3 -

43.1 

45.6 -

43.7 

49.7 -

51.4 

51.4 -

53.6 

51.8 -

57.1 

52.7 -

60.0 

58.2 -

64.3 

59.8 -

65.5 

Ford 2010 

2008 

42.0 -

41.0 

42.5 -

42.5 

45.1 -

44.4 

50.7 -

48.0 

52.0 -

50.1 

52.7 -

57.7 

52.8 -

57.7 

61.7 -

64.7 

65.9 -

65.3 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.2 

44.5 -

42.3 

44.9 -

43.5 

44.9 -

43.5 

45.8 -

44.3 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

41.3 -

40.5 

44.9 -

44.7 

45.8 -

46.4 

49.4 -

50.7 

54.0 -

59.2 

54.3 -

59.6 

60.2 -

59.5 

61.3 -

60.6 

64.6 -

67.2 

Honda 2010 

2008 

40.8 -

43.1 

47.1 -

48.3 

49.1 -

50.4 

49.2 -

51.0 

54.4 -

55.7 

55.1 -

56.7 

63.4 -

61.9 

64.9 -

63.0 

67.5 -

69.1 

Hyundai 2010 

2008 

44.7 -

44.0 

45.5 -

44.6 

50.0 -

51.3 

50.7 -

52.4 

55.0 -

54.3 

58.9 -

58.3 

61.0 -

59.8 

63.7 -

63.0 

63.8 -

63.1 

Kia 2010 

2008 

43.5 -

42.6 

44.2 -

42.7 

50.1 -

45.9 

55.4 -

54.4 

56.7 -

57.8 

63.1 -

59.5 

63.8 -

60.6 

64.2 -

60.7 

64.2 -

72.9 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

44.2 -

44.3 

45.4 -

46.7 

45.9 -

47.6 

50.6 -

50.3 

51.1 -

50.6 

55.3 -

62.1 

56.2 -

62.9 

56.3 -

62.8 

63.2 -

79.4 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.5 -

41.9 

44.5 -

42.0 

49.2 -

55.2 

60.1 -

59.6 

60.5 -

60.0 

60.6 -

60.3 

60.5 -

61.0 

67.3 -

66.2 

Nissan 2010 

2008 

40.1 -

42.9 

41.3 -

45.7 

51.3 -

50.3 

52.0 -

51.3 

52.6 -

51.8 

55.2 -

55.0 

60.6 -

63.6 

62.7 -

66.4 

67.3 -

67.1 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

635 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

40.7 -

42.6 

41.2 -

44.4 

46.0 -

45.0 

52.8 -

50.2 

52.8 -

50.2 

52.8 -

50.3 

53.4 -

50.3 

54.6 -

54.2 

55.8 -

70.9 

Suzuki 2010 

2008 

43.7 -

46.7 

43.7 -

47.0 

50.2 -

51.4 

53.6 -

51.8 

56.0 -

53.8 

56.2 -

54.0 

56.2 -

54.0 

56.4 -

66.4 

72.2 -

74.5 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

41.4 -

42.1 

43.2 -

45.0 

49.9 -

48.7 

51.4 -

53.6 

56.0 -

56.0 

57.2 -

58.0 

57.3 -

58.1 

64.9 -

63.7 

67.1 -

69.2 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

40.8 -

41.2 

43.0 -

43.9 

46.6 -

46.3 

49.1 -

49.7 

52.0 -

52.5 

53.3 -

55.1 

55.8 -

56.7 

59.6 -

59.8 

62.2 -

63.9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

636 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

7% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.4 

38.0 -

39.4 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

40.8 -

41.3 

42.1 -

44.1 

46.6 -

44.7 

49.3 -

52.5 

50.9 -

54.4 

51.9 -

57.2 

59.0 -

64.1 

59.6 -

69.1 

72.0 -

69.7 

Ford 2010 

2008 

42.7 -

41.6 

43.3 -

43.8 

45.6 -

45.2 

50.8 -

48.8 

51.9 -

51.5 

53.3 -

52.2 

53.3 -

52.2 

58.5 -

58.5 

63.5 -

60.7 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.2 

44.5 -

42.3 

44.9 -

43.5 

44.9 -

43.5 

45.8 -

44.3 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

42.3 -

41.3 

46.0 -

45.5 

48.6 -

47.1 

51.7 -

51.0 

55.1 -

60.1 

55.4 -

60.4 

60.1 -

60.6 

60.5 -

68.2 

63.2 -

71.1 

Honda 2010 

2008 

42.4 -

44.4 

50.4 -

50.4 

52.9 -

53.5 

53.0 -

54.0 

56.9 -

59.6 

60.1 -

60.6 

65.5 -

64.6 

68.4 -

70.9 

68.7 -

70.8 

Hyundai 2010 

2008 

44.9 -

44.6 

45.8 -

45.7 

49.7 -

52.6 

51.1 -

53.8 

55.1 -

55.5 

66.0 -

68.1 

68.9 -

69.9 

70.8 -

69.9 

71.0 -

70.0 

Kia 2010 

2008 

45.3 -

42.6 

46.0 -

42.7 

52.0 -

46.9 

56.0 -

56.5 

57.6 -

59.8 

63.3 -

61.2 

66.4 -

63.1 

66.6 -

63.2 

68.5 -

79.7 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

44.4 -

45.8 

45.6 -

47.9 

46.3 -

49.2 

51.1 -

51.4 

51.2 -

51.5 

54.8 -

80.3 

56.2 -

81.9 

56.3 -

82.1 

62.8 -

82.6 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.5 -

42.0 

44.5 -

42.1 

50.1 -

55.1 

53.8 -

59.5 

53.8 -

59.9 

53.9 -

60.2 

54.0 -

63.0 

71.0 -

64.2 

Nissan 2010 

2008 

42.0 -

43.3 

43.6 -

46.1 

50.4 -

51.3 

51.9 -

52.4 

52.4 -

53.3 

58.9 -

61.2 

59.6 -

65.4 

64.2 -

69.7 

64.6 -

69.9 

Porsche 2010 33.2 - 34.8 - 36.5 - 36.5 - 37.3 - 40.1 - 40.5 - 40.6 - 40.6 -
 

 

 

 

 

 

 

 

 

637 

2008 34.4 35.7 35.7 35.8 37.5 40.3 40.3 41.5 41.5 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

41.2 -

42.2 

41.7 -

43.7 

44.7 -

47.7 

54.1 -

53.3 

54.1 -

53.1 

54.3 -

53.0 

54.9 -

52.9 

55.2 -

52.9 

75.2 -

66.1 

Suzuki 2010 

2008 

43.8 -

46.7 

43.8 -

47.0 

49.7 -

51.9 

53.2 -

52.3 

55.6 -

57.9 

55.9 -

58.0 

55.9 -

57.9 

56.1 -

71.5 

83.6 -

81.4 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

42.3 -

43.8 

44.5 -

47.3 

51.9 -

51.8 

53.6 -

57.9 

58.0 -

60.8 

63.8 -

68.5 

63.8 -

68.4 

75.1 -

68.5 

77.2 -

68.7 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

41.7 -

42.0 

44.1 -

44.9 

47.7 -

47.6 

50.3 -

51.1 

52.6 -

54.3 

55.6 -

57.8 

58.0 -

59.2 

61.3 -

62.8 

64.8 -

64.7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

638 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

Max Net Benefits, 3% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.4 

38.0 -

39.4 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

41.8 -

44.0 

42.8 -

46.4 

46.4 -

46.6 

49.2 -

50.8 

50.7 -

52.1 

51.7 -

52.5 

53.3 -

54.0 

53.9 -

54.8 

56.3 -

55.7 

Ford 2010 

2008 

42.7 -

42.2 

43.1 -

42.5 

48.6 -

47.9 

51.8 -

50.2 

52.2 -

51.7 

53.8 -

52.2 

54.0 -

52.8 

55.5 -

53.6 

57.0 -

53.5 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.3 

44.5 -

42.4 

44.9 -

43.6 

44.9 -

43.6 

45.8 -

44.4 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

42.7 -

44.0 

45.5 -

46.5 

45.7 -

47.4 

50.3 -

49.9 

51.7 -

52.9 

52.0 -

53.0 

53.5 -

53.4 

55.7 -

55.2 

57.8 -

56.4 

Honda 2010 

2008 

45.7 -

46.9 

48.7 -

51.1 

49.6 -

52.2 

49.8 -

52.4 

52.7 -

55.1 

53.3 -

55.6 

56.4 -

56.3 

56.9 -

56.6 

57.1 -

57.4 

Hyundai 2010 

2008 

46.2 -

46.1 

46.5 -

46.3 

50.1 -

51.5 

51.3 -

52.2 

53.2 -

53.1 

55.3 -

54.8 

56.4 -

55.1 

58.1 -

57.2 

58.3 -

57.3 

Kia 2010 

2008 

46.5 -

44.9 

46.5 -

45.1 

52.3 -

46.4 

53.7 -

54.5 

54.9 -

55.8 

56.1 -

56.3 

56.4 -

56.4 

56.4 -

56.5 

56.8 -

56.6 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

44.6 -

45.5 

45.9 -

47.4 

46.0 -

47.4 

50.3 -

58.5 

50.8 -

58.6 

55.1 -

58.8 

55.3 -

59.2 

55.4 -

58.8 

62.0 -

58.6 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.3 -

42.0 

44.4 -

42.1 

55.9 -

55.1 

58.8 -

55.2 

58.8 -

55.6 

58.8 -

55.9 

59.0 -

55.8 

59.0 -

56.2 

Nissan 2010 

2008 

42.6 -

44.2 

44.1 -

46.0 

49.9 -

50.0 

50.9 -

50.9 

51.6 -

51.1 

52.8 -

51.8 

54.4 -

52.7 

57.6 -

56.2 

58.1 -

56.4 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

639 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

41.4 -

42.7 

41.6 -

43.5 

65.1 -

47.3 

72.5 -

53.2 

71.1 -

53.1 

70.1 -

52.9 

69.0 -

52.9 

68.4 -

52.8 

67.6 -

61.7 

Suzuki 2010 

2008 

45.4 -

44.8 

45.4 -

44.9 

50.4 -

55.9 

53.5 -

56.8 

56.3 -

57.9 

56.5 -

58.0 

56.5 -

58.0 

56.7 -

58.1 

61.6 -

59.4 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

43.1 -

45.1 

44.4 -

47.2 

50.1 -

48.3 

51.0 -

50.8 

53.8 -

54.1 

54.2 -

54.9 

54.4 -

54.9 

57.3 -

56.5 

57.6 -

56.5 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

42.4 -

43.2 

44.1 -

45.1 

47.4 -

47.3 

49.6 -

49.7 

51.1 -

51.5 

52.1 -

52.2 

53.2 -

52.7 

55.0 -

54.1 

56.2 -

54.9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

640 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

Max Net Benefits, 7% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.4 

38.0 -

39.4 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

41.8 -

44.0 

42.8 -

45.9 

45.8 -

46.1 

49.1 -

49.1 

50.1 -

50.0 

50.5 -

50.2 

51.9 -

51.7 

52.8 -

52.1 

54.1 -

53.3 

Ford 2010 

2008 

42.6 -

42.2 

43.0 -

42.4 

46.9 -

46.3 

50.1 -

49.2 

51.3 -

50.5 

52.1 -

50.7 

52.2 -

51.2 

54.1 -

52.0 

54.7 -

51.9 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.3 

44.5 -

42.4 

44.9 -

43.6 

44.9 -

43.6 

45.8 -

44.4 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

42.2 -

43.8 

44.8 -

45.9 

45.1 -

46.5 

49.6 -

48.2 

50.8 -

50.5 

50.8 -

50.6 

51.9 -

51.3 

53.7 -

52.5 

55.2 -

54.3 

Honda 2010 

2008 

44.3 -

46.3 

47.1 -

49.6 

47.8 -

50.9 

47.9 -

51.0 

52.3 -

53.2 

52.5 -

53.5 

54.0 -

54.5 

54.6 -

54.9 

54.9 -

55.5 

Hyundai 2010 

2008 

45.9 -

46.1 

46.1 -

46.2 

49.0 -

50.4 

49.8 -

50.7 

51.8 -

51.7 

53.0 -

52.8 

53.6 -

53.1 

55.6 -

54.2 

55.7 -

54.3 

Kia 2010 

2008 

45.8 -

44.6 

45.9 -

44.8 

51.2 -

45.9 

52.7 -

51.7 

53.3 -

52.9 

54.0 -

53.4 

54.2 -

53.4 

54.3 -

53.6 

56.7 -

56.3 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

44.5 -

45.9 

45.9 -

48.2 

46.0 -

48.2 

50.2 -

51.6 

50.7 -

51.7 

55.0 -

54.0 

55.2 -

54.7 

55.3 -

54.7 

55.4 -

55.7 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.3 -

42.0 

44.4 -

42.1 

52.8 -

55.3 

55.8 -

55.4 

55.8 -

55.8 

55.8 -

56.1 

56.0 -

56.0 

57.1 -

56.4 

Nissan 2010 

2008 

42.4 -

43.8 

43.8 -

45.1 

49.3 -

48.7 

50.3 -

49.2 

50.5 -

49.5 

51.6 -

50.4 

52.1 -

51.6 

55.2 -

53.7 

55.5 -

54.4 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

641 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

41.4 -

42.7 

41.6 -

43.5 

46.1 -

47.3 

61.5 -

53.2 

61.5 -

53.1 

61.9 -

52.9 

62.0 -

52.9 

62.4 -

52.8 

62.5 -

61.7 

Suzuki 2010 

2008 

45.4 -

44.8 

45.4 -

44.8 

50.3 -

53.6 

53.4 -

54.8 

57.5 -

55.9 

57.7 -

55.9 

57.7 -

55.9 

57.7 -

57.0 

57.7 -

60.5 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

42.8 -

45.1 

44.0 -

46.5 

49.5 -

47.4 

50.4 -

49.2 

52.3 -

52.2 

52.6 -

53.1 

52.6 -

53.1 

54.5 -

54.8 

54.6 -

55.3 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

42.1 -

43.1 

43.7 -

44.6 

46.4 -

46.4 

48.7 -

48.4 

50.2 -

49.9 

50.8 -

50.6 

51.6 -

51.2 

53.2 -

52.3 

54.0 -

53.4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

642 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

Total Cost=Total Benefit, 3% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.4 

38.0 -

39.4 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

41.8 -

44.7 

42.8 -

47.2 

46.4 -

47.6 

49.2 -

52.2 

50.7 -

54.0 

51.7 -

54.6 

57.5 -

56.6 

58.1 -

59.4 

58.1 -

59.3 

Ford 2010 

2008 

42.6 -

47.1 

42.9 -

47.3 

48.8 -

49.6 

52.3 -

54.1 

52.8 -

55.4 

55.0 -

55.4 

55.4 -

55.5 

56.8 -

55.7 

59.7 -

56.4 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.3 

44.5 -

42.4 

44.9 -

43.6 

44.9 -

43.6 

45.8 -

44.4 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

43.0 -

45.3 

45.7 -

47.5 

45.9 -

48.3 

50.1 -

50.7 

53.1 -

53.8 

53.6 -

53.8 

57.8 -

55.9 

58.8 -

58.5 

58.8 -

59.7 

Honda 2010 

2008 

45.9 -

48.4 

49.4 -

51.6 

50.4 -

52.5 

50.5 -

52.9 

53.5 -

56.1 

54.2 -

56.4 

58.4 -

58.4 

59.5 -

59.3 

60.0 -

59.8 

Hyundai 2010 

2008 

46.2 -

47.4 

46.5 -

47.6 

50.4 -

51.9 

51.6 -

53.3 

53.6 -

54.5 

55.8 -

56.8 

56.2 -

57.7 

58.9 -

60.5 

58.9 -

60.6 

Kia 2010 

2008 

46.3 -

47.3 

46.3 -

47.5 

50.0 -

49.0 

54.7 -

56.7 

55.3 -

57.7 

58.6 -

58.4 

59.1 -

58.9 

59.2 -

59.0 

59.2 -

59.1 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

45.1 -

46.4 

45.9 -

48.0 

46.0 -

48.0 

49.1 -

51.6 

49.5 -

51.6 

55.4 -

62.8 

56.9 -

63.1 

57.9 -

62.9 

60.8 -

63.0 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.3 -

42.0 

44.4 -

42.1 

58.0 -

55.1 

61.5 -

59.5 

61.4 -

59.9 

61.4 -

60.2 

61.7 -

60.3 

61.7 -

60.6 

Nissan 2010 

2008 

43.2 -

45.1 

44.2 -

46.6 

50.6 -

50.0 

51.8 -

50.8 

52.4 -

52.4 

53.3 -

55.2 

54.5 -

56.7 

61.6 -

58.5 

61.8 -

58.6 
 

 

 

 

 

 

 

 

 

 

643 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

41.6 -

42.7 

41.6 -

43.5 

65.2 -

47.3 

69.6 -

53.2 

68.4 -

53.1 

67.3 -

52.9 

66.2 -

52.9 

65.6 -

52.8 

64.9 -

66.1 

Suzuki 2010 

2008 

45.7 -

46.8 

45.7 -

46.8 

50.2 -

52.5 

53.7 -

55.0 

56.3 -

56.3 

56.6 -

56.8 

56.6 -

56.9 

56.8 -

56.9 

65.6 -

66.5 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

43.5 -

47.0 

44.9 -

48.8 

51.1 -

50.8 

52.1 -

53.4 

54.9 -

55.5 

55.8 -

57.5 

56.0 -

57.6 

59.1 -

59.3 

60.8 -

61.6 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

42.6 -

44.8 

44.2 -

46.4 

47.7 -

48.2 

49.9 -

50.8 

51.7 -

52.6 

52.9 -

53.8 

54.9 -

54.8 

56.9 -

56.3 

58.0 -

57.6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

644 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Passenger Cars
 

Total Cost=Total Benefit, 7% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

25.7 -

28.7 

27.7 -

31.1 

27.7 -

31.1 

30.7 -

31.1 

33.8 -

31.1 

34.7 -

31.1 

BMW 2010 

2008 

32.9 -

33.5 

37.2 -

38.3 

37.9 -

39.4 

38.0 -

39.4 

39.3 -

40.0 

40.1 -

40.7 

40.2 -

41.0 

44.1 -

46.4 

44.2 -

46.4 

Daimler 2010 

2008 

33.6 -

35.7 

33.7 -

35.9 

34.9 -

36.7 

36.3 -

38.5 

36.4 -

38.9 

37.8 -

40.1 

40.9 -

42.2 

40.9 -

41.9 

43.0 -

45.5 

Fiat 2010 

2008 

41.8 -

44.7 

42.8 -

47.2 

46.4 -

47.6 

49.2 -

52.2 

50.7 -

54.0 

51.7 -

54.6 

57.5 -

56.6 

58.1 -

59.4 

58.1 -

59.3 

Ford 2010 

2008 

42.6 -

47.1 

42.9 -

47.3 

48.8 -

49.6 

52.3 -

54.1 

52.8 -

55.4 

55.0 -

55.4 

55.4 -

55.5 

56.8 -

55.7 

59.7 -

56.4 

Geely 2010 

2008 

37.2 -

36.4 

39.0 -

39.5 

43.7 -

42.3 

44.5 -

42.4 

44.9 -

43.6 

44.9 -

43.6 

45.8 -

44.4 

47.4 -

45.0 

51.7 -

45.1 

General Motors 2010 

2008 

43.0 -

45.3 

45.7 -

47.5 

45.9 -

48.3 

50.1 -

50.7 

53.1 -

53.8 

53.6 -

53.8 

57.8 -

55.9 

58.8 -

58.5 

58.8 -

59.7 

Honda 2010 

2008 

45.9 -

48.4 

49.4 -

51.6 

50.4 -

52.5 

50.5 -

52.9 

53.5 -

56.1 

54.2 -

56.4 

58.4 -

58.4 

59.5 -

59.3 

60.0 -

59.8 

Hyundai 2010 

2008 

46.2 -

47.4 

46.5 -

47.6 

50.4 -

51.9 

51.6 -

53.3 

53.6 -

54.5 

55.8 -

56.8 

56.2 -

57.7 

58.9 -

60.5 

58.9 -

60.6 

Kia 2010 

2008 

46.3 -

47.3 

46.3 -

47.5 

50.0 -

49.0 

54.7 -

56.7 

55.3 -

57.7 

58.6 -

58.4 

59.1 -

58.9 

59.2 -

59.0 

59.2 -

59.1 

Lotus 2010 

2008 

33.8 -

37.0 

33.8 -

37.0 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.2 -

39.9 

39.8 -

41.8 

39.8 -

41.8 

39.8 -

41.8 

Mazda 2010 

2008 

45.1 -

46.4 

45.9 -

48.0 

46.0 -

48.0 

49.1 -

51.6 

49.5 -

51.6 

55.4 -

62.8 

56.9 -

63.1 

57.9 -

62.9 

60.8 -

63.0 

Mitsubishi 2010 

2008 

44.5 -

40.6 

44.3 -

42.0 

44.4 -

42.1 

58.0 -

55.1 

61.5 -

59.5 

61.4 -

59.9 

61.4 -

60.2 

61.7 -

60.3 

61.7 -

60.6 

Nissan 2010 

2008 

43.2 -

45.1 

44.2 -

46.6 

50.6 -

50.0 

51.8 -

50.8 

52.4 -

52.4 

53.3 -

55.2 

54.5 -

56.7 

61.6 -

58.5 

61.8 -

58.6 

Porsche 2010 

2008 

33.2 -

34.4 

34.8 -

35.7 

36.5 -

35.7 

36.5 -

35.8 

37.3 -

37.5 

40.1 -

40.3 

40.5 -

40.3 

40.6 -

41.5 

40.6 -

41.5 
 

 

 

 

 

 

 

 

 

645 

Spyker 2010 

2008 

- ­

36.4 

- ­

38.5 

- ­

40.7 

- ­

40.7 

- ­

41.4 

- ­

42.2 

- ­

44.1 

- ­

47.6 

- ­

47.6 

Subaru 2010 

2008 

41.6 -

42.7 

41.6 -

43.5 

65.2 -

47.3 

69.6 -

53.2 

68.4 -

53.1 

67.3 -

52.9 

66.2 -

52.9 

65.6 -

52.8 

64.9 -

66.1 

Suzuki 2010 

2008 

45.7 -

46.8 

45.7 -

46.8 

50.2 -

52.5 

53.7 -

55.0 

56.3 -

56.3 

56.6 -

56.8 

56.6 -

56.9 

56.8 -

56.9 

65.6 -

66.5 

Tata 2010 

2008 

30.3 -

36.4 

34.5 -

39.4 

34.4 -

39.4 

36.3 -

40.8 

37.1 -

41.3 

37.1 -

42.4 

38.7 -

43.1 

38.7 -

43.1 

39.3 -

43.5 

Tesla 2010 

2008 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

- ­

283.0 

Toyota 2010 

2008 

43.5 -

47.0 

44.9 -

48.8 

51.1 -

50.8 

52.1 -

53.4 

54.9 -

55.5 

55.8 -

57.5 

56.0 -

57.6 

59.1 -

59.3 

60.8 -

61.6 

Volkswagen 2010 

2008 

38.8 -

37.9 

41.7 -

38.7 

42.2 -

40.1 

44.2 -

44.1 

45.3 -

44.8 

45.7 -

45.6 

46.1 -

46.1 

47.9 -

46.4 

50.2 -

48.4 

Total/Average 2010 

2008 

42.6 -

44.8 

44.2 -

46.4 

47.7 -

48.2 

49.9 -

50.8 

51.7 -

52.6 

52.9 -

53.8 

54.9 -

54.8 

56.9 -

56.3 

58.0 -

57.6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

646 

Table VI-5
 

Estimated Fuel Economy (mpg), Without CAFE Standards 

Light Trucks 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

24.1 -

22.7 

24.0 -

22.7 

24.1 -

22.6 

24.1 -

22.6 

24.0 -

22.6 

24.1 -

22.6 

24.1 -

22.5 

24.1 -

22.5 

24.0 -

22.5 

Daimler 2010 

2008 

21.1 -

20.8 

21.1 -

20.8 

21.1 -

20.8 

21.1 -

20.8 

21.1 -

20.7 

21.1 -

20.7 

21.1 -

20.6 

21.2 -

20.7 

21.2 -

20.7 

Fiat 2010 

2008 

21.7 -

22.2 

21.7 -

22.3 

21.7 -

22.3 

21.6 -

22.3 

21.6 -

22.4 

21.6 -

22.4 

21.6 -

22.4 

21.6 -

22.4 

21.6 -

22.4 

Ford 2010 

2008 

22.3 -

21.2 

22.2 -

21.3 

22.2 -

21.4 

22.1 -

21.4 

22.1 -

21.4 

22.1 -

21.3 

22.1 -

21.4 

22.1 -

21.5 

22.1 -

21.5 

Geely 2010 

2008 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

22.8 -

21.1 

General Motors 2010 

2008 

22.4 -

21.6 

22.4 -

21.6 

22.4 -

21.7 

22.4 -

21.7 

22.4 -

21.8 

22.4 -

21.8 

22.4 -

21.9 

22.4 -

21.9 

22.4 -

21.9 

Honda 2010 

2008 

25.2 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

25.1 -

24.8 

Hyundai 2010 

2008 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

28.2 -

24.2 

Kia 2010 

2008 

25.0 -

23.8 

25.0 -

23.8 

25.0 -

23.8 

25.0 -

23.8 

25.0 -

23.8 

25.0 -

23.8 

25.1 -

23.8 

25.1 -

23.8 

25.1 -

23.8 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

25.3 -

24.7 

25.3 -

24.8 

25.2 -

24.7 

25.1 -

24.6 

25.1 -

24.4 

25.1 -

24.3 

25.1 -

24.2 

25.1 -

24.2 

25.1 -

24.3 

Mitsubishi 2010 

2008 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

28.1 -

23.7 

Nissan 2010 

2008 

23.7 -

21.9 

23.6 -

22.0 

23.5 -

22.1 

23.4 -

22.1 

23.4 -

22.1 

23.4 -

22.1 

23.3 -

22.1 

23.3 -

22.2 

23.3 -

22.2 

Porsche 2010 

2008 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 

20.5 -

20.0 
 

 

 

 

 

 

 

 

647 

Spyker 2010 

2008 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

- ­

19.8 

Subaru 2010 

2008 

30.7 -

27.2 

30.7 -

27.2 

30.7 -

27.1 

30.7 -

27.2 

30.7 -

27.2 

30.7 -

27.2 

30.7 -

27.1 

30.7 -

27.2 

30.7 -

27.2 

Suzuki 2010 

2008 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

26.1 -

23.3 

Tata 2010 

2008 

18.9 -

19.5 

18.9 -

19.5 

18.9 -

19.5 

18.9 -

19.6 

18.9 -

19.6 

18.9 -

19.6 

18.9 -

19.6 

18.9 -

19.6 

18.9 -

19.6 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

24.2 -

24.1 

24.2 -

24.1 

24.2 -

24.2 

24.2 -

24.2 

24.2 -

24.2 

24.2 -

24.2 

24.2 -

24.2 

24.2 -

24.3 

24.2 -

24.3 

Volkswagen 2010 

2008 

24.0 -

20.1 

24.0 -

20.1 

24.1 -

20.1 

24.1 -

20.1 

24.1 -

20.1 

24.1 -

20.1 

24.1 -

20.1 

24.2 -

20.1 

24.1 -

20.1 

Total/Average 2010 

2008 

23.2 -

22.6 

23.1 -

22.6 

23.1 -

22.6 

23.1 -

22.6 

23.1 -

22.6 

23.1 -

22.7 

23.1 -

22.7 

23.1 -

22.7 

23.1 -

22.7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

648 

Table VI-6
 

Estimated Fuel Economy (mpg), Adjusted Baseline 

Light Trucks
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

31.2 -

30.7 

31.0 -

30.7 

31.1 -

30.7 

31.2 -

30.6 

31.1 -

30.5 

31.2 -

30.4 

31.2 -

30.3 

31.2 -

30.3 

31.1 -

30.4 

Daimler 2010 

2008 

29.6 -

29.6 

30.2 -

29.7 

30.2 -

29.7 

30.3 -

29.6 

30.5 -

29.4 

30.5 -

29.2 

30.5 -

29.1 

30.6 -

29.3 

30.6 -

29.4 

Fiat 2010 

2008 

28.8 -

28.9 

28.8 -

28.9 

28.8 -

28.9 

28.8 -

28.9 

28.8 -

28.9 

29.2 -

29.6 

29.2 -

29.6 

29.2 -

29.7 

29.3 -

29.7 

Ford 2010 

2008 

26.6 -

27.6 

26.5 -

27.7 

26.6 -

27.8 

26.8 -

27.9 

27.7 -

28.6 

27.7 -

28.6 

27.7 -

28.7 

27.7 -

28.8 

27.7 -

28.8 

Geely 2010 

2008 

28.2 -

30.6 

32.7 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

32.8 -

31.0 

General Motors 2010 

2008 

26.6 -

27.3 

26.6 -

27.4 

26.9 -

27.9 

27.9 -

27.9 

27.9 -

28.1 

27.9 -

28.1 

28.0 -

28.2 

28.1 -

28.3 

28.1 -

28.3 

Honda 2010 

2008 

30.0 -

29.8 

30.0 -

29.8 

30.4 -

30.2 

30.4 -

30.8 

30.4 -

30.8 

30.4 -

30.8 

30.4 -

30.7 

30.4 -

30.8 

30.4 -

30.8 

Hyundai 2010 

2008 

30.3 -

31.4 

31.4 -

31.4 

31.6 -

31.4 

31.8 -

31.4 

31.8 -

31.4 

31.8 -

31.4 

31.8 -

31.4 

31.8 -

31.4 

31.8 -

31.4 

Kia 2010 

2008 

29.6 -

29.4 

29.6 -

29.4 

29.6 -

29.6 

29.6 -

29.8 

29.6 -

29.8 

29.6 -

29.8 

29.6 -

29.8 

29.6 -

29.8 

29.6 -

29.8 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

29.7 -

29.7 

31.9 -

30.9 

31.7 -

30.9 

31.8 -

30.9 

31.7 -

31.0 

31.8 -

30.9 

31.7 -

30.7 

31.7 -

30.8 

31.7 -

30.8 

Mitsubishi 2010 

2008 

32.4 -

32.3 

32.4 -

32.3 

32.4 -

32.3 

32.4 -

32.3 

33.2 -

32.5 

33.2 -

32.5 

33.2 -

32.5 

33.2 -

32.5 

33.2 -

32.5 

Nissan 2010 

2008 

29.3 -

29.1 

29.1 -

29.2 

29.1 -

29.3 

29.2 -

29.4 

29.3 -

29.6 

29.3 -

29.6 

29.2 -

29.7 

29.2 -

29.8 

29.2 -

29.8 

Porsche 2010 

2008 

27.9 -

30.3 

28.1 -

30.9 

30.8 -

30.9 

30.8 -

30.9 

30.8 -

30.9 

30.8 -

30.9 

30.8 -

30.9 

30.8 -

30.9 

30.8 -

30.9 
 

 

 

 

 

 

 

 

649 

Spyker 2010 

2008 

- ­

30.9 

- ­

30.9 

- ­

30.9 

- ­

30.9 

- ­

31.8 

- ­

31.8 

- ­

31.8 

- ­

31.8 

- ­

31.8 

Subaru 2010 

2008 

32.1 -

33.2 

32.2 -

33.5 

34.6 -

33.6 

34.6 -

33.6 

34.7 -

33.6 

34.9 -

33.6 

34.9 -

33.6 

34.9 -

33.6 

34.9 -

33.6 

Suzuki 2010 

2008 

33.3 -

30.7 

33.3 -

30.7 

33.3 -

31.7 

33.3 -

31.7 

33.5 -

31.7 

33.5 -

31.7 

33.5 -

31.7 

33.5 -

31.7 

33.5 -

31.7 

Tata 2010 

2008 

28.2 -

30.4 

28.2 -

30.4 

28.7 -

31.3 

28.7 -

31.4 

31.2 -

32.1 

31.1 -

32.1 

31.1 -

32.1 

31.1 -

32.1 

31.1 -

32.1 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

27.7 -

29.0 

28.7 -

29.2 

29.0 -

29.4 

29.3 -

29.4 

29.3 -

29.6 

29.3 -

29.6 

29.3 -

29.8 

29.3 -

29.8 

29.3 -

29.9 

Volkswagen 2010 

2008 

29.4 -

27.8 

30.1 -

29.0 

30.6 -

29.6 

30.7 -

29.4 

30.7 -

29.6 

30.7 -

29.5 

30.7 -

29.4 

30.7 -

29.5 

30.7 -

29.5 

Total/Average 2010 

2008 

28.0 -

28.7 

28.2 -

28.8 

28.4 -

29.0 

28.8 -

29.1 

29.0 -

29.3 

29.0 -

29.4 

29.0 -

29.4 

29.1 -

29.5 

29.1 -

29.5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

650 

Table VI-7
 

Estimated Required Fuel Economy Levels for Preferred Alternative 

Estimated mpg 

Light Trucks 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

31.2 -

30.6 

32.0 -

31.4 

32.7 -

32.1 

33.5 -

32.9 

35.8 -

35.1 

37.5 -

36.7 

39.3 -

38.4 

41.1 -

40.2 

43.1 -

42.1 

Daimler 2010 

2008 

30.1 -

29.1 

30.8 -

29.6 

31.4 -

30.2 

32.2 -

30.9 

34.4 -

32.9 

36.0 -

34.5 

37.7 -

36.1 

39.5 -

37.8 

41.4 -

39.5 

Fiat 2010 

2008 

29.6 -

29.6 

30.2 -

30.2 

30.7 -

30.8 

31.5 -

31.5 

33.6 -

33.7 

35.2 -

35.3 

36.9 -

37.0 

38.6 -

38.8 

40.4 -

40.6 

Ford 2010 

2008 

27.5 -

28.6 

27.8 -

29.1 

28.0 -

29.6 

28.4 -

30.0 

30.2 -

32.0 

31.7 -

33.5 

33.1 -

35.2 

34.7 -

37.0 

36.4 -

38.8 

Geely 2010 

2008 

31.4 -

31.1 

32.4 -

32.1 

33.0 -

32.7 

33.9 -

33.5 

36.2 -

35.8 

37.9 -

37.5 

39.7 -

39.3 

41.6 -

41.2 

43.6 -

43.1 

General Motors 2010 

2008 

27.8 -

28.0 

28.1 -

28.5 

28.6 -

29.1 

29.2 -

29.6 

31.2 -

31.7 

32.8 -

33.2 

34.3 -

34.9 

36.0 -

36.6 

37.8 -

38.4 

Honda 2010 

2008 

30.4 -

31.0 

31.1 -

31.7 

31.7 -

32.3 

32.5 -

33.1 

34.7 -

35.4 

36.4 -

37.0 

38.1 -

38.8 

39.9 -

40.7 

41.8 -

42.6 

Hyundai 2010 

2008 

32.1 -

31.3 

33.0 -

32.1 

33.7 -

32.8 

34.6 -

33.6 

36.9 -

35.9 

38.7 -

37.6 

40.5 -

39.4 

42.5 -

41.3 

44.5 -

43.2 

Kia 2010 

2008 

30.3 -

30.0 

31.0 -

30.6 

31.7 -

31.2 

32.5 -

32.0 

34.8 -

34.2 

36.5 -

35.8 

38.3 -

37.5 

40.1 -

39.3 

42.1 -

41.1 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

31.6 -

31.4 

32.5 -

32.4 

33.1 -

33.1 

33.9 -

33.8 

36.2 -

35.9 

38.0 -

37.6 

39.8 -

39.3 

41.7 -

41.2 

43.6 -

43.2 

Mitsubishi 2010 

2008 

34.1 -

32.9 

35.1 -

33.9 

35.9 -

34.6 

36.7 -

35.5 

39.3 -

37.9 

41.1 -

39.7 

43.1 -

41.6 

45.2 -

43.6 

47.3 -

45.7 

Nissan 2010 

2008 

29.6 -

29.6 

30.1 -

30.3 

30.5 -

30.9 

31.1 -

31.6 

33.1 -

33.5 

34.6 -

35.1 

36.2 -

36.8 

37.9 -

38.7 

39.7 -

40.6 

Porsche 2010 

2008 

30.3 -

30.3 

31.1 -

31.2 

31.8 -

31.8 

32.6 -

32.6 

34.8 -

34.8 

36.4 -

36.5 

38.2 -

38.2 

40.0 -

40.0 

41.9 -

41.9 
 

 

 

 

 

 

 

 

651 

Spyker 2010 

2008 

- ­

31.2 

- ­

32.1 

- ­

32.8 

- ­

33.6 

- ­

35.9 

- ­

37.6 

- ­

39.4 

- ­

41.3 

- ­

43.3 

Subaru 2010 

2008 

34.9 -

34.4 

35.9 -

35.4 

36.7 -

36.1 

37.6 -

37.1 

40.2 -

39.6 

42.1 -

41.5 

44.1 -

43.5 

46.2 -

45.5 

48.4 -

47.7 

Suzuki 2010 

2008 

34.2 -

32.2 

35.2 -

33.2 

36.0 -

33.9 

36.9 -

34.7 

39.4 -

37.1 

41.3 -

38.9 

43.3 -

40.7 

45.3 -

42.7 

47.5 -

44.7 

Tata 2010 

2008 

31.6 -

32.1 

32.5 -

33.1 

33.2 -

33.8 

34.0 -

34.6 

36.3 -

37.0 

38.1 -

38.8 

39.9 -

40.6 

41.8 -

42.6 

43.8 -

44.6 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

29.4 -

29.7 

30.0 -

30.4 

30.5 -

31.0 

31.1 -

31.6 

32.9 -

33.7 

34.4 -

35.3 

36.1 -

37.0 

37.8 -

38.9 

39.6 -

40.7 

Volkswagen 2010 

2008 

30.9 -

29.5 

31.7 -

30.1 

32.4 -

30.8 

33.2 -

31.5 

35.4 -

33.5 

37.1 -

35.1 

38.9 -

36.7 

40.8 -

38.5 

42.7 -

40.3 

Total/Average 2010 

2008 

29.1 -

29.4 

29.6 -

30.0 

30.0 -

30.6 

30.6 -

31.2 

32.6 -

33.3 

34.2 -

34.9 

35.8 -

36.6 

37.5 -

38.5 

39.3 -

40.3 
 

 

 

 

 

 

 

 

 

 

 

 

 

652 

Table VI-8
 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

Preferred Alternative
 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.5 -

35.0 

34.6 -

35.2 

34.7 -

35.5 

35.3 -

35.4 

36.7 -

36.8 

39.5 -

39.6 

39.4 -

39.5 

39.4 -

39.5 

39.5 -

39.4 

Daimler 2010 

2008 

30.5 -

31.8 

32.3 -

32.0 

32.4 -

32.1 

32.4 -

32.8 

32.7 -

32.6 

37.2 -

37.6 

37.4 -

37.5 

37.4 -

37.6 

37.8 -

37.8 

Fiat 2010 

2008 

30.1 -

29.2 

30.1 -

29.2 

30.1 -

29.2 

30.1 -

29.2 

30.1 -

29.2 

33.9 -

35.3 

38.5 -

38.2 

38.6 -

38.4 

38.5 -

40.6 

Ford 2010 

2008 

27.4 -

28.5 

27.5 -

28.9 

28.2 -

29.2 

28.8 -

30.5 

34.4 -

34.6 

34.4 -

35.3 

34.5 -

35.5 

34.8 -

36.5 

34.7 -

36.5 

Geely 2010 

2008 

28.2 -

31.0 

34.9 -

34.8 

35.1 -

35.1 

35.1 -

35.1 

35.9 -

35.1 

36.6 -

38.8 

40.8 -

41.0 

40.8 -

41.0 

40.8 -

41.0 

General Motors 2010 

2008 

27.1 -

27.4 

27.4 -

28.4 

30.6 -

30.7 

34.8 -

32.9 

34.9 -

33.3 

34.9 -

33.6 

35.1 -

34.6 

36.0 -

34.7 

36.0 -

36.9 

Honda 2010 

2008 

30.2 -

32.1 

30.5 -

32.3 

33.3 -

34.2 

33.3 -

34.5 

35.2 -

37.1 

38.4 -

40.5 

38.8 -

40.5 

39.1 -

41.5 

39.1 -

41.5 

Hyundai 2010 

2008 

32.2 -

32.1 

32.4 -

32.3 

37.7 -

35.9 

38.1 -

36.1 

38.1 -

36.1 

42.6 -

39.0 

43.4 -

39.0 

45.5 -

40.7 

45.7 -

41.2 

Kia 2010 

2008 

30.4 -

30.3 

30.6 -

30.9 

32.6 -

32.4 

32.6 -

33.6 

37.6 -

41.1 

37.5 -

41.1 

40.0 -

41.6 

40.7 -

41.8 

40.9 -

41.8 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

29.8 -

29.8 

37.6 -

38.9 

37.5 -

39.0 

37.6 -

39.7 

38.3 -

39.7 

38.3 -

39.8 

40.2 -

39.8 

41.9 -

39.8 

41.8 -

39.8 

Mitsubishi 2010 

2008 

34.1 -

33.5 

34.8 -

33.7 

35.0 -

33.8 

35.0 -

33.8 

45.3 -

43.9 

45.3 -

43.9 

45.3 -

43.9 

45.3 -

43.9 

45.3 -

43.9 

Nissan 2010 

2008 

29.1 -

29.7 

29.1 -

30.0 

33.6 -

31.5 

34.8 -

32.1 

35.8 -

35.5 

36.8 -

38.0 

36.9 -

38.2 

36.9 -

39.3 

36.8 -

40.7 
 

 

 

 

 

 

 

 

 

653 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

31.2 

34.3 -

34.0 

34.3 -

34.0 

34.3 -

34.0 

35.0 -

34.5 

38.1 -

37.6 

38.1 -

37.6 

38.1 -

37.6 

Spyker 2010 

2008 

- ­

32.5 

- ­

33.6 

- ­

33.7 

- ­

33.7 

- ­

36.9 

- ­

36.9 

- ­

36.9 

- ­

36.9 

- ­

36.9 

Subaru 2010 

2008 

38.2 -

33.2 

38.7 -

35.4 

42.0 -

43.8 

42.0 -

43.9 

42.0 -

44.5 

42.0 -

44.5 

42.0 -

44.5 

48.5 -

44.5 

48.5 -

44.5 

Suzuki 2010 

2008 

34.9 -

31.0 

35.1 -

31.1 

35.2 -

39.8 

35.2 -

39.8 

45.4 -

40.8 

45.4 -

40.8 

45.4 -

40.8 

45.4 -

40.8 

45.4 -

40.8 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

28.5 -

29.2 

30.0 -

31.1 

31.7 -

32.7 

32.3 -

33.6 

34.1 -

35.5 

34.6 -

35.7 

35.6 -

36.3 

38.4 -

39.6 

39.4 -

40.6 

Volkswagen 2010 

2008 

30.2 -

27.9 

31.6 -

29.8 

34.2 -

35.3 

38.1 -

35.3 

38.7 -

36.6 

38.8 -

36.6 

39.6 -

37.6 

40.0 -

38.0 

40.7 -

38.0 

Total/Average 2010 

2008 

28.8 -

29.3 

29.3 -

30.3 

31.3 -

31.9 

32.8 -

33.3 

34.9 -

35.2 

35.5 -

36.1 

36.5 -

36.8 

37.4 -

37.9 

37.6 -

39.0 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

654 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

2% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

35.0 -

32.3 

35.0 -

32.5 

35.2 -

32.6 

35.8 -

33.9 

37.1 -

34.9 

38.0 -

37.7 

37.9 -

37.6 

38.0 -

37.5 

38.3 -

37.5 

Daimler 2010 

2008 

31.5 -

30.9 

32.9 -

31.1 

33.0 -

31.2 

33.6 -

31.9 

33.6 -

31.6 

35.5 -

35.9 

36.5 -

35.9 

36.5 -

36.0 

37.0 -

36.1 

Fiat 2010 

2008 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

33.8 -

34.2 

35.5 -

35.1 

35.4 -

35.4 

35.4 -

35.4 

Ford 2010 

2008 

28.9 -

28.9 

29.1 -

29.2 

29.9 -

29.6 

30.1 -

30.4 

30.7 -

33.1 

30.7 -

33.5 

30.7 -

33.7 

31.2 -

33.9 

31.1 -

33.9 

Geely 2010 

2008 

28.2 -

31.5 

34.1 -

34.7 

34.5 -

34.8 

34.5 -

34.8 

34.9 -

34.8 

36.1 -

36.7 

38.7 -

37.6 

38.7 -

37.6 

38.7 -

37.6 

General Motors 2010 

2008 

28.1 -

28.0 

28.4 -

28.9 

30.0 -

30.8 

32.1 -

31.9 

32.1 -

32.2 

32.3 -

32.3 

32.8 -

32.8 

32.9 -

33.0 

32.9 -

33.6 

Honda 2010 

2008 

32.2 -

32.8 

32.6 -

33.0 

33.5 -

33.8 

33.7 -

34.7 

34.4 -

35.6 

35.0 -

37.2 

35.5 -

37.2 

37.1 -

37.4 

37.1 -

37.4 

Hyundai 2010 

2008 

33.0 -

32.6 

33.2 -

32.8 

37.4 -

35.4 

37.9 -

35.5 

37.9 -

35.5 

39.7 -

36.7 

39.7 -

36.7 

40.6 -

36.9 

40.6 -

36.9 

Kia 2010 

2008 

33.1 -

32.2 

33.3 -

32.9 

33.6 -

33.6 

33.6 -

34.3 

35.2 -

34.3 

35.2 -

34.3 

35.9 -

34.9 

35.9 -

35.9 

35.9 -

35.9 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

30.4 -

29.9 

34.7 -

35.1 

34.6 -

35.2 

34.7 -

35.6 

36.1 -

36.3 

36.1 -

36.1 

40.7 -

41.6 

41.4 -

42.1 

41.4 -

42.1 

Mitsubishi 2010 

2008 

34.1 -

33.5 

35.4 -

33.7 

35.6 -

33.8 

35.6 -

33.8 

40.7 -

40.1 

40.7 -

40.1 

40.7 -

40.0 

40.7 -

40.1 

40.7 -

40.1 

Nissan 2010 

2008 

29.5 -

30.7 

29.5 -

31.0 

31.7 -

32.3 

32.4 -

32.9 

32.7 -

33.7 

34.1 -

34.5 

34.2 -

34.6 

34.6 -

35.4 

34.5 -

35.4 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

31.7 

35.1 -

34.0 

35.1 -

34.0 

35.1 -

34.0 

35.7 -

34.5 

37.6 -

36.9 

37.6 -

36.9 

37.6 -

36.9 
 

 

 

 

 

 

 

 

655 

Spyker 2010 

2008 

- ­

31.9 

- ­

32.6 

- ­

32.7 

- ­

32.7 

- ­

36.9 

0.0 -

36.9 

0.0 -

36.9 

0.0 -

36.9 

0.0 -

36.9 

Subaru 2010 

2008 

34.1 -

33.9 

34.4 -

35.9 

39.0 -

41.2 

39.0 -

41.3 

39.0 -

41.3 

40.3 -

41.3 

40.3 -

41.2 

42.1 -

41.3 

42.1 -

41.3 

Suzuki 2010 

2008 

35.9 -

31.0 

36.1 -

31.1 

36.5 -

37.3 

36.5 -

37.3 

40.2 -

37.6 

40.2 -

37.6 

40.2 -

37.6 

40.2 -

37.6 

40.2 -

39.9 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

29.8 -

30.5 

30.7 -

31.8 

31.5 -

32.6 

31.8 -

33.1 

32.9 -

34.0 

33.3 -

34.2 

33.6 -

34.4 

34.7 -

35.7 

35.0 -

35.7 

Volkswagen 2010 

2008 

30.2 -

28.1 

31.4 -

30.5 

33.6 -

35.5 

35.7 -

35.4 

35.7 -

35.9 

36.5 -

35.9 

36.7 -

35.9 

37.1 -

35.9 

37.1 -

35.9 

Total/Average 2010 

2008 

29.8 -

30.0 

30.2 -

30.7 

31.4 -

31.9 

32.3 -

32.8 

32.9 -

33.8 

33.3 -

34.3 

33.8 -

34.6 

34.3 -

35.1 

34.3 -

35.3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

656 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

3% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

33.6 -

34.6 

33.6 -

34.8 

34.4 -

34.9 

34.5 -

35.6 

35.1 -

37.3 

40.5 -

40.3 

40.4 -

40.2 

40.4 -

40.1 

40.7 -

40.0 

Daimler 2010 

2008 

32.2 -

34.4 

33.7 -

34.6 

33.8 -

34.7 

35.0 -

34.6 

35.0 -

34.6 

37.2 -

37.3 

38.2 -

37.2 

38.3 -

37.3 

38.3 -

37.5 

Fiat 2010 

2008 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

30.4 -

29.9 

34.2 -

36.4 

38.6 -

38.3 

38.7 -

38.5 

38.6 -

38.5 

Ford 2010 

2008 

28.9 -

29.9 

29.2 -

30.3 

29.8 -

30.9 

30.1 -

31.7 

34.0 -

34.9 

34.1 -

35.6 

34.1 -

35.9 

34.3 -

36.2 

35.6 -

37.8 

Geely 2010 

2008 

28.7 -

31.3 

36.2 -

36.0 

36.9 -

36.3 

36.8 -

36.3 

37.7 -

37.2 

38.3 -

39.8 

41.7 -

39.8 

41.7 -

39.8 

41.7 -

39.8 

General Motors 2010 

2008 

28.5 -

28.0 

28.9 -

29.1 

30.9 -

32.3 

35.4 -

34.4 

35.4 -

34.8 

35.8 -

35.0 

35.8 -

35.6 

36.3 -

36.3 

36.3 -

36.3 

Honda 2010 

2008 

32.6 -

34.0 

33.0 -

34.2 

35.4 -

35.6 

35.6 -

36.5 

37.2 -

38.0 

38.9 -

39.8 

39.0 -

40.1 

39.7 -

40.5 

39.7 -

41.7 

Hyundai 2010 

2008 

32.4 -

34.2 

32.6 -

34.4 

38.0 -

37.5 

38.7 -

37.5 

38.7 -

37.5 

41.6 -

39.2 

41.7 -

39.2 

43.2 -

41.6 

43.5 -

42.3 

Kia 2010 

2008 

33.1 -

30.7 

33.3 -

30.9 

34.3 -

33.0 

34.3 -

34.0 

38.0 -

38.3 

38.0 -

38.3 

40.6 -

39.6 

40.7 -

39.6 

40.9 -

39.8 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

30.4 -

29.9 

37.9 -

38.8 

37.8 -

38.9 

37.9 -

39.6 

37.9 -

39.6 

37.9 -

39.6 

40.7 -

42.2 

42.6 -

42.4 

42.5 -

42.7 

Mitsubishi 2010 

2008 

35.2 -

34.0 

36.0 -

34.2 

36.1 -

34.3 

36.1 -

34.3 

44.7 -

43.3 

44.7 -

43.3 

44.7 -

43.3 

44.7 -

43.3 

44.7 -

43.3 

Nissan 2010 

2008 

30.8 -

30.7 

30.8 -

31.0 

32.6 -

32.9 

33.8 -

33.4 

34.4 -

35.7 

36.9 -

37.4 

36.9 -

38.0 

38.1 -

39.0 

38.8 -

39.8 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.7 -

34.0 

36.7 -

34.0 

36.7 -

34.0 

37.6 -

34.5 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

 

657 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.2 

- ­

34.3 

- ­

34.3 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

38.5 -

35.6 

38.9 -

38.3 

43.4 -

43.6 

43.4 -

43.6 

43.4 -

44.1 

43.4 -

44.1 

43.4 -

44.1 

45.3 -

46.7 

45.3 -

46.6 

Suzuki 2010 

2008 

36.3 -

31.9 

36.5 -

32.1 

36.6 -

38.6 

36.6 -

38.6 

45.3 -

39.6 

45.3 -

41.1 

45.3 -

41.1 

45.3 -

41.1 

45.3 -

41.1 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

30.6 -

31.0 

31.7 -

32.6 

33.5 -

34.4 

34.3 -

35.6 

35.5 -

36.8 

35.7 -

36.9 

37.2 -

37.9 

38.3 -

38.7 

38.7 -

39.1 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.0 -

30.9 

34.8 -

36.0 

37.6 -

35.9 

37.7 -

36.2 

38.2 -

36.1 

39.2 -

36.1 

40.0 -

39.2 

41.8 -

39.2 

Total/Average 2010 

2008 

30.2 -

30.5 

30.7 -

31.4 

32.3 -

33.3 

33.9 -

34.7 

35.3 -

36.1 

36.0 -

36.8 

36.9 -

37.4 

37.5 -

38.2 

37.9 -

38.6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

658 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

4% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

36.3 -

35.6 

36.4 -

35.8 

36.9 -

36.3 

37.6 -

36.6 

38.8 -

37.3 

41.3 -

39.7 

41.3 -

39.6 

41.3 -

39.5 

41.7 -

39.5 

Daimler 2010 

2008 

32.2 -

35.6 

33.7 -

35.8 

33.8 -

36.0 

35.1 -

35.9 

35.2 -

35.8 

37.1 -

37.2 

38.0 -

37.2 

38.1 -

37.3 

38.5 -

37.5 

Fiat 2010 

2008 

30.7 -

31.3 

30.7 -

31.3 

30.7 -

31.3 

30.7 -

31.3 

30.7 -

31.3 

35.0 -

39.5 

40.5 -

41.4 

40.7 -

41.9 

44.4 -

42.0 

Ford 2010 

2008 

29.3 -

29.5 

29.7 -

30.3 

30.0 -

30.7 

30.7 -

31.7 

35.5 -

37.0 

35.8 -

38.0 

35.8 -

38.6 

36.6 -

38.8 

37.9 -

41.8 

Geely 2010 

2008 

28.7 -

31.3 

36.9 -

36.8 

37.6 -

37.0 

37.5 -

37.0 

39.0 -

37.3 

39.6 -

40.0 

42.3 -

40.0 

42.3 -

40.0 

42.3 -

40.0 

General Motors 2010 

2008 

28.5 -

28.3 

28.9 -

29.7 

31.2 -

34.2 

36.5 -

37.1 

36.6 -

37.3 

36.6 -

37.4 

36.9 -

37.9 

37.6 -

37.9 

38.7 -

37.9 

Honda 2010 

2008 

32.9 -

35.4 

33.3 -

35.6 

36.1 -

36.7 

36.5 -

37.8 

38.8 -

40.0 

41.3 -

43.4 

41.6 -

43.4 

43.1 -

44.3 

43.1 -

44.5 

Hyundai 2010 

2008 

32.7 -

36.1 

33.2 -

36.3 

38.5 -

39.4 

39.1 -

39.4 

39.1 -

39.4 

44.6 -

41.5 

45.0 -

41.5 

48.1 -

45.8 

48.1 -

46.5 

Kia 2010 

2008 

33.0 -

31.2 

33.2 -

31.4 

35.9 -

34.3 

36.0 -

35.9 

41.6 -

41.2 

41.6 -

41.2 

42.1 -

41.2 

43.0 -

41.3 

43.0 -

41.3 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

31.2 -

29.9 

39.9 -

40.1 

39.8 -

40.2 

40.1 -

41.2 

40.1 -

41.3 

40.1 -

41.3 

43.2 -

43.7 

45.5 -

44.0 

45.4 -

44.2 

Mitsubishi 2010 

2008 

38.9 -

34.6 

39.2 -

34.8 

39.3 -

35.0 

39.3 -

34.9 

48.8 -

47.5 

48.8 -

47.5 

48.8 -

47.5 

48.8 -

47.5 

48.8 -

47.5 

Nissan 2010 

2008 

29.9 -

32.2 

29.9 -

32.5 

34.4 -

35.4 

35.9 -

36.3 

37.4 -

39.3 

39.7 -

40.2 

39.7 -

41.0 

40.8 -

42.1 

42.4 -

43.6 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.8 -

34.0 

36.8 -

34.0 

36.8 -

34.0 

37.6 -

34.5 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

 

659 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.2 

- ­

34.3 

- ­

34.3 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

38.8 -

35.6 

39.5 -

39.0 

45.1 -

44.4 

45.1 -

44.4 

45.1 -

44.9 

46.6 -

44.9 

46.6 -

44.9 

52.1 -

51.4 

52.1 -

51.4 

Suzuki 2010 

2008 

39.1 -

32.8 

39.4 -

33.1 

39.7 -

41.9 

39.7 -

41.9 

47.6 -

44.3 

47.6 -

44.3 

47.6 -

44.3 

47.6 -

44.3 

47.6 -

44.3 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

30.2 -

31.5 

32.6 -

33.6 

35.0 -

35.8 

35.6 -

37.2 

37.7 -

38.1 

38.3 -

38.4 

39.1 -

41.1 

41.4 -

43.0 

42.4 -

43.5 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.4 -

30.9 

35.0 -

36.5 

38.9 -

36.4 

39.0 -

36.2 

39.3 -

36.2 

40.1 -

36.4 

41.7 -

39.5 

43.8 -

39.5 

Total/Average 2010 

2008 

30.2 -

31.0 

31.1 -

32.2 

32.9 -

34.6 

34.9 -

36.4 

36.9 -

38.1 

37.6 -

38.9 

38.6 -

39.9 

39.7 -

40.8 

41.0 -

41.4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

660 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

5% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

36.2 

34.4 -

36.4 

35.3 -

36.5 

35.3 -

37.5 

36.0 -

38.3 

41.6 -

39.5 

41.6 -

39.5 

41.6 -

39.5 

42.1 -

39.5 

Daimler 2010 

2008 

32.2 -

35.3 

33.7 -

35.5 

33.8 -

35.7 

35.1 -

36.3 

35.2 -

36.2 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

31.7 

30.7 -

31.7 

30.7 -

31.7 

30.7 -

31.7 

30.7 -

31.7 

35.0 -

41.9 

41.9 -

43.8 

42.1 -

44.6 

43.5 -

44.7 

Ford 2010 

2008 

29.1 -

29.6 

29.6 -

30.9 

30.2 -

31.3 

31.4 -

34.8 

38.9 -

39.5 

39.2 -

41.0 

39.4 -

41.6 

40.2 -

42.2 

40.2 -

47.0 

Geely 2010 

2008 

28.7 -

31.7 

37.2 -

36.4 

37.9 -

36.7 

37.8 -

36.7 

39.3 -

36.7 

40.3 -

40.2 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

28.5 -

28.6 

29.1 -

30.2 

32.0 -

35.8 

38.7 -

39.3 

38.9 -

39.6 

39.1 -

39.7 

39.7 -

40.8 

40.4 -

40.8 

42.8 -

40.8 

Honda 2010 

2008 

33.2 -

36.6 

33.7 -

36.9 

37.7 -

38.4 

38.2 -

39.6 

41.1 -

42.1 

45.0 -

46.5 

46.1 -

47.6 

47.2 -

49.0 

47.7 -

50.6 

Hyundai 2010 

2008 

34.6 -

35.9 

35.5 -

36.1 

42.3 -

39.8 

42.8 -

40.2 

42.8 -

40.2 

46.9 -

45.0 

46.9 -

45.0 

52.5 -

51.4 

52.9 -

51.5 

Kia 2010 

2008 

33.7 -

33.7 

33.9 -

34.0 

39.1 -

36.9 

39.1 -

38.7 

43.4 -

44.0 

43.4 -

44.0 

45.5 -

45.4 

47.2 -

46.4 

47.2 -

46.4 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

31.6 -

29.9 

39.9 -

40.7 

39.9 -

40.9 

40.1 -

41.8 

40.1 -

41.8 

40.1 -

41.8 

45.7 -

47.3 

50.4 -

50.4 

50.3 -

51.9 

Mitsubishi 2010 

2008 

38.8 -

34.6 

39.5 -

34.8 

39.7 -

35.0 

39.7 -

35.4 

48.8 -

48.0 

48.8 -

48.0 

48.8 -

47.9 

48.8 -

48.0 

48.8 -

48.0 

Nissan 2010 

2008 

31.0 -

32.8 

31.0 -

33.1 

36.6 -

36.2 

38.3 -

37.8 

38.9 -

41.0 

40.7 -

42.8 

40.8 -

42.8 

45.0 -

44.7 

47.0 -

44.7 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.8 -

34.2 

36.8 -

34.2 

36.8 -

34.2 

37.6 -

34.7 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

 

661 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.2 -

37.0 

40.3 -

40.8 

51.2 -

48.6 

51.2 -

48.6 

51.3 -

49.6 

51.3 -

50.4 

51.3 -

50.4 

51.3 -

55.9 

51.3 -

55.8 

Suzuki 2010 

2008 

39.4 -

33.4 

39.6 -

33.6 

41.0 -

42.8 

41.0 -

42.8 

48.9 -

45.4 

48.9 -

45.4 

48.9 -

45.4 

48.9 -

45.4 

48.9 -

51.9 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

31.0 -

31.6 

33.2 -

34.6 

36.3 -

37.4 

37.3 -

39.0 

39.3 -

40.7 

40.4 -

41.6 

42.4 -

43.6 

46.3 -

46.8 

47.0 -

48.1 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

39.4 -

37.3 

39.5 -

37.2 

39.8 -

37.1 

40.4 -

37.4 

41.7 -

39.5 

43.8 -

39.5 

Total/Average 2010 

2008 

30.5 -

31.3 

31.3 -

32.9 

33.7 -

35.8 

36.2 -

38.4 

38.7 -

40.3 

39.6 -

41.4 

41.4 -

42.5 

42.8 -

43.9 

43.9 -

44.9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

662 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

6% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

36.5 

34.4 -

36.7 

35.3 -

37.2 

35.3 -

37.6 

36.0 -

38.5 

41.6 -

40.0 

41.6 -

39.9 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.5 

33.7 -

35.8 

33.8 -

35.9 

35.1 -

36.5 

35.2 -

36.3 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

32.4 

30.7 -

32.4 

30.7 -

32.4 

30.7 -

32.4 

30.7 -

32.4 

35.0 -

44.2 

42.0 -

45.8 

42.1 -

46.4 

43.6 -

47.9 

Ford 2010 

2008 

29.5 -

30.5 

30.1 -

32.0 

30.5 -

32.2 

31.8 -

39.1 

40.2 -

43.0 

40.5 -

43.5 

40.6 -

44.2 

41.3 -

45.4 

45.0 -

45.6 

Geely 2010 

2008 

28.7 -

31.5 

37.2 -

36.1 

37.9 -

36.6 

37.8 -

36.6 

39.3 -

36.6 

40.3 -

40.3 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

28.5 -

28.9 

29.1 -

30.5 

32.0 -

35.8 

38.8 -

40.0 

38.9 -

40.4 

39.3 -

40.7 

39.8 -

42.1 

40.7 -

42.8 

45.0 -

47.0 

Honda 2010 

2008 

34.9 -

36.8 

35.4 -

37.1 

38.2 -

38.9 

38.8 -

40.1 

42.7 -

43.5 

46.7 -

49.9 

47.5 -

49.9 

50.0 -

50.5 

50.3 -

52.2 

Hyundai 2010 

2008 

35.1 -

36.3 

35.3 -

36.5 

44.7 -

42.3 

44.9 -

43.2 

44.9 -

43.2 

50.4 -

47.9 

52.1 -

47.9 

58.1 -

51.3 

58.1 -

51.4 

Kia 2010 

2008 

35.1 -

34.5 

35.4 -

35.0 

40.6 -

37.4 

40.6 -

40.0 

47.2 -

49.0 

47.2 -

49.1 

51.8 -

50.4 

51.9 -

50.4 

51.9 -

50.4 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

32.0 -

30.0 

39.9 -

45.3 

39.9 -

45.5 

40.5 -

46.3 

40.5 -

46.4 

40.5 -

46.8 

50.2 -

50.3 

53.8 -

51.6 

53.8 -

53.9 

Mitsubishi 2010 

2008 

38.9 -

37.6 

39.2 -

37.8 

39.3 -

37.9 

39.3 -

39.6 

56.8 -

45.4 

56.8 -

45.4 

56.8 -

45.4 

56.8 -

45.4 

56.8 -

45.4 

Nissan 2010 

2008 

32.2 -

33.2 

32.2 -

33.5 

36.7 -

37.0 

39.4 -

38.3 

41.0 -

42.7 

43.5 -

44.1 

43.6 -

44.1 

47.1 -

44.4 

47.5 -

45.0 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

663 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

37.5 

39.9 -

42.4 

50.5 -

52.1 

50.5 -

52.2 

50.6 -

53.2 

50.6 -

53.2 

50.6 -

53.2 

63.6 -

57.3 

63.6 -

57.3 

Suzuki 2010 

2008 

38.2 -

34.9 

38.4 -

35.1 

40.3 -

42.7 

40.3 -

42.7 

49.6 -

52.6 

49.6 -

52.6 

49.6 -

52.6 

49.6 -

52.6 

49.6 -

58.7 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

31.5 -

32.4 

34.0 -

35.6 

38.0 -

38.8 

39.2 -

40.8 

41.1 -

43.0 

42.6 -

44.4 

44.8 -

45.3 

51.6 -

51.8 

52.0 -

52.2 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

30.8 -

31.9 

31.8 -

33.5 

34.1 -

36.5 

36.8 -

39.9 

39.5 -

42.0 

40.6 -

43.4 

42.4 -

44.3 

44.4 -

46.1 

46.6 -

47.7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

664 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

7% Annual Increase 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

36.3 

34.4 -

36.5 

35.3 -

36.6 

35.3 -

37.4 

36.0 -

38.6 

41.6 -

39.9 

41.6 -

39.8 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.6 

33.7 -

35.8 

33.8 -

35.9 

35.1 -

36.5 

35.2 -

36.3 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

32.3 

30.7 -

32.3 

30.7 -

32.3 

30.7 -

32.3 

30.7 -

32.3 

35.0 -

43.4 

42.0 -

46.7 

42.1 -

47.1 

43.6 -

49.0 

Ford 2010 

2008 

29.8 -

30.6 

30.4 -

32.5 

31.0 -

32.8 

34.2 -

36.4 

41.9 -

42.1 

42.1 -

43.0 

42.0 -

44.4 

42.6 -

45.1 

43.0 -

51.5 

Geely 2010 

2008 

28.7 -

31.0 

37.2 -

36.5 

37.9 -

37.1 

37.8 -

37.1 

39.3 -

37.1 

40.3 -

41.0 

42.4 -

41.0 

42.4 -

41.0 

42.4 -

41.0 

General Motors 2010 

2008 

28.9 -

29.3 

29.5 -

30.9 

32.9 -

36.1 

39.2 -

40.9 

39.4 -

41.5 

39.8 -

41.7 

40.4 -

42.9 

40.7 -

43.7 

44.4 -

46.0 

Honda 2010 

2008 

36.0 -

37.6 

36.7 -

37.8 

39.9 -

40.0 

40.5 -

40.7 

42.5 -

45.3 

45.8 -

52.0 

46.2 -

52.1 

48.5 -

53.1 

48.7 -

54.7 

Hyundai 2010 

2008 

36.5 -

37.4 

37.1 -

37.6 

46.6 -

43.0 

47.3 -

43.7 

47.3 -

43.7 

50.8 -

51.7 

51.3 -

51.7 

75.3 -

55.7 

75.3 -

55.8 

Kia 2010 

2008 

34.9 -

35.5 

35.2 -

36.0 

41.7 -

38.8 

41.7 -

41.6 

48.3 -

49.5 

48.3 -

49.5 

69.8 -

62.0 

70.5 -

62.6 

70.7 -

62.6 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

32.1 -

30.0 

42.0 -

44.2 

41.9 -

44.3 

42.6 -

45.1 

44.3 -

45.6 

44.3 -

45.6 

51.1 -

52.7 

54.1 -

53.2 

54.1 -

53.5 

Mitsubishi 2010 

2008 

38.9 -

37.9 

39.2 -

38.1 

39.3 -

38.2 

39.3 -

39.6 

56.8 -

45.0 

56.8 -

45.0 

56.8 -

45.0 

56.8 -

45.0 

56.8 -

45.0 

Nissan 2010 

2008 

33.2 -

33.7 

33.3 -

34.0 

37.7 -

37.4 

40.7 -

38.6 

42.7 -

42.9 

44.5 -

43.4 

44.6 -

43.6 

46.1 -

45.6 

47.1 -

45.7 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

665 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

37.5 

39.8 -

43.0 

50.4 -

53.1 

50.4 -

53.1 

50.5 -

53.2 

51.5 -

53.2 

51.5 -

53.2 

77.6 -

65.0 

77.6 -

65.0 

Suzuki 2010 

2008 

38.2 -

35.0 

38.4 -

35.2 

40.3 -

42.6 

40.3 -

42.6 

49.6 -

52.4 

49.6 -

52.4 

49.6 -

52.4 

49.6 -

52.4 

49.6 -

65.3 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

31.6 -

32.7 

34.4 -

37.0 

38.5 -

40.9 

39.7 -

42.8 

43.8 -

45.2 

44.8 -

46.7 

46.5 -

48.9 

50.5 -

50.9 

50.8 -

51.5 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

31.1 -

32.2 

32.2 -

34.1 

34.7 -

37.2 

37.8 -

40.2 

40.5 -

42.8 

41.4 -

44.2 

43.1 -

45.6 

44.7 -

46.8 

46.1 -

48.6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

666 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

Max Net Benefits, 3% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

37.4 

34.4 -

37.6 

35.3 -

38.0 

35.3 -

38.2 

36.0 -

39.1 

41.6 -

39.9 

41.6 -

39.8 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.8 

33.7 -

36.1 

33.8 -

36.2 

35.1 -

36.5 

35.2 -

36.4 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

35.0 -

39.7 

42.0 -

43.9 

42.1 -

44.7 

43.6 -

46.6 

Ford 2010 

2008 

30.0 -

32.0 

30.2 -

32.6 

31.5 -

33.3 

32.4 -

39.3 

39.2 -

43.0 

39.3 -

43.0 

39.3 -

43.4 

39.6 -

44.4 

40.0 -

44.5 

Geely 2010 

2008 

28.7 -

31.8 

37.2 -

36.5 

37.9 -

36.6 

37.8 -

36.6 

39.3 -

36.6 

40.3 -

40.2 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

29.4 -

31.7 

29.9 -

33.1 

32.5 -

36.9 

38.5 -

39.6 

38.6 -

40.3 

38.6 -

40.7 

39.0 -

41.6 

40.3 -

42.5 

43.1 -

44.3 

Honda 2010 

2008 

34.2 -

37.8 

34.6 -

38.1 

39.1 -

40.2 

39.8 -

41.1 

42.0 -

44.6 

45.1 -

47.7 

45.6 -

47.7 

46.8 -

48.6 

46.9 -

48.7 

Hyundai 2010 

2008 

36.7 -

37.7 

36.9 -

37.9 

44.8 -

43.6 

44.9 -

44.4 

44.9 -

44.4 

47.5 -

46.7 

47.5 -

46.7 

50.6 -

49.4 

51.1 -

49.5 

Kia 2010 

2008 

35.2 -

36.5 

35.4 -

36.9 

39.2 -

37.1 

39.3 -

39.1 

45.5 -

44.6 

45.4 -

44.7 

47.8 -

45.7 

47.8 -

45.7 

48.2 -

45.7 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

33.4 -

33.3 

41.3 -

42.3 

41.3 -

42.5 

41.9 -

43.6 

42.8 -

44.0 

42.8 -

44.0 

46.3 -

47.0 

49.0 -

48.1 

49.0 -

48.1 

Mitsubishi 2010 

2008 

38.9 -

38.0 

39.2 -

38.2 

39.3 -

38.3 

39.3 -

39.6 

51.9 -

48.0 

51.9 -

48.0 

51.9 -

47.9 

51.9 -

48.0 

51.9 -

48.0 

Nissan 2010 

2008 

32.9 -

35.7 

32.9 -

35.9 

37.2 -

38.0 

39.6 -

44.5 

41.3 -

46.5 

42.7 -

46.5 

42.8 -

46.4 

43.5 -

46.8 

44.9 -

46.8 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

 

667 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

39.2 

39.9 -

42.4 

50.3 -

52.2 

50.3 -

52.3 

50.5 -

52.3 

50.5 -

52.4 

50.5 -

52.3 

51.0 -

55.3 

51.0 -

55.3 

Suzuki 2010 

2008 

38.9 -

34.3 

39.2 -

34.5 

40.3 -

46.3 

40.3 -

46.3 

67.7 -

47.1 

67.7 -

47.1 

67.7 -

47.1 

67.7 -

47.2 

67.7 -

52.2 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

31.8 -

35.4 

34.4 -

38.1 

36.7 -

40.1 

37.8 -

40.8 

40.3 -

43.0 

41.6 -

43.9 

42.7 -

44.7 

44.1 -

46.3 

44.5 -

47.1 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

31.2 -

34.0 

32.1 -

35.2 

34.3 -

37.5 

36.7 -

40.2 

39.1 -

42.1 

39.9 -

42.8 

41.3 -

43.6 

42.2 -

44.6 

43.3 -

45.4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

668 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

Max Net Benefits, 7% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

37.4 

34.4 -

37.6 

35.3 -

38.0 

35.3 -

38.2 

36.0 -

39.1 

41.6 -

39.9 

41.6 -

39.8 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.8 

33.7 -

36.1 

33.8 -

36.2 

35.1 -

36.5 

35.2 -

36.4 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

30.7 -

33.5 

35.0 -

39.3 

42.0 -

43.0 

42.1 -

43.6 

43.6 -

45.1 

Ford 2010 

2008 

30.0 -

31.8 

30.2 -

32.4 

31.5 -

33.1 

32.2 -

35.5 

38.6 -

40.6 

38.7 -

40.8 

38.7 -

41.1 

38.9 -

41.6 

42.1 -

41.6 

Geely 2010 

2008 

28.7 -

31.8 

37.2 -

36.5 

37.9 -

36.6 

37.8 -

36.6 

39.3 -

36.6 

40.3 -

40.2 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

29.4 -

31.7 

29.9 -

33.0 

32.5 -

36.6 

38.4 -

38.8 

38.6 -

39.5 

38.6 -

39.8 

38.7 -

40.4 

39.9 -

41.2 

42.9 -

42.7 

Honda 2010 

2008 

34.2 -

37.3 

34.6 -

37.5 

39.1 -

40.3 

39.8 -

41.3 

42.4 -

43.7 

45.4 -

46.6 

46.2 -

46.6 

47.0 -

47.4 

47.2 -

47.6 

Hyundai 2010 

2008 

36.9 -

37.4 

37.2 -

37.6 

44.3 -

43.4 

44.9 -

43.6 

44.9 -

43.6 

46.3 -

45.2 

46.3 -

45.2 

50.9 -

46.2 

50.9 -

46.2 

Kia 2010 

2008 

35.1 -

35.8 

35.4 -

36.2 

39.5 -

36.9 

39.5 -

38.7 

44.9 -

44.5 

44.9 -

44.5 

45.9 -

45.3 

46.3 -

45.4 

46.3 -

45.7 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

33.4 -

32.8 

40.5 -

42.0 

40.4 -

42.1 

40.5 -

44.8 

41.9 -

44.6 

41.9 -

44.6 

45.9 -

46.8 

47.8 -

48.0 

47.7 -

48.0 

Mitsubishi 2010 

2008 

38.9 -

38.0 

39.2 -

38.2 

39.3 -

38.3 

39.3 -

39.6 

52.1 -

47.2 

52.1 -

47.2 

52.1 -

47.1 

52.1 -

47.2 

52.1 -

47.1 

Nissan 2010 

2008 

32.7 -

35.3 

32.8 -

35.5 

36.4 -

37.8 

38.5 -

44.6 

40.6 -

44.5 

41.6 -

44.5 

41.5 -

44.4 

44.0 -

44.6 

45.1 -

44.5 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

 

669 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

38.1 

39.9 -

41.1 

49.7 -

49.8 

49.7 -

49.9 

49.9 -

49.9 

49.9 -

50.0 

49.9 -

49.9 

54.0 -

53.3 

54.0 -

53.3 

Suzuki 2010 

2008 

38.7 -

33.2 

38.9 -

33.4 

40.3 -

45.6 

40.3 -

45.6 

49.6 -

47.1 

49.6 -

47.1 

49.6 -

47.1 

49.6 -

47.1 

49.6 -

48.5 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

32.1 -

35.2 

34.4 -

38.0 

37.0 -

39.9 

38.1 -

40.3 

40.1 -

41.8 

41.1 -

42.5 

42.8 -

42.8 

44.3 -

44.3 

44.6 -

45.2 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

31.3 -

33.8 

32.1 -

35.0 

34.3 -

37.4 

36.6 -

39.3 

38.9 -

41.0 

39.6 -

41.7 

41.1 -

42.2 

42.0 -

43.0 

43.8 -

43.8 
 

 

 

 

 

 

 

 

 

 

 

 

 

670 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

Total Cost=Total Benefit, 3% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

37.4 

34.4 -

37.6 

35.3 -

38.0 

35.3 -

38.2 

36.0 -

39.1 

41.6 -

39.9 

41.6 -

39.8 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.8 

33.7 -

36.1 

33.8 -

36.2 

35.1 -

36.5 

35.2 -

36.4 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

35.0 -

40.0 

42.0 -

43.5 

42.1 -

44.2 

43.6 -

46.9 

Ford 2010 

2008 

29.8 -

32.5 

29.9 -

33.0 

30.9 -

33.7 

33.1 -

39.5 

39.2 -

43.6 

39.3 -

43.6 

39.3 -

44.2 

39.5 -

44.8 

41.4 -

45.2 

Geely 2010 

2008 

28.7 -

31.8 

37.2 -

36.5 

37.9 -

36.6 

37.8 -

36.6 

39.3 -

36.6 

40.3 -

40.2 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

29.4 -

31.7 

29.9 -

33.1 

32.5 -

36.9 

38.5 -

39.9 

38.6 -

40.7 

38.6 -

40.9 

39.0 -

42.1 

40.3 -

42.8 

42.5 -

44.6 

Honda 2010 

2008 

36.1 -

38.2 

36.6 -

38.4 

39.1 -

41.8 

39.9 -

42.7 

42.1 -

45.1 

44.8 -

49.0 

45.5 -

49.0 

46.9 -

49.6 

47.1 -

49.7 

Hyundai 2010 

2008 

37.2 -

38.9 

37.4 -

39.2 

44.8 -

44.4 

45.1 -

44.9 

45.1 -

44.9 

47.5 -

48.2 

47.5 -

48.2 

50.6 -

50.3 

51.1 -

50.4 

Kia 2010 

2008 

35.2 -

36.8 

35.4 -

37.2 

40.0 -

37.5 

40.0 -

39.6 

44.4 -

45.2 

44.3 -

45.2 

45.7 -

45.5 

46.7 -

45.5 

46.7 -

46.1 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

33.4 -

33.4 

41.3 -

42.5 

41.3 -

42.7 

41.9 -

45.4 

43.6 -

45.0 

43.6 -

44.8 

47.6 -

46.7 

49.6 -

48.3 

49.6 -

48.3 

Mitsubishi 2010 

2008 

38.9 -

38.0 

39.2 -

38.2 

39.3 -

38.3 

39.3 -

39.6 

51.9 -

48.0 

51.9 -

48.0 

51.9 -

47.9 

51.9 -

48.0 

51.9 -

48.0 

Nissan 2010 

2008 

32.9 -

35.8 

32.9 -

36.0 

37.1 -

37.9 

39.7 -

44.3 

41.7 -

46.2 

42.2 -

46.1 

42.1 -

46.3 

44.0 -

46.7 

44.5 -

46.6 
 

 

 

 

 

 

 

 

 

671 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

39.4 

39.9 -

42.5 

49.7 -

51.9 

49.7 -

52.0 

49.9 -

52.1 

49.9 -

52.1 

49.9 -

52.1 

54.0 -

55.9 

54.0 -

55.9 

Suzuki 2010 

2008 

39.1 -

34.4 

39.4 -

34.6 

39.5 -

45.0 

39.5 -

45.0 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

52.0 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

32.0 -

35.5 

34.5 -

38.1 

36.8 -

40.1 

37.9 -

40.6 

41.9 -

43.0 

42.2 -

43.7 

43.2 -

44.8 

44.8 -

46.5 

45.1 -

47.2 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

31.4 -

34.2 

32.2 -

35.4 

34.2 -

37.8 

36.9 -

40.4 

39.4 -

42.3 

39.9 -

43.0 

41.3 -

43.9 

42.3 -

44.8 

43.6 -

45.7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

672 

Estimated Achievable Fuel Economy Levels, by Alternative 

Estimated mpg 

Light Trucks 

Total Cost=Total Benefit, 7% Discount Rate 

Manufacturer Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 

Aston Martin 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

BMW 2010 

2008 

34.4 -

37.4 

34.4 -

37.6 

35.3 -

38.0 

35.3 -

38.2 

36.0 -

39.1 

41.6 -

39.9 

41.6 -

39.8 

41.6 -

39.9 

42.1 -

39.8 

Daimler 2010 

2008 

32.2 -

35.8 

33.7 -

36.1 

33.8 -

36.2 

35.1 -

36.5 

35.2 -

36.4 

37.1 -

37.6 

38.0 -

37.5 

38.1 -

37.6 

38.5 -

37.8 

Fiat 2010 

2008 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

30.7 -

33.7 

35.0 -

40.0 

42.0 -

43.5 

42.1 -

44.2 

43.6 -

46.9 

Ford 2010 

2008 

29.8 -

32.5 

29.9 -

33.0 

30.9 -

33.7 

33.1 -

39.5 

39.2 -

43.6 

39.3 -

43.6 

39.3 -

44.2 

39.5 -

44.8 

41.4 -

45.2 

Geely 2010 

2008 

28.7 -

31.8 

37.2 -

36.5 

37.9 -

36.6 

37.8 -

36.6 

39.3 -

36.6 

40.3 -

40.2 

42.4 -

41.6 

42.4 -

41.6 

42.4 -

41.6 

General Motors 2010 

2008 

29.4 -

31.7 

29.9 -

33.1 

32.5 -

36.9 

38.5 -

39.9 

38.6 -

40.7 

38.6 -

40.9 

39.0 -

42.1 

40.3 -

42.8 

42.5 -

44.6 

Honda 2010 

2008 

36.1 -

38.2 

36.6 -

38.4 

39.1 -

41.8 

39.9 -

42.7 

42.1 -

45.1 

44.8 -

49.0 

45.5 -

49.0 

46.9 -

49.6 

47.1 -

49.7 

Hyundai 2010 

2008 

37.2 -

38.9 

37.4 -

39.2 

44.8 -

44.4 

45.1 -

44.9 

45.1 -

44.9 

47.5 -

48.2 

47.5 -

48.2 

50.6 -

50.3 

51.1 -

50.4 

Kia 2010 

2008 

35.2 -

36.8 

35.4 -

37.2 

40.0 -

37.5 

40.0 -

39.6 

44.4 -

45.2 

44.3 -

45.2 

45.7 -

45.5 

46.7 -

45.5 

46.7 -

46.1 

Lotus 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Mazda 2010 

2008 

33.4 -

33.4 

41.3 -

42.5 

41.3 -

42.7 

41.9 -

45.4 

43.6 -

45.0 

43.6 -

44.8 

47.6 -

46.7 

49.6 -

48.3 

49.6 -

48.3 

Mitsubishi 2010 

2008 

38.9 -

38.0 

39.2 -

38.2 

39.3 -

38.3 

39.3 -

39.6 

51.9 -

48.0 

51.9 -

48.0 

51.9 -

47.9 

51.9 -

48.0 

51.9 -

48.0 

Nissan 2010 

2008 

32.9 -

35.8 

32.9 -

36.0 

37.1 -

37.9 

39.7 -

44.3 

41.7 -

46.2 

42.2 -

46.1 

42.1 -

46.3 

44.0 -

46.7 

44.5 -

46.6 

Porsche 2010 

2008 

28.0 -

30.4 

28.5 -

32.0 

36.9 -

34.6 

36.9 -

34.6 

36.9 -

34.6 

37.6 -

35.1 

37.6 -

37.6 

37.6 -

37.6 

37.6 -

37.6 
 

 

 

 

 

 

 

673 

Spyker 2010 

2008 

- ­

32.9 

- ­

34.5 

- ­

34.6 

- ­

34.6 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

- ­

37.2 

Subaru 2010 

2008 

39.3 -

39.4 

39.9 -

42.5 

49.7 -

51.9 

49.7 -

52.0 

49.9 -

52.1 

49.9 -

52.1 

49.9 -

52.1 

54.0 -

55.9 

54.0 -

55.9 

Suzuki 2010 

2008 

39.1 -

34.4 

39.4 -

34.6 

39.5 -

45.0 

39.5 -

45.0 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

46.9 

52.5 -

52.0 

Tata 2010 

2008 

28.3 -

30.5 

28.4 -

30.7 

29.0 -

31.6 

29.0 -

31.7 

33.5 -

35.8 

33.7 -

35.8 

33.7 -

35.8 

33.7 -

35.9 

33.7 -

35.8 

Tesla 2010 

2008 

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- ­

- -

Toyota 2010 

2008 

32.0 -

35.5 

34.5 -

38.1 

36.8 -

40.1 

37.9 -

40.6 

41.9 -

43.0 

42.2 -

43.7 

43.2 -

44.8 

44.8 -

46.5 

45.1 -

47.2 

Volkswagen 2010 

2008 

30.3 -

28.1 

32.9 -

30.9 

35.6 -

37.3 

40.1 -

37.3 

40.1 -

37.7 

40.2 -

37.6 

40.9 -

37.9 

42.3 -

39.5 

43.9 -

39.5 

Total/Average 2010 

2008 

31.4 -

34.2 

32.2 -

35.4 

34.2 -

37.8 

36.9 -

40.4 

39.4 -

42.3 

39.9 -

43.0 

41.3 -

43.9 

42.3 -

44.8 

43.6 -

45.7 
674 

VII.	 COST AND SALES IMPACTS 

The technology application algorithm implemented with the Volpe model was used as the basis 

for estimating costs for the fleet. Here, costs refer to costs or fines to manufacturers relative to 

the adjusted baseline of MY 2016. Manufacturers’ costs or fines to bring light duty fleets into 

compliance with MY 2016 standards are outside the scope of these costs as they have been 

addressed in the final CAFE rulemaking for MYs 2012 to 2016. 

Tables VII-1a to 1v show the estimated cost per vehicle and incremental total costs in millions 

for the various alternatives for passenger cars. Tables VII-2a to 2v show the estimated cost per 

vehicle and incremental total costs in millions for the various alternatives for light trucks. 

The costs for several manufacturers are the fines that these manufacturers would have to pay in 

addition to the technology improvements on an average vehicle basis. We assume that the costs 

of fines will be passed on to consumers. The incremental total cost tables show the estimated 

total manufacturer costs and fines in millions of dollars. Later in the analysis, when we are 

considering total societal costs and benefits, fines are not included, since fines are transfer 

payments and not technology costs. 

Note that the choice of the discount rate (3% or 7%) impacts only the Max Net Benefits and 

Total Cost = Total Benefit scenarios. Therefore, additional detail is given in Tables VII-1 and 

VII-2 for these scenarios to highlight the results under both discount rates. 
675 

Table VII-1a 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Preferred Alternative

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$73 -

$84 

$150 -

$161 

$227 -

$249 

$321 -

$343 

$420 -

$447 

$541 -

$568 

$662 -

$700 

$783 -

$832 

BMW 

2010 2008 

$87 -

$78 

$251 -

$302 

$307 -

$320 

$388 -

$336 

$535 -

$610 

$814 -

$771 

$961 -

$939 

$1,808 

$2,141 

Daimler 

2010 2008 

$68 -

$90 

$141 -

$157 

$218 -

$253 

$303 -

$694 

$429 -

$789 

$715 -

$1,010 

$1,054 -

$1,413 

$1,162 

$1,555 

Fiat 

2010 2008 

$324 -

$257 

$400 -

$495 

$656 -

$491 

$885 -

$916 

$1,160 -

$956 

$1,159 -

$1,057 

$1,415 -

$1,357 

$1,614 

$1,399 

Ford 

2010 2008 

$321 -

$141 

$328 -

$162 

$458 -

$467 

$803 -

$902 

$914 -

$1,278 

$1,084 -

$1,612 

$1,074 -

$1,637 

$1,460 

$1,616 

Geely 

2010 2008 

$73 -

$189 

$313 -

$370 

$767 -

$726 

$809 -

$707 

$815 -

$857 

$954 -

$970 

$1,159 -

$1,240 

$1,426 

$1,421 

General Motors 

2010 2008 

$207 -

$235 

$476 -

$556 

$500 -

$692 

$721 -

$1,058 

$915 -

$1,175 

$898 -

$1,165 

$1,131 -

$1,298 

$1,154 

$1,293 

Honda 

2010 2008 

$250 -

$157 

$663 -

$428 

$728 -

$474 

$720 -

$512 

$1,028 -

$1,001 

$1,018 -

$1,101 

$1,196 -

$1,188 

$1,204 

$1,204 

Hyundai 

2010 2008 

$561 -

$551 

$591 -

$607 

$756 -

$899 

$737 -

$933 

$892 -

$1,005 

$1,091 -

$1,114 

$1,114 -

$1,115 

$1,222 

$1,091 

Kia 

2010 2008 

$339 -

$186 

$322 -

$106 

$636 -

$543 

$876 -

$932 

$953 -

$982 

$1,111 -

$1,056 

$1,125 -

$1,098 

$1,107 

$1,074 

Lotus 

2010 2008 

$242 -

$90 

$322 -

$178 

$1,228 -

$255 

$1,306 -

$354 

$1,396 -

$469 

$1,503 -

$601 

$758 -

$739 

$894 -

$882 

Mazda 

2010 2008 

$458 -

$417 

$508 -

$599 

$512 -

$542 

$880 -

$955 

$856 -

$924 

$1,219 -

$1,461 

$1,307 -

$1,438 

$1,300 

$1,479 

Mitsubishi 

2010 2008 

$397 -

$267 

$503 -

$630 

$456 -

$601 

$1,357 -

$1,429 

$2,121 -

$2,156 

$2,102 -

$2,110 

$2,065 -

$2,081 

$2,063 

$2,407 
676 

Nissan 

2010 2008 

$361 -

$190 

$437 -

$318 

$656 -

$868 

$655 -

$975 

$717 -

$979 

$898 -

$1,330 

$941 -

$1,406 

$1,235 

$1,621 

Porsche 

2010 2008 

$62 -

$79 

$110 -

$310 

$168 -

$410 

$283 -

$493 

$518 -

$603 

$1,200 -

$635 

$1,388 -

$774 

$1,521 

$886 

Spyker 

2010 2008 

- ­

$79 

- ­

$203 

- ­

$334 

- ­

$453 

- ­

$572 

- ­

$742 

- ­

$1,259 

- ­

$1,965 

Subaru 

2010 2008 

$13 -

$321 

$15 -

$351 

$590 -

$593 

$1,498 -

$1,437 

$1,469 -

$1,384 

$1,467 -

$1,342 

$1,480 -

$1,498 

$2,065 

$1,674 

Suzuki 

2010 2008 

$349 -

$5 

$346 -

$16 

$682 -

$1,002 

$813 -

$1,096 

$1,085 -

$1,210 

$1,185 -

$1,288 

$1,210 -

$1,268 

$1,192 

$1,313 

Tata 

2010 2008 

$73 -

$342 

$153 -

$676 

$231 -

$621 

$313 -

$649 

$378 -

$789 

$484 -

$1,036 

$849 -

$1,260 

$962 -

$1,367 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$257 -

$205 

$319 -

$414 

$755 -

$558 

$811 -

$718 

$1,006 -

$926 

$1,014 -

$929 

$1,003 -

$915 

$1,291 

$1,506 

Volkswagen 

2010 2008 

$170 -

$82 

$493 -

$171 

$570 -

$251 

$757 -

$776 

$920 -

$953 

$1,037 -

$1,130 

$1,183 -

$1,328 

$1,337 

$1,392 

Total/Average 

2010 2008 

$284 -

$208 

$424 -

$377 

$603 -

$571 

$762 -

$837 

$934 -

$1,034 

$1,024 -

$1,168 

$1,129 -

$1,255 

$1,328 

$1,440 
677 

Table VII-1b 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Preferred Alternative

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

BMW 

2010 2008 

$28 -

$24 

$80 -

$98 

$100 -

$111 

$128 -

$120 

$180 -

$219 

$278 -

$278 

$333 -

$339 

$647 -

$831 

Daimler 

2010 2008 

$17 -

$26 

$34 -

$43 

$54 -

$71 

$74 -

$202 

$107 -

$237 

$180 -

$308 

$267 -

$442 

$301 -

$517 

Fiat 

2010 2008 

$237 -

$110 

$295 -

$202 

$506 -

$197 

$697 -

$390 

$936 -

$413 

$962 -

$460 

$1,206 -

$591 

$1,420 

$612 

Ford 

2010 2008 

$433 -

$184 

$442 -

$212 

$615 -

$623 

$1,083 -

$1,243 

$1,244 -

$1,791 

$1,494 -

$2,281 

$1,499 -

$2,414 

$2,071 

$2,430 

Geely 

2010 2008 

$4 -

$17 

$18 -

$33 

$46 -

$67 

$49 -

$66 

$50 -

$79 

$60 -

$90 

$73 -

$120 

$93 -

$141 

General Motors 

2010 2008 

$342 -

$357 

$770 -

$856 

$806 -

$1,082 

$1,163 -

$1,704 

$1,487 -

$1,914 

$1,471 -

$1,911 

$1,869 -

$2,165 

$1,934 

$2,196 

Honda 

2010 2008 

$280 -

$181 

$755 -

$487 

$835 -

$542 

$841 -

$596 

$1,221 -

$1,200 

$1,235 -

$1,362 

$1,481 -

$1,503 

$1,526 

$1,574 

Hyundai 

2010 2008 

$485 -

$326 

$502 -

$351 

$648 -

$524 

$635 -

$558 

$779 -

$616 

$968 -

$700 

$1,002 -

$707 

$1,123 

$717 

Kia 

2010 2008 

$117 -

$60 

$109 -

$33 

$209 -

$171 

$287 -

$302 

$315 -

$325 

$373 -

$358 

$381 -

$376 

$384 -

$378 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$117 -

$98 

$126 -

$145 

$127 -

$134 

$219 -

$237 

$213 -

$231 

$308 -

$371 

$333 -

$385 

$337 -

$403 
678 

Mitsubishi 

2010 2008 

$24 -

$21 

$29 -

$47 

$28 -

$45 

$82 -

$109 

$131 -

$166 

$133 -

$165 

$132 -

$164 

$138 -

$198 

Nissan 

2010 2008 

$321 -

$166 

$380 -

$270 

$573 -

$742 

$572 -

$860 

$631 -

$894 

$795 -

$1,247 

$841 -

$1,342 

$1,121 

$1,593 

Porsche 

2010 2008 

$1 -

$3 

$2 -

$11 

$3 -

$15 

$5 -

$18 

$9 -

$22 

$21 -

$23 

$24 -

$29 

$27 -

$35 

Spyker 

2010 2008 

- ­

$2 

- ­

$4 

- ­

$7 

- ­

$10 

- ­

$12 

- ­

$16 

- ­

$28 

- ­

$45 

Subaru 

2010 2008 

$3 -

$72 

$3 -

$76 

$121 -

$129 

$308 -

$321 

$304 -

$319 

$308 -

$320 

$313 -

$362 

$445 -

$416 

Suzuki 

2010 2008 

$15 -

$0 

$15 -

$1 

$30 -

$91 

$36 -

$103 

$49 -

$116 

$54 -

$126 

$56 -

$126 

$57 -

$132 

Tata 

2010 2008 

$2 -

$19 

$4 -

$38 

$7 -

$36 

$9 -

$38 

$11 -

$46 

$14 -

$61 

$25 -

$76 

$29 -

$87 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$392 -

$379 

$479 -

$760 

$1,140 -

$1,025 

$1,228 -

$1,352 

$1,539 -

$1,763 

$1,569 -

$1,845 

$1,572 -

$1,863 

$2,064 

$3,133 

Volkswagen 

2010 2008 

$82 -

$45 

$232 -

$92 

$264 -

$135 

$348 -

$430 

$424 -

$558 

$482 -

$670 

$553 -

$793 

$636 -

$842 

Total/Average 

2010 2008 

$2,901 -

$2,089 

$4,276 -

$3,761 

$6,111 -

$5,745 

$7,764 -

$8,659 

$9,630 -

$10,923 

$10,705 -

$12,593 

$11,962 -

$13,825 

$14,356 

$16,280 
679 

Table VII-1c 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2009 Dollars) 

2% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$40 -

$51 

$84 -

$95 

$128 -

$139 

$172 -

$189 

$222 -

$233 

$266 -

$282 

$315 -

$337 

$359 -

$392 

BMW 

2010 2008 

$52 -

$74 

$200 -

$219 

$240 -

$218 

$256 -

$286 

$326 -

$440 

$520 -

$606 

$596 -

$667 

$1,377 

$1,608 

Daimler 

2010 2008 

$40 -

$54 

$68 -

$101 

$123 -

$166 

$143 -

$546 

$152 -

$586 

$449 -

$851 

$707 -

$1,074 

$740 -

$1,119 

Fiat 

2010 2008 

$302 -

$101 

$281 -

$374 

$359 -

$359 

$520 -

$630 

$636 -

$607 

$633 -

$604 

$696 -

$770 

$693 -

$772 

Ford 

2010 2008 

$230 -

$18 

$237 -

$25 

$357 -

$107 

$559 -

$313 

$587 -

$431 

$688 -

$492 

$694 -

$479 

$704 -

$536 

Geely 

2010 2008 

$40 -

$181 

$300 -

$335 

$746 -

$640 

$745 -

$640 

$743 -

$709 

$729 -

$700 

$812 -

$892 

$850 -

$1,021 

General Motors 

2010 2008 

$2 -

$153 

$181 -

$347 

$188 -

$394 

$390 -

$542 

$632 -

$621 

$626 -

$624 

$676 -

$677 

$672 -

$731 

Honda 

2010 2008 

$151 -

$43 

$496 -

$75 

$498 -

$0 

$509 -

$21 

$518 -

$271 

$546 -

$308 

$684 -

$459 

$693 -

$521 

Hyundai 

2010 2008 

$234 -

$438 

$260 -

$492 

$281 -

$558 

$299 -

$554 

$565 -

$565 

$601 -

$588 

$613 -

$612 

$729 -

$555 

Kia 

2010 2008 

$275 -

$159 

$272 -

$143 

$427 -

$158 

$550 -

$263 

$592 -

$444 

$651 -

$505 

$680 -

$585 

$685 -

$561 

Lotus 

2010 2008 

$209 -

$51 

$250 -

$101 

$1,118 -

$139 

$1,147 -

$189 

$1,176 -

$244 

$1,212 -

$293 

$384 -

$348 

$437 -

$409 

Mazda 

2010 2008 

$234 -

$68 

$247 -

$259 

$227 -

$266 

$289 -

$559 

$297 -

$528 

$471 -

$786 

$502 -

$772 

$502 -

$762 
680 

Mitsubishi 

2010 2008 

$174 -

$239 

$236 -

$284 

$215 -

$269 

$468 -

$433 

$686 -

$827 

$681 -

$794 

$664 -

$784 

$690 -

$777 

Nissan 

2010 2008 

$38 -

$188 

$46 -

$278 

$356 -

$633 

$426 -

$677 

$403 -

$679 

$457 -

$730 

$500 -

$792 

$845 -

$1,078 

Porsche 

2010 2008 

$29 -

$78 

$44 -

$247 

$91 -

$317 

$153 -

$323 

$274 -

$378 

$912 -

$327 

$932 -

$380 

$1,040 

$402 

Spyker 

2010 2008 

- ­

$49 

- ­

$153 

- ­

$251 

- ­

$295 

- ­

$360 

- ­

$448 

- ­

$891 

- ­

$1,370 

Subaru 

2010 2008 

$5 -

$402 

$5 -

$409 

$296 -

$1,838 

$635 -

$1,506 

$616 -

$1,465 

$608 -

$1,420 

$599 -

$1,400 

$627 -

$1,396 

Suzuki 

2010 2008 

$440 -

$35 

$434 -

$45 

$328 -

$133 

$276 -

$140 

$310 -

$170 

$441 -

$188 

$437 -

$186 

$433 -

$190 

Tata 

2010 2008 

$46 -

$271 

$87 -

$582 

$126 -

$527 

$170 -

$546 

$180 -

$599 

$220 -

$742 

$513 -

$880 

$555 -

$857 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$78 -

$107 

$131 -

$250 

$361 -

$338 

$409 -

$428 

$561 -

$447 

$567 -

$488 

$559 -

$482 

$776 -

$530 

Volkswagen 

2010 2008 

$99 -

$65 

$436 -

$96 

$454 -

$150 

$627 -

$606 

$682 -

$703 

$695 -

$754 

$740 -

$841 

$850 -

$834 

Total/Average 

2010 2008 

$130 -

$125 

$232 -

$224 

$333 -

$322 

$443 -

$449 

$546 -

$529 

$592 -

$578 

$638 -

$631 

$744 -

$719 
681 

Table VII-1d 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

2% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

BMW 

2010 2008 

$17 -

$23 

$64 -

$71 

$79 -

$75 

$84 -

$102 

$110 -

$158 

$178 -

$218 

$207 -

$241 

$493 -

$624 

Daimler 

2010 2008 

$10 -

$15 

$16 -

$28 

$30 -

$47 

$35 -

$159 

$38 -

$176 

$113 -

$259 

$179 -

$336 

$191 -

$372 

Fiat 

2010 2008 

$221 -

$43 

$208 -

$153 

$277 -

$144 

$409 -

$268 

$514 -

$262 

$525 -

$263 

$593 -

$335 

$610 -

$338 

Ford 

2010 2008 

$310 -

$23 

$319 -

$33 

$478 -

$142 

$753 -

$432 

$798 -

$604 

$947 -

$696 

$968 -

$706 

$998 -

$806 

Geely 

2010 2008 

$2 -

$16 

$17 -

$30 

$45 -

$59 

$45 -

$59 

$46 -

$66 

$46 -

$65 

$51 -

$86 

$55 -

$101 

General Motors 

2010 2008 

$3 -

$233 

$293 -

$534 

$304 -

$617 

$629 -

$873 

$1,026 -

$1,011 

$1,026 -

$1,024 

$1,117 -

$1,129 

$1,127 

$1,243 

Honda 

2010 2008 

$170 -

$50 

$566 -

$85 

$572 -

$0 

$594 -

$24 

$615 -

$325 

$662 -

$381 

$847 -

$580 

$879 -

$681 

Hyundai 

2010 2008 

$203 -

$259 

$221 -

$284 

$241 -

$325 

$257 -

$331 

$493 -

$346 

$533 -

$369 

$551 -

$388 

$670 -

$365 

Kia 

2010 2008 

$95 -

$51 

$92 -

$45 

$141 -

$50 

$180 -

$85 

$195 -

$147 

$219 -

$171 

$230 -

$201 

$238 -

$197 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$59 -

$16 

$62 -

$63 

$56 -

$66 

$72 -

$139 

$74 -

$132 

$119 -

$200 

$128 -

$207 

$130 -

$207 
682 

Mitsubishi 

2010 2008 

$11 -

$18 

$14 -

$21 

$13 -

$20 

$28 -

$33 

$42 -

$64 

$43 -

$62 

$42 -

$62 

$46 -

$64 

Nissan 

2010 2008 

$34 -

$164 

$40 -

$236 

$311 -

$540 

$372 -

$597 

$354 -

$619 

$404 -

$684 

$447 -

$756 

$767 -

$1,060 

Porsche 

2010 2008 

$1 -

$3 

$1 -

$9 

$2 -

$11 

$3 -

$12 

$5 -

$14 

$16 -

$12 

$16 -

$14 

$18 -

$16 

Spyker 

2010 2008 

- ­

$1 

- ­

$3 

- ­

$5 

- ­

$6 

- ­

$8 

- ­

$10 

- ­

$20 

- ­

$31 

Subaru 

2010 2008 

$1 -

$90 

$1 -

$89 

$61 -

$399 

$131 -

$336 

$127 -

$338 

$127 -

$339 

$127 -

$338 

$135 -

$347 

Suzuki 

2010 2008 

$19 -

$3 

$18 -

$4 

$14 -

$12 

$12 -

$13 

$14 -

$16 

$20 -

$18 

$20 -

$18 

$21 -

$19 

Tata 

2010 2008 

$1 -

$15 

$2 -

$33 

$4 -

$30 

$5 -

$32 

$5 -

$35 

$6 -

$44 

$15 -

$53 

$17 -

$55 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$119 -

$197 

$197 -

$458 

$545 -

$620 

$620 -

$806 

$858 -

$851 

$877 -

$970 

$877 -

$981 

$1,240 

$1,102 

Volkswagen 

2010 2008 

$48 -

$36 

$205 -

$52 

$210 -

$80 

$288 -

$336 

$314 -

$412 

$323 -

$447 

$346 -

$502 

$404 -

$505 

Total/Average 

2010 2008 

$1,323 -

$1,257 

$2,336 -

$2,230 

$3,382 -

$3,244 

$4,519 -

$4,646 

$5,630 -

$5,584 

$6,186 -

$6,233 

$6,763 -

$6,954 

$8,040 

$8,134 
683 

Table VII-1e 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

3% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$62 -

$73 

$128 -

$139 

$194 -

$216 

$266 -

$288 

$343 -

$359 

$420 -

$442 

$497 -

$530 

$574 -

$612 

BMW 

2010 2008 

$46 -

$75 

$252 -

$260 

$328 -

$304 

$387 -

$375 

$563 -

$482 

$683 -

$760 

$798 -

$850 

$1,599 

$1,922 

Daimler 

2010 2008 

$57 -

$59 

$123 -

$156 

$189 -

$226 

$254 -

$585 

$257 -

$708 

$597 -

$889 

$886 -

$1,251 

$951 -

$1,346 

Fiat 

2010 2008 

$337 -

$242 

$338 -

$478 

$490 -

$449 

$699 -

$864 

$871 -

$858 

$872 -

$899 

$955 -

$958 

$957 -

$957 

Ford 

2010 2008 

$352 -

$94 

$365 -

$193 

$486 -

$318 

$671 -

$586 

$707 -

$743 

$795 -

$917 

$788 -

$875 

$838 -

$937 

Geely 

2010 2008 

$62 -

$220 

$357 -

$372 

$769 -

$727 

$786 -

$724 

$831 -

$809 

$822 -

$846 

$1,001 -

$1,083 

$1,206 

$1,211 

General Motors 

2010 2008 

$69 -

$234 

$308 -

$506 

$343 -

$545 

$528 -

$818 

$693 -

$917 

$680 -

$922 

$725 -

$923 

$771 -

$996 

Honda 

2010 2008 

$109 -

$144 

$358 -

$338 

$402 -

$274 

$403 -

$290 

$403 -

$596 

$462 -

$713 

$788 -

$735 

$827 -

$779 

Hyundai 

2010 2008 

$579 -

$533 

$610 -

$590 

$757 -

$678 

$854 -

$679 

$824 -

$693 

$973 -

$669 

$998 -

$657 

$1,119 

$651 

Kia 

2010 2008 

$235 -

$11 

$232 -

($75) 

$605 -

$316 

$927 -

$636 

$998 -

$812 

$1,199 -

$821 

$1,197 -

$820 

$1,177 

$813 

Lotus 

2010 2008 

$231 -

$79 

$300 -

$156 

$1,195 -

$216 

$1,251 -

$299 

$1,314 -

$381 

$1,377 -

$464 

$582 -

$557 

$668 -

$645 

Mazda 

2010 2008 

$234 -

$191 

$283 -

$378 

$261 -

$345 

$451 -

$679 

$421 -

$652 

$809 -

$1,165 

$905 -

$1,178 

$908 -

$1,187 
684 

Mitsubishi 

2010 2008 

$168 -

$373 

$280 -

$474 

$250 -

$442 

$576 -

$864 

$1,064 -

$1,277 

$1,078 -

$1,235 

$1,059 -

$1,217 

$1,070 

$1,487 

Nissan 

2010 2008 

$9 -

$170 

$19 -

$260 

$540 -

$798 

$592 -

$861 

$589 -

$868 

$799 -

$1,132 

$867 -

$1,146 

$1,023 

$1,153 

Porsche 

2010 2008 

$51 -

$116 

$88 -

$302 

$191 -

$422 

$301 -

$442 

$481 -

$515 

$1,096 -

$498 

$1,113 -

$592 

$1,307 

$650 

Spyker 

2010 2008 

- ­

$71 

- ­

$180 

- ­

$318 

- ­

$400 

- ­

$492 

- ­

$616 

- ­

$1,088 

- ­

$1,740 

Subaru 

2010 2008 

$5 -

$81 

$5 -

$97 

$463 -

$278 

$1,176 -

$1,198 

$1,155 -

$1,148 

$1,158 -

$1,112 

$1,130 -

$1,096 

$1,663 

$1,099 

Suzuki 

2010 2008 

$443 -

($69) 

$437 -

($56) 

$573 -

$771 

$661 -

$786 

$716 -

$889 

$730 -

$859 

$717 -

$854 

$729 -

$843 

Tata 

2010 2008 

$68 -

$342 

$131 -

$737 

$198 -

$667 

$264 -

$696 

$301 -

$781 

$363 -

$860 

$689 -

$1,330 

$759 -

$1,371 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$254 -

$156 

$316 -

$378 

$545 -

$522 

$582 -

$629 

$631 -

$694 

$643 -

$727 

$645 -

$721 

$1,060 

$710 

Volkswagen 

2010 2008 

$161 -

$92 

$469 -

$152 

$508 -

$244 

$679 -

$697 

$805 -

$839 

$896 -

$991 

$999 -

$1,030 

$1,222 

$1,237 

Total/Average 

2010 2008 

$209 -

$172 

$317 -

$330 

$476 -

$455 

$608 -

$656 

$673 -

$764 

$755 -

$865 

$833 -

$885 

$986 -

$962 
685 

Table VII-1f 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

3% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

BMW 

2010 2008 

$15 -

$24 

$80 -

$84 

$107 -

$105 

$128 -

$134 

$189 -

$173 

$233 -

$274 

$277 -

$306 

$573 -

$746 

Daimler 

2010 2008 

$14 -

$17 

$30 -

$43 

$46 -

$64 

$62 -

$170 

$64 -

$213 

$150 -

$271 

$225 -

$391 

$246 -

$447 

Fiat 

2010 2008 

$246 -

$104 

$250 -

$195 

$378 -

$181 

$551 -

$368 

$703 -

$371 

$724 -

$391 

$814 -

$417 

$842 -

$418 

Ford 

2010 2008 

$474 -

$122 

$492 -

$253 

$651 -

$423 

$905 -

$808 

$961 -

$1,042 

$1,095 -

$1,297 

$1,099 -

$1,290 

$1,189 

$1,409 

Geely 

2010 2008 

$4 -

$19 

$21 -

$33 

$46 -

$67 

$47 -

$67 

$51 -

$75 

$51 -

$78 

$63 -

$105 

$79 -

$120 

General Motors 

2010 2008 

$114 -

$355 

$498 -

$778 

$552 -

$851 

$852 -

$1,317 

$1,125 -

$1,494 

$1,114 -

$1,513 

$1,198 -

$1,539 

$1,292 

$1,693 

Honda 

2010 2008 

$122 -

$166 

$408 -

$385 

$461 -

$314 

$470 -

$337 

$479 -

$715 

$560 -

$883 

$976 -

$930 

$1,049 

$1,018 

Hyundai 

2010 2008 

$501 -

$316 

$519 -

$341 

$649 -

$395 

$735 -

$406 

$720 -

$425 

$863 -

$420 

$898 -

$417 

$1,029 

$428 

Kia 

2010 2008 

$81 -

$4 

$79 -

($23) 

$199 -

$99 

$304 -

$206 

$330 -

$269 

$403 -

$278 

$406 -

$281 

$408 -

$286 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$59 -

$45 

$71 -

$92 

$65 -

$85 

$112 -

$168 

$105 -

$163 

$204 -

$296 

$231 -

$315 

$236 -

$323 
686 

Mitsubishi 

2010 2008 

$10 -

$29 

$16 -

$36 

$15 -

$33 

$35 -

$66 

$66 -

$98 

$68 -

$97 

$68 -

$96 

$72 -

$122 

Nissan 

2010 2008 

$8 -

$148 

$16 -

$221 

$471 -

$682 

$517 -

$760 

$518 -

$793 

$707 -

$1,061 

$775 -

$1,094 

$929 -

$1,133 

Porsche 

2010 2008 

$1 -

$4 

$2 -

$11 

$3 -

$15 

$5 -

$16 

$8 -

$19 

$19 -

$18 

$19 -

$22 

$23 -

$26 

Spyker 

2010 2008 

- ­

$1 

- ­

$4 

- ­

$6 

- ­

$8 

- ­

$10 

- ­

$13 

- ­

$24 

- ­

$40 

Subaru 

2010 2008 

$1 -

$18 

$1 -

$21 

$95 -

$60 

$242 -

$268 

$239 -

$265 

$243 -

$265 

$239 -

$265 

$358 -

$273 

Suzuki 

2010 2008 

$19 -

($6) 

$19 -

($5) 

$25 -

$70 

$29 -

$73 

$32 -

$85 

$33 -

$84 

$33 -

$85 

$35 -

$85 

Tata 

2010 2008 

$2 -

$19 

$4 -

$41 

$6 -

$38 

$7 -

$40 

$9 -

$46 

$11 -

$51 

$21 -

$81 

$23 -

$87 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$388 -

$289 

$474 -

$693 

$823 -

$958 

$882 -

$1,185 

$966 -

$1,322 

$995 -

$1,445 

$1,011 -

$1,470 

$1,694 

$1,478 

Volkswagen 

2010 2008 

$78 -

$51 

$221 -

$82 

$235 -

$131 

$312 -

$387 

$371 -

$491 

$417 -

$588 

$467 -

$615 

$582 -

$749 

Total/Average 

2010 2008 

$2,138 -

$1,724 

$3,198 -

$3,285 

$4,830 -

$4,579 

$6,196 -

$6,787 

$6,937 -

$8,069 

$7,892 -

$9,325 

$8,820 -

$9,744 

$10,658 

$10,882 
687 

Table VII-1g 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

4% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$84 -

$95 

$172 -

$189 

$271 -

$293 

$370 -

$392 

$475 -

$497 

$579 -

$612 

$695 -

$733 

$805 -

$860 

BMW 

2010 2008 

$96 -

$112 

$301 -

$330 

$397 -

$389 

$486 -

$476 

$598 -

$596 

$868 -

$925 

$1,002 -

$1,059 

$1,836 

$2,168 

Daimler 

2010 2008 

$84 -

$90 

$172 -

$200 

$260 -

$287 

$367 -

$703 

$479 -

$852 

$762 -

$1,054 

$1,084 -

$1,453 

$1,182 

$1,582 

Fiat 

2010 2008 

$529 -

$277 

$575 -

$579 

$823 -

$539 

$1,147 -

$1,121 

$1,335 -

$1,149 

$1,380 -

$1,283 

$1,641 -

$1,686 

$1,799 

$1,767 

Ford 

2010 2008 

$295 -

$150 

$315 -

$249 

$493 -

$521 

$1,032 -

$988 

$1,153 -

$1,220 

$1,384 -

$1,495 

$1,387 -

$1,649 

$1,422 

$1,767 

Geely 

2010 2008 

$90 -

$254 

$412 -

$385 

$793 -

$716 

$896 -

$760 

$991 -

$954 

$1,087 -

$1,030 

$1,244 -

$1,289 

$1,464 

$1,450 

General Motors 

2010 2008 

$318 -

$272 

$538 -

$603 

$571 -

$724 

$818 -

$1,108 

$1,028 -

$1,237 

$1,005 -

$1,233 

$1,200 -

$1,450 

$1,229 

$1,411 

Honda 

2010 2008 

$266 -

$149 

$613 -

$532 

$667 -

$502 

$660 -

$512 

$966 -

$1,025 

$962 -

$1,125 

$1,138 -

$1,152 

$1,194 

$1,172 

Hyundai 

2010 2008 

$689 -

$548 

$720 -

$602 

$885 -

$663 

$932 -

$685 

$1,048 -

$791 

$1,186 -

$966 

$1,184 -

$985 

$1,400 

$1,548 

Kia 

2010 2008 

$545 -

$254 

$525 -

$167 

$867 -

$564 

$1,117 -

$930 

$1,167 -

$1,042 

$1,264 -

$1,107 

$1,263 -

$1,187 

$1,246 

$1,163 

Lotus 

2010 2008 

$259 -

$106 

$355 -

$205 

$1,272 -

$299 

$1,361 -

$409 

$1,451 -

$530 

$1,553 -

$651 

$796 -

$777 

$921 -

$915 

Mazda 

2010 2008 

$500 -

$586 

$549 -

$791 

$510 -

$719 

$876 -

$1,041 

$849 -

$1,018 

$1,264 -

$2,051 

$1,387 -

$2,131 

$1,394 

$2,179 
688 

Mitsubishi 

2010 2008 

$188 -

$527 

$250 -

$720 

$228 -

$670 

$1,513 -

$1,547 

$1,947 -

$2,259 

$1,934 -

$2,205 

$1,899 -

$2,177 

$1,888 

$2,322 

Nissan 

2010 2008 

$474 -

$495 

$570 -

$596 

$874 -

$1,069 

$869 -

$1,126 

$928 -

$1,149 

$1,048 -

$1,265 

$1,101 -

$1,485 

$1,279 

$1,758 

Porsche 

2010 2008 

$73 -

$148 

$138 -

$352 

$281 -

$523 

$389 -

$552 

$564 -

$664 

$1,288 -

$685 

$1,427 -

$812 

$1,543 

$919 

Spyker 

2010 2008 

- ­

$98 

- ­

$241 

- ­

$405 

- ­

$504 

- ­

$630 

- ­

$786 

- ­

$1,297 

- ­

$1,993 

Subaru 

2010 2008 

$59 -

$247 

$61 -

$326 

$1,275 -

$562 

$2,014 -

$1,568 

$1,950 -

$1,496 

$1,900 -

$1,467 

$1,885 -

$1,704 

$2,302 

$1,905 

Suzuki 

2010 2008 

$456 -

($9) 

$449 -

$3 

$1,135 -

$1,109 

$1,362 -

$1,203 

$1,537 -

$1,488 

$1,514 -

$1,432 

$1,501 -

$1,459 

$1,474 

$1,378 

Tata 

2010 2008 

$90 -

$347 

$181 -

$690 

$269 -

$667 

$363 -

$779 

$427 -

$859 

$523 -

$1,089 

$882 -

$1,327 

$990 -

$1,428 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$261 -

$229 

$380 -

$468 

$826 -

$655 

$878 -

$738 

$1,108 -

$936 

$1,115 -

$981 

$1,096 -

$963 

$1,245 

$1,191 

Volkswagen 

2010 2008 

$181 -

$114 

$506 -

$202 

$610 -

$329 

$792 -

$810 

$1,002 -

$965 

$1,112 -

$1,201 

$1,246 -

$1,382 

$1,483 

$1,529 

Total/Average 

2010 2008 

$346 -

$255 

$482 -

$455 

$693 -

$623 

$894 -

$882 

$1,062 -

$1,064 

$1,149 -

$1,201 

$1,246 -

$1,332 

$1,380 

$1,503 
689 

Table VII-1h 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

4% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

BMW 

2010 2008 

$31 -

$35 

$96 -

$106 

$130 -

$135 

$160 -

$170 

$201 -

$214 

$296 -

$333 

$347 -

$382 

$657 -

$842 

Daimler 

2010 2008 

$21 -

$26 

$41 -

$55 

$64 -

$81 

$90 -

$205 

$119 -

$256 

$192 -

$321 

$275 -

$454 

$306 -

$526 

Fiat 

2010 2008 

$386 -

$119 

$424 -

$236 

$635 -

$217 

$904 -

$477 

$1,077 -

$496 

$1,146 -

$558 

$1,399 -

$733 

$1,582 

$773 

Ford 

2010 2008 

$398 -

$195 

$425 -

$327 

$661 -

$694 

$1,391 -

$1,362 

$1,569 -

$1,709 

$1,907 -

$2,116 

$1,935 -

$2,433 

$2,017 

$2,657 

Geely 

2010 2008 

$5 -

$22 

$24 -

$34 

$48 -

$66 

$54 -

$71 

$61 -

$88 

$68 -

$95 

$78 -

$125 

$95 -

$144 

General Motors 

2010 2008 

$525 -

$412 

$869 -

$928 

$921 -

$1,131 

$1,320 -

$1,784 

$1,670 -

$2,015 

$1,646 -

$2,023 

$1,984 -

$2,418 

$2,061 

$2,397 

Honda 

2010 2008 

$298 -

$172 

$699 -

$605 

$765 -

$574 

$771 -

$595 

$1,148 -

$1,228 

$1,167 -

$1,392 

$1,410 -

$1,457 

$1,514 

$1,532 

Hyundai 

2010 2008 

$596 -

$324 

$612 -

$348 

$759 -

$387 

$803 -

$410 

$915 -

$485 

$1,052 -

$607 

$1,065 -

$625 

$1,287 

$1,018 

Kia 

2010 2008 

$188 -

$82 

$178 -

$52 

$285 -

$178 

$366 -

$301 

$386 -

$345 

$424 -

$375 

$428 -

$407 

$432 -

$409 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$127 -

$137 

$137 -

$192 

$126 -

$177 

$218 -

$258 

$212 -

$254 

$319 -

$521 

$353 -

$570 

$362 -

$593 
690 

Mitsubishi 

2010 2008 

$11 -

$41 

$15 -

$54 

$14 -

$50 

$92 -

$118 

$120 -

$174 

$123 -

$173 

$121 -

$172 

$127 -

$191 

Nissan 

2010 2008 

$422 -

$431 

$495 -

$506 

$763 -

$913 

$760 -

$994 

$816 -

$1,049 

$927 -

$1,186 

$984 -

$1,417 

$1,161 

$1,727 

Porsche 

2010 2008 

$1 -

$5 

$3 -

$12 

$5 -

$19 

$7 -

$20 

$10 -

$24 

$22 -

$25 

$25 -

$30 

$27 -

$36 

Spyker 

2010 2008 

- ­

$2 

- ­

$5 

- ­

$8 

- ­

$11 

- ­

$13 

- ­

$17 

- ­

$29 

- ­

$45 

Subaru 

2010 2008 

$12 -

$55 

$13 -

$71 

$263 -

$122 

$414 -

$350 

$403 -

$345 

$399 -

$350 

$399 -

$412 

$496 -

$473 

Suzuki 

2010 2008 

$20 -

($1) 

$19 -

$0 

$49 -

$100 

$60 -

$113 

$69 -

$142 

$69 -

$140 

$70 -

$145 

$70 -

$138 

Tata 

2010 2008 

$3 -

$19 

$5 -

$39 

$8 -

$38 

$10 -

$45 

$12 -

$50 

$15 -

$65 

$26 -

$80 

$30 -

$91 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$399 -

$423 

$570 -

$858 

$1,246 -

$1,202 

$1,330 -

$1,391 

$1,696 -

$1,782 

$1,727 -

$1,948 

$1,719 -

$1,962 

$1,990 

$2,477 

Volkswagen 

2010 2008 

$87 -

$63 

$238 -

$109 

$283 -

$177 

$364 -

$449 

$462 -

$565 

$517 -

$713 

$582 -

$824 

$706 -

$926 

Total/Average 

2010 2008 

$3,533 -

$2,564 

$4,863 -

$4,540 

$7,024 -

$6,270 

$9,114 -

$9,125 

$10,947 -

$11,240 

$12,018 -

$12,959 

$13,201 -

$14,676 

$14,922 

$16,998 
691 

Table VII-1i 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

5% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$106 -

$117 

$222 -

$244 

$348 -

$370 

$475 -

$508 

$612 -

$645 

$755 -

$794 

$909 -

$959 

$1,069 

$1,129 

BMW 

2010 2008 

$120 -

$145 

$351 -

$355 

$482 -

$425 

$596 -

$599 

$838 -

$841 

$1,053 -

$1,107 

$1,222 -

$1,279 

$2,100 

$2,432 

Daimler 

2010 2008 

$106 -

$123 

$216 -

$244 

$337 -

$390 

$471 -

$699 

$616 -

$737 

$933 -

$1,190 

$1,293 -

$1,503 

$1,441 

$1,683 

Fiat 

2010 2008 

$493 -

$404 

$642 -

$676 

$1,128 -

$713 

$1,725 -

$1,615 

$2,071 -

$1,673 

$2,216 -

$1,839 

$2,484 -

$2,920 

$2,578 

$2,994 

Ford 

2010 2008 

$464 -

$167 

$501 -

$286 

$1,399 -

$582 

$2,029 -

$1,737 

$2,333 -

$2,370 

$2,738 -

$2,683 

$2,919 -

$2,690 

$2,864 

$2,753 

Geely 

2010 2008 

$112 -

$289 

$457 -

$408 

$873 -

$797 

$1,014 -

$917 

$1,142 -

$1,092 

$1,281 -

$1,222 

$1,472 -

$1,509 

$1,733 

$1,709 

General Motors 

2010 2008 

$329 -

$318 

$668 -

$717 

$693 -

$845 

$1,062 -

$1,408 

$1,260 -

$1,909 

$1,238 -

$1,897 

$1,805 -

$2,160 

$2,124 

$2,520 

Honda 

2010 2008 

$503 -

$240 

$915 -

$624 

$936 -

$616 

$923 -

$653 

$1,092 -

$1,290 

$1,146 -

$1,397 

$1,754 -

$1,813 

$1,855 

$1,919 

Hyundai 

2010 2008 

$687 -

$518 

$720 -

$572 

$973 -

$1,026 

$1,011 -

$1,086 

$1,198 -

$1,209 

$1,558 -

$1,553 

$1,576 -

$1,582 

$2,195 

$2,799 

Kia 

2010 2008 

$683 -

$476 

$691 -

$387 

$1,164 -

$591 

$1,416 -

$1,503 

$1,425 -

$1,876 

$1,663 -

$2,138 

$1,665 -

$2,440 

$1,646 

$2,416 

Lotus 

2010 2008 

$281 -

$128 

$404 -

$260 

$1,354 -

$387 

$1,477 -

$530 

$1,605 -

$684 

$1,740 -

$849 

$1,027 -

$1,025 

$1,202 

$1,206 

Mazda 

2010 2008 

$572 -

$811 

$650 -

$1,124 

$612 -

$1,028 

$1,058 -

$1,428 

$1,044 -

$1,395 

$1,863 -

$2,549 

$2,221 -

$2,683 

$2,266 

$3,059 
692 

Mitsubishi 

2010 2008 

$319 -

$727 

$358 -

$888 

$323 -

$828 

$1,849 -

$3,824 

$2,207 -

$4,217 

$2,179 -

$4,231 

$2,142 -

$4,246 

$2,438 

$4,200 

Nissan 

2010 2008 

$541 -

$533 

$659 -

$649 

$991 -

$1,132 

$1,027 -

$1,238 

$1,036 -

$1,311 

$1,148 -

$1,580 

$1,293 -

$1,838 

$2,161 

$3,028 

Porsche 

2010 2008 

$95 -

$170 

$187 -

$407 

$367 -

$614 

$519 -

$673 

$763 -

$818 

$1,469 -

$883 

$1,641 -

$1,060 

$1,807 

$1,211 

Spyker 

2010 2008 

- ­

$120 

- ­

$302 

- ­

$488 

- ­

$620 

- ­

$778 

- ­

$973 

- ­

$1,528 

- ­

$2,268 

Subaru 

2010 2008 

$293 -

$557 

$387 -

$642 

$1,545 -

$890 

$2,242 -

$1,401 

$2,146 -

$1,553 

$2,100 -

$1,632 

$2,312 -

$1,804 

$2,540 

$1,894 

Suzuki 

2010 2008 

$486 -

$327 

$479 -

$336 

$1,247 -

$1,550 

$1,606 -

$1,611 

$1,899 -

$2,409 

$1,891 -

$2,353 

$1,858 -

$2,321 

$1,970 

$2,303 

Tata 

2010 2008 

$112 -

$369 

$225 -

$690 

$341 -

$738 

$467 -

$878 

$559 -

$991 

$693 -

$1,254 

$1,091 -

$1,536 

$1,243 

$1,676 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$264 -

$259 

$358 -

$596 

$912 -

$762 

$970 -

$966 

$1,315 -

$1,232 

$1,333 -

$1,279 

$1,310 -

$1,262 

$1,598 

$1,546 

Volkswagen 

2010 2008 

$204 -

$136 

$562 -

$251 

$694 -

$417 

$925 -

$937 

$1,147 -

$1,146 

$1,295 -

$1,388 

$1,473 -

$1,613 

$1,753 

$1,810 

Total/Average 

2010 2008 

$414 -

$315 

$592 -

$550 

$944 -

$747 

$1,208 -

$1,196 

$1,418 -

$1,541 

$1,579 -

$1,723 

$1,832 -

$1,927 

$2,117 

$2,298 
693 

Table VII-1j 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

5% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

BMW 

2010 2008 

$39 -

$46 

$112 -

$115 

$158 -

$147 

$196 -

$214 

$281 -

$302 

$360 -

$398 

$424 -

$461 

$752 -

$944 

Daimler 

2010 2008 

$27 -

$35 

$52 -

$67 

$83 -

$110 

$116 -

$203 

$154 -

$221 

$234 -

$363 

$328 -

$470 

$373 -

$559 

Fiat 

2010 2008 

$360 -

$173 

$474 -

$276 

$869 -

$287 

$1,359 -

$688 

$1,671 -

$722 

$1,840 -

$800 

$2,117 -

$1,270 

$2,268 

$1,309 

Ford 

2010 2008 

$626 -

$217 

$675 -

$376 

$1,877 -

$776 

$2,734 -

$2,395 

$3,173 -

$3,321 

$3,773 -

$3,798 

$4,071 -

$3,967 

$4,063 

$4,139 

Geely 

2010 2008 

$7 -

$25 

$26 -

$36 

$53 -

$73 

$61 -

$85 

$70 -

$101 

$80 -

$113 

$93 -

$146 

$113 -

$169 

General Motors 

2010 2008 

$544 -

$482 

$1,079 -

$1,104 

$1,117 -

$1,321 

$1,713 -

$2,267 

$2,047 -

$3,110 

$2,028 -

$3,113 

$2,982 -

$3,602 

$3,562 

$4,281 

Honda 

2010 2008 

$565 -

$278 

$1,043 -

$710 

$1,073 -

$705 

$1,077 -

$759 

$1,298 -

$1,546 

$1,390 -

$1,728 

$2,173 -

$2,294 

$2,352 

$2,510 

Hyundai 

2010 2008 

$595 -

$307 

$612 -

$331 

$835 -

$598 

$871 -

$650 

$1,047 -

$741 

$1,382 -

$975 

$1,418 -

$1,003 

$2,017 

$1,841 

Kia 

2010 2008 

$236 -

$153 

$235 -

$121 

$383 -

$186 

$464 -

$486 

$471 -

$622 

$559 -

$725 

$564 -

$836 

$571 -

$850 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$145 -

$190 

$162 -

$273 

$151 -

$254 

$263 -

$354 

$260 -

$348 

$471 -

$647 

$566 -

$718 

$588 -

$833 
694 

Mitsubishi 

2010 2008 

$20 -

$56 

$21 -

$67 

$19 -

$62 

$112 -

$292 

$136 -

$325 

$138 -

$332 

$137 -

$335 

$163 -

$345 

Nissan 

2010 2008 

$481 -

$464 

$572 -

$552 

$865 -

$968 

$898 -

$1,093 

$911 -

$1,197 

$1,015 -

$1,481 

$1,156 -

$1,754 

$1,962 

$2,976 

Porsche 

2010 2008 

$2 -

$6 

$3 -

$14 

$6 -

$22 

$9 -

$24 

$13 -

$30 

$25 -

$32 

$28 -

$39 

$32 -

$48 

Spyker 

2010 2008 

- ­

$2 

- ­

$6 

- ­

$10 

- ­

$13 

- ­

$17 

- ­

$21 

- ­

$34 

- ­

$52 

Subaru 

2010 2008 

$61 -

$125 

$80 -

$139 

$318 -

$193 

$461 -

$313 

$444 -

$358 

$441 -

$389 

$489 -

$436 

$547 -

$470 

Suzuki 

2010 2008 

$21 -

$30 

$20 -

$30 

$54 -

$140 

$71 -

$151 

$85 -

$231 

$87 -

$230 

$87 -

$230 

$94 -

$231 

Tata 

2010 2008 

$3 -

$21 

$6 -

$39 

$10 -

$42 

$13 -

$51 

$16 -

$58 

$20 -

$74 

$33 -

$93 

$38 -

$107 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$404 -

$478 

$537 -

$1,094 

$1,376 -

$1,399 

$1,469 -

$1,819 

$2,013 -

$2,346 

$2,064 -

$2,541 

$2,053 -

$2,572 

$2,555 

$3,217 

Volkswagen 

2010 2008 

$98 -

$75 

$265 -

$136 

$322 -

$224 

$425 -

$520 

$528 -

$671 

$602 -

$824 

$688 -

$962 

$834 -

$1,095 

Total/Average 

2010 2008 

$4,233 -

$3,163 

$5,975 -

$5,486 

$9,570 -

$7,517 

$12,313 -

$12,379 

$14,620 -

$16,268 

$16,509 -

$18,586 

$19,407 -

$21,227 

$22,885 

$25,979 
695 

Table VII-1k 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

6% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$128 -

$145 

$271 -

$293 

$425 -

$453 

$590 -

$623 

$761 -

$799 

$948 -

$997 

$1,146 -

$1,206 

$1,355 

$1,432 

BMW 

2010 2008 

$120 -

$153 

$400 -

$429 

$559 -

$541 

$712 -

$709 

$992 -

$996 

$1,246 -

$1,299 

$1,458 -

$1,521 

$2,391 

$2,724 

Daimler 

2010 2008 

$128 -

$145 

$266 -

$271 

$414 -

$421 

$581 -

$817 

$765 -

$1,001 

$1,120 -

$1,377 

$1,524 -

$1,740 

$1,721 

$1,964 

Fiat 

2010 2008 

$620 -

$473 

$805 -

$842 

$1,263 -

$881 

$1,896 -

$1,855 

$2,154 -

$2,131 

$2,214 -

$3,060 

$2,450 -

$3,514 

$4,011 

$4,183 

Ford 

2010 2008 

$669 -

$523 

$735 -

$657 

$1,569 -

$880 

$2,258 -

$1,635 

$2,520 -

$2,013 

$2,598 -

$3,805 

$2,871 -

$3,768 

$5,567 

$5,912 

Geely 

2010 2008 

$134 -

$327 

$521 -

$458 

$956 -

$869 

$1,130 -

$1,033 

$1,296 -

$1,246 

$1,479 -

$1,409 

$1,719 -

$1,746 

$2,025 

$2,000 

General Motors 

2010 2008 

$522 -

$381 

$979 -

$933 

$1,060 -

$1,105 

$1,410 -

$1,766 

$2,425 -

$3,449 

$2,393 -

$3,468 

$4,621 -

$3,421 

$4,733 

$3,556 

Honda 

2010 2008 

$221 -

$448 

$671 -

$836 

$706 -

$823 

$687 -

$853 

$1,356 -

$1,492 

$1,412 -

$1,579 

$2,455 -

$2,309 

$2,609 

$2,428 

Hyundai 

2010 2008 

$802 -

$670 

$832 -

$722 

$1,204 -

$1,348 

$1,214 -

$1,406 

$1,896 -

$1,647 

$2,413 -

$2,253 

$2,580 -

$2,535 

$2,994 

$3,030 

Kia 

2010 2008 

$740 -

$533 

$754 -

$443 

$1,310 -

$711 

$1,857 -

$1,496 

$1,975 -

$2,068 

$2,774 -

$2,242 

$2,822 -

$2,366 

$2,855 

$2,323 

Lotus 

2010 2008 

$308 -

$156 

$459 -

$321 

$1,442 -

$475 

$1,598 -

$656 

$1,765 -

$854 

$1,949 -

$1,063 

$1,286 -

$1,289 

$1,515 

$1,531 

Mazda 

2010 2008 

$948 -

$884 

$1,100 -

$1,164 

$1,022 -

$1,125 

$1,973 -

$1,454 

$2,043 -

$1,436 

$2,263 -

$3,502 

$2,554 -

$3,527 

$2,735 

$3,525 
696 

Mitsubishi 

2010 2008 

$881 -

$746 

$874 -

$889 

$848 -

$828 

$1,550 -

$3,870 

$3,806 -

$4,063 

$3,759 -

$4,096 

$3,722 -

$4,117 

$3,883 

$4,144 

Nissan 

2010 2008 

$231 -

$816 

$374 -

$1,078 

$1,407 -

$1,465 

$1,409 -

$1,554 

$1,431 -

$1,581 

$1,961 -

$2,383 

$2,918 -

$4,543 

$3,304 

$4,753 

Porsche 

2010 2008 

$123 -

$197 

$237 -

$467 

$449 -

$705 

$635 -

$799 

$911 -

$988 

$1,656 -

$1,097 

$1,878 -

$1,324 

$2,093 

$1,535 

Spyker 

2010 2008 

- ­

$148 

- ­

$354 

- ­

$570 

- ­

$735 

- ­

$938 

- ­

$1,177 

- ­

$1,776 

- ­

$2,570 

Subaru 

2010 2008 

$347 -

$554 

$459 -

$717 

$1,607 -

$794 

$2,440 -

$1,573 

$2,431 -

$1,790 

$2,417 -

$1,940 

$2,779 -

$2,161 

$3,157 

$2,970 

Suzuki 

2010 2008 

$466 -

$797 

$460 -

$797 

$1,213 -

$1,228 

$1,596 -

$1,244 

$1,992 -

$1,414 

$2,071 -

$1,627 

$2,286 -

$1,872 

$2,471 

$3,655 

Tata 

2010 2008 

$134 -

$391 

$274 -

$731 

$418 -

$818 

$577 -

$990 

$708 -

$1,131 

$880 -

$1,432 

$1,322 -

$1,761 

$1,518 

$1,951 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$275 -

$317 

$428 -

$647 

$1,020 -

$861 

$1,126 -

$1,223 

$1,553 -

$1,444 

$1,617 -

$1,683 

$1,589 -

$1,667 

$2,662 

$2,695 

Volkswagen 

2010 2008 

$232 -

$164 

$613 -

$306 

$777 -

$473 

$1,052 -

$1,071 

$1,306 -

$1,328 

$1,493 -

$1,597 

$1,720 -

$1,866 

$2,050 

$2,112 

Total/Average 

2010 2008 

$453 -

$453 

$676 -

$734 

$1,108 -

$933 

$1,405 -

$1,381 

$1,866 -

$1,887 

$2,040 -

$2,416 

$2,700 -

$2,761 

$3,508 

$3,437 
697 

Table VII-1l 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

6% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

$1 -

$2 

BMW 

2010 2008 

$39 -

$48 

$128 -

$138 

$183 -

$187 

$234 -

$254 

$333 -

$358 

$426 -

$468 

$506 -

$548 

$856 -

$1,057 

Daimler 

2010 2008 

$32 -

$41 

$64 -

$75 

$102 -

$118 

$143 -

$238 

$191 -

$301 

$282 -

$420 

$387 -

$544 

$445 -

$653 

Fiat 

2010 2008 

$453 -

$203 

$594 -

$344 

$974 -

$354 

$1,494 -

$790 

$1,738 -

$920 

$1,839 -

$1,332 

$2,088 -

$1,529 

$3,528 

$1,828 

Ford 

2010 2008 

$902 -

$680 

$990 -

$862 

$2,105 -

$1,172 

$3,043 -

$2,255 

$3,427 -

$2,822 

$3,580 -

$5,385 

$4,005 -

$5,557 

$7,897 

$8,890 

Geely 

2010 2008 

$8 -

$29 

$30 -

$41 

$58 -

$80 

$68 -

$96 

$80 -

$115 

$92 -

$130 

$108 -

$169 

$132 -

$198 

General Motors 

2010 2008 

$863 -

$578 

$1,582 -

$1,437 

$1,708 -

$1,727 

$2,275 -

$2,844 

$3,940 -

$5,618 

$3,920 -

$5,691 

$7,636 -

$5,706 

$7,935 

$6,042 

Honda 

2010 2008 

$249 -

$517 

$765 -

$951 

$810 -

$942 

$802 -

$992 

$1,610 -

$1,789 

$1,712 -

$1,954 

$3,040 -

$2,922 

$3,308 

$3,176 

Hyundai 

2010 2008 

$694 -

$396 

$707 -

$418 

$1,032 -

$786 

$1,045 -

$841 

$1,656 -

$1,010 

$2,141 -

$1,415 

$2,322 -

$1,608 

$2,752 

$1,993 

Kia 

2010 2008 

$256 -

$172 

$256 -

$139 

$431 -

$224 

$609 -

$484 

$653 -

$685 

$932 -

$760 

$956 -

$811 

$990 -

$817 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$1 -

$0 

Mazda 

2010 2008 

$241 -

$207 

$274 -

$282 

$253 -

$278 

$490 -

$361 

$509 -

$359 

$571 -

$889 

$651 -

$944 

$710 -

$960 

Mitsubishi 

2010 2008 

$54 -

$57 

$51 -

$67 

$51 -

$62 

$94 -

$295 

$235 -

$313 

$238 -

$321 

$238 -

$325 

$260 -

$340 
698 

Nissan 

2010 2008 

$206 -

$711 

$324 -

$916 

$1,229 -

$1,252 

$1,231 -

$1,372 

$1,259 -

$1,443 

$1,735 -

$2,234 

$2,608 -

$4,336 

$3,000 

$4,671 

Porsche 

2010 2008 

$2 -

$7 

$4 -

$17 

$8 -

$25 

$11 -

$29 

$16 -

$36 

$29 -

$40 

$32 -

$49 

$37 -

$61 

Spyker 

2010 2008 

- ­

$3 

- ­

$7 

- ­

$11 

- ­

$15 

- ­

$20 

- ­

$26 

- ­

$40 

- ­

$59 

Subaru 

2010 2008 

$73 -

$124 

$94 -

$155 

$331 -

$172 

$502 -

$351 

$503 -

$413 

$507 -

$463 

$588 -

$522 

$681 -

$737 

Suzuki 

2010 2008 

$20 -

$72 

$20 -

$72 

$53 -

$111 

$70 -

$116 

$89 -

$135 

$95 -

$159 

$106 -

$186 

$118 -

$367 

Tata 

2010 2008 

$4 -

$22 

$7 -

$41 

$12 -

$47 

$16 -

$58 

$21 -

$66 

$26 -

$85 

$40 -

$107 

$46 -

$124 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$421 -

$586 

$643 -

$1,187 

$1,539 -

$1,582 

$1,706 -

$2,303 

$2,378 -

$2,748 

$2,504 -

$3,344 

$2,490 -

$3,395 

$4,256 

$5,608 

Volkswagen 

2010 2008 

$112 -

$90 

$289 -

$165 

$360 -

$254 

$484 -

$594 

$602 -

$778 

$694 -

$948 

$804 -

$1,113 

$976 -

$1,279 

Total/Average 

2010 2008 

$4,627 -

$4,544 

$6,822 -

$7,314 

$11,237 -

$9,386 

$14,319 -

$14,289 

$19,240 -

$19,931 

$21,324 -

$26,063 

$28,606 -

$30,412 

$37,927 

$38,863 
699 

Table VII-1m 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

7% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$156 -

$167 

$326 -

$348 

$508 -

$541 

$706 -

$750 

$920 -

$970 

$1,157 -

$1,212 

$1,404 -

$1,476 

$1,668 

$1,762 

BMW 

2010 2008 

$158 -

$191 

$455 -

$470 

$647 -

$638 

$833 -

$835 

$1,151 -

$1,155 

$1,455 -

$1,508 

$1,722 -

$1,785 

$2,710 

$3,048 

Daimler 

2010 2008 

$150 -

$170 

$321 -

$338 

$497 -

$544 

$697 -

$932 

$919 -

$1,155 

$1,323 -

$1,580 

$1,777 -

$1,993 

$2,029 

$2,277 

Fiat 

2010 2008 

$865 -

$617 

$1,043 -

$991 

$1,603 -

$1,015 

$1,782 -

$2,106 

$2,174 -

$2,262 

$2,510 -

$2,744 

$4,755 -

$4,449 

$4,965 

$5,509 

Ford 

2010 2008 

$894 -

$760 

$1,010 -

$1,407 

$1,709 -

$1,474 

$2,270 -

$1,898 

$2,659 -

$2,975 

$3,012 -

$3,192 

$3,240 -

$3,390 

$4,749 

$5,292 

Geely 

2010 2008 

$161 -

$359 

$571 -

$499 

$1,044 -

$958 

$1,251 -

$1,148 

$1,461 -

$1,405 

$1,688 -

$1,618 

$1,983 -

$2,004 

$2,355 

$2,314 

General Motors 

2010 2008 

$849 -

$508 

$1,315 -

$1,070 

$2,219 -

$1,193 

$2,272 -

$1,831 

$2,978 -

$3,696 

$3,038 -

$3,723 

$4,664 -

$3,717 

$4,913 

$5,944 

Honda 

2010 2008 

$460 -

$613 

$1,277 -

$1,060 

$1,354 -

$1,171 

$1,321 -

$1,188 

$1,903 -

$2,162 

$2,909 -

$2,238 

$3,626 -

$2,861 

$4,345 

$4,069 

Hyundai 

2010 2008 

$927 -

$778 

$993 -

$886 

$1,242 -

$1,485 

$1,296 -

$1,500 

$2,137 -

$1,871 

$4,328 -

$4,284 

$4,696 -

$4,463 

$4,814 

$4,428 

Kia 

2010 2008 

$951 -

$537 

$963 -

$447 

$1,456 -

$817 

$1,841 -

$1,946 

$1,924 -

$2,657 

$2,719 -

$2,812 

$3,076 -

$3,335 

$3,067 

$3,648 

Lotus 

2010 2008 

$336 -

$183 

$514 -

$376 

$1,530 -

$568 

$1,724 -

$794 

$1,941 -

$1,036 

$2,169 -

$1,300 

$1,566 -

$1,580 

$1,856 

$1,888 

Mazda 

2010 2008 

$974 -

$1,245 

$1,148 -

$1,488 

$1,048 -

$1,432 

$2,049 -

$1,608 

$2,202 -

$1,581 

$2,470 -

$7,841 

$2,846 -

$7,900 

$3,098 

$7,864 

Mitsubishi 

2010 2008 

$881 -

$774 

$874 -

$905 

$983 -

$894 

$1,676 -

$5,197 

$2,137 -

$5,397 

$2,352 -

$5,526 

$2,588 -

$5,674 

$2,877 

$6,134 
700 

Nissan 

2010 2008 

$587 -

$915 

$781 -

$1,182 

$1,355 -

$1,635 

$1,482 -

$1,790 

$1,532 -

$1,909 

$3,798 -

$3,889 

$4,037 -

$4,855 

$4,521 

$5,357 

Porsche 

2010 2008 

$145 -

$225 

$286 -

$522 

$532 -

$801 

$756 -

$937 

$1,076 -

$1,170 

$1,865 -

$1,334 

$2,136 -

$1,615 

$2,412 

$1,893 

Spyker 

2010 2008 

- ­

$170 

- ­

$409 

- ­

$658 

- ­

$862 

- ­

$1,108 

- ­

$1,397 

- ­

$2,051 

- ­

$2,911 

Subaru 

2010 2008 

$508 -

$463 

$654 -

$701 

$963 -

$2,621 

$2,507 -

$2,875 

$2,626 -

$3,033 

$2,851 -

$3,141 

$3,125 -

$3,492 

$3,286 

$3,721 

Suzuki 

2010 2008 

$493 -

$797 

$487 -

$858 

$1,079 -

$1,375 

$1,527 -

$1,388 

$2,134 -

$2,797 

$2,389 -

$3,081 

$2,629 -

$3,374 

$2,892 

$6,259 

Tata 

2010 2008 

$156 -

$419 

$324 -

$781 

$500 -

$895 

$687 -

$1,100 

$862 -

$1,285 

$1,078 -

$1,630 

$1,575 -

$2,003 

$1,826 

$2,253 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$467 -

$482 

$693 -

$974 

$1,358 -

$1,362 

$1,474 -

$1,982 

$1,929 -

$2,299 

$3,710 -

$3,798 

$3,662 -

$3,757 

$5,135 

$3,738 

Volkswagen 

2010 2008 

$254 -

$191 

$668 -

$361 

$865 -

$591 

$1,173 -

$1,203 

$1,471 -

$1,504 

$1,708 -

$1,817 

$1,990 -

$2,146 

$2,385 

$2,453 

Total/Average 

2010 2008 

$664 -

$584 

$959 -

$979 

$1,461 -

$1,251 

$1,688 -

$1,712 

$2,136 -

$2,424 

$3,048 -

$3,275 

$3,705 -

$3,606 

$4,382 

$4,525 
701 

Table VII-1n 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

7% Annual Increase 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

$1 -

$2 

$1 -

$2 

BMW 

2010 2008 

$51 -

$60 

$145 -

$152 

$212 -

$221 

$274 -

$299 

$387 -

$415 

$497 -

$543 

$597 -

$644 

$970 -

$1,183 

Daimler 

2010 2008 

$38 -

$48 

$77 -

$93 

$122 -

$153 

$171 -

$271 

$229 -

$347 

$333 -

$482 

$451 -

$623 

$525 -

$757 

Fiat 

2010 2008 

$632 -

$265 

$769 -

$405 

$1,236 -

$408 

$1,405 -

$897 

$1,754 -

$977 

$2,084 -

$1,194 

$4,053 -

$1,936 

$4,367 

$2,408 

Ford 

2010 2008 

$1,205 -

$988 

$1,361 -

$1,845 

$2,292 -

$1,963 

$3,059 -

$2,617 

$3,616 -

$4,170 

$4,150 -

$4,518 

$4,520 -

$4,999 

$6,736 

$7,957 

Geely 

2010 2008 

$10 -

$32 

$33 -

$45 

$63 -

$88 

$75 -

$107 

$90 -

$130 

$105 -

$150 

$125 -

$194 

$153 -

$229 

General Motors 

2010 2008 

$1,404 -

$771 

$2,125 -

$1,647 

$3,576 -

$1,865 

$3,665 -

$2,949 

$4,838 -

$6,020 

$4,977 -

$6,110 

$7,706 -

$6,200 

$8,236 

$10,100 

Honda 

2010 2008 

$516 -

$708 

$1,455 -

$1,206 

$1,553 -

$1,341 

$1,542 -

$1,383 

$2,261 -

$2,592 

$3,528 -

$2,769 

$4,490 -

$3,621 

$5,509 

$5,321 

Hyundai 

2010 2008 

$802 -

$461 

$843 -

$512 

$1,065 -

$866 

$1,116 -

$897 

$1,867 -

$1,148 

$3,839 -

$2,690 

$4,226 -

$2,831 

$4,424 

$2,912 

Kia 

2010 2008 

$328 -

$173 

$327 -

$140 

$479 -

$257 

$603 -

$630 

$636 -

$880 

$913 -

$954 

$1,042 -

$1,143 

$1,064 

$1,284 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$1 

Mazda 

2010 2008 

$248 -

$292 

$286 -

$361 

$259 -

$354 

$509 -

$399 

$549 -

$395 

$624 -

$1,991 

$725 -

$2,115 

$804 -

$2,141 

Mitsubishi 

2010 2008 

$54 -

$60 

$51 -

$68 

$59 -

$67 

$102 -

$396 

$132 -

$416 

$149 -

$433 

$165 -

$448 

$193 -

$504 
702 

Nissan 

2010 2008 

$522 -

$797 

$677 -

$1,004 

$1,183 -

$1,397 

$1,296 -

$1,580 

$1,347 -

$1,743 

$3,361 -

$3,645 

$3,608 -

$4,633 

$4,105 

$5,264 

Porsche 

2010 2008 

$3 -

$8 

$5 -

$19 

$9 -

$29 

$13 -

$34 

$19 -

$43 

$32 -

$49 

$37 -

$60 

$42 -

$75 

Spyker 

2010 2008 

- ­

$3 

- ­

$8 

- ­

$13 

- ­

$18 

- ­

$24 

- ­

$30 

- ­

$46 

- ­

$66 

Subaru 

2010 2008 

$106 -

$104 

$134 -

$152 

$198 -

$569 

$516 -

$643 

$543 -

$700 

$598 -

$749 

$661 -

$844 

$708 -

$924 

Suzuki 

2010 2008 

$21 -

$72 

$21 -

$77 

$47 -

$125 

$67 -

$130 

$96 -

$268 

$109 -

$301 

$122 -

$335 

$138 -

$629 

Tata 

2010 2008 

$4 -

$23 

$9 -

$44 

$14 -

$51 

$20 -

$64 

$25 -

$75 

$32 -

$97 

$47 -

$121 

$56 -

$144 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$714 -

$891 

$1,041 -

$1,786 

$2,049 -

$2,501 

$2,233 -

$3,734 

$2,953 -

$4,378 

$5,744 -

$7,543 

$5,741 -

$7,653 

$8,210 

$7,776 

Volkswagen 

2010 2008 

$122 -

$106 

$315 -

$195 

$401 -

$317 

$539 -

$667 

$678 -

$881 

$794 -

$1,078 

$930 -

$1,281 

$1,135 

$1,485 

Total/Average 

2010 2008 

$6,780 -

$5,862 

$9,675 -

$9,758 

$14,818 -

$12,586 

$17,205 -

$17,714 

$22,020 -

$25,601 

$31,871 -

$35,328 

$39,248 -

$39,727 

$47,378 

$51,162 
703 

Table VII-1o 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Max Net Benefits (3% Discount Rate) 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$337 -

$376 

$464 -

$491 

$585 -

$618 

$667 -

$706 

$739 -

$761 

$783 -

$821 

$843 -

$887 

$959 -

$953 

BMW 

2010 2008 

$357 -

$397 

$593 -

$620 

$719 -

$713 

$789 -

$796 

$964 -

$952 

$1,075 -

$1,129 

$1,150 -

$1,207 

$1,990 

$2,256 

Daimler 

2010 2008 

$332 -

$363 

$458 -

$486 

$568 -

$631 

$658 -

$894 

$743 -

$963 

$955 -

$1,212 

$1,227 -

$1,432 

$1,331 

$1,513 

Fiat 

2010 2008 

$1,163 -

$1,569 

$1,188 -

$1,706 

$1,556 -

$1,642 

$1,747 -

$1,821 

$1,970 -

$1,875 

$2,116 -

$1,861 

$2,324 -

$2,003 

$2,382 

$2,088 

Ford 

2010 2008 

$835 -

$946 

$894 -

$968 

$2,418 -

$2,473 

$2,456 -

$2,442 

$2,475 -

$2,545 

$2,673 -

$2,596 

$2,669 -

$2,649 

$3,211 

$2,806 

Geely 

2010 2008 

$354 -

$552 

$719 -

$658 

$1,121 -

$1,051 

$1,212 -

$1,126 

$1,274 -

$1,223 

$1,308 -

$1,260 

$1,400 -

$1,453 

$1,618 

$1,548 

General Motors 

2010 2008 

$938 -

$1,016 

$1,182 -

$1,309 

$1,085 -

$1,358 

$1,537 -

$1,671 

$1,620 -

$1,994 

$1,585 -

$1,940 

$1,839 -

$1,954 

$2,123 

$2,220 

Honda 

2010 2008 

$755 -

$1,082 

$947 -

$1,157 

$878 -

$995 

$875 -

$989 

$1,144 -

$1,230 

$1,165 -

$1,254 

$1,400 -

$1,260 

$1,409 

$1,266 

Hyundai 

2010 2008 

$850 -

$859 

$814 -

$867 

$1,120 -

$1,200 

$1,148 -

$1,164 

$1,370 -

$1,257 

$1,583 -

$1,399 

$1,603 -

$1,401 

$1,741 

$1,694 

Kia 

2010 2008 

$1,050 -

$932 

$981 -

$834 

$1,310 -

$873 

$1,346 -

$1,714 

$1,392 -

$1,813 

$1,489 -

$1,796 

$1,494 -

$1,793 

$1,462 

$1,768 

Lotus 

2010 2008 

$534 -

$403 

$668 -

$535 

$1,613 -

$651 

$1,686 -

$750 

$1,737 -

$816 

$1,767 -

$876 

$956 -

$942 

$1,086 

$1,014 

Mazda 

2010 2008 

$950 -

$1,159 

$1,206 -

$1,353 

$1,100 -

$1,243 

$2,003 -

$4,092 

$2,056 -

$4,037 

$2,290 -

$4,034 

$2,268 -

$4,067 

$2,239 

$3,966 

Mitsubishi 

2010 2008 

$885 -

$980 

$859 -

$905 

$885 -

$1,114 

$2,934 -

$3,838 

$2,958 -

$3,778 

$2,915 -

$3,819 

$2,877 -

$3,842 

$2,865 

$3,812 
704 

Nissan 

2010 2008 

$673 -

$914 

$851 -

$1,085 

$1,181 -

$1,332 

$1,230 -

$1,400 

$1,241 -

$1,374 

$1,422 -

$1,446 

$1,613 -

$1,562 

$2,023 

$2,116 

Porsche 

2010 2008 

$332 -

$445 

$429 -

$682 

$603 -

$883 

$717 -

$893 

$889 -

$950 

$1,491 -

$910 

$1,570 -

$977 

$1,697 

$1,018 

Spyker 

2010 2008 

- ­

$379 

- ­

$558 

- ­

$741 

- ­

$823 

- ­

$899 

- ­

$1,001 

- ­

$1,451 

- ­

$2,086 

Subaru 

2010 2008 

$550 -

$614 

$759 -

$561 

$6,106 -

$2,206 

$5,761 -

$2,261 

$5,547 -

$2,223 

$5,400 -

$2,260 

$5,221 -

$2,204 

$5,119 

$2,337 

Suzuki 

2010 2008 

$529 -

$230 

$523 -

$225 

$1,236 -

$2,318 

$1,582 -

$2,329 

$1,995 -

$2,315 

$1,968 -

$2,277 

$1,936 -

$2,241 

$2,016 

$2,281 

Tata 

2010 2008 

$332 -

$606 

$461 -

$913 

$572 -

$966 

$649 -

$1,061 

$680 -

$1,098 

$721 -

$1,278 

$1,025 -

$1,470 

$1,133 

$1,511 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$620 -

$526 

$701 -

$821 

$1,162 -

$845 

$1,171 -

$997 

$1,313 -

$1,239 

$1,325 -

$1,226 

$1,318 -

$1,210 

$1,627 

$1,282 

Volkswagen 

2010 2008 

$446 -

$400 

$811 -

$510 

$942 -

$670 

$1,134 -

$1,159 

$1,279 -

$1,289 

$1,323 -

$1,416 

$1,401 -

$1,541 

$1,637 

$1,623 

Total/Average 

2010 2008 

$774 -

$830 

$908 -

$981 

$1,373 -

$1,287 

$1,515 -

$1,525 

$1,634 -

$1,680 

$1,722 -

$1,710 

$1,831 -

$1,756 

$2,083 

$1,941 
705 

Table VII-1p 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Max Net Benefits (3% Discount Rate) 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

BMW 

2010 2008 

$114 -

$124 

$189 -

$200 

$235 -

$247 

$260 -

$285 

$324 -

$342 

$367 -

$406 

$399 -

$435 

$712 -

$876 

Daimler 

2010 2008 

$84 -

$103 

$110 -

$134 

$140 -

$178 

$162 -

$260 

$185 -

$289 

$240 -

$369 

$311 -

$448 

$344 -

$503 

Fiat 

2010 2008 

$850 -

$673 

$877 -

$697 

$1,200 -

$661 

$1,377 -

$775 

$1,590 -

$809 

$1,757 -

$810 

$1,981 -

$871 

$2,095 

$913 

Ford 

2010 2008 

$1,126 -

$1,230 

$1,204 -

$1,270 

$3,244 -

$3,294 

$3,310 -

$3,367 

$3,366 -

$3,567 

$3,683 -

$3,674 

$3,723 -

$3,906 

$4,555 

$4,220 

Geely 

2010 2008 

$21 -

$49 

$41 -

$59 

$68 -

$96 

$73 -

$105 

$78 -

$113 

$82 -

$117 

$88 -

$141 

$105 -

$153 

General Motors 

2010 2008 

$1,550 -

$1,541 

$1,910 -

$2,015 

$1,748 -

$2,123 

$2,478 -

$2,691 

$2,632 -

$3,248 

$2,596 -

$3,183 

$3,039 -

$3,259 

$3,559 

$3,772 

Honda 

2010 2008 

$847 -

$1,249 

$1,079 -

$1,317 

$1,007 -

$1,139 

$1,022 -

$1,151 

$1,359 -

$1,474 

$1,412 -

$1,552 

$1,734 -

$1,594 

$1,786 

$1,656 

Hyundai 

2010 2008 

$735 -

$509 

$691 -

$502 

$960 -

$700 

$989 -

$697 

$1,197 -

$771 

$1,404 -

$879 

$1,442 -

$889 

$1,600 

$1,114 

Kia 

2010 2008 

$363 -

$300 

$333 -

$261 

$431 -

$275 

$441 -

$555 

$460 -

$601 

$500 -

$609 

$506 -

$615 

$507 -

$622 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$241 -

$272 

$300 -

$328 

$272 -

$307 

$497 -

$1,015 

$513 -

$1,008 

$578 -

$1,024 

$578 -

$1,089 

$581 -

$1,080 

Mitsubishi 

2010 2008 

$54 -

$75 

$50 -

$68 

$53 -

$84 

$178 -

$293 

$183 -

$291 

$185 -

$299 

$184 -

$303 

$192 -

$313 
706 

Nissan 

2010 2008 

$598 -

$796 

$739 -

$922 

$1,031 -

$1,138 

$1,075 -

$1,236 

$1,091 -

$1,254 

$1,258 -

$1,356 

$1,442 -

$1,490 

$1,837 

$2,079 

Porsche 

2010 2008 

$6 -

$16 

$8 -

$24 

$10 -

$32 

$12 -

$32 

$15 -

$35 

$26 -

$33 

$27 -

$36 

$30 -

$40 

Spyker 

2010 2008 

- ­

$8 

- ­

$11 

- ­

$15 

- ­

$17 

- ­

$19 

- ­

$22 

- ­

$33 

- ­

$48 

Subaru 

2010 2008 

$115 -

$138 

$156 -

$121 

$1,257 -

$479 

$1,185 -

$505 

$1,147 -

$513 

$1,133 -

$539 

$1,105 -

$532 

$1,103 

$580 

Suzuki 

2010 2008 

$23 -

$21 

$22 -

$20 

$54 -

$210 

$70 -

$218 

$89 -

$222 

$90 -

$222 

$90 -

$222 

$96 -

$229 

Tata 

2010 2008 

$9 -

$34 

$13 -

$51 

$16 -

$55 

$18 -

$62 

$20 -

$64 

$21 -

$76 

$31 -

$89 

$35 -

$96 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$947 -

$972 

$1,053 -

$1,506 

$1,754 -

$1,551 

$1,774 -

$1,877 

$2,010 -

$2,358 

$2,051 -

$2,435 

$2,067 -

$2,465 

$2,601 

$2,667 

Volkswagen 

2010 2008 

$215 -

$221 

$382 -

$275 

$436 -

$360 

$522 -

$643 

$589 -

$755 

$615 -

$840 

$655 -

$920 

$779 -

$982 

Total/Average 

2010 2008 

$7,901 -

$8,330 

$9,158 -

$9,782 

$13,918 -

$12,944 

$15,444 -

$15,784 

$16,850 -

$17,736 

$18,000 -

$18,447 

$19,402 -

$19,339 

$22,519 

$21,945 
707 

Table VII-1q 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Max Net Benefits (7% Discount Rate) 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$315 -

$359 

$414 -

$469 

$519 -

$546 

$612 -

$634 

$684 -

$673 

$722 -

$684 

$766 -

$733 

$849 -

$794 

BMW 

2010 2008 

$329 -

$380 

$543 -

$598 

$653 -

$647 

$734 -

$725 

$909 -

$869 

$1,020 -

$997 

$1,073 -

$1,059 

$1,880 

$2,108 

Daimler 

2010 2008 

$310 -

$349 

$403 -

$464 

$502 -

$565 

$603 -

$822 

$682 -

$875 

$900 -

$1,085 

$1,156 -

$1,289 

$1,226 

$1,364 

Fiat 

2010 2008 

$1,141 -

$1,569 

$1,172 -

$1,653 

$1,322 -

$1,591 

$1,689 -

$1,661 

$1,807 -

$1,699 

$1,801 -

$1,667 

$1,977 -

$1,751 

$2,000 

$1,763 

Ford 

2010 2008 

$818 -

$922 

$852 -

$944 

$1,590 -

$1,834 

$1,757 -

$2,074 

$2,051 -

$2,160 

$2,076 -

$2,152 

$2,060 -

$2,188 

$2,468 

$2,356 

Geely 

2010 2008 

$326 -

$541 

$664 -

$636 

$1,049 -

$985 

$1,152 -

$1,054 

$1,213 -

$1,135 

$1,248 -

$1,133 

$1,329 -

$1,305 

$1,508 

$1,399 

General Motors 

2010 2008 

$760 -

$965 

$983 -

$1,163 

$902 -

$1,121 

$1,353 -

$1,310 

$1,385 -

$1,444 

$1,356 -

$1,413 

$1,467 -

$1,476 

$1,629 

$1,624 

Honda 

2010 2008 

$496 -

$968 

$673 -

$999 

$612 -

$888 

$613 -

$865 

$1,073 -

$1,095 

$1,063 -

$1,112 

$1,188 -

$1,166 

$1,212 

$1,171 

Hyundai 

2010 2008 

$830 -

$853 

$797 -

$856 

$998 -

$1,074 

$1,058 -

$1,053 

$1,264 -

$1,101 

$1,365 -

$1,167 

$1,391 -

$1,192 

$1,601 

$1,232 

Kia 

2010 2008 

$987 -

$822 

$919 -

$726 

$1,247 -

$742 

$1,269 -

$1,147 

$1,250 -

$1,261 

$1,318 -

$1,259 

$1,310 -

$1,251 

$1,294 

$1,237 

Lotus 

2010 2008 

$506 -

$392 

$608 -

$502 

$1,541 -

$574 

$1,625 -

$667 

$1,677 -

$717 

$1,707 -

$733 

$873 -

$777 

$971 -

$843 

Mazda 

2010 2008 

$946 -

$1,276 

$1,206 -

$1,573 

$1,100 -

$1,455 

$1,970 -

$2,031 

$1,986 -

$1,974 

$2,258 -

$2,119 

$2,240 -

$2,157 

$2,218 

$2,129 

Mitsubishi 

2010 2008 

$881 -

$969 

$859 -

$905 

$794 -

$1,015 

$2,138 -

$3,884 

$2,201 -

$3,823 

$2,159 -

$3,865 

$2,133 -

$3,890 

$2,120 

$3,859 
708 

Nissan 

2010 2008 

$629 -

$846 

$773 -

$919 

$1,055 -

$1,134 

$1,105 -

$1,161 

$1,091 -

$1,148 

$1,226 -

$1,262 

$1,240 -

$1,414 

$1,606 

$1,678 

Porsche 

2010 2008 

$304 -

$434 

$374 -

$649 

$537 -

$806 

$657 -

$810 

$829 -

$851 

$1,436 -

$767 

$1,498 -

$812 

$1,587 

$848 

Spyker 

2010 2008 

- ­

$368 

- ­

$530 

- ­

$669 

- ­

$746 

- ­

$806 

- ­

$863 

- ­

$1,297 

- ­

$1,927 

Subaru 

2010 2008 

$544 -

$611 

$760 -

$533 

$1,344 -

$2,131 

$4,020 -

$2,194 

$3,970 -

$2,157 

$4,008 -

$2,134 

$4,007 -

$2,060 

$4,026 

$2,201 

Suzuki 

2010 2008 

$529 -

$212 

$523 -

$208 

$1,232 -

$1,471 

$1,578 -

$1,554 

$2,231 -

$1,538 

$2,189 -

$1,514 

$2,154 -

$1,491 

$2,131 

$1,458 

Tata 

2010 2008 

$310 -

$589 

$412 -

$891 

$506 -

$900 

$599 -

$995 

$625 -

$1,015 

$660 -

$1,152 

$953 -

$1,327 

$1,028 

$1,373 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$580 -

$526 

$661 -

$715 

$1,092 -

$746 

$1,104 -

$875 

$1,156 -

$1,116 

$1,153 -

$1,112 

$1,138 -

$1,098 

$1,278 

$1,208 

Volkswagen 

2010 2008 

$424 -

$389 

$762 -

$482 

$870 -

$599 

$1,074 -

$1,082 

$1,218 -

$1,196 

$1,262 -

$1,278 

$1,324 -

$1,382 

$1,527 

$1,463 

Total/Average 

2010 2008 

$696 -

$797 

$816 -

$899 

$1,048 -

$1,090 

$1,281 -

$1,265 

$1,427 -

$1,384 

$1,466 -

$1,408 

$1,522 -

$1,462 

$1,712 

$1,597 
709 

Table VII-1r 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Max Net Benefits (7% Discount Rate) 

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

BMW 

2010 2008 

$106 -

$119 

$173 -

$193 

$214 -

$224 

$242 -

$259 

$305 -

$312 

$349 -

$359 

$372 -

$382 

$673 -

$818 

Daimler 

2010 2008 

$78 -

$99 

$97 -

$128 

$123 -

$159 

$148 -

$239 

$170 -

$263 

$226 -

$331 

$293 -

$403 

$317 -

$453 

Fiat 

2010 2008 

$834 -

$673 

$865 -

$675 

$1,019 -

$640 

$1,332 -

$707 

$1,458 -

$734 

$1,496 -

$726 

$1,685 -

$762 

$1,759 

$771 

Ford 

2010 2008 

$1,103 -

$1,198 

$1,148 -

$1,238 

$2,133 -

$2,443 

$2,368 -

$2,859 

$2,790 -

$3,028 

$2,861 -

$3,045 

$2,873 -

$3,227 

$3,500 

$3,542 

Geely 

2010 2008 

$20 -

$48 

$38 -

$57 

$63 -

$90 

$69 -

$98 

$75 -

$105 

$78 -

$105 

$84 -

$126 

$98 -

$139 

General Motors 

2010 2008 

$1,257 -

$1,464 

$1,589 -

$1,791 

$1,454 -

$1,752 

$2,182 -

$2,110 

$2,250 -

$2,353 

$2,221 -

$2,319 

$2,424 -

$2,461 

$2,731 

$2,760 

Honda 

2010 2008 

$556 -

$1,118 

$767 -

$1,137 

$702 -

$1,017 

$716 -

$1,007 

$1,274 -

$1,313 

$1,289 -

$1,377 

$1,470 -

$1,476 

$1,537 

$1,532 

Hyundai 

2010 2008 

$718 -

$505 

$677 -

$495 

$856 -

$626 

$911 -

$630 

$1,104 -

$675 

$1,211 -

$733 

$1,252 -

$756 

$1,471 

$810 

Kia 

2010 2008 

$341 -

$265 

$312 -

$227 

$410 -

$234 

$416 -

$371 

$413 -

$418 

$442 -

$427 

$444 -

$429 

$449 -

$435 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$241 -

$300 

$300 -

$382 

$272 -

$359 

$489 -

$503 

$495 -

$493 

$570 -

$538 

$571 -

$577 

$575 -

$580 

Mitsubishi 

2010 2008 

$54 -

$75 

$50 -

$68 

$48 -

$76 

$130 -

$296 

$136 -

$294 

$137 -

$303 

$136 -

$307 

$142 -

$317 
710 

Nissan 

2010 2008 

$559 -

$737 

$671 -

$781 

$921 -

$969 

$966 -

$1,025 

$959 -

$1,048 

$1,084 -

$1,183 

$1,108 -

$1,349 

$1,458 

$1,649 

Porsche 

2010 2008 

$6 -

$15 

$7 -

$23 

$9 -

$29 

$11 -

$29 

$14 -

$31 

$25 -

$28 

$26 -

$30 

$28 -

$33 

Spyker 

2010 2008 

- ­

$7 

- ­

$11 

- ­

$13 

- ­

$16 

- ­

$17 

- ­

$19 

- ­

$29 

- ­

$44 

Subaru 

2010 2008 

$114 -

$137 

$156 -

$115 

$277 -

$463 

$827 -

$490 

$821 -

$498 

$841 -

$509 

$848 -

$498 

$868 -

$547 

Suzuki 

2010 2008 

$23 -

$19 

$22 -

$19 

$53 -

$133 

$70 -

$145 

$100 -

$147 

$100 -

$148 

$100 -

$148 

$102 -

$146 

Tata 

2010 2008 

$9 -

$33 

$11 -

$50 

$14 -

$52 

$17 -

$58 

$18 -

$60 

$19 -

$68 

$28 -

$80 

$31 -

$87 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$886 -

$972 

$992 -

$1,312 

$1,648 -

$1,370 

$1,672 -

$1,649 

$1,769 -

$2,125 

$1,785 -

$2,208 

$1,784 -

$2,236 

$2,043 

$2,513 

Volkswagen 

2010 2008 

$204 -

$215 

$359 -

$260 

$403 -

$322 

$494 -

$600 

$561 -

$700 

$587 -

$758 

$619 -

$824 

$727 -

$886 

Total/Average 

2010 2008 

$7,108 -

$7,999 

$8,234 -

$8,961 

$10,622 -

$10,971 

$13,060 -

$13,094 

$14,715 -

$14,615 

$15,323 -

$15,184 

$16,119 -

$16,101 

$18,511 

$18,063 
711 

Table VII-1s 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Total Cost = Total Benefit (3% Discount Rate)

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$376 -

$453 

$475 -

$563 

$585 -

$645 

$667 -

$750 

$766 -

$805 

$854 -

$931 

$931 -

$1,030 

$1,085 

$1,135 

BMW 

2010 2008 

$398 -

$471 

$609 -

$692 

$719 -

$746 

$789 -

$840 

$997 -

$996 

$1,152 -

$1,239 

$1,244 -

$1,350 

$2,122 

$2,432 

Daimler 

2010 2008 

$370 -

$440 

$469 -

$552 

$568 -

$658 

$658 -

$932 

$770 -

$1,001 

$1,032 -

$1,316 

$1,315 -

$1,569 

$1,457 

$1,683 

Fiat 

2010 2008 

$1,202 -

$2,045 

$1,188 -

$2,145 

$1,599 -

$2,151 

$1,747 -

$2,299 

$1,977 -

$2,401 

$2,176 -

$2,427 

$3,932 -

$2,770 

$3,903 

$3,389 

Ford 

2010 2008 

$817 -

$3,310 

$842 -

$2,948 

$2,894 -

$3,110 

$2,976 -

$3,315 

$3,002 -

$3,341 

$3,276 -

$3,305 

$3,275 -

$3,280 

$3,848 

$3,300 

Geely 

2010 2008 

$392 -

$629 

$730 -

$724 

$1,121 -

$1,079 

$1,212 -

$1,170 

$1,301 -

$1,267 

$1,385 -

$1,364 

$1,494 -

$1,591 

$1,750 

$1,724 

General Motors 

2010 2008 

$1,065 -

$1,532 

$1,293 -

$1,721 

$1,197 -

$1,770 

$1,597 -

$2,059 

$2,208 -

$2,359 

$2,160 -

$2,320 

$3,142 -

$2,672 

$3,198 

$2,995 

Honda 

2010 2008 

$773 -

$1,117 

$1,058 -

$1,202 

$981 -

$1,050 

$977 -

$1,047 

$1,255 -

$1,372 

$1,301 -

$1,378 

$1,637 -

$1,527 

$1,731 

$1,596 

Hyundai 

2010 2008 

$850 -

$879 

$814 -

$901 

$1,120 -

$1,358 

$1,149 -

$1,383 

$1,372 -

$1,515 

$1,607 -

$1,902 

$1,587 -

$1,983 

$1,882 

$2,514 

Kia 

2010 2008 

$1,040 -

$1,850 

$968 -

$1,666 

$1,100 -

$1,674 

$1,395 -

$2,087 

$1,408 -

$2,150 

$1,699 -

$2,176 

$1,713 -

$2,210 

$1,679 

$2,194 

Lotus 

2010 2008 

$572 -

$491 

$679 -

$607 

$1,613 -

$684 

$1,686 -

$799 

$1,770 -

$860 

$1,850 -

$997 

$1,055 -

$1,102 

$1,224 

$1,206 

Mazda 

2010 2008 

$1,133 -

$1,443 

$1,195 -

$1,522 

$1,091 -

$1,402 

$1,584 -

$2,051 

$1,756 -

$2,150 

$2,118 -

$3,708 

$2,273 -

$3,674 

$2,465 

$3,624 

Mitsubishi 

2010 2008 

$923 -

$1,063 

$859 -

$905 

$861 -

$1,204 

$3,831 -

$3,838 

$3,873 -

$4,034 

$3,818 -

$4,066 

$3,782 -

$4,084 

$3,778 

$4,048 
712 

Nissan 

2010 2008 

$725 -

$913 

$874 -

$1,104 

$1,352 -

$1,514 

$1,427 -

$1,592 

$1,455 -

$1,669 

$1,602 -

$2,175 

$1,764 -

$2,377 

$2,806 

$2,528 

Porsche 

2010 2008 

$370 -

$533 

$440 -

$753 

$603 -

$916 

$717 -

$942 

$917 -

$994 

$1,568 -

$1,031 

$1,663 -

$1,137 

$1,824 

$1,211 

Spyker 

2010 2008 

- ­

$461 

- ­

$629 

- ­

$768 

- ­

$867 

- ­

$943 

- ­

$1,111 

- ­

$1,600 

- ­

$2,273 

Subaru 

2010 2008 

$587 -

$710 

$671 -

$638 

$6,139 -

$2,240 

$5,415 -

$2,303 

$5,211 -

$2,259 

$5,057 -

$2,375 

$4,876 -

$2,365 

$4,773 

$2,559 

Suzuki 

2010 2008 

$620 -

$807 

$613 -

$790 

$1,175 -

$1,516 

$1,623 -

$1,964 

$2,043 -

$2,002 

$2,041 -

$2,124 

$2,084 -

$2,205 

$2,219 

$2,294 

Tata 

2010 2008 

$370 -

$677 

$472 -

$979 

$572 -

$994 

$649 -

$1,105 

$713 -

$1,136 

$792 -

$1,377 

$1,113 -

$1,602 

$1,259 

$1,681 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$569 -

$837 

$679 -

$1,055 

$1,222 -

$1,111 

$1,266 -

$1,283 

$1,483 -

$1,452 

$1,497 -

$1,530 

$1,492 -

$1,517 

$1,681 

$1,636 

Volkswagen 

2010 2008 

$485 -

$483 

$828 -

$581 

$942 -

$703 

$1,134 -

$1,203 

$1,312 -

$1,333 

$1,400 -

$1,531 

$1,495 -

$1,690 

$1,775 

$1,810 

Total/Average 

2010 2008 

$804 -

$1,351 

$929 -

$1,422 

$1,485 -

$1,562 

$1,626 -

$1,775 

$1,849 -

$1,930 

$1,965 -

$2,069 

$2,325 -

$2,199 

$2,607 

$2,396 
713 

Table VII-1t 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Total Cost = Total Benefit (3% Discount Rate)

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

$1 -

$1 

BMW 

2010 2008 

$128 -

$147 

$194 -

$223 

$235 -

$258 

$260 -

$301 

$335 -

$358 

$394 -

$446 

$431 -

$487 

$760 -

$944 

Daimler 

2010 2008 

$94 -

$125 

$113 -

$152 

$140 -

$185 

$162 -

$271 

$192 -

$301 

$259 -

$401 

$334 -

$490 

$377 -

$559 

Fiat 

2010 2008 

$878 -

$878 

$877 -

$876 

$1,233 -

$866 

$1,377 -

$979 

$1,595 -

$1,037 

$1,808 -

$1,056 

$3,351 -

$1,205 

$3,433 

$1,482 

Ford 

2010 2008 

$1,102 -

$4,303 

$1,135 -

$3,866 

$3,883 -

$4,143 

$4,010 -

$4,570 

$4,083 -

$4,683 

$4,514 -

$4,677 

$4,568 -

$4,837 

$5,459 

$4,963 

Geely 

2010 2008 

$24 -

$55 

$42 -

$65 

$68 -

$99 

$73 -

$109 

$80 -

$117 

$86 -

$126 

$94 -

$154 

$114 -

$171 

General Motors 

2010 2008 

$1,761 -

$2,324 

$2,090 -

$2,649 

$1,928 -

$2,768 

$2,576 -

$3,316 

$3,587 -

$3,843 

$3,539 -

$3,807 

$5,192 -

$4,457 

$5,362 

$5,088 

Honda 

2010 2008 

$868 -

$1,290 

$1,206 -

$1,367 

$1,125 -

$1,202 

$1,141 -

$1,218 

$1,491 -

$1,645 

$1,579 -

$1,705 

$2,027 -

$1,932 

$2,194 

$2,088 

Hyundai 

2010 2008 

$735 -

$520 

$691 -

$521 

$961 -

$792 

$989 -

$828 

$1,199 -

$929 

$1,425 -

$1,195 

$1,428 -

$1,258 

$1,729 

$1,653 

Kia 

2010 2008 

$359 -

$596 

$328 -

$520 

$362 -

$527 

$457 -

$675 

$465 -

$712 

$570 -

$738 

$580 -

$757 

$582 -

$772 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$288 -

$339 

$298 -

$369 

$270 -

$346 

$393 -

$509 

$438 -

$537 

$535 -

$942 

$579 -

$983 

$640 -

$987 

Mitsubishi 

2010 2008 

$56 -

$82 

$50 -

$68 

$52 -

$90 

$232 -

$293 

$239 -

$311 

$242 -

$319 

$242 -

$322 

$253 -

$332 
714 

Nissan 

2010 2008 

$644 -

$795 

$758 -

$938 

$1,180 -

$1,294 

$1,247 -

$1,405 

$1,280 -

$1,523 

$1,417 -

$2,039 

$1,576 -

$2,268 

$2,547 

$2,484 

Porsche 

2010 2008 

$7 -

$19 

$8 -

$27 

$10 -

$33 

$12 -

$34 

$16 -

$36 

$27 -

$38 

$29 -

$42 

$32 -

$48 

Spyker 

2010 2008 

- ­

$9 

- ­

$13 

- ­

$15 

- ­

$18 

- ­

$20 

- ­

$24 

- ­

$36 

- ­

$52 

Subaru 

2010 2008 

$123 -

$159 

$138 -

$138 

$1,264 -

$486 

$1,114 -

$515 

$1,078 -

$521 

$1,061 -

$567 

$1,032 -

$572 

$1,029 

$635 

Suzuki 

2010 2008 

$27 -

$73 

$26 -

$71 

$51 -

$137 

$72 -

$184 

$91 -

$192 

$93 -

$207 

$97 -

$219 

$106 -

$230 

Tata 

2010 2008 

$10 -

$38 

$13 -

$55 

$16 -

$57 

$18 -

$64 

$21 -

$67 

$23 -

$82 

$33 -

$97 

$38 -

$107 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$870 -

$1,547 

$1,020 -

$1,935 

$1,844 -

$2,040 

$1,918 -

$2,417 

$2,269 -

$2,765 

$2,318 -

$3,038 

$2,338 -

$3,090 

$2,688 

$3,404 

Volkswagen 

2010 2008 

$234 -

$266 

$390 -

$314 

$436 -

$378 

$522 -

$667 

$604 -

$781 

$651 -

$908 

$698 -

$1,008 

$845 -

$1,095 

Total/Average 

2010 2008 

$8,207 -

$13,567 

$9,377 -

$14,169 

$15,060 -

$15,717 

$16,574 -

$18,374 

$19,065 -

$20,379 

$20,544 -

$22,316 

$24,632 -

$24,218 

$28,189 

$27,097 
715 

Table VII-1u 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Total Cost = Total Benefit (7% Discount Rate)

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$376 -

$453 

$475 -

$563 

$585 -

$645 

$667 -

$750 

$766 -

$805 

$854 -

$931 

$931 -

$1,030 

$1,085 

$1,135 

BMW 

2010 2008 

$398 -

$471 

$609 -

$692 

$719 -

$746 

$789 -

$840 

$997 -

$996 

$1,152 -

$1,239 

$1,244 -

$1,350 

$2,122 

$2,432 

Daimler 

2010 2008 

$370 -

$440 

$469 -

$552 

$568 -

$658 

$658 -

$932 

$770 -

$1,001 

$1,032 -

$1,316 

$1,315 -

$1,569 

$1,457 

$1,683 

Fiat 

2010 2008 

$1,202 -

$2,045 

$1,188 -

$2,145 

$1,599 -

$2,151 

$1,747 -

$2,299 

$1,977 -

$2,401 

$2,176 -

$2,427 

$3,932 -

$2,770 

$3,903 

$3,389 

Ford 

2010 2008 

$817 -

$3,310 

$842 -

$2,948 

$2,894 -

$3,110 

$2,976 -

$3,315 

$3,002 -

$3,341 

$3,276 -

$3,305 

$3,275 -

$3,280 

$3,848 

$3,300 

Geely 

2010 2008 

$392 -

$629 

$730 -

$724 

$1,121 -

$1,079 

$1,212 -

$1,170 

$1,301 -

$1,267 

$1,385 -

$1,364 

$1,494 -

$1,591 

$1,750 

$1,724 

General Motors 

2010 2008 

$1,065 -

$1,532 

$1,293 -

$1,721 

$1,197 -

$1,770 

$1,597 -

$2,059 

$2,208 -

$2,359 

$2,160 -

$2,320 

$3,142 -

$2,672 

$3,198 

$2,995 

Honda 

2010 2008 

$773 -

$1,117 

$1,058 -

$1,202 

$981 -

$1,050 

$977 -

$1,047 

$1,255 -

$1,372 

$1,301 -

$1,378 

$1,637 -

$1,527 

$1,731 

$1,596 

Hyundai 

2010 2008 

$850 -

$879 

$814 -

$901 

$1,120 -

$1,358 

$1,149 -

$1,383 

$1,372 -

$1,515 

$1,607 -

$1,902 

$1,587 -

$1,983 

$1,882 

$2,514 

Kia 

2010 2008 

$1,040 -

$1,850 

$968 -

$1,666 

$1,100 -

$1,674 

$1,395 -

$2,087 

$1,408 -

$2,150 

$1,699 -

$2,176 

$1,713 -

$2,210 

$1,679 

$2,194 

Lotus 

2010 2008 

$572 -

$491 

$679 -

$607 

$1,613 -

$684 

$1,686 -

$799 

$1,770 -

$860 

$1,850 -

$997 

$1,055 -

$1,102 

$1,224 

$1,206 

Mazda 

2010 2008 

$1,133 -

$1,443 

$1,195 -

$1,522 

$1,091 -

$1,402 

$1,584 -

$2,051 

$1,756 -

$2,150 

$2,118 -

$3,708 

$2,273 -

$3,674 

$2,465 

$3,624 

Mitsubishi 

2010 2008 

$923 -

$1,063 

$859 -

$905 

$861 -

$1,204 

$3,831 -

$3,838 

$3,873 -

$4,034 

$3,818 -

$4,066 

$3,782 -

$4,084 

$3,778 

$4,048 
716 

Nissan 

2010 2008 

$725 -

$913 

$874 -

$1,104 

$1,352 -

$1,514 

$1,427 -

$1,592 

$1,455 -

$1,669 

$1,602 -

$2,175 

$1,764 -

$2,377 

$2,806 

$2,528 

Porsche 

2010 2008 

$370 -

$533 

$440 -

$753 

$603 -

$916 

$717 -

$942 

$917 -

$994 

$1,568 -

$1,031 

$1,663 -

$1,137 

$1,824 

$1,211 

Spyker 

2010 2008 

- ­

$461 

- ­

$629 

- ­

$768 

- ­

$867 

- ­

$943 

- ­

$1,111 

- ­

$1,600 

- ­

$2,273 

Subaru 

2010 2008 

$587 -

$710 

$671 -

$638 

$6,139 -

$2,240 

$5,415 -

$2,303 

$5,211 -

$2,259 

$5,057 -

$2,375 

$4,876 -

$2,365 

$4,773 

$2,559 

Suzuki 

2010 2008 

$620 -

$807 

$613 -

$790 

$1,175 -

$1,516 

$1,623 -

$1,964 

$2,043 -

$2,002 

$2,041 -

$2,124 

$2,084 -

$2,205 

$2,219 

$2,294 

Tata 

2010 2008 

$370 -

$677 

$472 -

$979 

$572 -

$994 

$649 -

$1,105 

$713 -

$1,136 

$792 -

$1,377 

$1,113 -

$1,602 

$1,259 

$1,681 

Tesla 

2010 2008 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$2 

Toyota 

2010 2008 

$569 -

$837 

$679 -

$1,055 

$1,222 -

$1,111 

$1,266 -

$1,283 

$1,483 -

$1,452 

$1,497 -

$1,530 

$1,492 -

$1,517 

$1,681 

$1,636 

Volkswagen 

2010 2008 

$485 -

$483 

$828 -

$581 

$942 -

$703 

$1,134 -

$1,203 

$1,312 -

$1,333 

$1,400 -

$1,531 

$1,495 -

$1,690 

$1,775 

$1,810 

Total/Average 

2010 2008 

$804 -

$1,351 

$929 -

$1,422 

$1,485 -

$1,562 

$1,626 -

$1,775 

$1,849 -

$1,930 

$1,965 -

$2,069 

$2,325 -

$2,199 

$2,607 

$2,396 
717 

Table VII-1v 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Total Cost = Total Benefit (7% Discount Rate)

Passenger Cars

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

$0 -

$0 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$0 -

$1 

$1 -

$1 

$1 -

$1 

$1 -

$1 

BMW 

2010 2008 

$128 -

$147 

$194 -

$223 

$235 -

$258 

$260 -

$301 

$335 -

$358 

$394 -

$446 

$431 -

$487 

$760 -

$944 

Daimler 

2010 2008 

$94 -

$125 

$113 -

$152 

$140 -

$185 

$162 -

$271 

$192 -

$301 

$259 -

$401 

$334 -

$490 

$377 -

$559 

Fiat 

2010 2008 

$878 -

$878 

$877 -

$876 

$1,233 -

$866 

$1,377 -

$979 

$1,595 -

$1,037 

$1,808 -

$1,056 

$3,351 -

$1,205 

$3,433 

$1,482 

Ford 

2010 2008 

$1,102 -

$4,303 

$1,135 -

$3,866 

$3,883 -

$4,143 

$4,010 -

$4,570 

$4,083 -

$4,683 

$4,514 -

$4,677 

$4,568 -

$4,837 

$5,459 

$4,963 

Geely 

2010 2008 

$24 -

$55 

$42 -

$65 

$68 -

$99 

$73 -

$109 

$80 -

$117 

$86 -

$126 

$94 -

$154 

$114 -

$171 

General Motors 

2010 2008 

$1,761 -

$2,324 

$2,090 -

$2,649 

$1,928 -

$2,768 

$2,576 -

$3,316 

$3,587 -

$3,843 

$3,539 -

$3,807 

$5,192 -

$4,457 

$5,362 

$5,088 

Honda 

2010 2008 

$868 -

$1,290 

$1,206 -

$1,367 

$1,125 -

$1,202 

$1,141 -

$1,218 

$1,491 -

$1,645 

$1,579 -

$1,705 

$2,027 -

$1,932 

$2,194 

$2,088 

Hyundai 

2010 2008 

$735 -

$520 

$691 -

$521 

$961 -

$792 

$989 -

$828 

$1,199 -

$929 

$1,425 -

$1,195 

$1,428 -

$1,258 

$1,729 

$1,653 

Kia 

2010 2008 

$359 -

$596 

$328 -

$520 

$362 -

$527 

$457 -

$675 

$465 -

$712 

$570 -

$738 

$580 -

$757 

$582 -

$772 

Lotus 

2010 2008 

$0 -

$0 

$0 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$1 -

$0 

$0 -

$0 

$0 -

$0 

Mazda 

2010 2008 

$288 -

$339 

$298 -

$369 

$270 -

$346 

$393 -

$509 

$438 -

$537 

$535 -

$942 

$579 -

$983 

$640 -

$987 

Mitsubishi 

2010 2008 

$56 -

$82 

$50 -

$68 

$52 -

$90 

$232 -

$293 

$239 -

$311 

$242 -

$319 

$242 -

$322 

$253 -

$332 
718 

Nissan 

2010 2008 

$644 -

$795 

$758 -

$938 

$1,180 -

$1,294 

$1,247 -

$1,405 

$1,280 -

$1,523 

$1,417 -

$2,039 

$1,576 -

$2,268 

$2,547 

$2,484 

Porsche 

2010 2008 

$7 -

$19 

$8 -

$27 

$10 -

$33 

$12 -

$34 

$16 -

$36 

$27 -

$38 

$29 -

$42 

$32 -

$48 

Spyker 

2010 2008 

- ­

$9 

- ­

$13 

- ­

$15 

- ­

$18 

- ­

$20 

- ­

$24 

- ­

$36 

- ­

$52 

Subaru 

2010 2008 

$123 -

$159 

$138 -

$138 

$1,264 -

$486 

$1,114 -

$515 

$1,078 -

$521 

$1,061 -

$567 

$1,032 -

$572 

$1,029 

$635 

Suzuki 

2010 2008 

$27 -

$73 

$26 -

$71 

$51 -

$137 

$72 -

$184 

$91 -

$192 

$93 -

$207 

$97 -

$219 

$106 -

$230 

Tata 

2010 2008 

$10 -

$38 

$13 -

$55 

$16 -

$57 

$18 -

$64 

$21 -

$67 

$23 -

$82 

$33 -

$97 

$38 -

$107 

Tesla 

2010 2008 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

- ­

$0 

Toyota 

2010 2008 

$870 -

$1,547 

$1,020 -

$1,935 

$1,844 -

$2,040 

$1,918 -

$2,417 

$2,269 -

$2,765 

$2,318 -

$3,038 

$2,338 -

$3,090 

$2,688 

$3,404 

Volkswagen 

2010 2008 

$234 -

$266 

$390 -

$314 

$436 -

$378 

$522 -

$667 

$604 -

$781 

$651 -

$908 

$698 -

$1,008 

$845 -

$1,095 

Total/Average 

2010 2008 

$8,207 -

$13,567 

$9,377 -

$14,169 

$15,060 -

$15,717 

$16,574 -

$18,374 

$19,065 -

$20,379 

$20,544 -

$22,316 

$24,632 -

$24,218 

$28,189 

$27,097 
719 

Table VII-2a 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Preferred Alternative

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$275 -

$607 

$291 -

$607 

$264 -

$590 

$259 -

$582 

$438 -

$903 

$741 -

$1,337 

$718 -

$1,319 

$724 -

$1,339 

Daimler 

2010 2008 

$253 -

$240 

$346 -

$247 

$326 -

$237 

$320 -

$317 

$417 -

$309 

$805 -

$1,311 

$877 -

$1,306 

$855 -

$1,285 

Fiat 

2010 2008 

$474 -

$52 

$472 -

$60 

$541 -

$111 

$949 -

$745 

$1,269 -

$836 

$1,245 -

$839 

$1,727 -

$1,222 

$1,699 

$1,243 

Ford 

2010 2008 

$131 -

$81 

$149 -

$101 

$216 -

$116 

$258 -

$261 

$997 -

$765 

$988 -

$832 

$982 -

$838 

$981 -

$855 

Geely 

2010 2008 

$12 -

$104 

$445 -

$340 

$439 -

$368 

$430 -

$362 

$425 -

$352 

$510 -

$889 

$1,266 -

$1,251 

$1,275 

$1,234 

General Motors 

2010 2008 

$46 -

($7) 

$62 -

$97 

$587 -

$335 

$995 -

$550 

$984 -

$550 

$959 -

$547 

$958 -

$625 

$1,020 

$631 

Honda 

2010 2008 

($4) ­

$288 

$48 -

$300 

$313 -

$375 

$320 -

$329 

$782 -

$630 

$1,026 -

$868 

$1,045 -

$859 

$1,068 

$903 

Hyundai 

2010 2008 

$293 -

$54 

$211 -

$68 

$967 -

$233 

$964 -

$252 

$950 -

$245 

$1,248 -

$572 

$1,270 -

$565 

$1,484 

$820 

Kia 

2010 2008 

$209 -

$237 

$218 -

$284 

$476 -

$465 

$473 -

$544 

$791 -

$1,108 

$777 -

$1,088 

$832 -

$1,128 

$855 -

$1,164 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$15 -

$2 

$683 -

$859 

$594 -

$771 

$570 -

$823 

$593 -

$740 

$583 -

$743 

$749 -

$730 

$912 -

$719 

Mitsubishi 

2010 2008 

$302 -

$69 

$444 -

$82 

$406 -

$57 

$402 -

$58 

$1,161 -

$1,837 

$1,128 -

$1,785 

$1,113 -

$1,741 

$1,099 

$1,717 
720 

Nissan 

2010 2008 

$5 -

$178 

$18 -

$185 

$414 -

$366 

$540 -

$440 

$660 -

$675 

$729 -

$1,033 

$729 -

$1,008 

$712 -

$1,153 

Porsche 

2010 2008 

$1 -

$1 

$41 -

$13 

$528 -

$453 

$516 -

$447 

$502 -

$440 

$528 -

$483 

$1,255 -

$1,279 

$1,319 

$1,342 

Spyker 

2010 2008 

- ­

$257 

- ­

$294 

- ­

$287 

- ­

$283 

- ­

$633 

- ­

$650 

- ­

$658 

- ­

$803 

Subaru 

2010 2008 

$731 -

$1 

$755 -

$104 

$971 -

$613 

$958 -

$572 

$940 -

$582 

$911 -

$582 

$899 -

$574 

$1,442 

$568 

Suzuki 

2010 2008 

($13) ­

$4 

$0 -

$16 

($3) ­

$582 

($2) ­

$574 

$900 -

$662 

$854 -

$651 

$844 -

$643 

$835 -

$635 

Tata 

2010 2008 

$7 -

$9 

$68 -

$62 

$101 -

$112 

$150 -

$151 

$599 -

$636 

$740 -

$714 

$837 -

$804 

$933 -

$905 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$132 -

$25 

$160 -

$230 

$258 -

$400 

$314 -

$482 

$463 -

$626 

$522 -

$648 

$581 -

$659 

$904 -

$886 

Volkswagen 

2010 2008 

$202 -

$1 

$309 -

$102 

$576 -

$658 

$1,037 -

$667 

$1,022 -

$822 

$1,007 -

$829 

$1,136 -

$1,051 

$1,155 

$1,088 

Total/Average 

2010 2008 

$158 -

$87 

$187 -

$179 

$416 -

$331 

$596 -

$470 

$863 -

$648 

$911 -

$752 

$1,000 -

$808 

$1,081 

$888 
721 

Table VII-2b 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Preferred Alternative

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$29 -

$84 

$30 -

$80 

$28 -

$78 

$26 -

$75 

$44 -

$116 

$74 -

$84 

$71 -

$80 

$73 -

$83 

Daimler 

2010 2008 

$25 -

$21 

$38 -

$21 

$35 -

$21 

$35 -

$29 

$46 -

$31 

$90 -

$21 

$100 -

$21 

$100 -

$22 

Fiat 

2010 2008 

$367 -

$21 

$351 -

$23 

$405 -

$40 

$703 -

$266 

$930 -

$288 

$917 -

$21 

$1,263 -

$23 

$1,227 

$40 

Ford 

2010 2008 

$136 -

$62 

$153 -

$75 

$219 -

$84 

$257 -

$187 

$987 -

$546 

$979 -

$62 

$968 -

$75 

$973 -

$84 

Geely 

2010 2008 

$0 -

$4 

$14 -

$14 

$15 -

$16 

$14 -

$15 

$14 -

$15 

$16 -

$4 

$39 -

$14 

$41 -

$16 

General Motors 

2010 2008 

$55 -

($9) 

$74 -

$133 

$714 -

$481 

$1,205 -

$805 

$1,199 -

$807 

$1,176 -

($9) 

$1,181 -

$133 

$1,268 

$481 

Honda 

2010 2008 

($2) ­

$172 

$25 -

$163 

$165 -

$198 

$166 -

$173 

$401 -

$338 

$529 -

$172 

$533 -

$163 

$540 -

$198 

Hyundai 

2010 2008 

$39 -

$8 

$27 -

$10 

$118 -

$36 

$114 -

$39 

$112 -

$38 

$145 -

$8 

$146 -

$10 

$173 -

$36 

Kia 

2010 2008 

$9 -

$23 

$9 -

$28 

$20 -

$47 

$19 -

$53 

$31 -

$106 

$30 -

$23 

$32 -

$28 

$33 -

$47 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$1 -

$0 

$40 -

$67 

$33 -

$60 

$30 -

$66 

$31 -

$62 

$31 -

$0 

$39 -

$67 

$48 -

$60 

Mitsubishi 

2010 2008 

$4 -

$2 

$6 -

$2 

$6 -

$1 

$6 -

$1 

$17 -

$44 

$17 -

$2 

$17 -

$2 

$17 -

$1 
722 

Nissan 

2010 2008 

$2 -

$79 

$6 -

$76 

$128 -

$146 

$164 -

$175 

$201 -

$275 

$222 -

$79 

$222 -

$76 

$220 -

$146 

Porsche 

2010 2008 

$0 -

$0 

$1 -

$0 

$10 -

$5 

$10 -

$5 

$9 -

$5 

$10 -

$0 

$23 -

$1 

$25 -

$7 

Spyker 

2010 2008 

- ­

$1 

- ­

$1 

- ­

$1 

- ­

$1 

- ­

$2 

- ­

$1 

- ­

$1 

- ­

$2 

Subaru 

2010 2008 

$71 -

$0 

$71 -

$8 

$90 -

$45 

$87 -

$41 

$86 -

$42 

$84 -

$0 

$83 -

$8 

$136 -

$45 

Suzuki 

2010 2008 

($0) ­

$0 

$0 -

$0 

($0) ­

$12 

($0) ­

$12 

$3 -

$14 

$3 -

$0 

$3 -

$0 

$3 -

$12 

Tata 

2010 2008 

$0 -

$1 

$4 -

$4 

$5 -

$6 

$8 -

$8 

$31 -

$37 

$38 -

$10 

$42 -

$16 

$47 -

$22 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$127 -

$33 

$153 -

$282 

$245 -

$456 

$293 -

$556 

$429 -

$761 

$483 -

$33 

$534 -

$282 

$830 -

$456 

Volkswagen 

2010 2008 

$21 -

$0 

$31 -

$15 

$59 -

$97 

$105 -

$98 

$104 -

$122 

$103 -

$0 

$115 -

$15 

$121 -

$97 

Total/Average 

2010 2008 

$885 -

$501 

$1,034 -

$1,003 

$2,295 -

$1,829 

$3,241 -

$2,606 

$4,675 -

$3,650 

$4,946 -

$501 

$5,411 -

$1,003 

$5,875 

$1,829 
723 

Table VII-2c 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

2% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$383 -

$318 

$400 -

$322 

$362 -

$310 

$355 -

$350 

$490 -

$539 

$517 -

$1,070 

$510 -

$1,054 

$487 -

$1,033 

Daimler 

2010 2008 

$385 -

$78 

$490 -

$101 

$464 -

$106 

$473 -

$172 

$460 -

$149 

$746 -

$1,040 

$775 -

$1,035 

$748 -

$1,001 

Fiat 

2010 2008 

$587 -

$149 

$584 -

$161 

$701 -

$169 

$933 -

$677 

$1,181 -

$699 

$1,170 -

$689 

$1,304 -

$792 

$1,279 

$810 

Ford 

2010 2008 

$552 -

$63 

$568 -

$74 

$599 -

$86 

$583 -

$159 

$415 -

$475 

$414 -

$513 

$407 -

$500 

$422 -

$492 

Geely 

2010 2008 

$73 -

$222 

$285 -

$474 

$294 -

$463 

$287 -

$456 

$302 -

$445 

$377 -

$648 

$608 -

$669 

$569 -

$656 

General Motors 

2010 2008 

$433 -

$52 

$442 -

$142 

$529 -

$303 

$607 -

$420 

$595 -

$396 

$601 -

$389 

$604 -

$423 

$590 -

$432 

Honda 

2010 2008 

$216 -

$266 

$253 -

$279 

$265 -

$209 

$274 -

$217 

$335 -

$332 

$399 -

$469 

$486 -

$434 

$582 -

$471 

Hyundai 

2010 2008 

$297 -

$196 

$218 -

$208 

$838 -

$452 

$846 -

$461 

$834 -

$449 

$896 -

$599 

$884 -

$591 

$945 -

$579 

Kia 

2010 2008 

$513 -

$386 

$518 -

$435 

$493 -

$487 

$488 -

$531 

$678 -

$521 

$669 -

$511 

$707 -

$539 

$673 -

$628 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$150 -

$7 

$434 -

$603 

$416 -

$570 

$404 -

$651 

$423 -

$721 

$413 -

$709 

$570 -

$910 

$624 -

$973 

Mitsubishi 

2010 2008 

$302 -

$69 

$603 -

$82 

$557 -

$57 

$550 -

$58 

$961 -

$882 

$932 -

$837 

$919 -

$819 

$907 -

$809 
724 

Nissan 

2010 2008 

$33 -

$197 

$45 -

$205 

$227 -

$321 

$267 -

$438 

$261 -

$525 

$450 -

$616 

$467 -

$602 

$477 -

$743 

Porsche 

2010 2008 

$56 -

$1 

$96 -

$61 

$675 -

$453 

$664 -

$447 

$651 -

$413 

$677 -

$472 

$1,104 -

$985 

$1,091 

$966 

Spyker 

2010 2008 

- ­

$308 

- ­

$369 

- ­

$412 

- ­

$447 

- ­

$611 

- ­

$590 

- ­

$584 

- ­

$622 

Subaru 

2010 2008 

($7) ­

$42 

$14 -

$162 

$503 -

$446 

$476 -

$439 

$463 -

$400 

$560 -

$403 

$552 -

$398 

$642 -

$394 

Suzuki 

2010 2008 

($67) ­

$4 

($52) ­

$16 

($47) ­

$305 

($45) ­

$303 

$520 -

$340 

$511 -

$336 

$485 -

$333 

$478 -

$330 

Tata 

2010 2008 

$67 -

$59 

$123 -

$123 

$161 -

$172 

$210 -

$217 

$571 -

$595 

$652 -

$557 

$694 -

$657 

$729 -

$696 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$252 -

$150 

$183 -

$280 

$182 -

$315 

$181 -

$357 

$367 -

$405 

$414 -

$437 

$437 -

$425 

$639 -

$525 

Volkswagen 

2010 2008 

$252 -

$69 

$267 -

$303 

$409 -

$681 

$570 -

$674 

$556 -

$678 

$566 -

$669 

$576 -

$662 

$616 -

$645 

Total/Average 

2010 2008 

$376 -

$133 

$379 -

$205 

$457 -

$280 

$509 -

$376 

$555 -

$449 

$590 -

$512 

$626 -

$524 

$667 -

$564 
725 

Table VII-2d 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

2% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$41 -

$44 

$42 -

$43 

$38 -

$41 

$36 -

$45 

$50 -

$69 

$52 -

$44 

$51 -

$43 

$49 -

$41 

Daimler 

2010 2008 

$38 -

$7 

$53 -

$8 

$50 -

$9 

$51 -

$16 

$51 -

$15 

$84 -

$7 

$88 -

$8 

$87 -

$9 

Fiat 

2010 2008 

$455 -

$60 

$434 -

$62 

$525 -

$61 

$691 -

$242 

$866 -

$241 

$861 -

$60 

$953 -

$62 

$924 -

$61 

Ford 

2010 2008 

$571 -

$48 

$582 -

$56 

$609 -

$62 

$580 -

$114 

$411 -

$339 

$410 -

$48 

$401 -

$56 

$419 -

$62 

Geely 

2010 2008 

$3 -

$9 

$9 -

$20 

$10 -

$20 

$9 -

$19 

$10 -

$19 

$12 -

$9 

$19 -

$20 

$18 -

$20 

General Motors 

2010 2008 

$526 -

$67 

$531 -

$195 

$644 -

$435 

$736 -

$615 

$725 -

$580 

$737 -

$67 

$745 -

$195 

$734 -

$435 

Honda 

2010 2008 

$116 -

$159 

$133 -

$152 

$140 -

$110 

$141 -

$114 

$172 -

$178 

$206 -

$159 

$248 -

$152 

$294 -

$110 

Hyundai 

2010 2008 

$39 -

$30 

$28 -

$32 

$102 -

$70 

$100 -

$71 

$98 -

$70 

$104 -

$30 

$102 -

$32 

$110 -

$70 

Kia 

2010 2008 

$22 -

$38 

$22 -

$43 

$21 -

$49 

$20 -

$51 

$27 -

$50 

$26 -

$38 

$27 -

$43 

$26 -

$49 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$9 -

$0 

$26 -

$47 

$23 -

$44 

$22 -

$52 

$22 -

$61 

$22 -

$0 

$30 -

$47 

$33 -

$44 

Mitsubishi 

2010 2008 

$4 -

$2 

$8 -

$2 

$8 -

$1 

$8 -

$1 

$14 -

$21 

$14 -

$2 

$14 -

$2 

$14 -

$1 
726 

Nissan 

2010 2008 

$10 -

$88 

$14 -

$85 

$70 -

$128 

$81 -

$174 

$79 -

$214 

$137 -

$88 

$142 -

$85 

$147 -

$128 

Porsche 

2010 2008 

$1 -

$0 

$2 -

$1 

$13 -

$5 

$13 -

$5 

$12 -

$5 

$13 -

$0 

$20 -

$1 

$21 -

$5 

Spyker 

2010 2008 

- ­

$1 

- ­

$1 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$1 

- ­

$1 

- ­

$2 

Subaru 

2010 2008 

($1) ­

$3 

$1 -

$12 

$46 -

$33 

$43 -

$32 

$42 -

$29 

$51 -

$3 

$51 -

$12 

$61 -

$33 

Suzuki 

2010 2008 

($0) ­

$0 

($0) ­

$0 

($0) ­

$6 

($0) ­

$6 

$2 -

$7 

$2 -

$0 

$2 -

$0 

$2 -

$6 

Tata 

2010 2008 

$4 -

$3 

$7 -

$7 

$8 -

$10 

$11 -

$12 

$29 -

$35 

$33 -

$1 

$35 -

$8 

$37 -

$10 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$243 -

$200 

$175 -

$343 

$173 -

$360 

$168 -

$412 

$340 -

$492 

$383 -

$200 

$402 -

$343 

$586 -

$360 

Volkswagen 

2010 2008 

$26 -

$9 

$27 -

$44 

$42 -

$100 

$58 -

$99 

$56 -

$101 

$58 -

$9 

$59 -

$44 

$65 -

$100 

Total/Average 

2010 2008 

$2,107 -

$769 

$2,093 -

$1,152 

$2,523 -

$1,547 

$2,768 -

$2,084 

$3,006 -

$2,527 

$3,203 -

$769 

$3,387 -

$1,152 

$3,626 

$1,547 
727 

Table VII-2e 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

3% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$422 -

$556 

$441 -

$557 

$439 -

$522 

$471 -

$615 

$682 -

$941 

$934 -

$1,519 

$914 -

$1,483 

$912 -

$1,458 

Daimler 

2010 2008 

$511 -

$736 

$622 -

$744 

$591 -

$690 

$600 -

$692 

$584 -

$697 

$1,001 -

$1,207 

$1,017 -

$1,199 

$1,045 

$1,170 

Fiat 

2010 2008 

$624 -

$150 

$621 -

$163 

$793 -

$180 

$1,027 -

$1,003 

$1,313 -

$1,064 

$1,346 -

$1,060 

$1,696 -

$1,269 

$1,676 

$1,284 

Ford 

2010 2008 

$549 -

$125 

$587 -

$153 

$588 -

$164 

$583 -

$320 

$954 -

$712 

$948 -

$799 

$943 -

$785 

$936 -

$796 

Geely 

2010 2008 

$84 -

$183 

$593 -

$815 

$595 -

$829 

$581 -

$798 

$570 -

$828 

$669 -

$1,055 

$1,281 -

$1,041 

$1,257 

$1,023 

General Motors 

2010 2008 

$463 -

$52 

$478 -

$162 

$693 -

$555 

$1,182 -

$788 

$1,162 -

$761 

$1,124 -

$748 

$1,105 -

$784 

$1,121 

$824 

Honda 

2010 2008 

$196 -

$293 

$232 -

$307 

$353 -

$300 

$370 -

$310 

$492 -

$509 

$662 -

$757 

$640 -

$766 

$667 -

$734 

Hyundai 

2010 2008 

$262 -

$470 

$180 -

$485 

$829 -

$628 

$903 -

$619 

$893 -

$608 

$1,051 -

$792 

$1,044 -

$783 

$1,200 

$1,003 

Kia 

2010 2008 

$513 -

$251 

$518 -

$261 

$544 -

$616 

$540 -

$685 

$1,001 -

$863 

$956 -

$850 

$1,076 -

$875 

$1,063 

$869 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$150 -

$16 

$492 -

$792 

$426 -

$705 

$408 -

$790 

$400 -

$702 

$391 -

$688 

$762 -

$1,175 

$976 -

$1,166 

Mitsubishi 

2010 2008 

$228 -

$196 

$372 -

$206 

$322 -

$182 

$320 -

$180 

$1,277 -

$1,499 

$1,232 -

$1,418 

$1,215 -

$1,397 

$1,199 

$1,379 
728 

Nissan 

2010 2008 

$125 -

$237 

$137 -

$246 

$263 -

$421 

$387 -

$464 

$411 -

$759 

$794 -

$931 

$786 -

$968 

$895 -

$1,159 

Porsche 

2010 2008 

$73 -

$1 

$134 -

$152 

$1,050 -

$453 

$1,033 -

$502 

$1,015 -

$517 

$1,068 -

$604 

$1,061 -

$1,296 

$1,075 

$1,325 

Spyker 

2010 2008 

- ­

$358 

- ­

$419 

- ­

$403 

- ­

$496 

- ­

$763 

- ­

$767 

- ­

$825 

- ­

$889 

Subaru 

2010 2008 

$755 -

($28) 

$769 -

$73 

$1,073 -

$561 

$1,058 -

$556 

$1,039 -

$578 

$1,008 -

$536 

$993 -

$530 

$1,128 

$766 

Suzuki 

2010 2008 

$4 -

$51 

$18 -

$62 

($1) ­

$521 

$1 -

$513 

$868 -

$631 

$832 -

$696 

$823 -

$687 

$814 -

$678 

Tata 

2010 2008 

$84 -

$95 

$167 -

$155 

$227 -

$238 

$293 -

$305 

$676 -

$713 

$784 -

$742 

$853 -

$820 

$916 -

$888 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$417 -

$164 

$330 -

$297 

$376 -

$341 

$459 -

$484 

$509 -

$572 

$514 -

$570 

$618 -

$617 

$761 -

$720 

Volkswagen 

2010 2008 

$278 -

$85 

$422 -

$432 

$723 -

$727 

$882 -

$706 

$860 -

$683 

$900 -

$665 

$1,022 -

$641 

$1,158 

$1,394 

Total/Average 

2010 2008 

$435 -

$172 

$445 -

$258 

$570 -

$409 

$739 -

$583 

$876 -

$706 

$928 -

$777 

$996 -

$820 

$1,039 

$898 
729 

Table VII-2f 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

3% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$45 -

$77 

$46 -

$73 

$46 -

$69 

$48 -

$79 

$69 -

$121 

$94 -

$77 

$91 -

$73 

$92 -

$69 

Daimler 

2010 2008 

$51 -

$64 

$68 -

$62 

$64 -

$61 

$65 -

$64 

$64 -

$69 

$112 -

$64 

$115 -

$62 

$122 -

$62 

Fiat 

2010 2008 

$483 -

$61 

$462 -

$62 

$594 -

$65 

$761 -

$358 

$962 -

$367 

$991 -

$61 

$1,240 -

$62 

$1,210 

$65 

Ford 

2010 2008 

$568 -

$95 

$601 -

$115 

$598 -

$117 

$580 -

$230 

$944 -

$509 

$939 -

$95 

$929 -

$115 

$928 -

$117 

Geely 

2010 2008 

$3 -

$8 

$19 -

$34 

$20 -

$36 

$19 -

$34 

$18 -

$35 

$21 -

$8 

$40 -

$34 

$40 -

$36 

General Motors 

2010 2008 

$561 -

$67 

$574 -

$223 

$844 -

$797 

$1,432 -

$1,154 

$1,416 -

$1,115 

$1,378 -

$67 

$1,362 -

$223 

$1,395 

$797 

Honda 

2010 2008 

$105 -

$175 

$122 -

$167 

$186 -

$158 

$191 -

$163 

$252 -

$273 

$341 -

$175 

$326 -

$167 

$337 -

$158 

Hyundai 

2010 2008 

$35 -

$72 

$23 -

$74 

$101 -

$98 

$107 -

$95 

$105 -

$95 

$122 -

$72 

$120 -

$74 

$140 -

$98 

Kia 

2010 2008 

$22 -

$25 

$22 -

$26 

$23 -

$62 

$22 -

$66 

$39 -

$82 

$37 -

$25 

$41 -

$26 

$40 -

$62 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$9 -

$1 

$29 -

$61 

$23 -

$55 

$22 -

$63 

$21 -

$59 

$21 -

$1 

$40 -

$61 

$52 -

$55 

Mitsubishi 

2010 2008 

$3 -

$5 

$5 -

$5 

$5 -

$4 

$5 -

$4 

$18 -

$36 

$18 -

$5 

$18 -

$5 

$18 -

$4 
730 

Nissan 

2010 2008 

$38 -

$106 

$42 -

$101 

$81 -

$168 

$118 -

$185 

$125 -

$310 

$242 -

$106 

$239 -

$101 

$276 -

$168 

Porsche 

2010 2008 

$1 -

$0 

$3 -

$2 

$21 -

$5 

$19 -

$6 

$19 -

$6 

$20 -

$2 

$20 -

$2 

$20 -

$7 

Spyker 

2010 2008 

- ­

$1 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$3 

- ­

$1 

- ­

$2 

- ­

$2 

Subaru 

2010 2008 

$73 -

($2) 

$73 -

$5 

$99 -

$41 

$96 -

$40 

$95 -

$42 

$93 -

($2) 

$92 -

$5 

$106 -

$41 

Suzuki 

2010 2008 

$0 -

$1 

$0 -

$1 

($0) ­

$11 

$0 -

$11 

$3 -

$13 

$3 -

$1 

$3 -

$1 

$3 -

$11 

Tata 

2010 2008 

$5 -

$5 

$9 -

$9 

$12 -

$14 

$15 -

$17 

$34 -

$41 

$40 -

$11 

$43 -

$17 

$46 -

$21 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$403 -

$218 

$315 -

$363 

$358 -

$389 

$428 -

$558 

$472 -

$695 

$476 -

$218 

$568 -

$363 

$699 -

$389 

Volkswagen 

2010 2008 

$29 -

$11 

$42 -

$63 

$74 -

$107 

$89 -

$104 

$87 -

$102 

$92 -

$9 

$104 -

$62 

$121 -

$107 

Total/Average 

2010 2008 

$2,434 -

$989 

$2,455 -

$1,449 

$3,149 -

$2,258 

$4,016 -

$3,233 

$4,747 -

$3,973 

$5,039 -

$989 

$5,391 -

$1,449 

$5,648 

$2,258 
731 

Table VII-2g 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

4% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$630 -

$795 

$650 -

$791 

$624 -

$797 

$612 -

$844 

$759 -

$974 

$1,134 -

$1,409 

$1,168 -

$1,460 

$1,245 

$1,543 

Daimler 

2010 2008 

$511 -

$1,034 

$622 -

$1,041 

$630 -

$979 

$670 -

$976 

$634 -

$990 

$1,111 -

$1,188 

$1,160 -

$1,262 

$1,232 

$1,331 

Fiat 

2010 2008 

$706 -

$498 

$701 -

$489 

$899 -

$503 

$1,295 -

$1,723 

$1,543 -

$1,822 

$1,629 -

$1,869 

$2,097 -

$2,022 

$2,132 

$2,148 

Ford 

2010 2008 

$619 -

$62 

$693 -

$150 

$645 -

$155 

$731 -

$335 

$1,102 -

$1,200 

$1,109 -

$1,320 

$1,106 -

$1,397 

$1,215 

$1,386 

Geely 

2010 2008 

$100 -

$204 

$791 -

$837 

$791 -

$851 

$775 -

$819 

$829 -

$953 

$885 -

$1,087 

$1,476 -

$1,203 

$1,538 

$1,288 

General Motors 

2010 2008 

$463 -

$109 

$484 -

$284 

$715 -

$900 

$1,363 -

$1,248 

$1,340 -

$1,197 

$1,307 -

$1,168 

$1,315 -

$1,188 

$1,336 

$1,163 

Honda 

2010 2008 

$214 -

$653 

$255 -

$659 

$404 -

$602 

$450 -

$603 

$709 -

$946 

$1,077 -

$1,271 

$1,060 -

$1,240 

$1,241 

$1,342 

Hyundai 

2010 2008 

$326 -

$670 

$297 -

$680 

$1,011 -

$795 

$1,067 -

$783 

$1,052 -

$770 

$1,602 -

$1,134 

$1,594 -

$1,122 

$1,820 

$1,841 

Kia 

2010 2008 

$486 -

$373 

$492 -

$383 

$559 -

$692 

$555 -

$798 

$1,064 -

$1,410 

$1,018 -

$1,360 

$1,088 -

$1,341 

$1,074 

$1,324 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$408 -

$16 

$1,217 -

$1,064 

$1,112 -

$971 

$1,124 -

$1,039 

$1,102 -

$961 

$1,141 -

$947 

$1,350 -

$1,412 

$1,531 

$1,429 

Mitsubishi 

2010 2008 

$1,357 -

$342 

$1,347 -

$349 

$1,233 -

$326 

$1,293 -

$320 

$2,013 -

$2,577 

$1,980 -

$2,476 

$1,924 -

$2,436 

$1,895 

$2,400 
732 

Nissan 

2010 2008 

$126 -

$478 

$140 -

$474 

$654 -

$850 

$800 -

$954 

$925 -

$1,512 

$1,171 -

$1,665 

$1,168 -

$1,672 

$1,380 

$1,950 

Porsche 

2010 2008 

$95 -

$1 

$173 -

$190 

$1,084 -

$453 

$1,067 -

$590 

$1,048 -

$621 

$1,184 -

$741 

$1,273 -

$1,461 

$1,358 

$1,523 

Spyker 

2010 2008 

- ­

$358 

- ­

$419 

- ­

$451 

- ­

$584 

- ­

$873 

- ­

$905 

- ­

$996 

- ­

$1,093 

Subaru 

2010 2008 

$812 -

($30) 

$855 -

$207 

$1,219 -

$698 

$1,203 -

$689 

$1,184 -

$708 

$1,298 -

$665 

$1,228 -

$658 

$1,737 

$1,528 

Suzuki 

2010 2008 

$860 -

$20 

$858 -

$32 

$802 -

$1,255 

$789 -

$1,234 

$1,869 -

$1,613 

$1,839 -

$1,586 

$1,787 -

$1,562 

$1,760 

$1,538 

Tata 

2010 2008 

$106 -

$111 

$206 -

$172 

$288 -

$299 

$381 -

$395 

$791 -

$837 

$927 -

$908 

$1,024 -

$997 

$1,120 

$1,098 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$383 -

$184 

$472 -

$357 

$544 -

$466 

$565 -

$574 

$651 -

$672 

$670 -

$689 

$734 -

$924 

$1,020 

$1,061 

Volkswagen 

2010 2008 

$294 -

$102 

$495 -

$470 

$767 -

$829 

$1,034 -

$811 

$1,009 -

$751 

$1,088 -

$850 

$1,207 -

$1,002 

$1,504 

$1,590 

Total/Average 

2010 2008 

$468 -

$280 

$526 -

$399 

$679 -

$635 

$917 -

$864 

$1,071 -

$1,083 

$1,163 -

$1,166 

$1,247 -

$1,255 

$1,378 

$1,369 
733 

Table VII-2h 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

4% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$67 -

$110 

$68 -

$104 

$66 -

$105 

$62 -

$108 

$77 -

$125 

$114 -

$112 

$116 -

$119 

$126 -

$137 

Daimler 

2010 2008 

$51 -

$90 

$68 -

$87 

$68 -

$86 

$73 -

$91 

$70 -

$98 

$125 -

$90 

$132 -

$96 

$144 -

$107 

Fiat 

2010 2008 

$546 -

$202 

$521 -

$188 

$673 -

$182 

$959 -

$615 

$1,131 -

$629 

$1,199 -

$202 

$1,533 -

$188 

$1,540 

$182 

Ford 

2010 2008 

$641 -

$47 

$710 -

$113 

$656 -

$112 

$728 -

$241 

$1,091 -

$857 

$1,099 -

$47 

$1,090 -

$113 

$1,205 

$112 

Geely 

2010 2008 

$4 -

$9 

$26 -

$35 

$26 -

$37 

$25 -

$35 

$27 -

$40 

$28 -

$9 

$46 -

$42 

$49 -

$47 

General Motors 

2010 2008 

$561 -

$142 

$581 -

$389 

$870 -

$1,292 

$1,651 -

$1,829 

$1,632 -

$1,755 

$1,602 -

$142 

$1,621 -

$389 

$1,662 

$1,292 

Honda 

2010 2008 

$115 -

$389 

$134 -

$359 

$213 -

$317 

$233 -

$317 

$363 -

$507 

$555 -

$389 

$540 -

$359 

$627 -

$317 

Hyundai 

2010 2008 

$43 -

$102 

$38 -

$103 

$123 -

$124 

$126 -

$121 

$124 -

$120 

$186 -

$102 

$184 -

$103 

$212 -

$124 

Kia 

2010 2008 

$21 -

$37 

$21 -

$38 

$23 -

$70 

$22 -

$77 

$42 -

$135 

$40 -

$37 

$42 -

$38 

$41 -

$70 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$24 -

$1 

$72 -

$82 

$61 -

$75 

$60 -

$83 

$58 -

$81 

$60 -

$1 

$70 -

$82 

$81 -

$75 

Mitsubishi 

2010 2008 

$19 -

$9 

$19 -

$9 

$18 -

$8 

$18 -

$8 

$29 -

$62 

$29 -

$9 

$29 -

$9 

$29 -

$8 
734 

Nissan 

2010 2008 

$39 -

$213 

$43 -

$195 

$202 -

$339 

$243 -

$380 

$281 -

$617 

$356 -

$213 

$356 -

$195 

$426 -

$339 

Porsche 

2010 2008 

$2 -

$0 

$3 -

$2 

$21 -

$5 

$20 -

$7 

$20 -

$7 

$22 -

$3 

$24 -

$4 

$26 -

$9 

Spyker 

2010 2008 

- ­

$1 

- ­

$2 

- ­

$2 

- ­

$2 

- ­

$3 

- ­

$2 

- ­

$3 

- ­

$3 

Subaru 

2010 2008 

$79 -

($2) 

$81 -

$16 

$112 -

$51 

$109 -

$50 

$109 -

$52 

$119 -

($2) 

$113 -

$16 

$164 -

$51 

Suzuki 

2010 2008 

$3 -

$0 

$3 -

$1 

$3 -

$26 

$3 -

$26 

$7 -

$34 

$7 -

$0 

$7 -

$1 

$7 -

$26 

Tata 

2010 2008 

$6 -

$6 

$11 -

$10 

$15 -

$17 

$20 -

$22 

$40 -

$49 

$47 -

$21 

$51 -

$28 

$56 -

$34 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$370 -

$245 

$451 -

$436 

$518 -

$532 

$527 -

$663 

$604 -

$817 

$620 -

$245 

$674 -

$436 

$937 -

$532 

Volkswagen 

2010 2008 

$30 -

$13 

$50 -

$68 

$79 -

$122 

$104 -

$119 

$102 -

$112 

$111 -

$26 

$123 -

$92 

$157 -

$140 

Total/Average 

2010 2008 

$2,620 -

$1,614 

$2,899 -

$2,237 

$3,749 -

$3,502 

$4,984 -

$4,792 

$5,806 -

$6,098 

$6,319 -

$1,614 

$6,750 -

$2,237 

$7,489 

$3,502 
735 

Table VII-2i 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

5% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$543 -

$943 

$584 -

$938 

$542 -

$894 

$747 -

$1,049 

$977 -

$1,080 

$1,354 -

$1,541 

$1,463 -

$1,621 

$1,583 

$1,763 

Daimler 

2010 2008 

$511 -

$955 

$622 -

$961 

$690 -

$900 

$758 -

$1,020 

$807 -

$1,001 

$1,254 -

$1,378 

$1,336 -

$1,509 

$1,446 

$1,609 

Fiat 

2010 2008 

$706 -

$566 

$701 -

$551 

$946 -

$585 

$1,419 -

$2,227 

$1,667 -

$2,441 

$1,760 -

$2,520 

$2,598 -

$2,772 

$2,702 

$2,961 

Ford 

2010 2008 

$570 -

$197 

$648 -

$366 

$744 -

$358 

$1,214 -

$1,328 

$2,358 -

$2,038 

$2,371 -

$2,344 

$2,385 -

$2,430 

$2,564 

$2,489 

Geely 

2010 2008 

$122 -

$321 

$885 -

$696 

$882 -

$714 

$935 -

$747 

$1,016 -

$890 

$1,157 -

$1,385 

$1,636 -

$1,668 

$1,755 

$1,786 

General Motors 

2010 2008 

$463 -

$177 

$575 -

$430 

$1,103 -

$1,296 

$2,338 -

$1,817 

$2,274 -

$1,774 

$2,228 -

$1,739 

$2,312 -

$1,869 

$2,348 

$1,833 

Honda 

2010 2008 

$287 -

$840 

$334 -

$842 

$718 -

$823 

$744 -

$796 

$1,246 -

$1,469 

$2,072 -

$2,452 

$2,154 -

$2,467 

$2,337 

$2,750 

Hyundai 

2010 2008 

$611 -

$639 

$669 -

$650 

$1,240 -

$885 

$1,228 -

$916 

$1,208 -

$880 

$1,590 -

$1,829 

$1,552 -

$1,795 

$2,319 

$3,251 

Kia 

2010 2008 

$427 -

$531 

$433 -

$544 

$980 -

$721 

$974 -

$825 

$1,511 -

$1,829 

$1,487 -

$1,744 

$1,739 -

$1,966 

$1,815 

$1,945 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$416 -

$16 

$1,227 -

$1,243 

$1,121 -

$1,147 

$1,128 -

$1,212 

$1,104 -

$1,126 

$1,296 -

$1,130 

$1,773 -

$2,186 

$2,600 

$2,691 

Mitsubishi 

2010 2008 

$1,343 -

$342 

$1,423 -

$349 

$1,309 -

$326 

$1,474 -

$349 

$2,013 -

$2,757 

$1,980 -

$2,653 

$1,924 -

$2,608 

$2,135 

$2,647 
736 

Nissan 

2010 2008 

$290 -

$668 

$313 -

$639 

$769 -

$1,040 

$990 -

$1,525 

$1,104 -

$1,984 

$1,443 -

$2,427 

$1,414 -

$2,335 

$2,413 

$2,841 

Porsche 

2010 2008 

$111 -

$1 

$211 -

$234 

$1,084 -

$498 

$1,138 -

$672 

$1,189 -

$769 

$1,332 -

$915 

$1,455 -

$1,642 

$1,578 

$1,738 

Spyker 

2010 2008 

- ­

$358 

- ­

$477 

- ­

$571 

- ­

$719 

- ­

$994 

- ­

$1,059 

- ­

$1,183 

- ­

$1,313 

Subaru 

2010 2008 

$901 -

$126 

$1,045 -

$399 

$2,289 -

$1,382 

$2,252 -

$1,362 

$2,219 -

$1,369 

$2,113 -

$1,304 

$2,102 -

$1,284 

$2,049 

$2,353 

Suzuki 

2010 2008 

$1,120 -

$139 

$1,114 -

$150 

$1,175 -

$1,369 

$1,157 -

$1,346 

$2,200 -

$1,976 

$2,165 -

$1,924 

$2,117 -

$1,911 

$2,338 

$1,877 

Tata 

2010 2008 

$122 -

$133 

$250 -

$247 

$354 -

$370 

$474 -

$489 

$912 -

$964 

$1,081 -

$1,062 

$1,211 -

$1,190 

$1,345 

$1,324 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$426 -

$196 

$464 -

$477 

$624 -

$582 

$696 -

$758 

$883 -

$999 

$1,001 -

$1,064 

$1,163 -

$1,193 

$1,877 

$1,787 

Volkswagen 

2010 2008 

$316 -

$124 

$671 -

$509 

$955 -

$1,086 

$1,169 -

$1,063 

$1,222 -

$1,026 

$1,330 -

$1,217 

$1,466 -

$1,398 

$1,720 

$1,799 

Total/Average 

2010 2008 

$489 -

$363 

$568 -

$534 

$870 -

$851 

$1,334 -

$1,301 

$1,667 -

$1,567 

$1,819 -

$1,792 

$2,004 -

$1,906 

$2,289 

$2,190 
737 

Table VII-2j 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

5% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$130 

$61 -

$124 

$57 -

$117 

$76 -

$135 

$99 -

$139 

$136 -

$153 

$145 -

$162 

$160 -

$182 

Daimler 

2010 2008 

$51 -

$83 

$68 -

$80 

$75 -

$79 

$82 -

$95 

$89 -

$100 

$141 -

$92 

$152 -

$108 

$169 -

$120 

Fiat 

2010 2008 

$546 -

$230 

$521 -

$212 

$709 -

$212 

$1,051 -

$795 

$1,222 -

$842 

$1,295 -

$230 

$1,900 -

$212 

$1,952 

$213 

Ford 

2010 2008 

$590 -

$151 

$663 -

$274 

$756 -

$257 

$1,209 -

$952 

$2,335 -

$1,455 

$2,349 -

$151 

$2,351 -

$274 

$2,543 

$257 

Geely 

2010 2008 

$4 -

$13 

$29 -

$29 

$29 -

$31 

$30 -

$32 

$32 -

$37 

$37 -

$21 

$51 -

$40 

$56 -

$47 

General Motors 

2010 2008 

$561 -

$231 

$690 -

$591 

$1,343 -

$1,861 

$2,832 -

$2,662 

$2,770 -

$2,600 

$2,733 -

$231 

$2,849 -

$591 

$2,922 

$1,861 

Honda 

2010 2008 

$154 -

$501 

$176 -

$458 

$379 -

$434 

$385 -

$418 

$639 -

$787 

$1,069 -

$501 

$1,098 -

$458 

$1,181 

$434 

Hyundai 

2010 2008 

$81 -

$98 

$85 -

$98 

$151 -

$138 

$145 -

$141 

$142 -

$138 

$185 -

$98 

$179 -

$98 

$270 -

$138 

Kia 

2010 2008 

$19 -

$52 

$19 -

$53 

$41 -

$73 

$39 -

$80 

$59 -

$175 

$58 -

$52 

$66 -

$53 

$69 -

$73 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$25 -

$1 

$73 -

$96 

$62 -

$89 

$60 -

$97 

$58 -

$95 

$68 -

$1 

$92 -

$96 

$138 -

$89 

Mitsubishi 

2010 2008 

$18 -

$9 

$20 -

$9 

$19 -

$8 

$21 -

$8 

$29 -

$67 

$29 -

$9 

$29 -

$9 

$33 -

$10 
738 

Nissan 

2010 2008 

$89 -

$297 

$96 -

$264 

$238 -

$415 

$301 -

$607 

$335 -

$810 

$439 -

$297 

$431 -

$264 

$744 -

$427 

Porsche 

2010 2008 

$2 -

$0 

$4 -

$3 

$21 -

$6 

$21 -

$7 

$22 -

$9 

$25 -

$5 

$27 -

$6 

$30 -

$12 

Spyker 

2010 2008 

- ­

$1 

- ­

$2 

- ­

$2 

- ­

$3 

- ­

$4 

- ­

$2 

- ­

$3 

- ­

$4 

Subaru 

2010 2008 

$87 -

$10 

$99 -

$30 

$211 -

$101 

$204 -

$99 

$203 -

$100 

$194 -

$10 

$194 -

$30 

$193 -

$101 

Suzuki 

2010 2008 

$4 -

$3 

$4 -

$3 

$4 -

$28 

$4 -

$28 

$8 -

$41 

$8 -

$3 

$8 -

$4 

$10 -

$29 

Tata 

2010 2008 

$7 -

$8 

$13 -

$14 

$19 -

$21 

$24 -

$27 

$47 -

$56 

$55 -

$30 

$61 -

$39 

$68 -

$47 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$412 -

$261 

$444 -

$583 

$594 -

$665 

$649 -

$875 

$819 -

$1,214 

$926 -

$261 

$1,068 -

$583 

$1,724 

$665 

Volkswagen 

2010 2008 

$33 -

$16 

$67 -

$74 

$98 -

$159 

$118 -

$156 

$124 -

$153 

$136 -

$39 

$149 -

$109 

$180 -

$210 

Total/Average 

2010 2008 

$2,740 -

$2,095 

$3,131 -

$2,998 

$4,807 -

$4,695 

$7,253 -

$7,216 

$9,033 -

$8,819 

$9,883 -

$2,095 

$10,850 -

$2,998 

$12,441 

$4,695 
739 

Table VII-2k 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

6% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$543 -

$988 

$628 -

$984 

$679 -

$982 

$846 -

$1,089 

$1,103 -

$1,293 

$1,519 -

$1,793 

$1,667 -

$1,922 

$1,830 

$2,075 

Daimler 

2010 2008 

$511 -

$1,019 

$650 -

$1,014 

$756 -

$961 

$852 -

$1,122 

$959 -

$1,077 

$1,414 -

$1,572 

$1,528 -

$1,698 

$1,683 

$1,836 

Fiat 

2010 2008 

$699 -

$775 

$689 -

$757 

$982 -

$837 

$1,516 -

$2,608 

$1,789 -

$2,850 

$1,944 -

$3,493 

$2,808 -

$3,594 

$2,944 

$3,870 

Ford 

2010 2008 

$695 -

$601 

$825 -

$772 

$829 -

$720 

$1,321 -

$3,105 

$2,808 -

$3,431 

$2,800 -

$3,474 

$2,784 -

$3,634 

$3,065 

$3,748 

Geely 

2010 2008 

$139 -

$222 

$885 -

$605 

$926 -

$678 

$1,062 -

$899 

$1,148 -

$1,044 

$1,351 -

$1,545 

$1,845 -

$1,861 

$2,003 

$2,034 

General Motors 

2010 2008 

$463 -

$260 

$577 -

$536 

$1,116 -

$1,341 

$2,364 -

$2,087 

$2,313 -

$2,056 

$2,258 -

$2,022 

$2,459 -

$2,304 

$2,589 

$2,481 

Honda 

2010 2008 

$509 -

$829 

$557 -

$831 

$873 -

$1,013 

$927 -

$1,000 

$1,669 -

$1,707 

$2,314 -

$2,976 

$2,441 -

$2,895 

$2,934 

$3,027 

Hyundai 

2010 2008 

$524 -

$729 

$442 -

$737 

$1,762 -

$1,532 

$1,708 -

$1,556 

$1,681 -

$1,506 

$2,271 -

$2,576 

$2,317 -

$2,546 

$3,464 

$3,164 

Kia 

2010 2008 

$618 -

$584 

$622 -

$597 

$1,106 -

$722 

$1,098 -

$1,029 

$2,033 -

$2,736 

$1,998 -

$2,689 

$3,036 -

$2,884 

$3,014 

$2,836 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$519 -

$43 

$1,232 -

$2,249 

$1,126 -

$2,101 

$1,457 -

$2,154 

$1,386 -

$2,066 

$1,732 -

$2,094 

$3,340 -

$3,536 

$3,501 

$3,586 

Mitsubishi 

2010 2008 

$1,357 -

$1,271 

$1,347 -

$1,263 

$1,300 -

$1,171 

$1,213 -

$1,341 

$3,464 -

$2,458 

$3,381 -

$2,529 

$3,331 -

$2,615 

$3,312 

$2,862 
740 

Nissan 

2010 2008 

$323 -

$801 

$342 -

$761 

$1,222 -

$1,324 

$1,622 -

$1,765 

$1,791 -

$2,417 

$2,207 -

$2,755 

$2,182 -

$2,672 

$3,129 

$2,929 

Porsche 

2010 2008 

$128 -

$5 

$255 -

$273 

$1,110 -

$652 

$1,236 -

$893 

$1,365 -

$1,020 

$1,501 -

$1,196 

$1,653 -

$1,835 

$1,815 

$1,974 

Spyker 

2010 2008 

- ­

$369 

- ­

$511 

- ­

$645 

- ­

$813 

- ­

$1,126 

- ­

$1,224 

- ­

$1,386 

- ­

$1,560 

Subaru 

2010 2008 

$921 -

$141 

$977 -

$1,087 

$2,210 -

$2,216 

$2,174 -

$2,170 

$2,082 -

$2,173 

$2,031 -

$2,094 

$2,286 -

$2,168 

$3,727 

$3,112 

Suzuki 

2010 2008 

$638 -

$705 

$639 -

$706 

$848 -

$1,272 

$954 -

$1,251 

$2,018 -

$5,648 

$2,072 -

$5,584 

$2,192 -

$5,567 

$2,405 

$5,578 

Tata 

2010 2008 

$144 -

$155 

$288 -

$294 

$425 -

$436 

$568 -

$588 

$1,044 -

$1,096 

$1,246 -

$1,232 

$1,420 -

$1,399 

$1,593 

$1,582 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$464 -

$344 

$575 -

$624 

$978 -

$787 

$1,043 -

$997 

$1,331 -

$1,302 

$1,574 -

$1,457 

$1,733 -

$1,538 

$3,365 

$3,018 

Volkswagen 

2010 2008 

$333 -

$140 

$712 -

$553 

$1,027 -

$1,086 

$1,355 -

$1,129 

$1,454 -

$1,230 

$1,584 -

$1,371 

$1,774 -

$1,585 

$2,076 

$2,030 

Total/Average 

2010 2008 

$542 -

$506 

$639 -

$704 

$1,012 -

$1,057 

$1,507 -

$1,770 

$1,960 -

$2,046 

$2,132 -

$2,320 

$2,371 -

$2,462 

$2,910 

$2,937 
741 

Table VII-2l 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

6% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$136 

$66 -

$130 

$71 -

$129 

$86 -

$140 

$112 -

$166 

$152 -

$176 

$165 -

$191 

$185 -

$225 

Daimler 

2010 2008 

$51 -

$89 

$71 -

$85 

$82 -

$85 

$93 -

$104 

$106 -

$107 

$159 -

$117 

$174 -

$132 

$197 -

$150 

Fiat 

2010 2008 

$541 -

$315 

$512 -

$290 

$736 -

$304 

$1,123 -

$931 

$1,312 -

$983 

$1,431 -

$315 

$2,054 -

$290 

$2,126 

$364 

Ford 

2010 2008 

$720 -

$459 

$845 -

$578 

$842 -

$517 

$1,315 -

$2,226 

$2,781 -

$2,450 

$2,774 -

$459 

$2,745 -

$578 

$3,039 

$517 

Geely 

2010 2008 

$5 -

$9 

$29 -

$26 

$31 -

$29 

$34 -

$38 

$37 -

$44 

$43 -

$24 

$57 -

$44 

$64 -

$56 

General Motors 

2010 2008 

$561 -

$340 

$693 -

$736 

$1,359 -

$1,925 

$2,864 -

$3,058 

$2,818 -

$3,013 

$2,769 -

$340 

$3,031 -

$736 

$3,221 

$1,925 

Honda 

2010 2008 

$273 -

$495 

$293 -

$453 

$461 -

$535 

$480 -

$525 

$856 -

$915 

$1,193 -

$495 

$1,244 -

$453 

$1,483 

$535 

Hyundai 

2010 2008 

$69 -

$111 

$56 -

$112 

$215 -

$238 

$202 -

$240 

$198 -

$236 

$264 -

$111 

$267 -

$117 

$403 -

$238 

Kia 

2010 2008 

$27 -

$58 

$27 -

$59 

$46 -

$73 

$44 -

$99 

$80 -

$261 

$78 -

$58 

$116 -

$59 

$115 -

$73 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$31 -

$3 

$73 -

$174 

$62 -

$163 

$78 -

$173 

$73 -

$174 

$91 -

$3 

$174 -

$174 

$186 -

$163 

Mitsubishi 

2010 2008 

$19 -

$33 

$19 -

$31 

$19 -

$28 

$17 -

$32 

$50 -

$59 

$50 -

$35 

$49 -

$38 

$50 -

$42 
742 

Nissan 

2010 2008 

$99 -

$356 

$105 -

$314 

$378 -

$528 

$493 -

$702 

$544 -

$986 

$672 -

$356 

$665 -

$314 

$965 -

$643 

Porsche 

2010 2008 

$3 -

$0 

$5 -

$3 

$22 -

$7 

$23 -

$10 

$26 -

$11 

$28 -

$6 

$31 -

$8 

$34 -

$16 

Spyker 

2010 2008 

- ­

$1 

- ­

$2 

- ­

$2 

- ­

$3 

- ­

$4 

- ­

$3 

- ­

$4 

- ­

$5 

Subaru 

2010 2008 

$89 -

$11 

$92 -

$82 

$204 -

$161 

$197 -

$157 

$191 -

$158 

$187 -

$11 

$211 -

$89 

$351 -

$161 

Suzuki 

2010 2008 

$2 -

$16 

$2 -

$15 

$3 -

$26 

$4 -

$26 

$8 -

$117 

$8 -

$16 

$9 -

$15 

$10 -

$27 

Tata 

2010 2008 

$8 -

$9 

$15 -

$17 

$22 -

$25 

$29 -

$33 

$53 -

$64 

$63 -

$40 

$71 -

$51 

$80 -

$62 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$448 -

$457 

$549 -

$764 

$931 -

$899 

$973 -

$1,151 

$1,234 -

$1,583 

$1,456 -

$457 

$1,592 -

$764 

$3,091 

$899 

Volkswagen 

2010 2008 

$34 -

$18 

$72 -

$80 

$106 -

$159 

$137 -

$166 

$147 -

$183 

$162 -

$57 

$180 -

$134 

$217 -

$247 

Total/Average 

2010 2008 

$3,037 -

$2,916 

$3,523 -

$3,949 

$5,589 -

$5,834 

$8,191 -

$9,815 

$10,624 -

$11,515 

$11,579 -

$2,916 

$12,834 -

$3,949 

$15,818 

$5,834 
743 

Table VII-2m 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

7% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$543 -

$968 

$667 -

$963 

$750 -

$920 

$945 -

$1,236 

$1,241 -

$1,474 

$1,695 -

$1,950 

$1,887 -

$2,122 

$2,105 

$2,344 

Daimler 

2010 2008 

$511 -

$1,021 

$688 -

$1,016 

$822 -

$963 

$951 -

$1,215 

$1,111 -

$1,199 

$1,579 -

$1,737 

$1,743 -

$1,901 

$1,947 

$2,084 

Fiat 

2010 2008 

$721 -

$779 

$724 -

$778 

$1,048 -

$919 

$1,627 -

$2,362 

$1,930 -

$2,728 

$2,109 -

$3,493 

$3,017 -

$3,934 

$3,202 

$4,174 

Ford 

2010 2008 

$887 -

$557 

$1,027 -

$793 

$1,123 -

$751 

$2,251 -

$2,011 

$3,108 -

$3,083 

$3,115 -

$3,271 

$3,103 -

$4,160 

$3,442 

$4,437 

Geely 

2010 2008 

$161 -

$104 

$885 -

$785 

$997 -

$978 

$1,166 -

$1,142 

$1,285 -

$1,307 

$1,578 -

$1,838 

$2,065 -

$2,017 

$2,278 

$2,230 

General Motors 

2010 2008 

$605 -

$352 

$744 -

$710 

$1,330 -

$1,541 

$2,444 -

$2,696 

$2,431 -

$2,682 

$2,444 -

$2,649 

$2,677 -

$3,094 

$2,852 

$3,455 

Honda 

2010 2008 

$869 -

$844 

$1,006 -

$846 

$1,313 -

$1,218 

$1,440 -

$1,251 

$1,635 -

$2,218 

$2,296 -

$3,435 

$2,362 -

$3,424 

$3,013 

$3,535 

Hyundai 

2010 2008 

$884 -

$938 

$885 -

$949 

$1,819 -

$1,592 

$1,808 -

$1,595 

$1,778 -

$1,537 

$2,299 -

$4,536 

$2,265 -

$4,480 

$5,644 

$5,085 

Kia 

2010 2008 

$519 -

$888 

$525 -

$903 

$1,265 -

$1,091 

$1,256 -

$1,385 

$2,155 -

$2,816 

$2,121 -

$2,768 

$5,554 -

$4,913 

$5,580 

$4,939 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$538 -

$43 

$1,478 -

$1,911 

$1,367 -

$1,792 

$1,646 -

$1,831 

$1,709 -

$1,735 

$1,732 -

$1,716 

$3,554 -

$3,948 

$3,792 

$3,930 

Mitsubishi 

2010 2008 

$1,357 -

$1,366 

$1,347 -

$1,357 

$1,417 -

$1,261 

$1,255 -

$1,448 

$3,464 -

$2,189 

$3,381 -

$2,548 

$3,331 -

$2,717 

$3,514 

$2,934 
744 

Nissan 

2010 2008 

$561 -

$999 

$586 -

$953 

$1,314 -

$1,425 

$1,971 -

$1,831 

$2,127 -

$2,504 

$2,564 -

$2,650 

$2,735 -

$2,852 

$3,148 

$3,569 

Porsche 

2010 2008 

$150 -

$21 

$299 -

$317 

$1,176 -

$720 

$1,335 -

$992 

$1,497 -

$1,152 

$1,672 -

$1,367 

$1,867 -

$2,049 

$2,079 

$2,244 

Spyker 

2010 2008 

- ­

$391 

- ­

$555 

- ­

$717 

- ­

$917 

- ­

$1,264 

- ­

$1,400 

- ­

$1,606 

- ­

$1,835 

Subaru 

2010 2008 

$921 -

$141 

$969 -

$1,128 

$2,202 -

$2,255 

$2,166 -

$2,208 

$2,152 -

$2,122 

$2,064 -

$2,094 

$2,521 -

$2,416 

$5,059 

$4,182 

Suzuki 

2010 2008 

$638 -

$747 

$639 -

$840 

$1,018 -

$1,256 

$1,037 -

$1,236 

$2,090 -

$5,608 

$2,264 -

$5,570 

$2,477 -

$5,740 

$2,702 

$5,965 

Tata 

2010 2008 

$166 -

$172 

$338 -

$338 

$497 -

$513 

$672 -

$692 

$1,182 -

$1,239 

$1,427 -

$1,414 

$1,645 -

$1,630 

$1,873 

$1,863 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$476 -

$284 

$624 -

$736 

$1,042 -

$1,210 

$1,125 -

$1,433 

$1,821 -

$1,852 

$2,007 -

$2,047 

$2,151 -

$2,510 

$3,436 

$2,934 

Volkswagen 

2010 2008 

$355 -

$157 

$756 -

$591 

$1,093 -

$1,086 

$1,454 -

$1,222 

$1,586 -

$1,362 

$1,755 -

$1,536 

$1,994 -

$1,794 

$2,345 

$2,283 

Total/Average 

2010 2008 

$670 -

$535 

$797 -

$801 

$1,191 -

$1,240 

$1,805 -

$1,907 

$2,178 -

$2,339 

$2,361 -

$2,685 

$2,641 -

$3,144 

$3,207 

$3,504 
745 

Table VII-2n 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

7% Annual Increase 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$134 

$70 -

$127 

$79 -

$121 

$96 -

$159 

$126 -

$190 

$170 -

$197 

$187 -

$217 

$213 -

$256 

Daimler 

2010 2008 

$51 -

$89 

$75 -

$85 

$89 -

$85 

$103 -

$113 

$122 -

$119 

$177 -

$134 

$198 -

$153 

$228 -

$176 

Fiat 

2010 2008 

$558 -

$316 

$538 -

$299 

$785 -

$333 

$1,205 -

$843 

$1,416 -

$941 

$1,552 -

$376 

$2,207 -

$373 

$2,313 

$474 

Ford 

2010 2008 

$919 -

$426 

$1,052 -

$593 

$1,141 -

$539 

$2,241 -

$1,442 

$3,077 -

$2,202 

$3,087 -

$481 

$3,059 -

$699 

$3,414 

$804 

Geely 

2010 2008 

$6 -

$4 

$29 -

$33 

$33 -

$42 

$37 -

$49 

$41 -

$55 

$50 -

$25 

$64 -

$63 

$72 -

$76 

General Motors 

2010 2008 

$734 -

$461 

$894 -

$975 

$1,618 -

$2,212 

$2,960 -

$3,951 

$2,962 -

$3,931 

$2,997 -

$461 

$3,299 -

$1,326 

$3,549 

$2,746 

Honda 

2010 2008 

$467 -

$504 

$529 -

$461 

$693 -

$643 

$745 -

$657 

$838 -

$1,188 

$1,184 -

$504 

$1,204 -

$484 

$1,523 

$669 

Hyundai 

2010 2008 

$117 -

$143 

$113 -

$144 

$222 -

$248 

$214 -

$246 

$209 -

$240 

$267 -

$143 

$261 -

$145 

$657 -

$248 

Kia 

2010 2008 

$23 -

$88 

$23 -

$89 

$53 -

$110 

$51 -

$134 

$85 -

$269 

$82 -

$88 

$212 -

$89 

$212 -

$110 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$32 -

$3 

$87 -

$148 

$75 -

$139 

$88 -

$147 

$90 -

$146 

$91 -

$3 

$185 -

$152 

$201 -

$147 

Mitsubishi 

2010 2008 

$19 -

$35 

$19 -

$34 

$20 -

$30 

$18 -

$35 

$50 -

$53 

$50 -

$45 

$49 -

$50 

$54 -

$53 
746 

Nissan 

2010 2008 

$172 -

$444 

$180 -

$393 

$406 -

$568 

$600 -

$729 

$646 -

$1,022 

$780 -

$466 

$833 -

$528 

$971 -

$775 

Porsche 

2010 2008 

$3 -

$0 

$6 -

$4 

$23 -

$8 

$25 -

$11 

$28 -

$13 

$31 -

$8 

$35 -

$11 

$39 -

$19 

Spyker 

2010 2008 

- ­

$1 

- ­

$2 

- ­

$3 

- ­

$3 

- ­

$4 

- ­

$3 

- ­

$5 

- ­

$6 

Subaru 

2010 2008 

$89 -

$11 

$92 -

$85 

$203 -

$164 

$197 -

$160 

$197 -

$154 

$190 -

$11 

$233 -

$110 

$477 -

$164 

Suzuki 

2010 2008 

$2 -

$17 

$2 -

$18 

$4 -

$26 

$4 -

$26 

$8 -

$116 

$9 -

$17 

$10 -

$20 

$11 -

$35 

Tata 

2010 2008 

$9 -

$10 

$18 -

$19 

$26 -

$30 

$35 -

$39 

$60 -

$72 

$72 -

$51 

$83 -

$65 

$94 -

$78 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$460 -

$378 

$596 -

$900 

$992 -

$1,381 

$1,048 -

$1,654 

$1,689 -

$2,252 

$1,857 -

$378 

$1,976 -

$900 

$3,156 

$1,381 

Volkswagen 

2010 2008 

$37 -

$20 

$76 -

$86 

$112 -

$159 

$147 -

$179 

$161 -

$203 

$179 -

$81 

$202 -

$166 

$245 -

$286 

Total/Average 

2010 2008 

$3,752 -

$3,083 

$4,397 -

$4,494 

$6,576 -

$6,841 

$9,814 -

$10,576 

$11,805 -

$13,170 

$12,827 -

$3,083 

$14,298 -

$4,494 

$17,429 

$6,841 
747 

Table VII-2o 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Max Net Benefits (3% Discount Rate) 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$543 -

$1,249 

$628 -

$1,309 

$712 -

$1,370 

$851 -

$1,480 

$1,169 -

$1,669 

$1,464 -

$1,759 

$1,496 -

$1,759 

$1,528 

$1,811 

Daimler 

2010 2008 

$555 -

$1,093 

$650 -

$1,122 

$762 -

$1,130 

$857 -

$1,284 

$1,044 -

$1,335 

$1,359 -

$1,572 

$1,363 -

$1,566 

$1,397 

$1,589 

Fiat 

2010 2008 

$783 -

$1,418 

$701 -

$1,308 

$1,024 -

$1,301 

$1,526 -

$1,956 

$1,868 -

$2,336 

$1,886 -

$2,337 

$2,648 -

$2,757 

$2,663 

$2,910 

Ford 

2010 2008 

$998 -

$973 

$1,026 -

$1,135 

$1,512 -

$1,308 

$1,650 -

$3,183 

$2,417 -

$3,402 

$2,395 -

$3,362 

$2,361 -

$3,370 

$2,375 

$3,459 

Geely 

2010 2008 

$216 -

$525 

$885 -

$746 

$931 -

$969 

$1,073 -

$1,069 

$1,214 -

$1,132 

$1,296 -

$1,544 

$1,669 -

$1,723 

$1,700 

$1,759 

General Motors 

2010 2008 

$967 -

$1,478 

$1,022 -

$1,538 

$1,283 -

$1,840 

$2,230 -

$2,325 

$2,221 -

$2,329 

$2,129 -

$2,278 

$2,235 -

$2,450 

$2,370 

$2,716 

Honda 

2010 2008 

$482 -

$954 

$523 -

$939 

$926 -

$981 

$974 -

$1,011 

$1,367 -

$1,611 

$1,948 -

$2,190 

$1,967 -

$2,161 

$2,207 

$2,339 

Hyundai 

2010 2008 

$1,013 -

$964 

$922 -

$971 

$1,578 -

$1,675 

$1,553 -

$1,630 

$1,528 -

$1,597 

$1,796 -

$1,977 

$1,770 -

$1,935 

$2,002 

$2,525 

Kia 

2010 2008 

$647 -

$729 

$651 -

$738 

$854 -

$617 

$847 -

$729 

$1,617 -

$1,606 

$1,540 -

$1,531 

$1,943 -

$1,704 

$1,906 

$1,683 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$1,048 -

$1,304 

$1,334 -

$1,722 

$1,220 -

$1,573 

$1,359 -

$1,745 

$1,315 -

$1,629 

$1,293 -

$1,693 

$1,758 -

$2,152 

$1,967 

$2,214 

Mitsubishi 

2010 2008 

$1,357 -

$1,508 

$1,347 -

$1,382 

$1,233 -

$1,287 

$1,433 -

$1,341 

$2,485 -

$2,760 

$2,415 -

$2,653 

$2,378 -

$2,608 

$2,342 

$2,619 
748 

Nissan 

2010 2008 

$471 -

$1,909 

$492 -

$1,828 

$1,185 -

$1,890 

$1,506 -

$4,260 

$1,580 -

$4,234 

$1,893 -

$4,185 

$1,873 -

$4,104 

$1,981 

$4,091 

Porsche 

2010 2008 

$199 -

$263 

$255 -

$504 

$1,116 -

$846 

$1,242 -

$1,052 

$1,426 -

$1,108 

$1,446 -

$1,196 

$1,482 -

$1,697 

$1,523 

$1,710 

Spyker 

2010 2008 

- ­

$639 

- ­

$753 

- ­

$849 

- ­

$978 

- ­

$1,214 

- ­

$1,218 

- ­

$1,238 

- ­

$1,285 

Subaru 

2010 2008 

$921 -

$196 

$977 -

$471 

$2,130 -

$1,895 

$2,095 -

$1,801 

$2,005 -

$1,763 

$1,956 -

$1,742 

$1,926 -

$1,713 

$1,918 

$1,973 

Suzuki 

2010 2008 

$821 -

$503 

$820 -

$504 

$848 -

$2,872 

$955 -

$2,803 

$5,928 -

$2,790 

$5,864 -

$2,748 

$5,826 -

$2,699 

$5,790 

$2,821 

Tata 

2010 2008 

$216 -

$430 

$294 -

$541 

$431 -

$651 

$573 -

$758 

$1,110 -

$1,189 

$1,191 -

$1,232 

$1,244 -

$1,250 

$1,290 

$1,296 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$521 -

$568 

$605 -

$766 

$702 -

$888 

$758 -

$989 

$1,005 -

$1,263 

$1,072 -

$1,306 

$1,178 -

$1,326 

$1,355 

$1,569 

Volkswagen 

2010 2008 

$404 -

$393 

$712 -

$773 

$1,032 -

$1,207 

$1,361 -

$1,283 

$1,515 -

$1,318 

$1,529 -

$1,371 

$1,603 -

$1,453 

$1,779 

$1,772 

Total/Average 

2010 2008 

$756 -

$1,070 

$798 -

$1,167 

$1,130 -

$1,370 

$1,481 -

$1,990 

$1,780 -

$2,175 

$1,860 -

$2,237 

$2,011 -

$2,315 

$2,116 

$2,502 
749 

Table VII-2p 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Max Net Benefits (3% Discount Rate) 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$172 

$66 -

$173 

$75 -

$180 

$87 -

$190 

$118 -

$215 

$147 -

$213 

$148 -

$205 

$155 -

$215 

Daimler 

2010 2008 

$55 -

$95 

$71 -

$94 

$83 -

$100 

$93 -

$119 

$115 -

$133 

$152 -

$124 

$155 -

$123 

$163 -

$129 

Fiat 

2010 2008 

$606 -

$575 

$521 -

$502 

$767 -

$472 

$1,130 -

$698 

$1,370 -

$806 

$1,388 -

$612 

$1,936 -

$506 

$1,923 

$481 

Ford 

2010 2008 

$1,033 -

$743 

$1,051 -

$850 

$1,536 -

$939 

$1,643 -

$2,282 

$2,393 -

$2,430 

$2,373 -

$743 

$2,327 -

$850 

$2,356 

$845 

Geely 

2010 2008 

$8 -

$22 

$29 -

$31 

$31 -

$42 

$34 -

$46 

$39 -

$47 

$41 -

$28 

$52 -

$42 

$54 -

$44 

General Motors 

2010 2008 

$1,173 -

$1,934 

$1,228 -

$2,111 

$1,561 -

$2,641 

$2,701 -

$3,406 

$2,706 -

$3,412 

$2,611 -

$1,829 

$2,755 -

$2,111 

$2,949 

$2,649 

Honda 

2010 2008 

$259 -

$569 

$275 -

$511 

$489 -

$518 

$504 -

$531 

$701 -

$864 

$1,004 -

$569 

$1,002 -

$511 

$1,116 

$518 

Hyundai 

2010 2008 

$134 -

$147 

$117 -

$147 

$193 -

$261 

$184 -

$251 

$180 -

$250 

$209 -

$147 

$204 -

$147 

$233 -

$261 

Kia 

2010 2008 

$28 -

$72 

$28 -

$73 

$36 -

$62 

$34 -

$70 

$63 -

$153 

$60 -

$72 

$74 -

$73 

$72 -

$62 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$63 -

$92 

$79 -

$133 

$67 -

$122 

$72 -

$140 

$70 -

$137 

$68 -

$95 

$92 -

$133 

$104 -

$122 

Mitsubishi 

2010 2008 

$19 -

$39 

$19 -

$34 

$18 -

$31 

$20 -

$32 

$36 -

$67 

$36 -

$36 

$35 -

$34 

$36 -

$32 
750 

Nissan 

2010 2008 

$144 -

$850 

$151 -

$754 

$366 -

$753 

$458 -

$1,695 

$480 -

$1,728 

$576 -

$850 

$571 -

$754 

$611 -

$753 

Porsche 

2010 2008 

$4 -

$3 

$5 -

$6 

$22 -

$10 

$23 -

$12 

$27 -

$12 

$27 -

$6 

$28 -

$7 

$29 -

$13 

Spyker 

2010 2008 

- ­

$2 

- ­

$3 

- ­

$3 

- ­

$3 

- ­

$4 

- ­

$3 

- ­

$4 

- ­

$4 

Subaru 

2010 2008 

$89 -

$15 

$92 -

$35 

$196 -

$138 

$190 -

$131 

$184 -

$128 

$180 -

$15 

$178 -

$35 

$181 -

$138 

Suzuki 

2010 2008 

$3 -

$11 

$3 -

$11 

$3 -

$59 

$4 -

$58 

$22 -

$58 

$23 -

$11 

$23 -

$11 

$24 -

$62 

Tata 

2010 2008 

$12 -

$25 

$16 -

$31 

$23 -

$38 

$30 -

$43 

$57 -

$69 

$60 -

$40 

$63 -

$43 

$65 -

$45 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$503 -

$756 

$578 -

$938 

$668 -

$1,014 

$707 -

$1,142 

$932 -

$1,535 

$992 -

$756 

$1,082 -

$938 

$1,244 

$1,014 

Volkswagen 

2010 2008 

$42 -

$51 

$72 -

$112 

$106 -

$177 

$137 -

$188 

$154 -

$196 

$156 -

$57 

$163 -

$114 

$186 -

$206 

Total/Average 

2010 2008 

$4,231 -

$6,173 

$4,400 -

$6,549 

$6,239 -

$7,559 

$8,052 -

$11,037 

$9,645 -

$12,244 

$10,102 

$6,173 

- $10,887 -

$6,549 

$11,501 

$7,559 
751 

Table VII-2q 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Max Net Benefits (7% Discount Rate) 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$543 -

$1,249 

$628 -

$1,265 

$701 -

$1,297 

$840 -

$1,447 

$1,131 -

$1,636 

$1,426 -

$1,682 

$1,452 -

$1,671 

$1,500 

$1,717 

Daimler 

2010 2008 

$555 -

$1,093 

$650 -

$1,084 

$756 -

$1,064 

$846 -

$1,246 

$1,011 -

$1,302 

$1,320 -

$1,500 

$1,325 -

$1,483 

$1,369 

$1,501 

Fiat 

2010 2008 

$783 -

$1,370 

$701 -

$1,308 

$1,010 -

$1,283 

$1,515 -

$1,862 

$1,827 -

$2,324 

$1,854 -

$2,277 

$2,610 -

$2,555 

$2,637 

$2,650 

Ford 

2010 2008 

$998 -

$915 

$1,026 -

$1,077 

$1,522 -

$1,309 

$1,542 -

$1,728 

$2,201 -

$2,399 

$2,172 -

$2,355 

$2,135 -

$2,352 

$2,102 

$2,340 

Geely 

2010 2008 

$216 -

$481 

$885 -

$702 

$920 -

$936 

$1,056 -

$1,031 

$1,175 -

$1,093 

$1,258 -

$1,467 

$1,630 -

$1,630 

$1,673 

$1,665 

General Motors 

2010 2008 

$967 -

$1,440 

$1,022 -

$1,494 

$1,286 -

$1,743 

$2,212 -

$2,015 

$2,170 -

$2,005 

$2,112 -

$1,959 

$2,104 -

$1,971 

$2,329 

$2,109 

Honda 

2010 2008 

$486 -

$928 

$528 -

$925 

$912 -

$1,042 

$979 -

$1,066 

$1,563 -

$1,391 

$2,167 -

$1,826 

$2,222 -

$1,798 

$2,320 

$1,961 

Hyundai 

2010 2008 

$1,005 -

$873 

$913 -

$878 

$1,472 -

$1,490 

$1,478 -

$1,461 

$1,455 -

$1,432 

$1,677 -

$1,668 

$1,653 -

$1,644 

$2,346 

$1,785 

Kia 

2010 2008 

$619 -

$635 

$624 -

$647 

$827 -

$637 

$821 -

$749 

$1,468 -

$1,658 

$1,443 -

$1,577 

$1,570 -

$1,636 

$1,612 

$1,614 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$1,048 -

$1,122 

$1,221 -

$1,636 

$1,110 -

$1,493 

$1,096 -

$2,424 

$1,094 -

$2,230 

$1,071 -

$2,264 

$1,600 -

$2,560 

$1,725 

$2,672 

Mitsubishi 

2010 2008 

$1,357 -

$1,464 

$1,347 -

$1,382 

$1,233 -

$1,287 

$1,441 -

$1,341 

$2,374 -

$2,577 

$2,308 -

$2,474 

$2,274 -

$2,430 

$2,240 

$2,395 
752 

Nissan 

2010 2008 

$434 -

$1,778 

$455 -

$1,697 

$973 -

$1,834 

$1,319 -

$4,272 

$1,464 -

$4,137 

$1,581 -

$4,091 

$1,550 -

$4,011 

$2,035 

$3,988 

Porsche 

2010 2008 

$199 -

$225 

$255 -

$460 

$1,110 -

$813 

$1,231 -

$1,014 

$1,393 -

$1,069 

$1,408 -

$1,119 

$1,444 -

$1,604 

$1,496 

$1,622 

Spyker 

2010 2008 

- ­

$595 

- ­

$709 

- ­

$816 

- ­

$945 

- ­

$1,176 

- ­

$1,141 

- ­

$1,144 

- ­

$1,192 

Subaru 

2010 2008 

$921 -

$146 

$977 -

$325 

$1,987 -

$1,311 

$1,954 -

$1,229 

$1,867 -

$1,200 

$1,819 -

$1,193 

$1,791 -

$1,176 

$2,064 

$1,711 

Suzuki 

2010 2008 

$742 -

$92 

$741 -

$99 

$848 -

$1,639 

$863 -

$1,561 

$2,018 -

$1,779 

$1,973 -

$1,748 

$1,991 -

$1,716 

$1,915 

$1,690 

Tata 

2010 2008 

$216 -

$386 

$294 -

$492 

$420 -

$612 

$562 -

$720 

$1,072 -

$1,151 

$1,152 -

$1,150 

$1,200 -

$1,151 

$1,263 

$1,197 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$529 -

$533 

$571 -

$748 

$677 -

$876 

$756 -

$903 

$1,025 -

$1,023 

$1,133 -

$1,077 

$1,255 -

$1,035 

$1,400 

$1,233 

Volkswagen 

2010 2008 

$404 -

$349 

$712 -

$734 

$1,021 -

$1,174 

$1,350 -

$1,244 

$1,482 -

$1,279 

$1,491 -

$1,294 

$1,565 -

$1,365 

$1,751 

$1,684 

Total/Average 

2010 2008 

$755 -

$1,019 

$788 -

$1,121 

$1,106 -

$1,320 

$1,438 -

$1,692 

$1,726 -

$1,873 

$1,811 -

$1,915 

$1,939 -

$1,927 

$2,074 

$2,046 
753 

Table VII-2r 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Max Net Benefits (7% Discount Rate) 

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$172 

$66 -

$167 

$74 -

$170 

$86 -

$186 

$114 -

$211 

$143 -

$203 

$144 -

$193 

$152 -

$202 

Daimler 

2010 2008 

$55 -

$95 

$71 -

$91 

$82 -

$94 

$92 -

$116 

$111 -

$130 

$148 -

$117 

$150 -

$115 

$160 -

$119 

Fiat 

2010 2008 

$606 -

$556 

$521 -

$502 

$757 -

$465 

$1,122 -

$665 

$1,339 -

$802 

$1,364 -

$593 

$1,909 -

$502 

$1,904 

$465 

Ford 

2010 2008 

$1,033 -

$698 

$1,051 -

$806 

$1,547 -

$940 

$1,535 -

$1,239 

$2,180 -

$1,713 

$2,152 -

$698 

$2,105 -

$806 

$2,085 

$804 

Geely 

2010 2008 

$8 -

$20 

$29 -

$30 

$31 -

$40 

$34 -

$44 

$38 -

$46 

$40 -

$25 

$51 -

$38 

$53 -

$40 

General Motors 

2010 2008 

$1,173 -

$1,883 

$1,228 -

$2,051 

$1,565 -

$2,502 

$2,680 -

$2,953 

$2,644 -

$2,938 

$2,590 -

$1,829 

$2,594 -

$2,051 

$2,897 

$2,502 

Honda 

2010 2008 

$261 -

$553 

$277 -

$504 

$481 -

$550 

$506 -

$560 

$802 -

$745 

$1,117 -

$553 

$1,132 -

$504 

$1,173 

$550 

Hyundai 

2010 2008 

$133 -

$133 

$116 -

$133 

$180 -

$232 

$175 -

$225 

$171 -

$224 

$195 -

$133 

$191 -

$133 

$273 -

$232 

Kia 

2010 2008 

$27 -

$63 

$27 -

$64 

$34 -

$64 

$33 -

$72 

$58 -

$158 

$56 -

$63 

$60 -

$64 

$61 -

$64 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$63 -

$79 

$72 -

$127 

$61 -

$116 

$58 -

$195 

$58 -

$188 

$56 -

$82 

$83 -

$127 

$91 -

$116 

Mitsubishi 

2010 2008 

$19 -

$38 

$19 -

$34 

$18 -

$31 

$21 -

$32 

$34 -

$62 

$34 -

$36 

$34 -

$34 

$34 -

$31 
754 

Nissan 

2010 2008 

$133 -

$791 

$140 -

$700 

$301 -

$731 

$401 -

$1,700 

$445 -

$1,688 

$481 -

$791 

$472 -

$700 

$628 -

$731 

Porsche 

2010 2008 

$4 -

$3 

$5 -

$6 

$22 -

$9 

$23 -

$11 

$26 -

$12 

$26 -

$6 

$27 -

$6 

$28 -

$12 

Spyker 

2010 2008 

- ­

$2 

- ­

$3 

- ­

$3 

- ­

$3 

- ­

$4 

- ­

$3 

- ­

$3 

- ­

$4 

Subaru 

2010 2008 

$89 -

$11 

$92 -

$24 

$183 -

$95 

$177 -

$89 

$171 -

$87 

$167 -

$11 

$165 -

$24 

$195 -

$95 

Suzuki 

2010 2008 

$3 -

$2 

$2 -

$2 

$3 -

$34 

$3 -

$32 

$8 -

$37 

$8 -

$2 

$8 -

$2 

$8 -

$34 

Tata 

2010 2008 

$12 -

$22 

$16 -

$28 

$22 -

$35 

$29 -

$40 

$55 -

$67 

$58 -

$35 

$60 -

$37 

$64 -

$39 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$511 -

$709 

$545 -

$915 

$644 -

$1,001 

$705 -

$1,042 

$950 -

$1,244 

$1,048 -

$709 

$1,153 -

$915 

$1,285 

$1,001 

Volkswagen 

2010 2008 

$42 -

$45 

$72 -

$107 

$105 -

$172 

$136 -

$183 

$150 -

$190 

$152 -

$46 

$159 -

$100 

$183 -

$192 

Total/Average 

2010 2008 

$4,227 -

$5,876 

$4,348 -

$6,291 

$6,110 -

$7,285 

$7,817 -

$9,387 

$9,354 -

$10,546 

$9,837 -

$5,876 

$10,497 -

$6,291 

$11,275 

$7,285 
755 

Table VII-2s 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Total Cost = Total Benefit (3% Discount Rate)

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$548 -

$1,249 

$650 -

$1,320 

$712 -

$1,390 

$851 -

$1,508 

$1,180 -

$1,697 

$1,481 -

$1,748 

$1,507 -

$1,776 

$1,528 

$1,849 

Daimler 

2010 2008 

$571 -

$1,093 

$672 -

$1,133 

$762 -

$1,162 

$857 -

$1,306 

$1,061 -

$1,363 

$1,370 -

$1,561 

$1,374 -

$1,577 

$1,397 

$1,627 

Fiat 

2010 2008 

$800 -

$1,448 

$702 -

$1,320 

$1,006 -

$1,311 

$1,538 -

$1,955 

$1,881 -

$2,305 

$1,906 -

$2,302 

$2,660 -

$2,718 

$2,630 

$2,885 

Ford 

2010 2008 

$862 -

$1,155 

$893 -

$1,281 

$1,123 -

$1,457 

$1,880 -

$3,185 

$2,533 -

$3,505 

$2,504 -

$3,471 

$2,457 -

$3,555 

$2,449 

$3,599 

Geely 

2010 2008 

$232 -

$547 

$885 -

$757 

$931 -

$980 

$1,073 -

$1,097 

$1,225 -

$1,159 

$1,335 -

$1,533 

$1,680 -

$1,734 

$1,700 

$1,797 

General Motors 

2010 2008 

$984 -

$1,502 

$1,022 -

$1,538 

$1,283 -

$1,841 

$2,230 -

$2,522 

$2,228 -

$2,540 

$2,129 -

$2,487 

$2,236 -

$2,707 

$2,348 

$2,937 

Honda 

2010 2008 

$834 -

$1,163 

$910 -

$1,138 

$1,057 -

$1,303 

$1,140 -

$1,320 

$1,367 -

$1,767 

$1,980 -

$2,439 

$1,943 -

$2,403 

$2,194 

$2,520 

Hyundai 

2010 2008 

$966 -

$1,083 

$876 -

$1,091 

$1,591 -

$1,823 

$1,563 -

$1,773 

$1,536 -

$1,740 

$1,796 -

$2,531 

$1,770 -

$2,485 

$1,997 

$3,035 

Kia 

2010 2008 

$647 -

$851 

$651 -

$853 

$919 -

$723 

$911 -

$872 

$1,616 -

$1,716 

$1,589 -

$1,637 

$1,756 -

$1,663 

$1,718 

$1,638 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$1,064 -

$1,552 

$1,334 -

$1,860 

$1,220 -

$1,715 

$1,497 -

$2,293 

$1,492 -

$2,115 

$1,472 -

$2,045 

$2,131 -

$2,329 

$2,251 

$2,462 

Mitsubishi 

2010 2008 

$1,357 -

$1,530 

$1,347 -

$1,382 

$1,233 -

$1,287 

$1,433 -

$1,397 

$2,485 -

$2,760 

$2,415 -

$2,653 

$2,378 -

$2,683 

$2,342 

$2,663 
756 

Nissan 

2010 2008 

$511 -

$1,919 

$534 -

$1,837 

$1,228 -

$1,843 

$1,863 -

$4,208 

$2,008 -

$4,175 

$2,015 -

$4,128 

$1,985 -

$4,053 

$2,247 

$4,040 

Porsche 

2010 2008 

$221 -

$285 

$277 -

$520 

$1,116 -

$857 

$1,242 -

$1,074 

$1,442 -

$1,135 

$1,457 -

$1,185 

$1,499 -

$1,708 

$1,523 

$1,754 

Spyker 

2010 2008 

- ­

$661 

- ­

$764 

- ­

$865 

- ­

$1,005 

- ­

$1,242 

- ­

$1,207 

- ­

$1,254 

- ­

$1,329 

Subaru 

2010 2008 

$921 -

$245 

$977 -

$497 

$1,987 -

$1,871 

$1,954 -

$1,778 

$1,867 -

$1,739 

$1,819 -

$1,719 

$1,791 -

$1,690 

$2,064 

$2,032 

Suzuki 

2010 2008 

$860 -

$525 

$858 -

$526 

$786 -

$2,115 

$913 -

$2,057 

$2,991 -

$2,475 

$2,913 -

$2,495 

$2,862 -

$2,514 

$2,813 

$2,561 

Tata 

2010 2008 

$238 -

$452 

$316 -

$552 

$431 -

$662 

$573 -

$786 

$1,121 -

$1,217 

$1,207 -

$1,216 

$1,255 -

$1,261 

$1,290 

$1,340 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$626 -

$608 

$688 -

$787 

$770 -

$901 

$837 -

$960 

$1,168 -

$1,258 

$1,164 -

$1,294 

$1,300 -

$1,366 

$1,496 

$1,606 

Volkswagen 

2010 2008 

$426 -

$415 

$734 -

$784 

$1,032 -

$1,218 

$1,361 -

$1,305 

$1,531 -

$1,340 

$1,540 -

$1,354 

$1,620 -

$1,464 

$1,779 

$1,810 

Total/Average 

2010 2008 

$791 -

$1,144 

$827 -

$1,221 

$1,081 -

$1,427 

$1,574 -

$2,076 

$1,855 -

$2,265 

$1,907 -

$2,338 

$2,054 -

$2,447 

$2,159 

$2,617 
757 

Table VII-2t 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Total Cost = Total Benefit (3% Discount Rate)

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$172 

$68 -

$174 

$75 -

$183 

$87 -

$193 

$119 -

$218 

$149 -

$211 

$149 -

$207 

$155 -

$221 

Daimler 

2010 2008 

$57 -

$95 

$73 -

$95 

$83 -

$103 

$93 -

$121 

$117 -

$136 

$154 -

$123 

$156 -

$124 

$163 -

$133 

Fiat 

2010 2008 

$619 -

$588 

$522 -

$507 

$754 -

$475 

$1,139 -

$698 

$1,380 -

$795 

$1,402 -

$610 

$1,945 -

$511 

$1,900 

$492 

Ford 

2010 2008 

$893 -

$882 

$915 -

$959 

$1,142 -

$1,046 

$1,871 -

$2,284 

$2,508 -

$2,504 

$2,481 -

$882 

$2,422 -

$959 

$2,429 

$946 

Geely 

2010 2008 

$8 -

$23 

$29 -

$32 

$31 -

$42 

$34 -

$47 

$39 -

$48 

$42 -

$28 

$52 -

$43 

$54 -

$46 

General Motors 

2010 2008 

$1,194 -

$1,965 

$1,228 -

$2,112 

$1,561 -

$2,643 

$2,701 -

$3,696 

$2,715 -

$3,723 

$2,611 -

$1,829 

$2,756 -

$2,112 

$2,921 

$2,674 

Honda 

2010 2008 

$448 -

$694 

$478 -

$620 

$558 -

$687 

$590 -

$693 

$701 -

$947 

$1,021 -

$694 

$990 -

$620 

$1,109 

$687 

Hyundai 

2010 2008 

$127 -

$166 

$112 -

$165 

$194 -

$284 

$185 -

$273 

$181 -

$272 

$209 -

$166 

$204 -

$165 

$232 -

$284 

Kia 

2010 2008 

$28 -

$84 

$28 -

$84 

$38 -

$73 

$37 -

$84 

$63 -

$164 

$62 -

$84 

$67 -

$84 

$65 -

$73 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$64 -

$109 

$79 -

$144 

$67 -

$133 

$80 -

$184 

$79 -

$178 

$78 -

$108 

$111 -

$144 

$119 -

$133 

Mitsubishi 

2010 2008 

$19 -

$39 

$19 -

$34 

$18 -

$31 

$20 -

$34 

$36 -

$67 

$36 -

$36 

$35 -

$36 

$36 -

$33 
758 

Nissan 

2010 2008 

$156 -

$854 

$164 -

$758 

$380 -

$735 

$567 -

$1,674 

$610 -

$1,703 

$613 -

$854 

$605 -

$758 

$693 -

$735 

Porsche 

2010 2008 

$4 -

$4 

$5 -

$6 

$22 -

$10 

$23 -

$12 

$27 -

$13 

$27 -

$6 

$28 -

$7 

$29 -

$14 

Spyker 

2010 2008 

- ­

$2 

- ­

$3 

- ­

$3 

- ­

$4 

- ­

$4 

- ­

$3 

- ­

$4 

- ­

$4 

Subaru 

2010 2008 

$89 -

$19 

$92 -

$37 

$183 -

$136 

$177 -

$129 

$171 -

$127 

$167 -

$19 

$165 -

$37 

$195 -

$136 

Suzuki 

2010 2008 

$3 -

$12 

$3 -

$11 

$3 -

$44 

$3 -

$43 

$11 -

$51 

$11 -

$13 

$11 -

$14 

$11 -

$48 

Tata 

2010 2008 

$13 -

$26 

$17 -

$31 

$23 -

$38 

$30 -

$44 

$57 -

$71 

$61 -

$39 

$63 -

$43 

$65 -

$48 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$605 -

$809 

$658 -

$963 

$733 -

$1,029 

$780 -

$1,108 

$1,083 -

$1,529 

$1,077 -

$809 

$1,194 -

$963 

$1,374 

$1,029 

Volkswagen 

2010 2008 

$44 -

$53 

$74 -

$114 

$106 -

$179 

$137 -

$191 

$155 -

$199 

$157 -

$55 

$165 -

$115 

$186 -

$212 

Total/Average 

2010 2008 

$4,429 -

$6,596 

$4,562 -

$6,849 

$5,971 -

$7,872 

$8,555 -

$11,512 

$10,052 -

$12,749 

$10,358 -

$6,596 

$11,120 -

$6,849 

$11,737 

$7,872 
759 

Table VII-2u 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Average Cost per Vehicle (2010 Dollars) 

Total Cost = Total Benefit (7% Discount Rate)

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$548 -

$1,249 

$650 -

$1,320 

$712 -

$1,390 

$851 -

$1,508 

$1,180 -

$1,697 

$1,481 -

$1,748 

$1,507 -

$1,776 

$1,528 

$1,849 

Daimler 

2010 2008 

$571 -

$1,093 

$672 -

$1,133 

$762 -

$1,162 

$857 -

$1,306 

$1,061 -

$1,363 

$1,370 -

$1,561 

$1,374 -

$1,577 

$1,397 

$1,627 

Fiat 

2010 2008 

$800 -

$1,448 

$702 -

$1,320 

$1,006 -

$1,311 

$1,538 -

$1,955 

$1,881 -

$2,305 

$1,906 -

$2,302 

$2,660 -

$2,718 

$2,630 

$2,885 

Ford 

2010 2008 

$862 -

$1,155 

$893 -

$1,281 

$1,123 -

$1,457 

$1,880 -

$3,185 

$2,533 -

$3,505 

$2,504 -

$3,471 

$2,457 -

$3,555 

$2,449 

$3,599 

Geely 

2010 2008 

$232 -

$547 

$885 -

$757 

$931 -

$980 

$1,073 -

$1,097 

$1,225 -

$1,159 

$1,335 -

$1,533 

$1,680 -

$1,734 

$1,700 

$1,797 

General Motors 

2010 2008 

$984 -

$1,502 

$1,022 -

$1,538 

$1,283 -

$1,841 

$2,230 -

$2,522 

$2,228 -

$2,540 

$2,129 -

$2,487 

$2,236 -

$2,707 

$2,348 

$2,937 

Honda 

2010 2008 

$834 -

$1,163 

$910 -

$1,138 

$1,057 -

$1,303 

$1,140 -

$1,320 

$1,367 -

$1,767 

$1,980 -

$2,439 

$1,943 -

$2,403 

$2,194 

$2,520 

Hyundai 

2010 2008 

$966 -

$1,083 

$876 -

$1,091 

$1,591 -

$1,823 

$1,563 -

$1,773 

$1,536 -

$1,740 

$1,796 -

$2,531 

$1,770 -

$2,485 

$1,997 

$3,035 

Kia 

2010 2008 

$647 -

$851 

$651 -

$853 

$919 -

$723 

$911 -

$872 

$1,616 -

$1,716 

$1,589 -

$1,637 

$1,756 -

$1,663 

$1,718 

$1,638 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$1,064 -

$1,552 

$1,334 -

$1,860 

$1,220 -

$1,715 

$1,497 -

$2,293 

$1,492 -

$2,115 

$1,472 -

$2,045 

$2,131 -

$2,329 

$2,251 

$2,462 

Mitsubishi 

2010 2008 

$1,357 -

$1,530 

$1,347 -

$1,382 

$1,233 -

$1,287 

$1,433 -

$1,397 

$2,485 -

$2,760 

$2,415 -

$2,653 

$2,378 -

$2,683 

$2,342 

$2,663 
760 

Nissan 

2010 2008 

$511 -

$1,919 

$534 -

$1,837 

$1,228 -

$1,843 

$1,863 -

$4,208 

$2,008 -

$4,175 

$2,015 -

$4,128 

$1,985 -

$4,053 

$2,247 

$4,040 

Porsche 

2010 2008 

$221 -

$285 

$277 -

$520 

$1,116 -

$857 

$1,242 -

$1,074 

$1,442 -

$1,135 

$1,457 -

$1,185 

$1,499 -

$1,708 

$1,523 

$1,754 

Spyker 

2010 2008 

- ­

$661 

- ­

$764 

- ­

$865 

- ­

$1,005 

- ­

$1,242 

- ­

$1,207 

- ­

$1,254 

- ­

$1,329 

Subaru 

2010 2008 

$921 -

$245 

$977 -

$497 

$1,987 -

$1,871 

$1,954 -

$1,778 

$1,867 -

$1,739 

$1,819 -

$1,719 

$1,791 -

$1,690 

$2,064 

$2,032 

Suzuki 

2010 2008 

$860 -

$525 

$858 -

$526 

$786 -

$2,115 

$913 -

$2,057 

$2,991 -

$2,475 

$2,913 -

$2,495 

$2,862 -

$2,514 

$2,813 

$2,561 

Tata 

2010 2008 

$238 -

$452 

$316 -

$552 

$431 -

$662 

$573 -

$786 

$1,121 -

$1,217 

$1,207 -

$1,216 

$1,255 -

$1,261 

$1,290 

$1,340 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$626 -

$608 

$688 -

$787 

$770 -

$901 

$837 -

$960 

$1,168 -

$1,258 

$1,164 -

$1,294 

$1,300 -

$1,366 

$1,496 

$1,606 

Volkswagen 

2010 2008 

$426 -

$415 

$734 -

$784 

$1,032 -

$1,218 

$1,361 -

$1,305 

$1,531 -

$1,340 

$1,540 -

$1,354 

$1,620 -

$1,464 

$1,779 

$1,810 

Total/Average 

2010 2008 

$791 -

$1,144 

$827 -

$1,221 

$1,081 -

$1,427 

$1,574 -

$2,076 

$1,855 -

$2,265 

$1,907 -

$2,338 

$2,054 -

$2,447 

$2,159 

$2,617 
761 

Table VII-2v 

Estimated Incremental Costs or Fines over Adjusted Baseline 

Total Incremental Costs in Millions (2010 Dollars) 

Total Cost = Total Benefit (7% Discount Rate)

Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2024 

Aston Martin 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

BMW 

2010 2008 

$58 -

$172 

$68 -

$174 

$75 -

$183 

$87 -

$193 

$119 -

$218 

$149 -

$211 

$149 -

$207 

$155 -

$221 

Daimler 

2010 2008 

$57 -

$95 

$73 -

$95 

$83 -

$103 

$93 -

$121 

$117 -

$136 

$154 -

$123 

$156 -

$124 

$163 -

$133 

Fiat 

2010 2008 

$619 -

$588 

$522 -

$507 

$754 -

$475 

$1,139 -

$698 

$1,380 -

$795 

$1,402 -

$610 

$1,945 -

$511 

$1,900 

$492 

Ford 

2010 2008 

$893 -

$882 

$915 -

$959 

$1,142 -

$1,046 

$1,871 -

$2,284 

$2,508 -

$2,504 

$2,481 -

$882 

$2,422 -

$959 

$2,429 

$946 

Geely 

2010 2008 

$8 -

$23 

$29 -

$32 

$31 -

$42 

$34 -

$47 

$39 -

$48 

$42 -

$28 

$52 -

$43 

$54 -

$46 

General Motors 

2010 2008 

$1,194 -

$1,965 

$1,228 -

$2,112 

$1,561 -

$2,643 

$2,701 -

$3,696 

$2,715 -

$3,723 

$2,611 -

$1,829 

$2,756 -

$2,112 

$2,921 

$2,674 

Honda 

2010 2008 

$448 -

$694 

$478 -

$620 

$558 -

$687 

$590 -

$693 

$701 -

$947 

$1,021 -

$694 

$990 -

$620 

$1,109 

$687 

Hyundai 

2010 2008 

$127 -

$166 

$112 -

$165 

$194 -

$284 

$185 -

$273 

$181 -

$272 

$209 -

$166 

$204 -

$165 

$232 -

$284 

Kia 

2010 2008 

$28 -

$84 

$28 -

$84 

$38 -

$73 

$37 -

$84 

$63 -

$164 

$62 -

$84 

$67 -

$84 

$65 -

$73 

Lotus 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Mazda 

2010 2008 

$64 -

$109 

$79 -

$144 

$67 -

$133 

$80 -

$184 

$79 -

$178 

$78 -

$108 

$111 -

$144 

$119 -

$133 

Mitsubishi 

2010 2008 

$19 -

$39 

$19 -

$34 

$18 -

$31 

$20 -

$34 

$36 -

$67 

$36 -

$36 

$35 -

$36 

$36 -

$33 
762 

Nissan 

2010 2008 

$156 -

$854 

$164 -

$758 

$380 -

$735 

$567 -

$1,674 

$610 -

$1,703 

$613 -

$854 

$605 -

$758 

$693 -

$735 

Porsche 

2010 2008 

$4 -

$4 

$5 -

$6 

$22 -

$10 

$23 -

$12 

$27 -

$13 

$27 -

$6 

$28 -

$7 

$29 -

$14 

Spyker 

2010 2008 

- ­

$2 

- ­

$3 

- ­

$3 

- ­

$4 

- ­

$4 

- ­

$3 

- ­

$4 

- ­

$4 

Subaru 

2010 2008 

$89 -

$19 

$92 -

$37 

$183 -

$136 

$177 -

$129 

$171 -

$127 

$167 -

$19 

$165 -

$37 

$195 -

$136 

Suzuki 

2010 2008 

$3 -

$12 

$3 -

$11 

$3 -

$44 

$3 -

$43 

$11 -

$51 

$11 -

$13 

$11 -

$14 

$11 -

$48 

Tata 

2010 2008 

$13 -

$26 

$17 -

$31 

$23 -

$38 

$30 -

$44 

$57 -

$71 

$61 -

$39 

$63 -

$43 

$65 -

$48 

Tesla 

2010 2008 

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

- ­- ­

Toyota 

2010 2008 

$605 -

$809 

$658 -

$963 

$733 -

$1,029 

$780 -

$1,108 

$1,083 -

$1,529 

$1,077 -

$809 

$1,194 -

$963 

$1,374 

$1,029 

Volkswagen 

2010 2008 

$44 -

$53 

$74 -

$114 

$106 -

$179 

$137 -

$191 

$155 -

$199 

$157 -

$55 

$165 -

$115 

$186 -

$212 

Total/Average 

2010 2008 

$4,429 -

$6,596 

$4,562 -

$6,849 

$5,971 -

$7,872 

$8,555 -

$11,512 

$10,052 -

$12,749 

$10,358 -

$6,596 

$11,120 -

$6,849 

$11,737 

$7,872 
 

                                                      

763 

Indirect Costs 

Indirect Cost Multiplier Changes 

As discussed in greater detail below, for the NPRM, the agencies revised the markups used to 

estimate indirect costs. The first change was to adjust ICM values based on a change in the retail 

price equivalent (RPE) value to which they are normalized. Previously, the ICM values were 

normalized to a single year value of 1.46, which was recommended in a study conducted by 

RTI.351 The agencies have revised the normalization to 1.50, which represents the historical 

average retail price equivalent (RPE). This was done by applying a factor of .50/.46 to all 

indirect cost elements. The second change was to re-consider the markup factors and the data 

used to generate them. The ICM values for low and medium complexity technologies are now 

based solely on modified Delphi estimates. The final change is the way in which the ICM 

factors are applied. In previous analyses ICMs were applied to the learned value of direct costs. 

However, since learning influences direct costs only, the agencies have reconsidered this 

approach and are no longer applying learning to ICMs, except the warranty component, which 

are influenced by the learned value of direct costs. Indirect costs are thus now established based 

on the initial value of direct costs and held constant until the long-term ICM is applied. The 

collective effect of these changes is to increase the ICM factors applied to technologies. 

Cost markups to account for indirect costs 

To produce a unit of output, auto manufacturers incur direct and indirect costs. Direct costs 

include the cost of materials and labor costs. Indirect costs may be related to production (such as 

research and development [R&D]), corporate operations (such as salaries, pensions, and health 

care costs for corporate staff), or selling (such as transportation, dealer support, and marketing). 

Indirect costs are generally recovered by allocating a share of the costs to each unit of goods 

sold. Although it is possible to account for direct costs allocated to each unit of goods sold, it is 

more challenging to account for indirect costs allocated to a unit of goods sold. To make a cost 

analysis process more feasible, markup factors, which relate total indirect costs to total direct 

costs, have been developed. These factors are often referred to as retail price equivalent (RPE) 

multipliers. 

351 RTI International. Automobile Industry Retail Price Equivalent and Indirect Cost Multipliers. February 2009. 

http://www.epa.gov/otaq/ld-hwy/420r09003.pdf (last accessed August 3, 2012); Rogozhin, A.,et al., “Using indirect 

cost multipliers to estimate the total cost of adding new technology in the automobile industry,” International 

Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031. The peer review for the RTI report is at 

http://www.epa.gov/otaq/ld-hwy/420r09004.pdf (last accessed August 3, 2012). 
                                                      

764 

Cost analysts and regulatory agencies including EPA and NHTSA have frequently used these 

multipliers to estimate the resultant impact on costs associated with manufacturers’ responses to 

regulatory requirements. The best approach to determining the impact of changes in direct 

manufacturing costs on a manufacturer’s indirect costs would be to actually estimate the cost 

impact on each indirect cost element. However, doing this within the constraints of an agency’s 

time or budget is not always feasible, and the technical, financial, and accounting information to 

carry out such an analysis may simply be unavailable. 

RPE multipliers provide, at an aggregate level, the relative shares of revenues (Revenue = Direct 

Costs + Indirect Costs + Net Income) to direct manufacturing costs. Using RPE multipliers 

implicitly assumes that incremental changes in direct manufacturing costs produce common 

incremental changes in all indirect cost contributors as well as net income. A concern in using 

the RPE multiplier in cost analysis for new technologies added in response to regulatory 

requirements is that the indirect costs of vehicle modifications are not likely to be the same for 

different technologies. For example, less complex technologies could require fewer R&D efforts 

or less warranty coverage than more complex technologies. In addition, some simple 

technological adjustments may, for example, have no effect on the number of corporate 

personnel and the indirect costs attributable to those personnel. The use of RPEs, with their 

assumption that all technologies have the same proportion of indirect costs, is likely to 

overestimate the costs of less complex technologies and underestimate the costs of more 

complex technologies. 

To address this concern, the agencies have developed modified multipliers. These multipliers 

are referred to as indirect cost multipliers (ICMs). In contrast to RPE multipliers, ICMs assign 

unique incremental changes to each indirect cost contributor. 

ICM = (direct cost + adjusted indirect cost + profit)/(direct cost) 

To develop the ICMs from the RPE multipliers adjustment factors were developed based on the 

complexity of the technology and the time frame under consideration. This methodology was 

used in the cost estimation for the MYs 2012-2016 final rule. The ICMs were developed in a 

peer-reviewed report from RTI International and were subsequently discussed in a peer-reviewed 

journal article.352 Note that the cost of capital (reflected in profit) is included because of the 

assumption implicit in ICMs (and RPEs) that capital costs are proportional to direct costs, and 

352 RTI International. Automobile Industry Retail Price Equivalent and Indirect Cost Multipliers. February 2009. 

http://www.epa.gov/otaq/ld-hwy/420r09003.pdf (last accessed August 3, 2012); Rogozhin, A.,et al., “Using indirect 

cost multipliers to estimate the total cost of adding new technology in the automobile industry,” International 

Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031. The peer review for the RTI report is at 

http://www.epa.gov/otaq/ld-hwy/420r09004.pdf (last accessed August 3, 2012). 
                                                      

 

765 

businesses need to be able to earn returns on their investments. The capital costs are those 

associated with the incremental costs of the new technologies. 

As noted above, for the analysis supporting this proposed rulemaking, the agencies are again 

using the ICM approach but have made some changes to both the ICM factors and to the method 

of applying those factors to arrive at a final cost estimate. The first of these changes was done in 

response to further analysis by the EPA-NHTSA team related to the derivation of the ICM 

values. The second change was implemented in response to both further consideration by the 

agencies and public feedback that learning effects should not be applied to indirect costs through 

the multiplicative approach that was being used. 

Regarding the first change, in the original work done under contract to EPA by RTI 

International,353 the EPA panel used a consensus approach to determine the impact of three new 

technologies on the indirect costs of manufacturers. Subsequent to that work, the EPA panel 

used a somewhat different approach to estimate the costs for three different technologies using a 

blind survey to make this determination on a different set of technology changes. This 

subsequent effort, referred to by EPA as a modified-Delphi approach, resulted in different ICM 

aggregate and individual element values. This effort is detailed in a memorandum contained in 

the docket for this rule.354 For the MY 2012-2016 GHG/CAFE rulemaking, the original RTI 

values were averaged with the modified-Delphi values to arrive at the final ICMs for low and 

medium complexity technologies, RTI values were used for high complexity level 1 

technologies, and modified-Delphi values were used for high complexity level 2 technologies. 

Recently, EPA and NHTSA have examined the elements of the ICMs more closely and 

determined that the technologies that were analyzed in the original RTI study are not as 

representative of the broad array of low and medium complexity technologies as the technologies 

that were examined in the modified-Delphi study, and that the values in the Delphi study better 

estimate the markup cost elements for low and medium complexity technologies. The original 

light-duty RTI study used low rolling resistance tires as a low complexity technology example 

and a dual clutch transmission as a medium complexity technology. In comparison, the 

modified-Delphi study used passive aerodynamic improvements as the representative low 

complexity technology and turbocharging with downsizing as the representative medium 

complexity technology. Consequently, the modified-Delphi values are being used alone as the 

basis for ICMs for low and medium complexity technologies. NHTSA and EPA technical staffs 

have also re-examined the selection of technology complexity category for each of the 

353 Rogozhin, A.,et al., “Using indirect cost multipliers to estimate the total cost of adding new technology in the 

automobile industry,” International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031.

354 Helfand, Gloria, and Todd Sherwood, “Documentation of the Development of Indirect Cost Multipliers for Three 

Automotive Technologies,” August 2009. EPA-HQ-OAR-2010-0799. 
 

766 

technologies to better align the unexamined technologies to the reference technologies for which 

ICM values were estimated. The resulting designations together with the associated reference 

technologies are shown in Table VII-3. 
 

 

 

 

 

 

 

 

 

 

 

767 

Table VII-3 

Technology Designations by ICM Category, with Reference Technology 

Low Technology 

Passive Aerodynamic Improvements. 

Medium Technology 

Engine Turbo Downsizing 

High Tech 1 

Hybrid Electric Vehicle 

High Tech 2 

Plug-in Hybrid Electric Vehicle 

Passive Aerodynamic Improv. 

Lubricant improvements 

Mass Reductions 3-10% 

Aggressive Shift Logic 

Engine Friction Reduction 

Engine Downsizing 

6 speed auto transmissions 

Low Drag Brakes 

Electro-hydraulic power steering 

Electric power steering 

WT intake or coupled 

Improved accessories 

6-speed DCTs 

Mass Reduction 15-20% 

Turbocharging 

Cylinder deactivation 

VVT-dual cam phasing & Discrete 

variable valve lift 

8-speed auto and DCT transmissions 

12 volt start-stop systems 

Active aerodynamic improvements 

Converting OHV/SOHC to DOHC 

Gasoline direct injection 

Turbo downsizing 

Turbo downsizing +EGR 

Advanced Diesel 

Strong Hybrids 

PHEV and EV chargers 

PHEV non battery 

components 

PHEV battery packs 

All Electric vehicles 

Many of the basic technologies listed in Table VII-3 have variations that share the same 

complexity designation and ICM estimate. Table VII-4 lists each of the technologies used in the 

VOLPE model together with both their ICM category and the year through which the short term 

ICM will be applied. Note that the number behind each ICM Category designation refers to the 

source of the ICM estimate, with 1 indicating the consensus panel and 2 indicating the modified 

Delphi panel. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

768 

Table VII-4 

ICM categories and Short Term ICM Schedules for CAFE Technologies 

Technology 

ICM 

Category 

Short 

Term 

Through 

Low Friction Lubricants - Level 1 Low2 2018 

Engine Friction Reduction - Level 1 Low2 2018 

Low Friction Lubricants and Engine Friction Reduction - Level 2 Low2 2024 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC Low2 2018 

Discrete Variable Valve Lift (DVVL) on SOHC Medium2 2018 

Cylinder Deactivation on SOHC Medium2 2018 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) Low2 2018 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) Medium2 2018 

Discrete Variable Valve Lift (DVVL) on DOHC Medium2 2018 

Continuously Variable Valve Lift (CVVL) Medium2 2018 

Cylinder Deactivation on DOHC Medium2 2018 

Stoichiometric Gasoline Direct Injection (GDI) Medium2 2018 

Cylinder Deactivation on OHV Medium2 2018 

Variable Valve Actuation - CCP and DVVL on OHV Medium2 2018 

Stoichiometric Gasoline Direct Injection (GDI) on OHV Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement - Turbo Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement - Downsize Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement -Turbo Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement - Downsize Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement - Turbo Medium2 2018 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement - Downsize Medium2 2018 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Turbo Medium2 2024 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Downsize Medium2 2018 
769 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Turbo Medium2 2024 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Downsize Medium2 2018 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Turbo Medium2 2024 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement - Downsize Medium2 2018 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement - Turbo Medium2 2024 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement - Downsize Medium2 2018 

Advanced Diesel - Small Displacement Medium2 2024 

Advanced Diesel - Medium Displacement Medium2 2024 

Advanced Diesel - Large Displacement Medium2 2024 

6-Speed Manual/Improved Internals Low2 2018 

Improved Auto. Trans. Controls/Externals Low2 2018 

6-Speed Trans with Improved Internals (Auto) Low2 2018 

6-speed DCT Medium2 2018 

8-Speed Trans (Auto or DCT) Medium2 2018 

High Efficiency Gearbox w/ dry sump (Auto or DCT) Low2 2024 

Shift Optimizer Low2 2024 

Electric Power Steering Low2 2018 
770 

Improved Accessories - Level 1 Low2 2018 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) Low2 2024 

12V Micro-Hybrid (Stop-Start) Medium2 2018 

Integrated Starter Generator High1 2018 

Strong Hybrid (Powersplit or 2-Mode) - Level 1 – Battery High1 2024 

Strong Hybrid (Powersplit or 2-Mode) - Level 1 - Non-Battery High1 2018 

Conversion from SHEV1 to SHEV2 HIgh1 2018 

Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 – Battery High1 2024 

Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 - Non-Battery High1 2018 

Plug-in Hybrid - 20 mi range – Battery High2 2024 

Plug-in Hybrid - 20 mi range - Non-Battery High1 2018 

Plug-in Hybrid - 40 mi range – Battery High2 2024 

Plug-in Hybrid - 40 mi range - Non-Battery High1 2018 

Electric Vehicle (Early Adopter) - 75 mile range – Battery High2 2024 

Electric Vehicle (Early Adopter) - 75 mile range - Non-Battery High2 2024 

Electric Vehicle (Early Adopter) - 100 mile range – Battery High2 2024 

Electric Vehicle (Early Adopter) - 100 mile range - Non-Battery High2 2024 

Electric Vehicle (Early Adopter) - 150 mile range – Battery High2 2024 

Electric Vehicle (Early Adopter) - 150 mile range - Non-Battery High2 2024 

Electric Vehicle (Broad Market) - 150 mile range – Battery High2 2024 

Electric Vehicle (Broad Market) - 150 mile range - Non-Battery High2 2024 

Fuel Cell Vehicle High2 2024 

Charger-PHEV20 High1 2024 

Charger-PHEV40 High1 2024 

Charger-EV High1 2024 

Charger Labor None 2024 

Mass Reduction - Level 1 Low2 2018 
 

 

 

 

 

 

 

 

 

 

 

 

 

771 

Mass Reduction - Level 2 

Mass Reduction - Level 3 

Mass Reduction - Level 4 

Mass Reduction - Level 5 

Low2 

Low2 

Low2 

Low2 

2018 

2018 

2018 

2018 

2018 

2024 

2024 

2018 

2018 

2018 

2024 

Low Rolling Resistance Tires - Level 1 

Low Rolling Resistance Tires - Level 2 

Low Rolling Resistance Tires - Level 3 

Low2 

Low2 

Low2 

Low Drag Brakes 

Secondary Axle Disconnect 

Aero Drag Reduction, Level 1 

Aero Drag Reduction, Level 2 

Low2 

Low2 

Low2 

Medium2 

A secondary-level change was also made as part of this ICM recalculation to the light-duty 

ICMs. That change was to revise upward the RPE level reported in the original RTI report from 

an original value of 1.46 to 1.50 to better reflect the long term average RPE. The original RTI 

study was based on 2007 data. However, an analysis of historical RPE data indicates that, 

although there is year to year variation, the average RPE has remained at approximately 1.50. 

The agencies believe that using the historical average value would result in ICMs that better 

estimate the future values. Therefore, ICMs in this proposed rulemaking were adjusted to reflect 

this average level. As a result, the ICM values for the High 1 and High 2 complexity 

technologies have also changed. 

Table VII-5 shows both the ICM values used in the MYs 2012-2016 final rule and the new ICM 

values used for the analysis supporting these proposed rules. Near term values 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 no longer be attributable to 

the standards and, as such, a lower ICM factor, the long term ICM is applied to direct costs. 
772 

Table VII-5 

Indirect Cost Multipliers Used in this Analysisa
 

2012-2016 Rule This Proposal 

Complexity Near term Long term Near term Long term 

Low 1.17 1.13 1.24 1.19 

Medium 1.31 1.19 1.39 1.29 

High1 1.51 1.32 1.56 1.35 

High2 1.70 1.45 1.77 1.50 a

 Rogozhin, A., et. al., “Using indirect cost multipliers to estimate the total cost of 

adding new technology in the automobile industry,” International Journal of Production 

Economics (2009); “Documentation of the Development of Indirect Cost Multipliers 

for Three Automotive Technologies,” Helfand, G., and Sherwood, T., Memorandum 

dated August 2009; “Heavy Duty Truck Retail Price Equivalent and Indirect Cost 

Multipliers,” Draft Report prepared by RTI International and Transportation Research 

Institute, University of Michigan, July 2010 

The second change made to the ICMs has to do with the way in which they are applied. In the 

past, ICMs have been applied as pure multiplicative factors. This way, a direct manufacturing 

cost of, say, $100 would be multiplied by an ICM of 1.24 to arrive at a marked up technology 

cost of $124. However, as learning effects (discussed below) are applied to the direct 

manufacturing cost, the indirect costs are also reduced accordingly. Therefore, in year two the 

$100 direct manufacturing cost might reduce to $97 because of learning, and the marked up cost 

would become $120 ($97 x 1.24). As a result, indirect costs would be reduced from $24 to $20. 

Given that indirect costs are composed of a number of costs, such as facility-related costs, 

electricity, etc., that are not affected by learning, the agencies do not believe ICMs should be 

applied to the learned direct costs, at least not for those indirect cost elements unlikely to change 

with learning. The EPA-NHTSA team believes that it is appropriate to allow only warranty costs 

to decrease with learning, since warranty costs are tied to direct manufacturing costs (since 

warranty typically involves replacement of actual parts which should be less costly with 

learning). The remaining elements of the indirect costs should remain constant year-over-year, 

at least until some of those indirect costs are no longer attributable to the rulemaking effort that 

imposed them (such as R&D). 

As a result, the ICM calculation has been modified for this proposal and is more complex. First 

the year in which the direct manufacturing costs are considered “valid” is established. For 

example, a cost estimate might be considered valid today, or perhaps not until high volume 

production is reached—which will not occur until MY 2015 or later. That year is known as the 

base year for the estimated cost. The costs in that year are used to determine the “non-warranty” 

portion of the indirect costs. For example, the non-warranty portion of the medium complexity 

ICM in the short-term is 0.343 (the warranty versus non-warranty portions of the ICMs are 

shown in Table VII-6.). For the dual cam phasing (DCP) technology on an I4 engine we have 

estimated a direct manufacturing cost of $70 in MY 2015. So the non-warranty portion of the 

indirect costs would be $24.01 ($70 x 0.343). This value would be added to the learned direct 

manufacturing cost for each year through 2018, the last year of short term indirect costs. 
 

                                                      

 

773 

Beginning in 2019, when long-term indirect costs begin, the additive factor would become 

$18.13 ($70 x 0.259). Additionally, the $70 cost in 2015 would become $67.90 in MY 2016 due 

to learning ($70 x (1-3%)). So, while the warranty portion of the indirect costs would be $3.15 

($70 x 0.045) in 2015, indirect costs would decrease to $3.06 ($67.90 x 0.045) in 2016 as 

warranty costs decrease with learning. The resultant indirect costs for the DCP-I4 technology 

would be $27.16 ($24.01+$3.15) in MY 2015 and $27.07 ($24.01+$3.06) in MY2016, and so on 

for subsequent years. 

Table VII-6 

Warranty and Non-Warranty Portions of ICMs 

Near term Long term 

Complexity Warranty Non-warranty Warranty Non-warranty 

Low 0.012 0.230 0.005 0.187 

Medium 0.045 0.343 0.031 0.259 

High1 0.065 0.499 0.032 0.314 

High2 0.074 0.696 0.049 0.448 

The impact of learning on direct costs, together with the eventual application of long-term ICMs, 

causes the effective ICM based markup to differ from the initial ICM on a year-by-year basis. 

An example of how this occurs is provided in Table VII-7355. This table traces the impact of 

learning on direct costs and its implications for both total costs and the derived ICM based 

markup. Direct costs are assigned a value of 1 to simplify the illustrative analysis and to use the 

same basis as for ICMs (in an ICM markup factor, the value of direct costs is represented by 1 

while the value of indirect costs is represent by the fraction of 1 to the right of the decimal.) The 

table examines the impacts of these factors on Turbo downsized engines, one of the more 

prevalent CAFE technologies. 

355 The table illustrates the learning process from the base year consistent with the direct cost estimate obtained by 

the agencies. It is a mature technology well into the flat portion of the learning curve. Note however, that the costs 

actually applied in this rulemaking will begin with the 2017 model year. 
 

 

 

 

774 

Table VII-7 

Derived Annual ICMs for Turbo Downsized Engines 

Year 

Learning 

Schedule 

#11 

Direct 

Costs 

Other 

Indirect 

Costs Warranty 

Total 

Costs 

 Effective 

ICM Based 

Markup 

Factor 

2010 0.03 

2011 0.03 

2012 0.03 1 0.3427 0.0446 1.3872 1.387 

2013 0.03 0.97 0.3427 0.0432451 1.3559 1.398 

2014 0.03 0.9409 0.3427 0.0419478 1.3255 1.409 

2015 0.03 0.912673 0.3427 0.0406893 1.2960 1.420 

2016 0.03 0.8852928 0.3427 0.0394687 1.2674 1.432 

2017 0.02 0.867587 0.3427 0.0386793 1.2489 1.440 

2018 0.02 0.8502352 0.3427 0.0379057 1.2308 1.448 

2019 0.02 0.8332305 0.2587 0.0310 1.1229 1.348 

2020 0.02 0.8165659 0.2587 0.0303882 1.1056 1.354 

2021 0.02 0.8002346 0.2587 0.0297805 1.0887 1.360 

2022 0.02 0.7842299 0.2587 0.0291849 1.0721 1.367 

2023 0.02 0.7685453 0.2587 0.0286012 1.0558 1.374 

2024 0.02 0.7531744 0.2587 0.0280291 1.0399 1.381 

2025 0.02 0.7381109 0.2587 0.0274686 1.0243 1.388 

2026 0.01 0.7307298 0.2587 0.0271939 1.0166 1.391 

2027 0.01 0.7234225 0.2587 0.0269219 1.0090 1.395 

2028 0.01 0.7161883 0.2587 0.0266527 1.0015 1.398 

2029 0.01 0.7090264 0.2587 0.0263862 0.9941 1.402 

2030 0.01 0.7019361 0.2587 0.0261223 0.9867 1.406 

Average ICM 2017 through 2030 = 1.389 
775 

The second column of Table VII-7 lists the learning schedule that is applied to turbocharging and 

downsizing. Turbocharging and downsizing is a mature technology so the learning schedule 

captures the relatively flat portion of the learning curve that occurs after the larger decreases 

have already reduced direct costs. The cost basis for Turbocharging and downsizing in the 

analysis was effective in 2012, so this is the base year for this calculation when direct costs are 

set to 1. The third column shows the progressive decline in direct costs as the learning schedule 

in column 2 is applied to direct costs. Column 4 contains the value of all indirect costs except 

warranty. Turbocharging and downsizing are a medium complexity technology so this value is 

taken from the Medium row of Table VII-6. The initial value in 2012 is the near term value, 

which is used through 2018. During this time, these indirect costs are not impacted by learning 

and they remain constant. Beginning in 2019, the long-term ICM from Table VII-6 is applied. 

The fifth column contains warranty costs. As previously mentioned, these costs are considered 

to be impacted by learning like direct costs, so they decline steadily until the long-term ICM is 

applied in 2019, at which point they drop before continuing their gradual decline. In the sixth 

column, direct and indirect costs are totaled. The results show an overall decline in total costs of 

roughly 30% during this 14 year period. The last column shows the effective ICM based 

markup, which is derived by dividing total costs by direct costs. Over this period, the derived 

ICM based markup rose from the initial short term ICM level of 1.39 to 1.45 in 2018. It then 

declined to 1.35 in 2019 when the long-term ICM was applied to the learned down direct cost. 

Over the remaining years, the ICM based markup gradually rises back up to 1.41 as learning 

continues to decrease direct costs. 

There are thus two somewhat offsetting processes that impact the effective ICM based markup. 

The first is the learning curve which reduces direct costs, which raises the derived ICM based 

markup. As noted previously learning reflects learned efficiencies in assembly methods as well 

as reduced parts and materials costs. The second is the application of a long-term ICM, which 

reduces the derived ICM based markup. This represents the reduced burden needed to maintain 

new technologies once they are fully developed. In this case, the two processes largely offset 

one another and produce an average ICM based markup over this 14 year period that roughly 

equals the original short term ICM. 

Figure VII-1 illustrates this process for each of the 4 representative technologies that are used to 

estimate ICM values for each of the complexity categories. As with the turbocharging and 

downsizing, aerodynamic improvements and strong hybrid vehicles show a gradual increase in 

the effective ICM based markup through the point where the long-term ICM is applied. At that 

time, the effective markup declines, and then begins a gradual rise. The advanced hybrid ICM 

behaves somewhat differently because the technology is not as mature and, as a result, 

experiences a greater change in the learning value that influences the effective markup value. 

This produces a step-up in markup values concurrent with each learning step, followed by a 

decline when the long-term ICM is applied. After that, the effective markup value begins a 

gradual rise as more moderate learning is applied to reflect its shift to a mature technology. Note 
 

 

776 

that, as with the turbocharging and downsizing example above, for the aerodynamic 

improvements and mild hybrid technologies the offsetting processes of learning and long-term 

ICMs result in an average effective ICM based markup over the full time frame that is roughly 

equal to the initial short-term ICM. However, the advanced hybrid markup rose to a level that is 

significantly higher than the initial ICM. This is a direct function of the rapid learning schedule 

applied in the early years to this developing technology. Brand new technologies might thus be 

expected to have lifetime effective ICM based markups that exceed their initial ICMs, while 

more mature technologies are more likely to experience markups over their remaining life span 

that more closely approximate their initial ICMs. 
777 

Figure VII-1

 Derived ICM Based Markups for Advanced Hybrid Technologies (PHEV Battery Packs and 

EVs), Hybrids, Turbocharging and Downsizing, and Passive Aerodynamic Improvements 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

2012201320142015201620172018201920202021202220232024202520262027202820292030

Adv Hybrid

Hybrid

Turbo

Aero

ICMs for these 4 technologies determine the indirect cost markup rate for all technologies used 

in the CAFE model analysis that supports this proposal. However, the overall impact on costs is 

also a function of the relative incidence of each of the 88 technologies shown in Table V11-4, 

which are estimated to have ICMs similar to one of these 4 technologies. The net impact on 

costs of these ICMs is also influenced by the learning curve that is appropriate to each 

technology, creating numerous different and unique ICM based markup paths. The average 

effective markup applied by the CAFE model is also a function of each technologies direct cost - 

since ICMs are applied to direct costs, the measured indirect cost is proportionately higher for 

any given ICM when direct costs are higher. The average ICM based markup applied to the fleet 

for any given model year is calculated as follows: 

88

݊ܣ݊ܦ ෍

1∑ 88 ݊ܣ݊ܦ

݊ ܫ ∗ܥܯ

1

Where: D = learned direct cost of each technology 

A = application rate for each technology 
                                                      

 

778 

ICM = average ICM applied to each technology 

n=1,88 

The VOLPE model predicts technology application rates assuming that manufacturers will apply 

technologies to meet standards in a logical fashion based on estimated costs and benefits. The 

application rates will thus be different for each model year and for each alternative scenario that 

is examined. To illustrate the overall impact of ICMs on total technology costs, NHTSA has 

calculated the weighted average ICM based markup across all technologies for the Preferred 

Alternative.356 This was done separately for each vehicle type and then aggregated based on the 

predicted sales of each vehicle type used in the model. The results are shown in Table VII-8. 

Table VII-8 

Average ICM Based Markup Applied in Preferred Alternative Scenario 

Model 

Year 

Passenger 

Cars Light Trucks All Vehicles 

2017 0.393 0.370 0.383 

2018 0.400 0.377 0.390 

2019 0.315 0.308 0.312 

2020 0.322 0.317 0.320 

2021 0.330 0.323 0.327 

2022 0.336 0.329 0.333 

2023 0.344 0.337 0.341 

2024 0.357 0.343 0.351 

2025 0.340 0.319 0.331 

All Years 0.348 0.336 0.343 

356 For each alternative, this rulemaking examined numerous scenarios based on different assumptions and these 

assumptions could have some influence on the relative frequency of selection of different technologies, which in 

turn could affect the average ICM. The scenario examined here uses the 2010 as the base year, assumes a 3% 

discount rate, a 1 year payback period, real world application of expected fines, and reflects expected voluntary 

over-compliance by manufacturers. 
779 

The effective ICM based markups in table VII-8 are derived in a manner consistent with the way 

that the RPE is measured, that is, they reflect the combined influences of direct cost learning and 

changes in indirect cost requirements weighted by both the incidence of each technologies 

adaptation and the relative direct cost of each technology. The results indicate slightly higher 

ICMs for passenger cars than for light trucks. This is a function of the technologies that are 

estimated to be adopted for each respective vehicle type, especially in the later years when 

hybrids and electric vehicles become more prevalent in the passenger car fleet. The influence of 

these advanced vehicles is driven primarily by their direct costs, which greatly outweigh the 

costs of other technologies. This results in the application of much more weight to their higher 

ICMs. This is most notable in 2024 and 2025 for passenger cars, when electric vehicles begin to 

enter the fleet in larger numbers. The average ICM increases 0.013 in 2024 primarily due to 

these vehicles. It immediately drops 0.017 in 2025 because both an additional application of 

20% learning to the direct cost of these vehicles (which reduces their relative weight), and the 

long term ICM becomes effective in that year (which decreases the absolute ICM factor). Both 

influences occur one year after these vehicles begin to enter the fleet due to CAFE requirements. 

The ICM based markups also change over time, again, reflecting the different mix of 

technologies that are present during the earlier years, but that are often replaced with more 

expensive technologies in the later years. Across all model years, the wide ranging application 

of diverse technologies required to meet CAFE standards produces an average ICM of 

approximately 1.34. 

There is some level of uncertainty surrounding both the ICM and RPE markup factors. The ICM 

estimates used in this proposal group all technologies into four broad categories (low, medium, 

and two levels of high complexity) and applies a single ICM factor to all of the individual 

technologies within each of the categories. This simplification assumes that the 4 technologies 

for which ICM values were estimated are representative of the other technologies which were not 

examined (see table VII-4 above). The accuracy of the estimates is affected by how 

appropriately each technology is categorized with the representative technology, and if the ICMs 

for that representative technology are near the midpoint of the real ICMs of all the technologies 

that they represent. 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. Additionally, there is 

uncertainty because the ICM estimates were developed using panel estimates rather than 

empirical data, and they have not been validated through a direct accounting of actual indirect 

costs for individual technologies. RPEs themselves are also inherently 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. Since empirical estimates of ICMs 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 
 

 

 

780 

specific technologies. Thus applying a single average RPE to any given technology by definition 

overstates costs for simple technologies, or understates them for advanced technologies. 

Recognizing this uncertainty, NHTSA has conducted a sensitivity analysis substituting the RPE 

for the ICMs used in the central analysis to mark up direct manufacturing costs. This serves as a 

measure of the potential impact on total costs of using ICMs compared to the RPE. As noted 

previously, the RPE is the ratio of aggregate retail prices to aggregate direct manufacturing costs. 

The ratio already reflects the mixture of learned costs of technologies at various stages of 

maturity. Therefore, the RPE is applied directly to the learned direct cost for each technology in 

each year. This was done for the same Preferred Alternative scenario used in the above analysis 

of average ICMs (see footnote 6). The results are shown in Tables VII-9a and VII-9b for the 

2010 and 2008 baselines respectively. 

Table VII-9a 

Relative Impacts of Applying ICMs vs. RPE to Determine Indirect Costs 

2010 Baseline 

Model 

Year 

 Incremental 

Technology 

Costs (Millions$) Ratios 

ICM 1.5 RPE RPE/ICM ICM/RPE 

RPE-ICM 

/RPE 

2017 $3,722 $3,749 1.01 0.99 0.01 

2018 $5,227 $5,522 1.06 0.95 0.05 

2019 $8,256 $9,604 1.16 0.86 0.14 

2020 $10,809 $12,451 1.15 0.87 0.13 

2021 $14,033 $16,214 1.16 0.87 0.13 

2022 $15,262 $18,079 1.18 0.84 0.16 

2023 $16,883 $20,806 1.23 0.81 0.19 

2024 $19,727 $24,691 1.25 0.80 0.20 

2025 $20,015 $27,244 1.36 0.73 0.27 

Total $113,935 $138,361 1.21 0.82 0.18 
 

 

 

781 

Table VII-9b 

Relative Impacts of Applying ICMs vs. RPE to Determine Indirect Costs 

2008 Baseline 

Model 

Year 

 Incremental 

Technology 

Costs (Millions$) Ratios 

ICM 1.5 RPE RPE/ICM ICM/RPE 

RPE-ICM 

/RPE 

2017 $2,499 $3,242 1.30 0.77 0.23 

2018 $4,589 $5,909 1.29 0.78 0.22 

2019 $7,349 $10,238 1.39 0.72 0.28 

2020 $11,059 $14,392 1.30 0.77 0.23 

2021 $14,236 $18,465 1.30 0.77 0.23 

2022 $16,447 $20,802 1.26 0.79 0.21 

2023 $17,767 $23,433 1.32 0.76 0.24 

2024 $20,552 $26,526 1.29 0.77 0.23 

2025 $23,289 $30,694 1.32 0.76 0.24 

Total $117,787 $153,702 1.30 0.77 0.23 

Application of an RPE instead of ICMs would result in technology cost increases averaging 

roughly 21 -30%- higher (depending on baseline year) over the MY2012-MY2025 timeframe 

that is represented in these cost estimates. The difference is generally higher in earlier model 

years because in those years the more cost effective technologies are incorporated into the fleet. 

These tend to be low complexity technologies with lower ICMs. In later years, the more 

expensive technologies are applied, including more hybrid and electric vehicles. These tend to 

be more complex technologies, and the average ICM based markup thus increases to a level 

closer to the average RPE. Note that there are two different reasons for these differences. The 

first is the direct impact of applying a higher retail markup. The second is an indirect effect 

resulting from the impact that these differing markups have on the order of the selection of 

technologies, which can change as different direct cost levels interact with altered retail markups, 

shifting their relative overall effectiveness. This has a very pronounced impact under the 2010 

baseline. The inclusion of additional technologies in the 2010 baseline fleet results in a different 

profile of available unused technologies. The shift to an RPE basis makes some of these 

technologies relatively more expensive and this shifts the pattern of technology adoption 

predicted by the VOLPE model. For example, fewer advanced engine and electric vehicles were 

applied under the RPE scenario. In addition, two technologies with negative costs, NAUTO and 

DCT, are applied more frequently under the RPE scenario, which also lowers the average cost. 
782 

In some cases, manufacturers may choose to pay fines under the higher cost RPE scenario. The 

net result is a predicted reduction in the relative costs of the RPE scenario, especially in the 

earlier years. By comparison, these factors are mitigated under the 2008 baseline, when more 

alternative technologies are available for selection in the future vehicles. 

The relative impacts of ICMs may vary somewhat by scenario, but in this case, the application of 

ICMs produces total technology cost estimates that are roughly 18-23% lower than those that 

would result from applying a single RPE factor to all technologies. The impacts of applying an 

RPE to other scenarios can be found in the Sensitivity Analysis Chapter. 

NPRM Comments on Indirect Cost Markups: 

In response to the NPRM, comments on the issue of applying ICMs or RPEs to estimate indirect 

costs were provided by the National Automobile Dealers Association (NADA) and the 

International Council on Clean Transportation (ICCT). NADA disagreed with the application of 

ICMs, stating that they were untested opinions and understated the true costs of CAFE 

regulations. ICCT supported the use of ICMs and advocated removing the sensitivity analysis 

that demonstrated the impact of using RPEs and how costs would differ under the two 

approaches. 

NADA Comments on Indirect Costs 

NADA argued that the ICM approach is not valid and should be replaced with an RPE approach. 

Further, it argued that the RPE factor should be 2x rather than the 1.5x approach that is 

supported by filings to the Securities and Exchange Commission. We have conducted a 

thorough analysis of the NADA comments on the RPE vs. ICM approach. We disagree with 

NADA’s arguments for both using the RPE approach and a 2x RPE factor, for the following 

reasons. 

NADA’s objections to the ICM approach include: 

1.	 There is no evidence that the RPE method is flawed. 

2.	 The ICMs do not include the total costs of complying with the standards, because 

it does not include all the costs included in the RPE. 

3.	 The ICMs use a subjective judgment to adjust indirect costs for different 

technologies, while the RPE uses one value for all components and does not rely 

on “nearly perfect foreknowledge.” 

4.	 The ICMs do not incorporate dealer and OEM profits. 

NADA’s arguments for the RPE of 2x include: 
                                                      

783 

5.	 Several scholarly papers support the use of RPEs in the 2.0 range. 

6.	 A case study comparison of the added content of a 1971 Chevrolet Vega and 2011 

Cruze shows that an RPE of 2.0 accounts for the change in retail price. 

The discussion above provides background on the issue of RPEs and ICMs, and on the agencies’ 

decision to use ICMs to estimate indirect costs for this rulemaking. Our responses here address 

the specific points raised by NADA. 

First, the RPE approach applies the same average indirect cost markup across all technologies in 

the redesigned vehicle fleet, regardless of the source of the direct cost (i.e. whether a technology 

is simple or complex; whether the source of the additional cost is a new or a mature technology). 

The RPE methodology also assumes that an indirect cost is associated with the rule, even if no 

relation is apparent. For instance, the RPEs (until recent union contract changes) would have 

included the costs to the domestic auto companies of the health insurance for retired auto 

workers. Because the rulemaking would not affect the current retiree health care costs (which 

account for about 1.5% of the RPE), they are irrelevant to the rulemaking. The ICM approach 

differs in that it allows indirect costs to vary with the complexity of the technology and the time 

frame.357 It is a reasonable assumption that simple technologies are expected to have fewer 

indirect costs per dollar than complex technologies. For instance, the use of low-rollingresistance tires, considered by the EPA/NHTSA team to be a low-complexity technology, adds 

costs, but, because they require significantly less vehicle integration effort than for example, 

adding a hybrid powertrain would, the additional indirect costs per dollar of direct manufacturing 

costs may be very low. In contrast, converting a conventional vehicle to a hybrid-electric is a far 

more complex activity, involving increases in indirect costs such as research and development 

disproportionate to its direct costs. Shortly after product introduction, indirect costs for 

components such as warranty and research may be relatively high, but auto makers are expected 

to be able to reduce the costs of any specific technology over time, as they gain experience with 

them and, thus, redirect those expenditures to other areas of their choosing. 

Second, the ICM approach excludes some costs included in the RPE when those costs are 

expected not to be affected by the standards. The ICM approach, as discussed above, begins 

with the RPE and includes all the relevant cost categories. ICMs reflect the indirect costs judged 

by the EPA panel (see above for further explanation) to be incurred for each technology in 

response to regulatory imposed changes. Any “omissions”, or instances where the ICM carries 

no costs for a given technology, are cases where the indirect costs are considered by the EPA 

357 Rogozhin, A., Gallaher, M., McManus, W., February 2009. Automobile industry retail price equivalent and 

indirect cost multipliers. EPA-420-R-09-003. Available at: /http://www.epa.gov/otaq/ld-hwy/420r09003.pdf (last 

accessed August 3, 2012) 
                                                      

 

 

 

784 

panel not to be impacted by regulatory imposed changes for that technology. For instance, the 

costs of switching from a standard tire to a low-rolling-resistance tire (the example of a lowcomplexity technology in Rogozhin et al. (2009)) are not expected to lead to an increase in 

transportation costs (i.e., costs for transporting finished vehicles from production site to retail 

site) because it is not expected to be any more expensive to ship a new vehicle with the new tires 

than with the old tires.358 

Third, the RPE approach relies on the assumption that applying the average RPE for the vehicle 

fleet as a whole will produce a reasonable average indirect cost for all technologies in the 

redesigned vehicle fleet resulting from these standards. The agencies believe that using the 

professional judgment and expertise of EPA staff with extensive experience in the auto industry 

provides useful insight into how a given regulation will impact indirect costs and is an 

improvement over ignoring differences among technologies. The agencies have therefore based 

their central analyses on the ICM method. 

Fourth, it is incorrect that the ICMs do not include profit. Although the initial ICM report 

reviewed by NRC did not include OEM profit, the ICM approach applied in this rulemaking does 

incorporate an allowance for profit, at the average corporate profit rate of 6% of sales. The 

inclusion of profit for the Joint NPRM is discussed in the draft Technical Support Document, and 

the agencies have included profit as an element of the indirect costs for the final rulemaking as 

well.359 

Fifth, the papers cited to support the use of an RPE of 2x are only a subset of the literature. The 

National Research Council (NRC)360 discusses the four studies that NADA’s Exhibit A cites in 

its support of an RPE of 2.0. The NRC also notes that NHTSA used an RPE of 1.5 for its MY 

2011 fuel economy rule; the NRC in 2002 used an RPE of 1.4, as did the California Air 

Resources Board; and EPA has used a markup factor of 1.3. The NRC report then discusses 

work done for the committee itself, doing a detailed analysis of a Honda Accord and a Ford F150 truck; the former had an RPE of “1.39 to market transaction price and 1.49 to MSRP,” and 

358 Rogozhin, A., Gallaher, M., McManus, W., February 2009. Automobile industry retail price equivalent and 

indirect cost multipliers. EPA-420-R-09-003, Table 4-3.
 359 U.S. Environmental Protection Agency and National Highway Traffic Safety Administration (November 2011).
 

Draft Joint Technical Support Document: Proposed Rulemaking for 2017-2025 Light-Duty Vehicle Greenhouse 

Gas Emission Standards and Corporate Average Fuel Economy Standards.” EPA-420-D-11_901, available at 

http://www.epa.gov/otaq/climate/documents/420d11901.pdf, p. 3-12. 360 National Research Council. Assessment of Fuel Economy Technologies for Light-Duty Vehicles. Washington, 

D.C.: National Academies Press, 2010. 
                                                       

 

 

785 

the latter had an RPE of “1.52 for market price and 1.54 for MSRP.” Most significantly, the 

NRC does not recommend an RPE of 2.0. Rather, the NRC recommends, for technologies where 

the primary manufacturer of the technology is the automotive supply base, an RPE of 1.5, except 

for hybrid powertrain components from the automotive supply base, where it recommends an 

RPE of 1.3 due to the inclusion of several indirect costs in their base estimate.361 Only in the 

case of technologies where an automotive OEM is the primary manufacturer does the NRC 

recommend an RPE of 2.0.362

 Further support for an average RPE lower than 2.0 comes from an examination of industry 

financial statements. NHTSA examined industry 10-K submissions to the Securities and 

Exchange Commission from the period 1972-1997.363 The cost information in these submissions 

represents all industry operations, including both OEM and supplier-sourced technologies. 

During this period, the RPE averaged 1.5 while varying slightly, but never dropped below 1.4 or 

exceeded 1.6. At no time did the average RPE approach the 2.0 value advocated by NADA. The 

results are shown, together with the 2007 results from Rogozhin et al in the following figure: 

361 NRC, ibid, pp. 3-22, 6-16. 362 Importantly, application of the 2.0x RPE in the “OEM as primary manufacturer” case would be done to a smaller 

direct cost since the OEM has produced the part in-house and, thus, is not paying the full supplier-level indirect 

costs that would be included in a part purchased from a supplier. The end result should be a total cost roughly 

equivalent or less than a 1.5x RPE applied to the supplier-produced part. If not, the manufacturer should probably 

not produce in-house and should, instead, purchase parts since they would be less costly (all other considerations 

being equal).

363 Spinney, B.C., Faigin, B.M, Bowie, N.N, Kratzke, S.R., Advanced Air Bag Systems Cost, Weight, and Lead 

Time Analysis Summary Report, Contract No. DTNH22-96-0-12003, Task Orders – 001, 003, and 005. 
 

786 

We note, without specifically commenting on the quality of the studies, that none of the papers 

NADA cites in support of an RPE of 2x was published in a peer-reviewed journal, and none of 

the studies claim to have been peer-reviewed. In contrast, the research in Rogozhin et al. (2009) 

was peer-reviewed twice: as documented in the Peer Review Report, and when it was submitted 

(and accepted) for publication in the International Journal of Production Economics. A full 

reading of the literature on RPEs thus shows little support for a value of 2x. 

Sixth, the comparison of the Vega and the Cruze uses circular logic; it assumes its conclusion. 

The direct costs of the vehicles are calculated using an RPE of 2, and the NADA analysis then 

calculates a quality difference based on the change in direct costs. The magnitude of the quality 

difference is then discovered to correspond to an RPE of 2, although it is also an inevitable result 

of the initial assumption of an RPE of 2. The analysis provided can be replicated with any value 

of RPE. This argument thus provides no evidence on the value of the RPE. 

For these reasons, we do not accept NADA’s request to use an RPE of 2x, and instead continue 

with our use of ICMs as the basis for our central analysis. However, the agencies recognize that 

there is uncertainty regarding the impact on indirect costs of changes imposed by CAFE 

regulations. For this reason, both agencies have conducted sensitivity analyses using different 

indirect cost estimates. EPA presents its sensitivities in Chapter 3 of its final RIA. NHTSA 

presents the impact of using the RPE as a basis for indirect costs in its analysis in Chapters 7 and 

10 of NHTSA’s FRIA. In addition, RPEs are incorporated into the Probabilistic Uncertainty 

analysis in Chapter 12 of NHTSA’s FRIA. 

ICCT Comments on Indirect Costs 

ICCT supported the use of ICMs as a method for estimating indirect costs, stating that it agreed 

“with the use of indirect cost multipliers (ICM) instead of Retail Price Equivalent (RPE) and the 

general approach of assigning technologies to several complexity classes for determining the 

ICM value.” ICCT further stated that “Trying to determine the indirect multiplier for each 

technology would be extremely difficult and time consuming, but it is also important to use more 

appropriate and targeted adjustments than a single, indiscriminant RPE.” Most of ICCTs 

subsequent discussion repeated the description of the ICM process and the nature of ICMs and 

the RPE supplied in the NPRM technical documents. However, ICCT then commented that 

NHTSA should remove any sensitivity analyses which examine the impact of using RPEs rather 

than ICMs in this rulemaking, arguing that “...the use of RPE for these two sensitivity analyses 

is inappropriate and distorts the cost results.” 
787 

ICCT’s request is unique in that it argues, not for a change in the central values, which already 

are based on ICMs, but for removal of any discussion that would quantify the impacts of the 

decision to use ICMs instead of the RPE. NHTSA has considered these arguments, but has 

retained the sensitivity analysis using RPEs for the final rule. 

OMB Circular No. A-94 establishes guidelines for conducting benefit-cost analysis of Federal 

programs. The circular states that “Estimates of benefits and costs are typically uncertain 

because of imprecision in both underlying data and modeling assumptions. Because such 

uncertainty is basic to many analyses, its effects should be analyzed and reported. Useful 

information in such a report would include the key sources of uncertainty; expected value 

estimates of outcomes; the sensitivity of results to important sources of uncertainty; and where 

possible, the probability distributions of benefits, costs, and net benefits.” NHTSA agrees with 

this guidance, and routinely conducts sensitivity analyses in its rulemakings to examine 

uncertainty around specific assumptions, as well as probabilistic uncertainty analyses to examine 

the cumulative impact of uncertainty surrounding the major inputs that drive the costs and 

benefits of its analyses. Thus, it is in no way novel that NHTSA should conduct sensitivity 

analyses to examine the impacts of particular inputs. 

By requesting that NHTSA remove the sensitivity analysis using RPEs, ICCT appears to be 

suggesting that there is zero uncertainty with regard to how indirect costs should be accounted 

for in rulemaking analysis. ICCT says as much when it states that the RPE sensitivity analysis 

“distorts the cost results.” Again, the purpose of sensitivity analysis is to examine the effects of 

different inputs on a cost-benefit analysis – thus, characterizing such an analysis as a “distortion” 

of the primary analysis seems to mistake its purpose. Additionally, ICCT provided no new 

information as to why there is zero uncertainty with regard to the agency’s use of ICMs for the 

central analysis, and largely recounted the agencies’ own discussions on the merits of ICMs. 

Having participated in the writing of that discussion, NHTSA is aware of those merits, but 

nonetheless found there to be value in analyzing RPEs as a sensitivity in the NPRM, and 

continues to find such value for this final rule. 

NHTSA acknowledges the theoretical advantage that comes with a more disaggregated approach 

to assigning indirect cost multipliers. This is the rationale for selecting ICMs as the basis for the 

central calculations in this analysis. However, there are over 60 technologies being applied to 

vehicles and only 4 of these technologies are actually examined under the ICM process. NHTSA 

believes that the small number of technologies actually examined together with the lack of 

validation of the ICM factors estimated for those 4 technologies creates sufficient uncertainty to 

support examination of alternative estimates as required by Circular A-94. We note further that 

the National Research Council (NRC) of the National Academy of Sciences (NAS) has also 

expressed uncertainty regarding the application of ICMs or the RPE to measure indirect costs, 

stating that “....At the present time, a rigorous and robust method for estimating these 
788 

differential impacts does not exist...Therefore, it is not clear that the accuracy of fuel 

consumption cost assessment would be increased by the use of technology-specific, as opposed 

to an industry-average, markup factor.” NRC also conducted its own studies on two different 

vehicles and found that retail prices for those vehicles were roughly 50% above their direct 

manufacturing costs. Another commenter to the NPRM, NADA, stated that “...There is no 

reason to believe that NHTSA and EPA, or even manufacturers have the ability to anticipate how 

a given regulation will impact indirect costs.” 

NHTSA believes that it is appropriate to examine the RPE as an alternative for several reasons. 

First, historically, the RPE has been used as the basis for most regulatory analyses. The RPE has 

been used for decades to mark up costs to the retail price level. Shifting to ICMs is a departure 

from NHTSA’s standard practice, and it is reasonable to conduct an analysis using RPE to 

consider how the results could be impacted. Second, the RPE is the only markup basis available 

that is derived from empirical data. During the roughly three decades for which RPE data has 

been tracked, the aggregate value of retail prices have been set roughly 50% above direct 

manufacturing costs. Third, this rulemaking is projected to affect most major components and 

vehicle systems, if not nearly the whole vehicle in some instances. This strengthens the reasons 

for conducting a sensitivity case using RPE, which is based on the relationship between retail 

prices and the direct costs of producing the complete vehicle. Finally, there is no broad 

consensus as to whether ICMs or the RPE provide the more accurate estimate of indirect costs, 

as evidenced by the comments to the proposal and the National Academy of Sciences study. 

NHTSA therefore believes that examining the impacts of alternate measures is an appropriate 

analytical exercise that provides useful information to decision makers. We note that while the 

RPE predicts higher vehicle costs than do the current ICM estimates, under both assumptions, 

the rule is highly cost-beneficial. NHTSA believes this is a valid consideration for policy 

makers, and in line with OMB guidance for treatment of uncertainty when analyzing the impacts 

of Federal programs. ICCT offered no information that leads the agency to conclude that a 

different approach is appropriate for the final rule. For these reasons, NHTSA has included the 

sensitivity analysis examining the impact of the RPE in the FRIA for this final rule. 

Learning Curves 

NHTSA applies estimates of learning curves to the various technologies that will be used to meet 

CAFE standards. Learning curves reflect the impact of experience and volume on the cost of 

production. As manufacturers gain experience through production, they refine production 

techniques, raw material and component sources, and assembly methods to maximize efficiency 

and reduce production costs. Typically, learning curves reflect initial learning rates that are 
789 

relatively high, followed by slower learning as the easier improvements are made and production 

efficiency peaks. This eventually produces an asymptotic shape to the learning curve as small 

percent decreases are applied to gradually declining cost levels (see figure 1). 

Learning Applications in Previous Rulemakings 

Over previous rulemakings, NHTSA has estimated the impact of learning using a variety of 

methods as our thinking about learning has evolved due to research, public comment, and 

methodology development. In the 2008 NPRM, working in conjunction with the EPA, NHTSA 

applied learning factors to technology costs for the first time. The factors were developed using 

three parameters which include learning threshold, learning rate, and the initial technology cost, 

and were based on the “experience curve” concept which describes reductions in production 

costs as a function of accumulated production volume. As noted above, the typical curve shows 

a relatively steep initial decline in cost which flattens out to a gentle downwardly sloping line as 

the volume increase to large values. In the 2008 NPRM, the agencies applied a learning rate 

discount of 20 percent for each successive doubling of production volume (on a per manufacturer 

basis), and a learning threshold of 25,000 units was assumed (thus a technology was viewed as 

being fully learned out at 100,000 units). The factor was only applied to certain technologies 

that were considered emerging or newly implemented on the basis that significant cost 

improvements would be achieved as economies of scale were realized (i.e., the technologies 

were on the steep part of the curve). 

In the MY 2011 final rule, the agencies continued to use this learning factor, referring to it as 

volume-based learning since the cost reductions were determined by production volume 

increases, and again only applied it to low volume, emerging technologies. However, in 

response to comments, the agencies revised the assumptions on learning threshold, basing them 

instead on an industry-wide production basis, and increasing the threshold to 300,000 units 

annually (thus a technology was considered to be fully learned out at 1.2M annual units). 

Additionally, commenters to the 2008 NPRM also described another type of learning factor 

which NHTSA, working in conjunction with its contractor Ricardo, adopted and implemented 

for the MY 2011 final rule. Commenters described a relatively small negotiated cost decrease 

that occurred on an annual basis through contractual agreements with first tier component and 

systems suppliers. These agreements were generally only applicable to readily available, high 

volume technologies that were commonly in use by multiple OEMs. Based on the same 

experience curve principle, however at production volumes that were on the extended, flatter part 

of the curve (and thus the types of volumes that more accurately represent an annual industrywide production volume), the agencies adopted this type of learning and referred to it as timebased learning. An annual cost reduction of 3 percent in the second and each subsequent year, 
790 

which was consistent with estimates from commenters and supported by work that Ricardo 

conducted for NHTSA, was used in the 2011 final rule. 

In response to the 2012-2016 NPRM, NHTSA received comments from ICCT and Ferrari related 

to learning curves. ICCT stated the agencies could improve the accuracy of the learning curve 

assumptions if they used a more dynamic or continuous learning curve that is more technologyspecific, rather than using step decreases as the current time- and volume-based learning curves 

appear to do. ICCT also commented on the appropriate application of volume- versus timebased learning, and stated further that worldwide production volumes should be taken into 

account when developing learning curves. Ferrari commented that it is more difficult for smallvolume manufacturers to negotiate cost decreases from things like cost learning effects with their 

suppliers, implying that learning effects may not be applicable equally for all manufacturers. 

NHTSA agreed that a continuous curve, if implemented correctly, could potentially improve the 

accuracy of modeling cost-learning effects. To implement a continuous curve, however, 

NHTSA would need to develop a learning curve cost model to be integrated into the agency’s 

existing model for CAFE analysis. Due to time constraints in the MY 2012-2016 rulemaking, 

the agencies were not able to then investigate fully the use of a continuous cost-learning effects 

curve for each technology, but noted that we would investigate the applicability of this approach 

for future rulemakings. 

Additionally, while NHTSA agreed that worldwide production volumes can impact learning 

curves, the agency does not forecast worldwide vehicle production volumes in addition to the 

already complex task of forecasting the U.S. market. That said, the agency does consider current 

and projected worldwide technology proliferation when determining the maturity of a particular 

technology used to determine the appropriateness of applying time- or volume-based learning, 

which helps to account for the effect of globalized production. 

With regard to ICCT’s comments on the appropriate application of volume- versus time-based 

learning, however, it seems as though ICCT is referencing a study that defines volume- and timebased learning in a different manner than the current definitions used by NHTSA. NHTSA uses 

“volume-based” learning for non-mature technologies that have the potential for significant cost 

reductions through learning, while “time-based” learning is used for mature technologies that 

have already had significant cost reductions and only have the potential for smaller cost 

reductions. For “time-based” learning, the agencies chose to emulate the small year-over-year 
 

791 

cost reductions manufacturers realize through defined cost reductions, approximately 3 percent 

per year, negotiated into contracts with suppliers. 

And finally, in response to Ferrari’s comment, NHTSA recognizes that cost negotiations can be 

different for different manufacturers, but believes that on balance, cost learning at the supplier 

level will generally impact costs to all purchasers. Thus, if cost reductions are realized for a 

particular technology, all entities that purchase the technology will benefit from these cost 

reductions. 

In developing the MY2012-2016 final rule, NHTSA, taking into account comments received, 

reviewed both types of learning factors, and the thresholds (300,000) and cost reduction rates (20 

percent for volume, 3 percent for time-based) they rely on, as implemented in the MY 2011 final 

rule and the MY2012-2016 NPRM, and concluded that both learning factors continued to be 

appropriate. NHTSA therefore continued to implement both time- and volume-based learning in 

the analyses that supported the MY2012-2016 final rule. Noting that only one type of learning 

can be applied to any single technology, if any learning is applied at all, NHTSA reviewed each 

technology to determine which if any learning factor was appropriate. 

Working under the principle that volume-based learning is applicable to lower volume, higher 

complexity, emerging technologies while time-based learning is appropriate for high volume, 

established and readily available technologies, NHTSA established a series of learning schedules 

which were applied to specific technologies (see Table V-8 in the 2012-2016 FRIA). These 

factors closely resemble the settings used in the 2011 final rule with the exception of PSHEV 

which was revised from time-based to volume-based learning. No learning was applied to 

technologies which are potentially affected by commodity costs (LUB, ROLL) or that have 

loosely-defined bill of materials (EFR, LDB) in this analysis, as was also the case in the MY 

2011 final rule analysis. Where volume-based learning was applied, NHTSA took great care to 

ensure that the initial costs (before learning is applied) properly reflect low volume, unlearned 

cost estimates (i.e., any high volume cost estimates used in the analysis have been appropriately 

“reverse learned” so as not to underestimate the final learned costs). 

Regarding these initial volume-based learning costs, ICCT commented that it would be helpful to 

clarify the assumed production volumes to better interpret the costs of technologies, which are 

eligible for “volume-based” learning. The agencies did not define the specific cumulative 

production volume for technologies that are eligible for volume-based learning. When 
 

 

792 

developing the costs for these technologies it was assumed that cumulative production volumes 

had not exceeded 300,000 but the agencies did not try to specify the exact production volume. 

Due to the uncertainty of projected production volumes the agency did not believe it appropriate 

to define costs based on a finer level of detail. 

Learning Application in the Current Rulemaking 

The learning curves the agency currently uses represent the agency’s best estimates regarding the 

pace of learning. Depending on the technology, the curves assume a learning rate of 3% over the 

previous years’ cost for a number of years, followed by 2% over several more years, followed by 

1% indefinitely. In a few cases, larger decreases of 20% are applied every 2 years during the 

initial years of production before learning decreases to the more typical levels described above. 

This occurs for the changes that involve relatively new emerging technologies that are not yet 

mature enough to warrant the slower learning rates. 

For this NPRM the agency has, however, adopted new terminology to distinguish the two 

different learning applications. Emerging technologies are adjusted using what we now call the 

“steep “learning schedule, which involves the larger 20% decreases, while mature technologies 

are modified using one of a number of “flat” schedules, involving the smaller 3%, 2%, or 1% 

decreases. These revised terms reflect the portion of a typical learning curve that would best 

represent the production history of each technology. Some schedules include both steep and flat 

characteristics as technologies transition through these phases during the years covered by this 

analysis. Again, these terms replace the “volume based” and “time based” learning terminology 

that was used in previous CAFE analyses. All learning essentially derives from knowledge 

gained through accumulated production experience, and the time based terminology seemed to 

create some confusion among commenters. The modified terminology helps to clarify this point 

reflects the portion of the volume based learning process that is likely to impact any specific 

technology. 

Table VII-10 lists the various learning schedules that NHTSA applies to technologies for the 

2017-2025 FRIA. The schedules are identified by a reference schedule number that was 

originally assigned to each schedule during the development of the agencies learning 

methodology. Many other schedules were originally developed, but only those shown in Table 

VII-10 were considered relevant to the technology costs used in the current analysis. The table 

illustrates cost reduction rates for years 2010 through 2030. However, only a subset of these 

years is relevant to each technology, depending on the year in which its direct cost estimate is 

based and the years in which the technology is applied. The second line in the table indicates the 
 

 

 

793 

base year that the direct manufacturing costs used by the agencies represent. The learning rates 

that are indicated prior to the direct manufacturing costs (DMC) base year reflect “prior 

learning” that was estimated to occur before the base year direct manufacturing cost estimate 

used by the agencies were developed. So, for example, if a cost estimate for a mature technology 

reflects expected conditions in MY 2012, there would have already been learning prior to that 

which would have impacted the MY 2012 costs. Additional learning would then commence in 

MY 2013. 

Table VII-11 lists the technologies that manufacturers may use to achieve higher CAFE levels, 

and the learning schedule that is applied to each technology. Selection of specific learning 

curves was based on the agency’s best judgment as to the maturity of each technology and where 

they would best fit along the learning curve, as well as the year on which their direct 

manufacturing costs are based. 

For example, schedules 11, 12, and 21 are appropriate for technologies that are more mature and 

have already passed through the steep portion of the learning curve, while schedules 16, 19, 24, 

and 25 are more appropriate for emerging technologies that will be experiencing learning along 

the steep part of the curve between MYs 2014-2025. 
 

 

 

 

 

 

 

 

 

 

 

 

 

794 

Table VII-10 

Learning Schedules by Model Year Applied to Specific CAFE Technologies 

Schedule # = 

DMC Year = 

Model Year 

6 

N/A 

11

2012 

12

2015 

16

2015 

19

2025 

21

2017 

24 

2017 

25 

2017 

2010 0 0.03 0.03 0 0 0.03 0 0 

2011 0 0.03 0.03 0 0 0.03 0 0 

2012 0 0.03 0.03 0 0 0.03 0 0 

2013 0 0.03 0.03 0 0 0.03 0 0 

2014 0 0.03 0.03 0.20 0.20 0.03 0.20 0 

2015 0 0.03 0.03 0.20 0 0.03 0 0 

2016 0 0.03 0.03 0 0.20 0.03 0.20 0 

2017 0 0.02 0.02 0.03 0 0.03 0 0 

2018 0 0.02 0.02 0.03 0.20 0.03 0.03 0 

2019 0 0.02 0.02 0.03 0 0.03 0.03 0.20 

2020 0 0.02 0.02 0.03 0.20 0.03 0.03 0 

2021 0 0.02 0.02 0.03 0 0.03 0.03 0.2 

2022 0 0.02 0.02 0.03 0 0.03 0.03 0.03 

2023 0 0.02 0.02 0.03 0 0.02 0.03 0.03 

2024 0 0.02 0.02 0.03 0 0.02 0.03 0.03 

2025 0 0.02 0.02 0.03 0.20 0.02 0.03 0.03 

2026 0 0.01 0.01 0.02 0.03 0.02 0.02 0.03 

2027 0 0.01 0.01 0.02 0.03 0.02 0.02 0.02 

2028 0 0.01 0.01 0.02 0.03 0.01 0.02 0.02 

2029 0 0.01 0.01 0.02 0.03 0.01 0.02 0.02 

2030 0 0.01 0.01 0.02 0.03 0.01 0.02 0.02 
 

 

795 

Table VII-11 

Learning Schedules for Specific CAFE Technologies 

Technology Learning 

Schedule 

Low Friction Lubricants - Level 1 6 

6 

6 

12 

12 

11 

12 

12 

12 

12 

11 

11 

12 

12 

11 

11 

11 

11 

11 

11 

11 

11 

11 

Engine Friction Reduction - Level 1 

Low Friction Lubricants and Engine Friction Reduction - Level 2 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC 

Discrete Variable Valve Lift (DVVL) on SOHC 

Cylinder Deactivation on SOHC 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) 

Discrete Variable Valve Lift (DVVL) on DOHC 

Continuously Variable Valve Lift (CVVL) 

Cylinder Deactivation on DOHC 

Stoichiometric Gasoline Direct Injection (GDI) 

Cylinder Deactivation on OHV 

Variable Valve Actuation - CCP and DVVL on OHV 

Stoichiometric Gasoline Direct Injection (GDI) on OHV 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement – Turbo 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement - Downsize 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement –Turbo 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement - Downsize 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement – Turbo 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement - Downsize 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Turbo 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Downsize 
 

 

796 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Turbo 11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

11 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Downsize 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Turbo 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement - Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement – Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement - Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement – 

Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement – Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement – Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement – Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement – Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement – Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement – 

Downsize 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement – Turbo 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement – Downsize 

Advanced Diesel - Small Displacement 

Advanced Diesel - Medium Displacement 

Advanced Diesel - Large Displacement 

6-Speed Manual/Improved Internals 12 

12 

11 

11 

11 

21 

21 

Improved Auto. Trans. Controls/Externals 

6-Speed Trans with Improved Internals (Auto) 

6-speed DCT 

8-Speed Trans (Auto or DCT) 

High Efficiency Gearbox w/ dry sump (Auto or DCT) 

Shift Optimizer 
Electric Power Steering 12 

Improved Accessories - Level 1 12 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) 12 

12V Micro-Hybrid (Stop-Start) 16 

Integrated Starter Generator 16 

Strong Hybrid (Powersplit or 2-Mode) - Level 1 – Battery 24 

Strong Hybrid (Powersplit or 2-Mode) - Level 1 - Non-Battery 11 

Conversion from SHEV1 to SHEV2 N/A 

Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 – Battery 24 

Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 - Non-Battery 11 

Plug-in Hybrid - 20 mi range – Battery 19 

Plug-in Hybrid - 20 mi range - Non-Battery 11 

Plug-in Hybrid - 40 mi range – Battery 19 

Plug-in Hybrid - 40 mi range - Non-Battery 11 

Electric Vehicle (Early Adopter) - 75 mile range – Battery 19 

Electric Vehicle (Early Adopter) - 75 mile range - Non-Battery 21 

Electric Vehicle (Early Adopter) - 100 mile range – Battery 19 

Electric Vehicle (Early Adopter) - 100 mile range - Non-Battery 21 

Electric Vehicle (Early Adopter) - 150 mile range – Battery 19 

Electric Vehicle (Early Adopter) - 150 mile range - Non-Battery 21 

Electric Vehicle (Broad Market) - 150 mile range – Battery 19 

Electric Vehicle (Broad Market) - 150 mile range - Non-Battery 21 

Charger-PHEV20 19 

Charger-PHEV40 19 

Charger-EV 19 

Charger Labor 6 

Mass Reduction - Level 1 21 

797 
 

798 

Mass Reduction - Level 2 21 

21 

21 

21 

Mass Reduction - Level 3 

Mass Reduction - Level 4 

Mass Reduction - Level 5 

Low Rolling Resistance Tires - Level 1 6 

25 

N/A 

Low Rolling Resistance Tires - Level 2 

Low Rolling Resistance Tires - Level 3 

Low Drag Brakes 6 

Secondary Axle Disconnect 12

Aero Drag Reduction, Level 1 12 

Aero Drag Reduction, Level 2 12

Table VII-12 was created to illustrate the level of the estimated direct cost reduction that occurs 

as a result of learning. The base model year for the cost comparison is MY 2012, in which the 

direct cost for each technology is assumed to be 100 percent. Due to learning, the direct cost will 

either stay the same or decrease in the subsequent model years. The table shows the estimated 

direct cost for each technology in each model year as a percentage of the cost in MY 2012. For 

an example, in 2021, estimated PHEV20 battery direct cost is 41percent of the estimated battery 

direct cost in MY2012. 

As explained above, the estimates in this table represent the direct manufacturing cost due to 

learning. The estimates do not include the effects of changes in indirect manufacturing costs over 

time, which the agencies account for through the use of short term and long term ICMs. For most 

technologies, the ICM is assumed to decrease in the later model years of the analysis as 

described in the previous section of this Chapter. 
799 

Table VII-12 Technology Cost Reduction Due to Learning 

Technology 

Tech Learning 

Factor 

Code 

2012 2013 2014 2015 2016 2017 2018 2019 2020 

 Abbr. 

Low Friction Lubricants - Level 1 LUB1 6 100% 100% 100% 100% 100% 100% 100% 100% 100% Engine Friction Reduction - Level 1 EFR1 6 100% 100% 100% 100% 100% 100% 100% 100% 100% Low Friction Lubricants and Engine Friction Reduction - Level 2 

LUB2_EFR2 6 100% 100% 100% 100% 100% 100% 100% 100% 100% 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC CCPS 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Discrete Variable Valve Lift (DVVL) on SOHC DVVLS 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Cylinder Deactivation on SOHC DEACS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) ICP 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) DCP 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Discrete Variable Valve Lift (DVVL) on DOHC DVVLD 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Continuously Variable Valve Lift (CVVL) CVVL 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Cylinder Deactivation on DOHC DEACD 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Stoichiometric Gasoline Direct Injection (GDI) SGDI 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Cylinder Deactivation on OHV DEACO 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Variable Valve Actuation - CCP and DVVL on OHV VVA 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Stoichiometric Gasoline Direct Injection (GDI) on OHV SGDIO 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement - Turbo 

TRBDS1_SD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement - Downsize 

TRBDS1_SD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement -Turbo 

TRBDS1_MD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement - Downsize 

TRBDS1_MD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement - Turbo 

TRBDS1_LD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement - Downsize 

TRBDS1_LD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 
800 

Technology Tech 

Learning 

Factor 

Code 

2012 2013 2014 2015 2016 2017 2018 2019 2020 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Turbo 

TRBDS2_SD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement - Downsize 

TRBDS2_SD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Turbo 

TRBDS2_MD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement - Downsize 

TRBDS2_MD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Turbo 

TRBDS2_LD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement - Downsize 

TRBDS2_LD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement - Turbo 

CEGR1_SD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement - Downsize 

CEGR1_SD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement - Turbo 

CEGR1_MD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement - Downsize 

CEGR1_MD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement - Turbo 

CEGR1_LD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement - Downsize 

CEGR1_LD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement - Turbo 

CEGR2_SD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement - Downsize 

CEGR2_SD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement - Turbo 

CEGR2_MD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement - Downsize 

CEGR2_MD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement - Turbo 

CEGR2_LD_TB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 
801 

Technology Tech 

Learning 

Factor 

Code 

2012 2013 2014 2015 2016 2017 2018 2019 2020 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement - Downsize 

CEGR2_LD_DS 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 

Advanced Diesel - Small Displacement ADSL_S D 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Advanced Diesel - Medium Displacement ADSL_M D 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Advanced Diesel - Large Displacement ADSL_L D 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 6-Speed Manual/Improved Internals 6MAN 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Improved Auto. Trans. Controls/Externals IATC 12 100% 97% 94% 91% 89% 87% 85% 83% 82% 6-Speed Trans with Improved Internals (Auto) NAUTO 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 6-speed DCT DCT 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 8-Speed Trans (Auto or DCT) 8SPD 11 100% 97% 94% 91% 89% 87% 85% 83% 82% High Efficiency Gearbox w/ dry sump (Auto or DCT) HETRAN S 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Shift Optimizer SHFTOP T 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Electric Power Steering EPS 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Improved Accessories - Level 1 IACC1 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) IACC2 12 100% 97% 94% 91% 89% 87% 85% 83% 82% 12V Micro-Hybrid (Stop-Start) MHEV 16 100% 100% 80% 64% 64% 62% 60% 58% 57% Integrated Starter Generator - Battery ISG_B 24 100% 100% 80% 80% 64% 64% 62% 60% 58% Integrated Starter Generator - Non-Battery ISG_NB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Strong Hybrid (Powersplit or 2-Mode) - Level 1 - Battery SHEV1_ B 24 100% 100% 80% 80% 64% 64% 62% 60% 58% Strong Hybrid (Powersplit or 2-Mode) - Level 1 - NonBattery SHEV1_ NB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 - Battery SHEV2_ B 24 100% 100% 80% 80% 64% 64% 62% 60% 58% Strong Hybrid (P2 Parallel or 2-Mode) - Level 2 - NonBattery SHEV2_ NB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Plug-in Hybrid - 20 mi range - Battery PHEV1_ B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Plug-in Hybrid - 20 mi range - Non-Battery PHEV1_ NB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% Plug-in Hybrid - 40 mi range - Battery PHEV2_ B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Plug-in Hybrid - 40 mi range - Non-Battery PHEV2_ NB 11 100% 97% 94% 91% 89% 87% 85% 83% 82% 
802 

Technology Tech

Learning 

Factor 

Code

2012 2013 2014 2015 2016 2017 2018 2019 2020 

Electric Vehicle (Early Adopter) - 75 mile range - Battery EV1_B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Electric Vehicle (Early Adopter) - 75 mile range - NonBattery EV1_NB 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Electric Vehicle (Early Adopter) - 100 mile range - Battery EV2_B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Electric Vehicle (Early Adopter) - 100 mile range - NonBattery EV2_NB 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Electric Vehicle (Early Adopter) - 150 mile range - Battery 1. EV3 _B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Electric Vehicle (Early Adopter) - 150 mile range - NonBattery EV3_NB 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Electric Vehicle (Broad Market) - 150 mile range - Battery EV4_B 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Electric Vehicle (Broad Market) - 150 mile range - NonBattery EV4_NB 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Charger-PHEV20 PHEV1_ C 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Charger-PHEV40 PHEV2_ C 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Charger-EV EV_C 19 100% 100% 80% 80% 64% 64% 51% 51% 41% Charger Labor CHRG_L 6 100% 100% 100% 100% 100% 100% 100% 100% 100% Mass Reduction - Level 1 MR1 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Mass Reduction - Level 2 MR2 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Mass Reduction - Level 3 MR3 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Mass Reduction - Level 4 MR4 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Mass Reduction - Level 5 MR5 21 100% 97% 94% 91% 89% 86% 83% 81% 78% Low Rolling Resistance Tires - Level 1 ROLL1 6 100% 100% 100% 100% 100% 100% 100% 100% 100% Low Rolling Resistance Tires - Level 2 ROLL2 25 100% 100% 100% 100% 100% 100% 100% 80% 80% Low Drag Brakes LDB 6 100% 100% 100% 100% 100% 100% 100% 100% 100% Secondary Axle Disconnect SAX 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Aero Drag Reduction, Level 1 AERO1 12 100% 97% 94% 91% 89% 87% 85% 83% 82% Aero Drag Reduction, Level 2 AERO2 12 100% 97% 94% 91% 89% 87% 85% 83% 82% 
 

 

                                                      

 

803 

Application of a Continuous Learning Curve to CAFE Technologies 

The purpose of the schedules employed by NHTSA is to approximate a learning curve. An 

alternate approach would be to apply a learning curve directly to the current cost estimates. As 

noted above, in response to comments received during previous rulemakings, NHTSA agreed 

that a continuous curve, if implemented correctly, could potentially improve the accuracy of 

modeling cost-learning effects, and noted that we would investigate the applicability of this 

approach for future rulemakings. Following are the results of this analysis. 

The basis for a continuous learning curve has been established in the literature. The method 

commonly mentioned in the literature estimates learning as a function of cumulative production. 

Essentially, each doubling of cumulative production results in a specified percentage reduction in 

costs. The specified reduction percentage is a function of the “progress rate.” The progress rate 

represents the portion of costs that remain after each step of learning. The progress rate usually 

cited is 0.8, implying that each doubling of cumulative production results in a 20% reduction in 

costs364. 

According to Dutton and Thomas365, the most common formulation of the progress function is 

the log-linear form: 

ݔܽ ൌ ݕ ௕ି

Where: 

y=input cost for the xth unit 

x= cumulative number of units produced 

a=input cost for the first unit 

b= progress rate 

Figure 1 portrays an example of cost decreases that occur over successive doublings of 

cumulative production under an assumed learning rate. The increments indicated on the x axis of 

364 Dutton, John M, and Thomas, Annie, “Treating Progress Functions as a Managerial Opportunity”, Academy of 

Management Review, 1984, Vol. 9, No. 2, pp.235-247 

365 Ibid 
                                                      

804 

Figure 1 represent successive instances of doubling of cumulative volume. The rate of cost 

decline is initially steep, but flattens out naturally over subsequent production increases. 

Doubling during the earlier years of a technologies life can occur relatively quickly once 

production is initiated in large portions of the fleet. Thus, for example, a single year’s 

production could produce 3 or 4 instances of doubling. However, as cumulative volume grows, 

the rate of doubling decreases since annual increases in cumulative production are limited to one 

year’s production level, while cumulative volume increases indefinitely. Successive doublings 

may require ever increasing multiples of years to occur. 

Figure 2 illustrates the practical impact of cumulative learning over time using a hypothetical 

production schedule for a new technology. The increments indicated on the x axis of Figure 2 

represent successive years in a technologies production life. In this example, successive 

doublings of cumulative production occur in the first few years as production is ramped up over 

the initial levels that occurred as the technology was introduced into the fleet, possibly in luxury 

or specialty vehicles. However, within a few years cumulative volume exceeds the stabilized 

annual production volume, and doubling becomes increasingly difficult to obtain. Both Figure 1 

and Figure 2 are based on the same learning rate, but figure 2 reflects the natural limitation on 

increases in cumulative volume (and thus learning) that result from the finite nature of annual 

production levels. 

Figure 1 also illustrates a practical limitation to the application of learning curves. If followed to 

its natural conclusion, the indefinite application of learning curves, even at relatively low rates, 

implies that technology costs will eventually approach zero, an infeasible result for virtually all 

automotive technologies. This in turn implies that there is likely some point at which learning 

will basically be exhausted and will cease to have an observable impact on costs – a threshold at 

which further application of learning would no longer be appropriate. Very few of the 

technologies used to improve CAFE are expected to last for more than 20 years, so practically 

speaking, the application of learning within the context of CAFE analyses is unlikely to produce 

such a result. While some breakthrough technologies have experienced significant cost 

reductions to levels that are a fraction of their original cost, it is likely that for most motor 

vehicle technologies, real reductions in cost began to be less feasible as they drop beyond a 

certain level. Baloff366 examined automotive assembly labor costs for 4 different start-up 

scenarios during the late 1960s and found that in 3 of the 4 scenarios, assembly costs reached a 

steady state condition where no further learning occurred when cumulative output reached 40 

percent of the total annual production. Assembly labor is only one aspect of total production 

366 Baloff, Nicholas, Extension of the Learning Curve – Some Empirical Results, Operational Research Quarterly 

(1970-0971), Vol 22, No. 4 (Dec., 1971, pp.32-43. 
                                                      

           

805 

costs – production techniques can be refined, material prices can change as cheaper sources are 

found, etc., but it seems likely that a practical floor exists for most if not all aspects of 

production. The National Research Council of the National Academy of Sciences warns against 

applying traditional learning curves to mature technologies for this same reason.367 

Neither the cumulative production method, nor the proxy learning schedules currently used by 

NHTSA and EPA recognize a steady state cost level, but as can be seen in Figure 2, they do 

eventually reach a point where costs decline at such a slow rate that the impact of further 

production is relatively insignificant. The agencies do not currently have data to determine 

whether the timing of real world steady state cost trends is consistent with the trends that result 

from our learning curve estimates. 

Figure 1 

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1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47

Cost Changes Over Successive Doubling of

Cumulative Production

Cost

367 National Research Council of the National Academies, Committee on the Assessment of Technologies for 

Improving Light-Duty Vehicle Fuel Economy, Assessment for Fuel Economy Technologies for Light-Duty Vehicles, 

Washington D.C.: The National Academies Press, June 2011, p. 25. 
                                                      

 

             

806 

Figure 2 

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$60

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1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47

Cost Changes Over Time Based on Cumulative

Learning

Cost

As noted in the previous discussion, over the past several rulemakings NHTSA has attempted to 

simulate the learning process using a variety of methods and assumptions. NHTSA has not 

directly employed a cumulative volume algorithm for this purpose because to do so would 

require specific assumptions regarding the appropriate progress ratio for each technology, as well 

as information regarding the cumulative volume of each technology concurrent with its cost 

basis. The progress rate most often cited in the literature, 80%, is a general average derived from 

Dutton and Thomas’ 1984 compilation of over 100 empirical studies of progress curves in a 

large variety of industries between 1920 and 1980368. However, as those authors are careful to 

point out, the average progress rate across all of these studies has not been found to be a good 

predictor for specific industries. Baloff too warns against use of this simple average, referring to 

it as “the infamous “80 percent” curve”369. 

368 Dutton op.cit. 369 Baloff op. cit, p.41 
                                                      

 

807 

Table VII-12 summarizes the progress rates, along with the implied cost reduction rates for a 

variety of technologies gathered from more recent studies. For these technologies, a range of 

progress rates are indicated, averaging closer to 90% than 80%. However, none of these 

technologies are produced within the light vehicle industry or in volumes similar to those 

produced in that industry (although PV inverters require electronics technology similar to that 

used in some automotive applications). 

Table VII-13 

Progress Rates and Learning Rates for Selected Technologies 

Technology Progress Rate Learning Rate 

Solar Power370 0.77 0.23 

Wind Power371 0.87 0.13 

Ethanol372 0.85 0.15 

PV Inverters373 0.94 0.06 

Solar Thermal374 0.97 0.03 

Flue Gas DeSOx375 0.89 0.11 

Flue Gas DeNOx376 0.88 0.12 

To properly estimate the impact of learning under the cumulative volume approach, five things 

are required: 

370 The Carbon Productivity Challenge: Curbing Climate Change and Sustaining Economic Growth, McKinsey 

Climate Change Special Initiative, McKinsey Global Institute, June 2008 (quoting from UC Berkeley Energy 

Resource Group, Navigant Consulting). Available at 

http://www.mckinsey.com/insights/mgi/research/natural_resources/the_carbon_productivity_challenge. Docket No. 

NHTSA-2010-0131. 

371 Ibid 372 Ibid 373 Ibid 374 Ibid 375 Technology Innovation for Climate Mitigation and its Relation to Government Policies, Edward S. Rubin, 

Carnegie Mellon University, Presentation to the UNFCCC Workshop on Climate Change Mitigation, Bonn, 

Germany, June 19, 2004. Available at 

http://www.cmu.edu/epp/iecm/rubin/PDF%20files/2004/2004ti%20Rubin,%20UNFCCC%20Workshop%20Jun%20 

(c).pdf. Docket No. NHTSA-2010-0131. 376 Ibid 
808 

1) A progress rate representing the remaining portion of the price after each doubling of 

cumulative volume 

2) The direct cost of the technology at time n1 

3) An estimate of the cumulative production volume for the specific technology at time n1 

4) The direct cost of the technology at time n2 

5) A history of the production of the technology between time n1 and n2 

In an effort to explore the potential impacts of adopting a cumulative production curve (rather 

than simulating one with proxy estimates contained in schedules), NHTSA has examined the cost 

and production changes for several light vehicle technologies. NHTSA routinely performs 

evaluations of the costs and benefits of safety standards that were previously promulgated. To 

estimate costs, the agency conducts a tear down study of the technologies used to meet the 

standards. In some cases, the agency has performed multiple evaluations over a span of years. 

For example, a tear down study may be performed to support the agency’s initial estimates of 

costs that will result from the regulation, and again 5 years later to evaluate the impacts of the 

regulation after it has been in effect. These data, together with actual production data, supply 4 

of the 5 items required to develop a learning curve for the technology. Combining them with the 

methods previously discussed, we were able to derive a progress rate specific to each technology. 

The technologies that were examined were air bags, antilock braking systems, 3-point manual 

outboard safety belts with retractors, dual master brake cylinders, and adjustable head restraints. 

The derived progress rates for each technology are summarized in Table VII-14: 

Table VII-14 

Progress Rates and Learning Rates for Automotive Safety Technologies 

Technology Progress Rate Learning Rate 

Driver Air Bags 0.93 0.07 

Antilock Braking Systems 0.90 0.10 

Manual Lap/Shoulder Belts 0.96 0.04 

Adjustable Head Restraints 0.91 0.09 

Dual Master Brake Cylinders 0.95 0.05 

The results range from 0.90 for antilock brakes to 0.96 for 3-point belts with retractors. The 

average progress rate for these 5 technologies is 0.93. This limited sample of these safety related 
                                                      

 

809 

automotive technologies thus indicates a progress rate for technologies used in passenger 

vehicles that is roughly .10-.15 higher than the all-industry average noted in Dutton and Thomas 

and others. 

NHTSA does not have similar data for the specific technologies that will be used to meet CAFE 

standards. Specifically, we do not have cost teardown information over at least 2 time periods 

for these technologies, and in most cases we do not have the cumulative production volume 

associated with the cost estimates that are used in the Volpe model. However, we were able to 

determine the cumulative volume production for two specific technologies - turbochargers 

(TRBDS) and electronic power steering (EPS). These data were gathered from Ward’s 

Automotive Reports annuals, which specify production levels for some selected technologies, 

and from AA1CAR.com. In cases where data was not yet available though the year of the cost 

estimate, a conservative estimate based on the most recent years production or projections 

derived from the Volpe model was added to the total to represent the few missing years. We 

thus had a current cost estimate and the cumulative production that was concurrent with that cost 

estimate. In addition, we had our own projections for future production of these technologies 

through 2025, and our own calculated price for that technology through 2025 reflecting our 

current learning schedules. Using these data, we estimated the implied progress ratio that was 

consistent with the learning schedules we apply in our models that would produce the same cost 

estimate in MY 2025 as is predicted in our models. The resulting progress rates were 0.92 for 

turbochargers and .90 for electronic power steering. We note that, unlike the 5 safety 

technologies discussed above, these are not actual measurements of the learning curve progress 

rate for these technologies, rather they are measurements of the implied progress rate that results 

from the learning schedules we are applying. The implication is that we are applying learning 

schedules for these two technologies that would be consistent with progress rates of roughly 0.92 

and 0.90377. These are somewhat lower than, but reasonably consistent with, the average 

measured progress rates for the 5 safety technologies. 

As a final step in this analysis, NHTSA ran a comparison of the price trends that result from 

application of the current learning schedules to the trends that would result from applying the 

cumulative learning procedure assuming the average progress ratio of 0.93 derived from the 5 

vehicle safety technologies. The results are illustrated in Figures 3 and 4 below. In each case the 

technologies were assigned a token cost of $100 to facilitate examination of the results. In the 

377 Note that these progress rates were derived based on the curve that matched the Volpe model predicted costs in 

MY 2025. They were not necessarily best fit curves over the entire time span. Based on an examination of the 

curves in figures 3 and 4, we believe a best fit curve would produce a nearly identical progress ratio for the turbo, 

and would produce a slightly higher progress rate for electronic power steering. 
810 

case of turbos, the cumulative production method produces cost estimates that range from near 

zero in the early years to about 4% more than the current learning schedule over by MY2025. In 

the case of electronic power steering, the cumulative production method produces cost estimates 

that exceed the current learning schedule by near zero in the early years but that steadily rise to 

7% by MY 2025. 

This analysis indicates that the learning schedules used in the NPRM for these technologies 

provides cost estimates that are within 4-7% of cost estimates derived using a cumulative 

production basis, with smaller differences in earlier years. However, a number of caveats are 

required. The most obvious is that it is not certain that the average progress rate derived from 

the 5 safety technologies is actually representative of the progress rate that should be applicable 

to the roughly 40 different fuel economy technologies that will be incorporated into vehicle 

designs for CAFE. Although the range of progress rates for these safety technologies, 90-96%, 

is relatively narrow, if real data were available to measure the progress rate for all 40 CAFE 

technologies, it is likely that the range may be wider. It is uncertain how this would 

directionally affect the average. 

Figure 3 

TRBDS Cost Trend Under Current Learning Schedule and Cumulative Learning Basis 

$60

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123 4567 8 9 10 11 12 13 14

Cumulative

Current
 

811 

Figure 4 

EPS Cost Trend Under Current Learning Schedule and Cumulative Learning Basis 

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1 2 3 4 5 6 7 8 9 10 11

Cumulative

Current

A second caveat is that calculations of derived progress rates are highly sensitive to estimates of 

cumulative production. Empirical observations from this exercise indicate that each doubling or 

halving of the assumed initial cumulative production can shift calculated progress rates by 0.01­

0.02 or more, depending on the historical sales profile. It is thus important that initial cost 

estimates properly match up with the correct assessment of the cumulative production volumes 

that coincide with those costs, and for most technologies, this data is elusive. Although the 

cumulative production method has theoretical advantages over using a series of learning 

schedules based on expert judgment, as a practical matter, an inability to obtain this data could 

lead to the adoption of assumed or roughly estimated levels of cumulative production. This 

might result in replacing one set of judgments with another, and it is unclear which would have 

the greater margin of error. 

We note that the cost estimates provided in the FEV report represent the cost to annually produce 

mature technologies in a volume of 450,000 units. Mature technologies as defined in that study 

have mature product designs, high production volumes, significant marketplace competition, and 

established manufacturing processes. Presumably, in order for a technology to be considered 

mature it would have already been produced for a number of years so that production and 

assembly techniques had been refined to a level of efficiency where it could be considered a 
 

 

 

812 

mature technology. For each of the 2 technologies examined above, cumulative production 

volume through 2009 was over 4 million units, but these technologies are projected to grow at 

noticeably different rates in response to CAFE standards after 2009. It is likely that cumulative 

production for the 40+ technologies estimated in this study will have a wide range of cumulative 

volumes for MY 2012 (the base year for most technologies in the FEV report) , which could 

make application of a single assumed cumulative volume level problematic. 

In summary, to actually adopt a cumulative production based learning methodology that is 

confidently more accurate than current methods, NHTSA would have to develop at least 2 

historical cost estimates for each technology, a cumulative production volume estimate 

coinciding with the initial cost estimate, and a schedule of cumulative production between the 

cost estimates. With these data we could derive an accurate progress rate to apply to each 

technology going forward using the projected increase in cumulative production volume that is 

predicted to result from CAFE standards. This initial analysis of only two CAFE technologies 

and five safety technologies indicates that adopting a cumulative production basis for learning 

applications could produce cost estimates that are within 4-7% of those used in the NPRM by 

2025, with less variation in earlier years. However, this analysis is based on a very small sample 

of technologies and the data required to more precisely evaluate this issue are currently 

unavailable. Further, these data may not be obtainable without an extensive research effort, if at 

all. 

Overall, NHTSA acknowledges that there is uncertainty regarding the rate of learning that will 

occur for specific CAFE technologies. The schedules that are applied in this analysis represent 

our best effort to approximate the learning history that would typically occur over the course of a 

technology’s lifetime, with NHTSA’s best judgment as to the position of each technology along 

the learning curve. The agency requests comments regarding the learning rates currently used in 

this analysis, the application of cumulative learning curves to technologies, and any data sources 

that might assist in developing learning rates for specific CAFE technologies. 

Potential opportunity costs of improved fuel economy 

An important concern is whether achieving the fuel economy improvements required by 

alternative CAFE standards would require manufacturers to compromise the performance, 

carrying capacity, safety, or comfort of their vehicles. If it did so, the resulting sacrifice in the 
 

                                                      

813 

value of these attributes to vehicle buyers would represent an additional cost of achieving the 

required improvements in fuel economy, and thus of manufacturers’ compliance with stricter 

CAFE standards. While exact dollar values of these attributes to buyers are extremely difficult 

to infer from vehicle purchase prices, it is nevertheless clear that changes in these attributes can 

affect the utility that vehicles provide to their owners, and thus their value to potential buyers. 

The agency has approached this potential problem by developing cost estimates for fuel 

economy-improving technologies that include any additional manufacturing costs that would be 

necessary to maintain the performance, comfort, capacity, or safety of any vehicle to which those 

technologies are applied. Theoretically, opportunity costs could also include any foregone 

opportunities to enhance these products for consumers. However, estimating values for foregone 

opportunities is an even tougher task. So, the agency followed the precedent established by the 

National Academy of Sciences (NAS) in its 2002 analysis of the costs and benefits of improving 

fuel economy by raising CAFE standards.378 The NAS study estimated “constant performance 

and utility” costs for fuel economy technologies, and the agency has used these as the basis for 

developing the technology costs it employed in analyzing manufacturer’s costs for complying 

with alternative standards. 

NHTSA fully acknowledges the difficulty of estimating technology costs that include costs for 

the accompanying changes in vehicle design that are necessary to maintain performance, 

capacity, and utility. This is particularly difficult for electric vehicles and the potential effect 

that reduced driving distance could have on buying patterns and sales. This will be discussed 

further in Chapter VIII in the section on “The Value to Consumers of Changes in Driving 

Range.” 

Financial Impacts of Raising CAFE Standards 

Market forces are already requiring manufacturers to improve the fuel economy of their vehicles, 

as shown both by changes in product plans reported to NHTSA, and by automaker public 

announcements. The various compliance flexibility mechanisms permitted by EISA, including 

flexible and alternative fuel vehicles, banking, averaging, and trading of fuel economy credits 

will also reduce compliance costs to some degree. By statute, NHTSA is not permitted to 

consider the benefits of flexibility mechanisms in setting fuel economy standards. 

378 National Academy of Sciences, Costs and Effectiveness of Increasing Corporate Average Fuel Economy 

Standards, 2002. 
 

                                                      

814 

President Obama announced plans for these rules on July 29, 2011 and NHTSA and EPA issued 

a Supplemental Notice of Intent (NOI) outlining the agencies’ plans for proposing the MY 2017­

2025 standards and program.379 

This proposal reflects an agreement between EPA, NHTSA, CARB, 13 automobile companies, 

and general support from the United Auto Workers on desirable and achievable fuel economy 

standards. We believe that this agreement reflects the view of the industry that given current 

economic conditions that the standards finalized here are economically practicable. On the other 

hand, the agency is mindful that CAFE standards could affect the relative competitiveness of 

different vehicle manufacturers. 

Given the foregoing, therefore, the agency has decided that in this exceptional situation, 

economic practicability must be determined based on whether the expenditures needed to 

achieve compliance with the final MY 2017-2021 and augural MY 2022-2025 standards are 

“within the financial capability of the industry, but not so stringent as to threaten substantial 

economic hardship for the industry.” 

One of the primary ways in which the agency seeks to ensure that its standards are within the 

financial capability of the industry is to attempt to ensure that manufacturers have sufficient lead 

time to modify their manufacturing plans to comply with the final standards in the model years 

covered by them. Employing appropriate assumptions about lead time in our analysis helps to 

avoid applying technologies before they are ready to be applied, or when their benefits are 

insufficient to justify their costs. It also helps avoid basing standards on the assumption that 

technologies could be applied more rapidly than practically achievable by manufacturers. 

NHTSA considers these matters in its analysis of issues including refresh and redesign 

schedules, phase-in caps, and learning rates. 

The agency has neither the capability to predict the capital investment needs of the automobile 

industry to install fuel economy technologies, nor the capability to determine the level of capital 

investments available to specific manufacturers in the future. 

379 76 FR 48758 (August 9, 2011). 
                                                      

815 

Sales and Employment 

Projected Sales of MY 2017-2025 Passenger Cars and Light Trucks 

All projections of total passenger car and light truck sales for future years in the case of the MY 

2008 baseline fleet were obtained using the Annual Energy Outlook 2011 (AEO 2011) version of 

Energy Information Administration’s (EIA’s) National Energy Modeling System (NEMS), as 

described in the agencies’ joint Technical Support Document (TSD) supporting this rule. AEO 

is a standard government reference for projections of energy production and consumption in 

different sectors of the U.S. economy. In using these forecasts, NHTSA made the simplifying 

assumption that the NEMS-based projected sales of cars and light trucks during each calendar 

year from 2017 through 2025 represented the likely production volumes for the corresponding 

model year. The agency did not attempt to establish the exact correspondence between projected 

sales during individual calendar years and production volumes for specific model years; instead, 

the analysis is done on a model year basis. 

As also discussed in the TSD, in the case of the MY 2008 baseline fleet, NHTSA and EPA 

jointly made use of a custom long-range forecast purchased from CSM Worldwide. This 

forecast addresses trends such as changes in individual manufacturers’ shares of the U.S. light 

vehicle market and changes in the prominence of different market segments (e.g., crossover 

vehicles). Although not yet ready for use in this final rulemaking, NHTSA is developing a 

vehicle choice model to better analyze sales by manufacturer and sales of individual market 

segments.380 

The final market forecast applied by NHTSA reflects growth of the overall fleet to match the 

NEMS-based forecast of the overall size of the fleet, as well as normalization of the production 

volumes of individual vehicle models in consideration of (a) NEMS-based estimates of the sizes 

of the passenger car and light truck fleets, (b) CSM-based estimates of individual manufacturers’ 

market shares, and (c) CSM-based estimates of the prominence of specific market segments. 

These adjustments were conducted through an iterative process also described in the TSD, and 

result in the production (for the U.S. market) volumes shown below. 

380 Further details regarding the planned vehicle choice model are discussed below, see section titled “How does 

NHTSA plan to address this issue in the mid-term review and in future rulemakings?” 
816 

Sales projections of future vehicles derived from the MY 2010 baseline fleet were developed 

analogously to those of the MY 2008 baseline fleet with the exception that NHTSA and EPA 

jointly made use of J.D. Power and Associates forecasts of trends such as changes in individual 

manufacturer’s shares of the U.S. light vehicle market and changes in the prominence of 

different market segments. The final market forecast applied in the analysis of future vehicle 

sales derived from the MY 2010 baseline is consistent with the approach described above for the 

MY 2008 baseline; however, NHTSA utilized the Annual Energy Outlook 2012 Early Release 

(AEO 2012) version of Energy Information Administration’s (EIA’s) National Energy Modeling 

System (NEMS), as described in the agencies’ joint Technical Support Document (TSD) 

supporting this rule. 

Sales projections shown in Table VII-15 must be noted with the caveat that in the absence of a 

credible consumer choice model that incorporates a feedback loop between rule-driven vehicle 

price increases and consumer valuations of fuel economy, that an implicit assumption of zero 

price elasticity of demand with respect to vehicles for the program cost analysis. Should a peerreviewed consumer choice model of vehicle sales be developed, it is likely that such a model will 

incorporate a feedback loop into the sales projections of the main analysis such that the price 

elasticity of demand will change to a nonzero value. 
817 

Table VII-15a 

Sales Projections – Passenger Cars 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 

Aston Martin 2010 2008 634 - 1,035 617 - 1,051 620 - 1,072 620 - 1,034 623 - 1,058 626 - 1,049 630 - 1,041 63

1,

BMW 2010 2008 320,634 - 313,022 318,821 - 322,939 327,091 - 346,075 329,304 - 357,942 335,753 - 359,098 341,613 - 360,034 346,903 - 360,561 357,

388

Daimler 2010 2008 252,820 - 284,847 240,222 - 276,409 245,807 - 281,425 245,888 - 290,989 249,219 - 300,378 251,461 - 304,738 253,688 - 312,507 258,

332

Fiat 2010 2008 730,695 - 429,308 737,850 - 408,386 771,092 - 402,389 788,181 - 425,814 806,958 - 431,743 830,509 - 435,220 852,268 - 435,071 879,

437

Ford 2010 2008 1,348,543 - 1,299,899 1,347,544 - 1,311,467 1,341,628 - 1,332,039 1,347,596 - 1,378,789 1,359,990 - 1,401,617 1,377,947 - 1,415,221 1,394,907 - 1,474,797 1,418

1,50

Geely 2010 2008 60,422 - 88,234 57,655 - 89,394 60,338 - 91,575 60,040 - 93,003 61,433 - 92,726 62,399 - 92,512 63,076 - 96,840 65,1

99,

General Motors 2010 2008 1,652,946 - 1,516,867 1,616,449 - 1,539,537 1,611,415 - 1,563,210 1,612,666 - 1,610,404 1,624,561 - 1,628,896 1,638,066 - 1,640,878 1,652,324 - 1,667,884 1,676

1,69

Honda 2010 2008 1,122,558 - 1,154,600 1,139,856 - 1,138,087 1,147,055 - 1,144,639 1,167,627 - 1,163,666 1,187,756 - 1,198,880 1,212,900 - 1,237,504 1,238,278 - 1,265,564 1,267

1,30

Hyundai 2010 2008 865,069 - 592,027 849,727 - 578,373 857,497 - 582,971 861,062 - 598,283 873,625 - 613,355 887,004 - 627,964 899,936 - 634,308 918,

657

Kia 2010 2008 345,314 - 322,044 339,180 - 312,370 328,872 - 314,879 327,694 - 323,676 330,416 - 331,319 335,846 - 339,102 338,791 - 342,746 346,

351

Lotus 2010 2008 374 - 240 364 - 243 365 - 250 365 - 266 367 - 278 368 - 290 371 - 299 37

3

Mazda 2010 2008 254,270 - 234,781 249,048 - 242,561 247,203 - 246,902 248,350 - 247,929 249,288 - 249,694 252,522 - 253,955 254,751 - 267,692 259,

272

Mitsubishi 2010 2008 61,058 - 77,014 58,152 - 75,114 60,387 - 75,168 60,619 - 76,241 61,785 - 77,011 63,390 - 78,382 63,937 - 78,940 67,0

82,

Nissan 2010 2008 889,039 - 870,797 867,771 - 849,678 873,076 - 854,400 874,098 - 882,791 879,450 - 912,629 884,816 - 937,447 893,622 - 954,340 907,

982

Porsche 2010 2008 18,430 - 35,093 18,138 - 35,444 17,255 - 36,116 17,065 - 35,963 17,289 - 36,475 17,216 - 36,607 17,292 - 36,993 17,5

39,
818 

Spyker 2010 2008 -- 20,024 -- 20,007 -- 20,144 -- 21,069 -- 21,294 -- 21,709 -- 22,410 

22,

Subaru 2010 2008 209,137 - 224,112 205,550 - 216,598 205,868 - 217,095 205,749 - 223,466 206,863 - 230,780 209,828 - 238,613 211,621 - 241,612 215,

248

Suzuki 2010 2008 43,253 - 90,708 42,515 - 89,932 43,399 - 90,568 44,081 - 93,548 44,765 - 95,725 45,769 - 97,599 46,590 - 99,263 47,8

100

Tata 2010 2008 28,012 - 55,881 27,188 - 56,222 28,194 - 57,267 28,430 - 58,182 28,977 - 58,677 29,416 - 59,349 29,898 - 60,639 30,5

63,

Tesla 2010 2008 -- 27,986 -- 28,435 -- 28,990 -- 27,965 -- 28,623 -- 28,369 -- 28,150 

30,

Toyota 2010 2008 1,528,208 - 1,849,196 1,501,492 - 1,834,181 1,509,270 - 1,836,306 1,515,051 - 1,883,734 1,530,699 - 1,903,706 1,548,354 - 1,986,077 1,567,676 - 2,036,992 1,598

2,08

Volkswagen 2010 2008 481,894 - 551,638 470,826 - 540,036 463,329 - 537,114 459,868 - 554,822 460,777 - 585,607 465,011 - 593,314 467,170 - 596,749 475,

605

Total/Average 2010 2008 10,213,312 - 10,039,354 10,088,966 - 9,966,465 10,139,761 - 10,060,594 10,194,353 - 10,349,575 10,310,594 - 10,559,569 10,455,061 - 10,785,934 10,593,727 - 11,015,396 10,81

11,30
819 

Table VII-15b 

Sales Projections – Light Trucks 

Manufacturer Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 2

Aston Martin 2010 2008 ---­ ---­ ---­ ---­ ---­ ---­ ---­ ---­ 

BMW 2010 2008 106,150 - 138,053 104,625 - 131,942 105,104 - 131,373 101,805 - 128,339 101,238 - 128,724 100,345 - 128,899 99,084 - 127,521 101,1

146,

Daimler 2010 2008 99,125 - 86,913 108,510 - 83,651 108,294 - 88,188 108,598 - 92,919 110,235 - 99,449 112,133 - 100,935 113,550 - 105,315 116,8

107,

Fiat 2010 2008 774,065 - 405,833 743,375 - 383,710 749,206 - 362,541 740,640 - 357,098 733,257 - 344,942 735,937 - 359,099 731,269 - 357,102 722,2

341,

Ford 2010 2008 1,035,400 - 763,549 1,023,955 - 748,829 1,016,328 - 717,773 995,702 - 717,037 990,243 - 714,181 990,827 - 714,266 985,782 - 700,005 991,7

688,

Geely 2010 2008 35,087 - 41,887 32,438 - 42,187 33,299 - 43,125 32,149 - 42,615 31,977 - 41,768 31,598 - 41,686 31,007 - 42,031 31,79

42,4

General Motors 2010 2008 1,213,192 - 1,308,099 1,201,479 - 1,372,894 1,217,167 - 1,435,327 1,211,435 - 1,465,333 1,218,265 - 1,465,400 1,226,184 - 1,445,331 1,232,502 - 1,435,430 1,244,

1,431

Honda 2010 2008 536,998 - 596,481 525,327 - 544,619 527,814 - 527,535 517,268 - 525,089 512,800 - 535,916 515,656 - 539,235 509,628 - 536,898 505,5

536,

Hyundai 2010 2008 131,912 - 152,885 127,289 - 151,461 122,193 - 155,642 118,265 - 154,173 117,565 - 156,466 116,208 - 157,493 115,339 - 161,189 116,4

166,

Kia 2010 2008 43,374 - 98,702 43,209 - 98,280 41,648 - 100,679 40,270 - 96,535 39,205 - 95,432 38,857 - 94,694 38,203 - 95,688 38,03

96,1

Lotus 2010 2008 ---­ ---­ ---­ ---­ ---­ ---­ ---­ ---­ 

Mazda 2010 2008 59,862 - 70,547 59,114 - 77,485 55,108 - 77,542 53,334 - 80,303 52,946 - 84,273 52,752 - 87,502 52,158 - 91,184 52,99

90,3

Mitsubishi 2010 2008 13,701 - 25,717 13,840 - 24,857 14,276 - 24,112 14,262 - 24,054 14,307 - 24,149 14,778 - 24,106 14,824 - 24,209 15,22

24,6

Nissan 2010 2008 305,943 - 444,938 306,537 - 412,383 309,179 - 398,559 304,196 - 397,869 303,616 - 408,029 304,381 - 411,883 304,703 - 417,121 308,5

422,

Porsche 2010 2008 20,105 - 13,233 19,647 - 12,001 19,573 - 11,469 18,851 - 11,141 18,863 - 11,242 18,598 - 11,385 18,562 - 11,370 18,86

11,4
820 

Spyker 2010 2008 -- 2,871 -- 3,596 -- 3,826 -- 3,509 -- 3,560 -- 3,461 -- 3,435 -- 3,4Subaru 2010 2008 96,938 - 78,242 94,441 - 75,152 92,177 - 72,832 90,751 - 72,458 91,673 - 72,773 91,940 - 72,736 92,337 - 73,022 94,30

74,1

Suzuki 2010 2008 3,399 - 22,109 3,347 - 21,385 3,690 - 20,692 3,676 - 20,675 3,760 - 20,767 3,879 - 20,734 3,939 - 20,803 4,08

21,1

Tata 2010 2008 54,033 - 57,579 53,423 - 56,606 52,682 - 57,854 51,461 - 56,213 50,984 - 58,153 50,767 - 58,590 50,280 - 58,865 50,34

57,9

Tesla 2010 2008 ---­ ---­ ---­ ---­ ---­ ---­ ---­ ---­ 

Toyota 2010 2008 966,417 - 1,330,511 955,281 - 1,223,415 951,691 - 1,142,104 932,267 - 1,154,304 927,227 - 1,215,539 925,277 - 1,235,052 918,749 - 1,224,980 918,4

1,208

Volkswagen 2010 2008 103,088 - 128,819 100,596 - 145,491 102,910 - 146,891 100,916 - 146,700 101,344 - 148,734 102,022 - 146,750 101,558 - 153,927 104,6

156,

Total/Average 2010 2008 5,598,788 - 5,766,967 5,516,434 - 5,609,945 5,522,339 - 5,518,064 5,435,847 - 5,546,364 5,419,506 - 5,629,497 5,432,139 - 5,653,839 5,413,473 - 5,640,093 5,435,

5,626
                                                      

 

 

 

 

 

 

 

821 

The Impact of Higher Prices on Sales and Employment 

The effect of this rule on sales of new vehicles depends largely on how potential buyers evaluate 

and respond to its effects on vehicle prices and fuel economy. The rule will make new cars and 

light trucks more expensive, as manufacturers attempt to recover their costs for complying with 

the rule by raising vehicle prices. At the same time, the rule will require manufacturers to 

improve the fuel economy of many of their models, which will lower the operating costs of those 

models. While the initial purchase price of those vehicles will increase, the overall cost of 

owning them -- including their operating costs -- will decrease, because their fuel consumption 

will decline significantly. The net effect on sales will depend on the extent to which consumers 

are willing to pay for higher fuel economy and the resulting savings in operating costs, versus 

their sensitivity to changes in vehicles’ initial purchase prices, and is thus challenging to 

evaluate. 

The agency anticipates that consumers will place some value on improved fuel economy, both 

because it reduces the operating cost of the vehicles, and because recently promulgated EPA and 

DOT regulations require vehicles sold during 2017 through 2025 to display labels that more 

clearly communicate to potential buyers the fuel savings, economic, and environmental benefits 

of owning more fuel-efficient vehicles. We recognize that the magnitude of this effect cannot be 

predicted at this time, and that how consumers value fuel economy is a subject of ongoing 

debate. We also expect that consumers may consider other factors besides direct purchase price 

increases that affect the costs they pay for new vehicles, and have included these factors in the 

analysis. 

There is a broad consensus in the economic literature that the price elasticity of demand for 

automobiles is approximately –1.0,381, 382, 383, 384 meaning that every one percent increase in the 

1

Kleit, A.N. (1990). “The Effect of Annual Changes in Automobile Fuel Economy Standards,” Journal of 

Regulatory Economics, vol. 2, pp 151-172. Available at http://www.springerlink.com/content/m04787480k056018/ 

(last accessed August 1, 2012) or Docket No. NHTSA-2010-0131 

382Bordley, R. (1994). “An Overlapping Choice Set Model of Automotive Price Elasticities,” Transportation 

Research B, vol 28B, no 6, pp 401-408. Available at http://www.sciencedirect.com/science/article/B6V99­

466M3VD-1/2/3ecfe61bac45f1afb8d9b370330e3f0c (last accessed August 1, 2012) 383 McCarthy, P.S. (1996). “Market Price and Income Elasticities of New Vehicle Demands,” The Review of 

Economics and Statistics, vol. LXXVII, no. 3, pp. 543-547. Available at 

http://econpapers.repec.org/article/tprrestat/v_3a78_3ay_3a1996_3ai_3a3_3ap_3a543-47.htm (last accessed August 

1, 2012) or Docket No. NHTSA-2010-0131 

384 This elasticity is generally considered to be a short-run elasticity, reflecting the immediate impacts of a price 

change on vehicle sales. For a durable good such as an auto, the elasticity may be smaller in the long run: though 

people may be able to change the timing of their purchase when price changes in the short run, they must eventually 

make the investment. Using a smaller elasticity would reduce the magnitude of the estimates presented here for 

vehicle sales, but it would not change the direction. A short-run elasticity is more valid for initial responses to 

changes in price, but, over time, a long-run elasticity may better reflect behavior; thus, the results presented for the 

initial years of the program may be more appropriate for modeling with the short-run elasticity than the later years of 

the program. A search of the literature has not found studies more recent than the 1970s that specifically investigate 
                                                                                                                                                                              

 

 

822 

price of the vehicle would reduce sales by one percent (assuming no change in fuel economy, 

quality, or other attributes of vehicles). NHTSA typically assumes that manufacturers will be 

able to pass all of their costs to improve fuel economy on to consumers in the form of higher 

sales prices for models offering higher fuel economy. The subsequent discussion of consumer 

welfare, however, suggests that by itself, a net decrease in overall operating costs may not 

necessarily produce a net increase in sales. Many consumers are more sensitive to vehicles’ 

initial purchase prices than to their subsequent operating costs, and thus may not be willing to 

purchase vehicles with higher fuel economy even when it appears that doing so would reduce 

their overall costs to own a vehicle. 

There is considerable uncertainty in the economics literature about the extent to which 

consumers value fuel savings from increased fuel economy, and there is still more uncertainty 

about possible changes in consumer behavior over time (especially with the likelihood of 

consumer learning) and the extent to which this final rule could affect consumer behavior. In 

addition, consumers’ valuation of fuel economy improvements depends upon the price of 

gasoline, which has recently been very volatile. On balance, the effect of this final rule on 

vehicle sales will depend upon whether the value that potential buyers place on the increased fuel 

economy that this rule requires is greater or less than the increase in vehicle prices that results 

from the rule, as well as on how automakers interpret buyers’ likely responses to higher prices 

and increased fuel economy. Additional data would enhance the accuracy of predictions on these 

issues. In addition, it would be helpful to assess important emerging trends, such as the degree 

that longer financing terms affect consumers’ decisionmaking as they weigh operating costs 

versus upfront costs, and the degree to which extreme and continued volatility itself in gas prices 

affects assumptions about likely returns on upfront technology investments. 

How do consumers value fuel economy? 

The first question to evaluate is how consumers value fuel economy, or more accurately, how 

they value fuel savings attributable to increased fuel economy. Two interrelated economic 

concepts are commonly used to summarize how consumers appear to value future fuel savings 

that result from higher fuel economy. The first relates to the length of time that consumers 

consider when valuing fuel savings, or “payback period,” while the second relates to the discount 

rate that consumers apply to future savings. Although either of these two concepts can be used 

by itself to indicate how buyers value future fuel savings, our analysis uses a combination of the 

two to characterize consumers’ valuation of future fuel savings. 

long-run elasticities. See., e.g., Hymans, Saul H., “Consumer Durable Spending: Explanation and Prediction,” 

Brookings Papers on Economic Activity 1 (1970), which finds a short-run elasticity of auto expenditures (not sales) 

with respect to price of 0.78 to 1.17, and a long-run elasticity of 0.3 to 0.46 (pp. 173-206). Available at: 

http://www.brookings.edu/about/projects/bpea/editions/~/media/Projects/BPEA/1970%202/1970b_bpea_hymans_ac 

kley_juster.PDF or Docket No. NHTSA-2010-0131 (last accessed August 1, 2012) 
                                                      

 

823 

The length of time that consumers consider when valuing future fuel savings can significantly 

affect their comparisons of fuel savings to the increased cost of purchasing a vehicle that offers 

higher fuel economy. For example, there will be a significant difference in aggregate fuel savings 

if consumers consider 1 year, 3 years, 5 years, 10 years, or the lifetime of the vehicle as the 

relevant payback period. The discount rate that consumers use to discount future fuel savings to 

their present value can also have a significant impact; higher discount rates will reduce the 

importance of future fuel savings relative to a vehicle’s initial purchase price. If consumers value 

fuel savings over a short payback period, such as 1 to 2 years, then the discount rate will be less 

important, but if consumers consider fuel savings over a longer period, then the discount rate will 

become important. 

The payback period and discount rate are conceptual proxy measures for consumer decisions that 

may often be made without any explicit quantitative analysis. For example, some buyers 

choosing among a set of vehicles may know what they have been paying recently for fuel, what 

they are likely to pay to buy each of the vehicles considered, and some attributes—including 

labeled fuel economies—of those vehicles. However, these buyers may then make a choice 

without actually trying to estimate how much they would pay to fuel each of the vehicles they 

are considering buying; for such buyers, the idea of a payback period and discount rate may 

have no explicit meaning. This does not, however, limit the utility of these concepts for the 

agency’s analysis. If, as a group, buyers behave as if they value fuel consumption by considering 

an explicit payback period and discount rate, these concepts remain useful as a basis for 

estimating the market response to increases in fuel economy accompanied by increases in price. 

Information regarding the number of years that consumers value fuel savings comes from several 

sources. In past analyses, NHTSA has used five years as representing the average payback 

period, because this is the average length of time of a financing agreement.385 We conducted a 

search of the literature for additional estimates of consumer valuation of fuel savings, in order to 

determine whether the 5 year assumption was accurate or should be revised. A recent paper by 

David Greene6 examined studies from the past 20 years of consumers’ willingness to pay for fuel 

economy and found that “the available literature does not provide a reasonable consensus,” 

although the author states that “manufacturers have repeatedly stated that consumers will pay, in 

increased vehicle price, for only 2 - 4 years in fuel savings” based on manufacturers’ own market 

research. The National Research Council386 also used a 3 year payback period as one way to 

compare consumer valuation of benefits to a full lifetime value. A survey conducted for the 

Department of Energy in 2004, which asked 1,000 households how much they would pay for a 

385 National average financing terms for automobile loans are available from the Board of Governors of the Federal
 

Reserve System G.19 “Consumer Finance” release. See http://www.federalreserve.gov/releases/g19/ (last accessed 

August 25, 2011). The average new car loan at an auto finance company in the first quarter of 2011 is for 62 months 

at 4.73 %.
 386 National Research Council (2002), “Effectiveness and Impact of Corporate Average Fuel Economy (CAFE)
 

Standards”, National Academies Press, Washington D.C.
 
                                                      

824 

vehicle that saved them $400 or $1,200 per year in fuel costs, found implied payback periods of 

1.5 to 2.5 years. In reviewing this survey, Greene concluded: “The striking similarity of the 

implied payback periods from the two subsamples would seem to suggest that consumers 

understand the questions and are giving consistent and reliable responses: they require payback 

in 1.5 to 2.5 years.” However, Turrentine and Kurani’s387 in-depth interviews of 57 households 

found almost no evidence that consumers think about fuel economy in terms of payback periods. 

When asked such questions, some consumers became confused while others offered time periods 

that were meaningful to them for other reasons, such as the length of their car loan or lease. 

The effective discount rate that consumers have used in the past to value future fuel economy 

savings has been studied in many different ways and by many different economists. Greene 

examined and compiled many of these analyses and found: “Implicit consumer discount rates 

were estimated by Greene (1983) based on eight early multinomial logit choice models. ...The 

estimates range from 0 to 73% ... Most fall between 4 and 40%.” Greene added: “The more 

recent studies exhibit as least a wide a range as the earlier studies.” 

This is an extremely broad range. With such uncertainty about how consumers value future fuel 

savings and the discount rates they might use to determine the present value of future fuel 

savings, NHTSA chose for purposes of this analysis to utilize the standard 3 and 7 percent social 

discount rates recommended by OMB guidance to evaluate the costs and benefits of regulation. 

To the extent that some consumers appear to apply higher discount rates, the analysis of likely 

sales consequences would be different. This review leads us to conclude that consumer valuation 

of future fuel savings is highly uncertain, leading to different potential scenarios for vehicle 

sales. A negative impact on sales is possible if consumers don’t value the fuel savings or desire 

very short payback periods, because the final rule will lead to an increase in the perceived 

ownership cost of vehicles. In addition, sales decreases are possible if gasoline prices are lower 

than projected by manufacturers and the agencies or technology costs are higher than projected. 

A positive impact on sales is also possible, because the final rule will lead to a significant 

decrease in the lifetime cost of vehicles, and with consumer learning over time, this effect may 

produce an increase in sales. Whether a change in sales will result from this final rule, or will 

result from other factors that affect the way drivers consider fuel economy in their purchasing 

decisions, is subject to uncertainty. 

How do manufacturers believe consumers value fuel savings attributable to higher fuel 

economy? 

Although some manufacturers have indicated in public remarks or confidential statements to 

NHTSA that their plans to apply fuel-saving technology depend on fuel prices and consumers’ 

willingness to pay for fuel economy improvements, the agency does not have specific and robust 

387 Turrentine, T.S. and K.S. Kurani, 2007. “Car Buyers and Fuel Economy,” Energy Policy, vol. 35, 

pp. 1213-1223. 
825 

information regarding how manufacturers interpret consumers’ valuation of fuel savings. Based 

on our review of the literature and available evidence, it is not clear how accurately 

manufacturers are accounting for consumer valuation of fuel economy in making their pricing 

decisions, nor how that accuracy will be affected in the future as manufacturers’ costs to produce 

vehicles rise in response to the final standards. In standard economic theory, if manufacturers 

believe that consumers value the fuel savings at a higher dollar level than the technology costs, 

then manufacturers’ profit motives would lead them to voluntarily add the cost-effective 

technologies to their vehicles in the absence of government mandates, in the belief that their 

sales and profits would increase. 

This concept ties into the basic question of whether manufacturers are providing the amount of 

fuel economy that consumers wish to purchase—whether there is matching between consumers’ 

demand for fuel economy and the firms’ supply of fuel economy. It is possible that the light-duty 

vehicle market is currently operating according to standard economic assumptions, and 

manufacturers are providing approximately the amount of fuel economy that consumers wish to 

purchase, because they correctly interpret consumers’ valuation of fuel economy. On the other 

hand, it is possible that manufacturers are providing more or less fuel economy than consumers 

wish to purchase, because they do not correctly understand consumers’ valuation of fuel 

economy. Because NHTSA does not know which scenario is correct today, and cannot predict 

which will apply in the future, we evaluate the response of sales under both scenarios in the 

following sections in order to assess the range of potential impacts that could be attributable to 

this final rule. 

As discussed above, it is very difficult to determine how consumers will react to fuel economy 

improvements, and manufacturers presumably face this same challenge. Consumer consideration 

of fuel economy appears to evolve based on a variety of factors (fuel price, recessions, 

marketing), and consumers can react quickly to changes in these factors, sometimes more rapidly 

than the industry is able to change its product offerings. There have been examples of periods 

when demand for fuel efficient vehicles exceeded the available supply of highly efficient 

vehicles, and other periods where very efficient vehicle models were introduced into the market 

but sales stalled. If manufacturers did not accurately forecast consumers demand for fuel 

efficient vehicles, manufacturers’ investment in vehicle technologies would not result in desired 

payoff. Manufacturers may be likely to be particularly risk averse with regard to future changes 

in fuel prices, in large part due to the substantial capital investments that are necessary to 

develop and market fuel-efficient models. If a manufacturer invests substantially in fuel efficient 

technologies expecting higher consumer demand than realized, then the manufacturer has 

incurred the costs of investment but not reaped the benefits of those investments. On the other 

hand, if a manufacturer does not invest in fuel efficient technologies, then the manufacturers may 

lose some market share in the short run if demand for fuel economy is higher than expected, but 

they still retain the option of investing in fuel efficient technologies. The predicted level of 

investment under uncertainty related to consumer demand for fuel efficient vehicles and 
 

                                                      

 

826 

irreversibility of investment for fuel efficient technologies would be less than the predicted level 

of investment under no uncertainty and complete reversibility. 

In addition, there is reason to believe there may be risk aversion on the consumer side. The 

simultaneous investment by all companies may also encourage consumer confidence in the new 

technologies. If only one company adopted new technologies, early adopters might gravitate 

toward that company, but early adopters tend to be a relatively small portion of the public. More 

cautious buyers, who are likely to be more numerous, might wait for greater information before 

moving away from well-known technologies. If all companies adopt advanced technologies at 

the same time, though, potential buyers may perceive the new technologies as the new norm 

rather than as a risky innovation. They will then be more willing to move to the new 

technologies. As some commenters have pointed out, simultaneous action required by the rule 

may change buyers’ expectations (their reference points) for fuel economy, and investing in 

more fuel economy may seem less risky than in the absence of the rule.388 

Further, the certainty of the regulations reduces the costs of meeting them, because there will be 

a) more economies of scale and more learning curve benefits due to greater cumulative 

production of fuel-efficient technologies and b) more incentive for automakers and suppliers to 

invest in R&D to create future fuel-efficient technologies.389 We note that this risk aversion by 

itself does not indicate a market failure; it is the fact that the risk aversion leads to under 

provision of social benefits (e.g., reduction in greenhouse gas emissions). 

How did NHTSA attempt to calculate potential impacts of the final rule on vehicle sales 

under the different scenarios discussed above? 

Given the considerable uncertainty associated with consumer valuation of fuel savings and 

manufacturers’ understanding of that valuation, NHTSA sought to assess potential sales impacts 

under two possible basic scenarios: first, one in which the light-duty vehicle market is currently 

operating according to standard theoretical economic principles, and manufacturers are providing 

exactly the amount of fuel economy that consumers wish to purchase, because they perfectly 

understand consumers’ valuation of fuel economy; and second, one in which manufacturers are 

not providing the exact amount of fuel economy that consumers wish to purchase (either too 

much or too little), because they do not have perfect information regarding consumers’ valuation 

of fuel economy. In the first scenario, manufacturers and consumers would behave as though 

they are assuming the same payback period (and/or discount rate) for fuel savings attributable to 

388 We note that this risk aversion by itself does not indicate a market failure; but that the risk aversion leads to 

under-provision of social benefits (e.g., reduction in greenhouse gas emissions) 

389 The literature reviewed by Popp, Newell, and Jaffe (2010) shows that environmental regulation has 

played an important role in inducing innovation that reduces the cost of achieving environmental goals; Popp 

(2011) provides evidence that consumer pressure alone is rarely sufficient to achieve broad diffusion of 

environmentally-friendly technologies. 
                                                      

 

827 

higher fuel economy; in the second, manufacturers and consumers would behave as though they 

are assuming different payback periods (and/or discount rates). 

For years, consumers have been learning about the benefits that accrue to them from owning and 

operating vehicles with greater fuel efficiency. This type of learning is expected to continue 

before and during the model years affected by this rule, particularly given the new fuel economy 

labels that clarify potential economic effects and should therefore reinforce that learning. 

Therefore, some increase in the demand for, and production of, more fuel efficient vehicles is 

incorporated in the market driven baseline. 

The fuel savings associated with operating more fuel efficient vehicles will be more salient to 

individuals who own them, causing their subsequent purchase decisions to shift closer to 

minimizing the total cost of ownership over the lifetime of the vehicle. Second, this appreciation 

may spread across households through word of mouth and other forms of communications. 

Third, as more motorists experience the time and fuel savings associated with greater fuel 

efficiency, the price of used cars will better reflect such efficiency, further reducing the cost of 

owning more efficient vehicles for the buyers of new vehicles (since the resale price will 

increase). If these induced learning effects are strong, the rule could potentially increase total 

vehicle sales over time. These increased sales would not occur in the model years first affected 

by the rule, but they could occur once the induced learning takes place. It is not possible to 

quantify these learning effects years in advance and that effect may be speeded or slowed by 

other factors that enter into a consumer’s valuation of fuel efficiency in selecting vehicles. 

The possibility that the rule will (after a lag for consumer learning) increase sales need not rest 

on the assumption that automobile manufacturers are failing to pursue profitable opportunities to 

supply the vehicles that consumers demand. In the absence of the rule, no individual automobile 

manufacturer would find it profitable to move toward the more efficient vehicles mandated under 

the rule. In particular, no individual company can fully internalize the future boost to demand 

resulting from the rule. If one company were to make more efficient vehicles, counting on 

consumer learning to enhance demand in the future, that company would capture only a fraction 

of the extra sales so generated, because the learning at issue is not specific to any one company's 

fleet. Many of the extra sales would accrue to that company's competitors. 

In the language of economics, consumer learning about the benefits of fuel efficient vehicles 

involves positive externalities (spillovers) from one company to the others.390 These positive 

externalities may lead to benefits for manufacturers as a whole. We emphasize that this 

discussion has been tentative and qualified. Social learning of related kinds has been identified in 

390 Industry-wide positive spillovers of this type are hardly unique to this situation. In many industries, 

companies form trade associations to promote industry-wide public goods. For example, merchants in a given 

locale may band together to promote tourism in that locale. Antitrust law recognizes that this type of coordination 

can increase output. 
                                                      

 

828 

a number of contexts,391 and the agency expects that it will influence consumers’ future valuation 

of fuel economy. Thus, while it is difficult to determine how consumers will react to fuel 

economy improvements attributable to the final rule, we believe that it is likely that consumers 

will learn more about and increasingly value fuel economy improvements in the future. If 

manufacturers assume that consumers value fuel economy less than consumers actually value 

fuel economy, there will be a demand pull for better fuel economy vehicles into the market, and 

by virtue of the final standards forcing manufacturers to increase better fuel economy product 

offerings; it is possible that sales could increase as a result. 

How did NHTSA illustrate these scenarios analytically? 

The agency examined a number of cases to illustrate these scenarios. Sales impacts were 

determined for 6 cases that are combinations of manufacturers’ beliefs of how consumers value 

fuel savings and consumers’ valuation of fuel savings. The first two cases assume a flat baseline 

(no voluntary improvement in fuel economy above the MY 2016 standards by manufacturers 

absent new regulations), consistent with the agency’s main analysis in this rulemaking. In these 

first two cases we assume consumers value fuel savings for a 3 year period or a 5 year period 

(the average length of a loan), and we also determine the breakeven point of consumer valuation 

of fuel savings, where there would be no impact on sales, assuming all other factors remain 

constant. As can be seen in Table VII-17 below, with a flat baseline and assuming that 

consumers consider fuel economy benefits over a 3 or 5 year period, benefits exceed costs to the 

point that consumers will purchase more vehicles and sales will increase. NHTSA estimates a 

break-even point of 2.35 years for scenarios with a flat baseline; that is, if consumers value fuel 

savings over an average 2.35 years, neither an increase nor a decrease in sales is expected. 

The next 4 cases assume that manufacturers will, absent new regulations, implement 

technologies in response to their belief that consumers have either a 1 year, 3 year, or 5 year 

payback period, and for 3 of these scenarios where the consumer also values fuel economy over 

the same payback periods assumed by manufacturers. For example, the agency also examined 

the impact on sales and employment under the sensitivity analysis assumption that the baseline 

fleet included the manufacturers voluntarily implementing any technology that had a 1 year or 

less payback period for consumers. In this analysis, the least expensive technologies relative to 

their effects on fuel economy improvement (those that had a consumer payback where fuel 

savings over the first year of use were higher than new vehicle price increases) were assumed to 

be voluntarily implemented by manufacturers, resulting in improved fuel economy in the 

baseline case which would have occurred without adoption of this rule. The same methodology 

was used in the cases where both manufacturers and consumers value fuel savings over either a 3 

391 See Hunt Alcott, Social Norms and Energy Conservation, Journal of Public Economics (March 2011), available 

at http://opower.com/uploads/library/file/1/allcott_2011_jpubec_- _social_norms_and_energy_conservation.pdf (last 

accessed August 1, 2012); Christophe Chamley, Rational Herds: Economic Models of Social Learning (Cambridge, 

2004), available at http://bilder.buecher.de/zusatz/21/21995/21995098_lese_1.pdf (last accessed August 1, 2012) 
829 

year period or a 5 year period. All three of these cases result in reductions in sales, with the 

impact decreasing as the manufacturer’s baseline increases from 1 year to 3 year to 5 years. In a 

final case we assume that manufacturers voluntarily implement any technology that had a 1 year 

or less payback period for consumers, but that consumers value fuel savings over a 3 year period. 

Under that case, the breakeven point for consumers is about 3.1 years – meaning that if 

consumers valued their fuel savings over 3.1 years in this scenario, there would be no impact on 

sales; in other words if the payback period of the fuel saving technologies was less than 3.1 

years, then the vehicle sales would increase and vice versa. 

For the reader’s reference, Table VII-16 below shows the included combinations of payback 

periods assumed—for these different cases—to represent consumers’ and manufacturers’ 

decisions. The agency considered these different cases to represent an illustrative range of 

possible outcomes under the scenarios described above. 

Table VII-16 

Scenarios Considered for Sales Impact Analysis
 

Payback Period 

Representing 

Manufacturers’ 

Decisions 

Payback Period Representing Buyers’ Decisions 

1 Year 3 Years 5 Years 

0 Years (Flat) Included Included 

1 Year Included Included 

3 Years Included 

5 Years Included 

For the analysis for each of these cases, NHTSA makes several assumptions. For the fuel 

savings part of the equation, as shown in the table, we assumed that the average purchaser 

considers the fuel savings they would receive over a 1, 3, or 5 year timeframe. The present 

values of these savings were calculated using a 3 and 7 percent discount rate. We used a fuel 

price forecast that included taxes, because this is what consumers must pay. Fuel savings were 

calculated over the first 1, 3, or 5 years and discounted back to a present value. 

The agency believes that consumers may consider several other factors over the 5 year horizon 

when contemplating the purchase of a new vehicle. The agency added some of these factors into 

the calculation to represent how an increase in technology costs might affect consumers’ buying 

considerations. 
                                                      

830 

First, consumers might consider the sales taxes they have to pay at the time of purchasing the 

vehicle. As these costs are transfer payments, they are not included in the societal cost of the 

program, but they are included as one of the increased costs to the consumer for these standards. 

We took the most recent auto sales tax by state392 and weighted them by population by state to 

determine a national weighted-average sales tax of 5.46 percent (hereafter rounded to 5.5 percent 

in the discussion). NHTSA sought to weight sales taxes by new vehicle sales by state; however, 

such data were unavailable. NHTSA recognizes that for this purpose, new vehicle sales by state 

is a superior weighting mechanism to Census population; in an effort to approximate new vehicle 

sales by state NHTSA studied the change in new vehicle registrations (using R.L. Polk data) by 

state across recent years and developed a corresponding set of weights. The resulting national 

weighted-average sales tax rate was almost identical to that resulting from the use of Census 

population estimates as weights, just slightly above 5.5 percent. NHTSA opted to utilize Census 

population rather than the registration-based proxy of new vehicle sales as the basis for 

computing this weighted average, as the end results were negligibly different and the analytical 

approach involving new vehicle registrations had not been as thoroughly reviewed. 

Second, we considered insurance costs over the 5 year period. More expensive vehicles will 

require more expensive collision and comprehensive (e.g., theft) car insurance. The increase in 

insurance costs is estimated from the average value of collision plus comprehensive insurance as 

a proportion of average new vehicle price. Collision plus comprehensive insurance is the portion 

of insurance costs that depend on vehicle value. A recent study by Quality Planning393 provides 

the average value of collision plus comprehensive insurance for new vehicles, in 2010$, is $521 

($396 of which is collision and $125 of which is comprehensive). The average consumer 

expenditure for a new passenger car in 2011, according to the Bureau of Economic Analysis was 

$24,572 and the average price of a new light truck was $31,721 in $2010.394 Using sales volumes 

from the Bureau, we determined an average passenger car and an average light truck price was 

$27,953 in $2010 dollars.395 Average prices and estimated sales volumes are needed because 

392 See http://www.factorywarrantylist.com/car-tax-by-state.html (last accessed August 1, 2012). Note that county, 

city, and other municipality-specific taxes were excluded from NHTSA’s weighted average, as the variation in 

locality taxes within states, lack of accessible documentation of locality rates, and difficulty in obtaining reliable sets 

of weights to apply to locality taxes complicates the ability to perform this analysis. Localities with relatively high
 

automobile sales taxes may have relatively fewer auto dealerships, as consumers would likely endeavor to purchase 

vehicles in areas with lower locality taxes. 

393 “During Recession, American Drivers Assumed More Risk to Reduce Auto Insurance Costs,” Quality Planning, 

March 2011. See https://www.qualityplanning.com/media/4312/110329%20tough%20times_f2.pdf (last accessed 

August 1, 2012). 

394 U.S. Department of Commerce, Bureau of Economic Analysis, Table 7.2.5S. Auto and Truck Unit Sales, 

Production, Inventories, Expenditures, and Price, Available at
 

http://www.bea.gov/itable/ (last accessed August 1, 2012) 395 http://www.bls.gov/cpi/cpid11av.pdf, Table 1A. Consumer Price Index for All Urban Consumers (CPI-U): U.S. 

city average, by expenditure category and commodity and service group, for new vehicles. (Last accessed August 1, 

2012) 
                                                      

 

 

 

 

831 

price elasticity is an estimate of how a percent increase in price396 affects the percent decrease in 

sales. Dividing the cost to insure a new vehicle by the average price of a new vehicle gives the 

proportion of comprehensive plus collision insurance as 1.86 percent of the price of a vehicle. As 

vehicles’ values decline with vehicle age, comprehensive and collision insurance premiums 

likewise decline. Data on the change in insurance premiums as a function of vehicle age are 

scarce; however, NHTSA utilized data from the aforementioned Quality Planning study that cite 

the cost to insure the average vehicle on the road today (average age 10.8 years)397 to enable a 

linear interpolation of the change in insurance premiums during the first 11 years of a typical 

vehicle’s life. Using this interpolation, as a percentage of the base vehicle price of $27,953, the 

cost of collision and comprehensive insurance in each of the first five years of a vehicle’s life is 

1.86 percent, 1.82 percent, 1.75 percent, 1.64 percent, and 1.50 percent, respectively, or 8.57 

percent in aggregate. Discounting that stream of insurance costs back to present value indicates 

that the present value of the component of insurance costs that vary with vehicle price is equal to 

8.0 percent of the vehicle’s price at a 3 percent discount rate. 

Third, we considered that 70 percent of new vehicle purchasers take out loans to finance their 

purchase.398 Using proprietary forecasts available from Global Insight, NHTSA developed an 

average of 48-month399 bank and auto finance company loan rates for years 2017 through 2025, 

which – when deflated by Global Insight’s corresponding forecasts of the CPI – is 5.16 percent. 

In the construction of this estimate, NHTSA assumed an equal distribution of bank and auto 

finance company loans – an assumption necessitated by the lack of data on the distribution of the 

volume of loans between the differing types of creditors. NHTSA opted to adjust future loan 

rates using the CPI rather than the GDP deflator as this analysis is intended to facilitate further 

analysis from the perspective of the consumer, for which the CPI is the preferred deflation factor. 

At these terms the average person taking a loan will pay 13.7 percent more (undiscounted) for 

their vehicle over the 5 years than a consumer paying cash for the vehicle at the time of 

purchase. Discounting future loan payments at a 3 percent discount rate, a consumer financing a 

vehicle purchase pays 5.43 percent more as opposed to an all cash purchase. Taking into account 

to make the total baseline price for MY 2017 $25,443 ($24,572 + $871), for light trucks $1,090 

was added to the average price of a MY 2011 light truck to make the total baseline price for MY 

396 When estimating the sales impact, the price of the vehicle was increased from these MY 2011 prices based on the 

costs of estimated safety and MY 2011-2016 fuel economy rules. See the cumulative impact section for an estimate 

of those costs. For passenger cars $871 was added to the average price of a MY 2011 passenger car to make the 

total baseline price for MY 2017 $25,443 ($24,572 + $871), for light trucks $1,090 was added to the average price 

of a MY 2011 light truck to make the total baseline price for MY 2017 $32,811 ($31,721 + $1,090). All of these 

values are in 2010 dollars. 

397 See https://www.polk.com/company/news/average_age_of_vehicles_reaches_record_high_according_to_polk 

(last accessed August 1, 2012). 

398 Bird, Colin. “Should I Pay Cash, Lease or Finance My New Car?” 

http://www.cars.com/go/advice/Story.jsp?section=fin&story=should-i-pay-cash&subject=loan-quickstart&referer=advice&aff=sacbee, July 12, 2011, citing CNW Marketing Research. (Last accessed August 1, 2012) 399 No projections were available for rates of loan terms of 60 months. NHTSA compared the historical difference 

of 48-month and 60-month loan rates and determined the 48-month rate to be a suitable proxy for the 60-month rate. 
 

                                                      

832 

2017 $32,811 ($31,721 + $1,090). All of these values are in 2010 dollars. Assuming that only 

70 percent of vehicle purchases are financed, the average consumer would pay 3.80 (=0.70 * 

5.43 percent) percent more than the retail price of a vehicle. 

Fourth, we considered the residual value (or resale value) of the vehicle after 5 years and 

expressed this as a percentage of the new vehicle price. If the price of the vehicle increases due 

to fuel economy technologies, the resale value of the vehicle will go up proportionately. The 

average resale price of a vehicle after 5 years is about 35 percent400 of the original purchase 

price. Discounting the residual value back 5 years using a 3 percent discount rate (=35 percent * 

.8755) gives an effective residual value of 30.64 percent. Note that added CAFE technology 

could also result in more expensive or more frequent repairs. However, we do not have data to 

verify the extent to which this would be a factor during the first 5 years of vehicle life. We add 

these four factors together. At a 3 percent discount rate, the consumer considers that he could get 

30.64 percent back upon resale in 5 years, but will pay 5.5 percent more for taxes, 8.0 percent 

more in insurance, and 5.1 percent more for loans, resulting in an 12.0 percent return on the 

increase in price for fuel economy technology (=30.6 percent - 5.5 percent - 8.0 percent - 5.1 

percent). Thus, the increase in price per vehicle would be multiplied by 0.88 (=1 - 0.12) before 

subtracting the fuel savings to determine the overall net consumer valuation of the increase of 

costs on this purchase decision. This process results in estimates of the payback period for MY 

2025 vehicles of 2 years for light trucks and 4 years for passenger cars at a 3 percent discount 

rate. For ease of presentation, we combine the impact on passenger car and light truck sales for 

the Preferred Alternative only for the combined 9 year period of 2017-2025, and we compare the 

sales impact for both the MY 2010 baseline and for the MY 2008 baseline at the 3 percent and 7 

percent discount rates. There is not a significant difference in sales impacts depending upon the 

baseline considered (2010 versus 2008) and the discount rate impact is predictable, with sales 

increasing to a lesser extent under a 7 percent discount rate than in the case of a 3 percent 

discount rate, since benefits are valued lower with a higher discount rate. 

400 Consumer Reports, August 2008, “What That Car Really Costs to Own,” Available at 

http://www.consumerreports.org/cro/cars/pricing/what-that-car-really-costs-to-own-4-08/overview/what-that-carreally-costs-to-own-ov.htm (last accessed August 1, 2012). 
 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

833 

Table VII-17 

Potential Sales Impact for Passenger Cars and Light Trucks 

Vehicles in Thousands 

Years Fuel Valued 

by Manufacturers 

Years Fuel 

Valued by 

Consumers 

MYs 2017-2025 Sales 

Impact in Thousands and 

in Percent of Total Sales 

(3% discount rate) 

(000’s) (%) 

MYs 2017-2025 Sales 

Impact in Thousands and 

in Percent of Total Sales 

(7% discount rate) 

(000’s) (%) 

2008 Baseline 

0 Flat 3 yr. 911 0.6 757 0.5 

0 Flat 5 yr. 3,784 2.7 3,232 2.3 

1 yr. * 1 yr. * -2,696 -1.9 -2,322 -1.6 

1 yr. 3 yr. -360 -0.3 -445 -0.3 

3 yr. * 3 yr. * -530 -0.4 -542 -0.4 

5 yr. * 5 yr. * -3 -0.0 -36 -0.0 

2010 Baseline 

0 Flat 3 yr. 988 0.7 867 0.6 

0 Flat 5 yr. 3,804 2.7 3,261 2.3 

1 yr. * 1 yr. * -2,405 -1.7 -2,611 -1.8 

1 yr. 3 yr. -50 -0.0 -130 -0.1 

3 yr. * 3 yr. * -309 -0.2 -314 -0.2 

5 yr. * 5 yr. * 124 0.1 94 0.1 

* These scenarios are presented as theoretical cases. NHTSA believes it is unlikely that 

manufacturers and consumers would value improvements in fuel economy identically, 

and believes that on average, manufacturers will behave more conservatively in their 

assumptions of how consumers value fuel economy than how on average consumers will 

actually behave. NHTSA expects that in practice the number of years fuel is valued by 

manufacturers will be shorter than the number of years fuel is valued by consumers. 

What have commenters and other sources said in terms of potential sales impacts 

attributable to the final rule? 

A recent study on the effects on sales, attributable to NHTSA regulatory programs, including the 

fuel economy program was undertaken by the Center for Automotive Research (CAR).401 CAR 

examined the impacts of alternative fuel economy increases of 3%, 4%, 5%, and 6% per year on 

the outlook for the U.S. motor vehicle market, including the impacts of likely increases in costs 

401 “The U.S. Automotive Market and Industry in 2025,” Center for Automotive Research, June 2011, available at 

http://www.cargroup.org/assets/files/ami.pdf (last accessed August 1, 2012). 
834 

for increased fuel economy (based on the NAS report, which estimates higher costs than 

NHTSA’s current estimates) and required safety features. The CAR analysis also examined the 

technologies that would be used to achieve higher fuel economy, and how their production and 

use would affect the new vehicle market, production volumes, and automotive manufacturing 

employment in the year 2025. The required safety mandates were assumed to cost $1,500 per 

vehicle in 2025, but CAR did not evaluate the value of those safety mandates to consumers. Thus 

the CAR study cannot be compared to other studies, as it combines the cost of additional safety 

mandates along with costs for fuel economy improvements. The CAR study likely 

underestimates sales (that is, it overestimates the reduction in sales resulting from increased 

CAFE standards alone), as it assigns no value to consumers’ perceived values of additional 

safety features. In any case, unlike other analyses discussed in this final rule, sales changes 

shown cannot be solely attributed to the rulemaking. 

There are many factors that go into the CAR analysis of sales. CAR assumes a 22.0 mpg 

baseline, two gasoline price scenarios of $3.50 and $6.00 per gallon, VMT schedules by age, and 

a rebound rate of 10 percent (although it appears that the CAR report assumes a rebound effect 

even for the baseline and thus negates the impact of the rebound effect). Fuel savings are 

assumed to be valued by consumers over a 5 year period at a 10 percent discount rate. The 

impact on sales varies by scenario, the estimates of the cost of technology, the price of gasoline, 

etc. At $3.50 per gallon, the net change in consumer savings (costs minus the fuel savings valued 

by consumers) is a net cost to consumers of $359 for the 3% scenario, a net cost of $1,644 for the 

4% scenario, a net cost of $2,858 for the 5% scenario, and a net consumer cost of $6,525 for the 

6% scenario. At $6.00 per gallon, the net change in consumer savings (costs minus the fuel 

savings valued by consumers) is a net savings to consumers of $2,107 for the 3% scenario, a net 

savings of $1,131 for the 4% scenario, a net savings of $258 for the 5% scenario, and a net 

consumer cost of $3,051 for the 6% scenario. Thus, the price of gasoline can be a significant 

factor in affecting how consumers view whether they are getting value for their expenditures on 

technology. Table 14 on page 42 of the CAR report presents the results of their estimates of the 4 

alternative mpg scenarios and the 2 prices of gasoline on light vehicle sales and automotive 

employment. The table below shows these estimates. The baseline for the CAR report is 17.9 

million sales and 877,075 employees. The price of gasoline at $6.00 per gallon, rather than $3.50 

per gallon results in about 2.1 million additional sales per year and 100,000 more employees in 

year 2025. 

Table VII-18 CAR Report Estimates of 

Sales and Employment Impacts in 2025 

Gasoline at $3.50 

CAFE 

requirement of a 

3% increase in 

mpg per year 

CAFE 

requirement of a 

4% increase in 

mpg per year 

CAFE 

requirement of a 

5% increase in 

mpg per year 

CAFE 

requirement of a 

6% increase in 

mpg per year 
 

                                                      

835 

Sales (millions) 16.4 15.5 14.7 12.5 

Employment 803,548 757,700 717,626 612,567 

Gasoline at $6.00 

Sales 18.5 17.6 16.9 14.5 

Employment 903,135 861,739 826,950 711,538 

 Figure 13 on page 44 of the CAR report shows a graph of historical automotive labor 

productivity, indicating that there has been a long term 0.4 percent productivity growth rate from 

1960-2008, to indicate that there will be 12.26 vehicles produced in the U.S. per worker in 2025 

(which is higher than NHTSA’s estimate – see below). In addition, the CAR report discusses the 

jobs multiplier. For every one automotive manufacturing job, they estimate the economic 

contribution to the U.S. economy of 7.96 jobs402 stating “In 2010, about 1 million direct U.S. 

jobs were located at an auto and auto parts manufacturers; these jobs generated an additional 

1.966 million supplier jobs, largely in non-manufacturing sectors of the economy. The combined 

total of 2.966 jobs generated a further spin-off of 3.466 million jobs that depend on the consumer 

spending of direct and supplier employees, for a total jobs contribution from U.S. auto 

manufacturing of 6.432 million jobs in 2010. The figure actually rises to 7.96 million when 

direct jobs located at new vehicle dealerships (connected to the sale and service of new vehicles) 

are considered.” 

CAR uses econometric estimates of the sensitivity of new vehicle purchases to prices and 

consumer incomes and forecasts of income growth through 2025 to translate these estimated 

changes in net vehicle prices to estimates of changes in sales of MY 2025 vehicles; higher net 

prices – which occur when increases in vehicle prices exceeds the value of fuel savings – reduce 

vehicle sales, while lower net prices increase new vehicle sales in 2025. We do not have access 

to the statistical models that CAR develops to estimate the effects of price and income changes 

on vehicle sales. CAR’s analysis assumes continued increases in labor productivity over time and 

then translates the estimated impacts of higher CAFE standards on net vehicle prices into 

estimated impacts on sales and employment in the automobile production and related industries. 

The agency disagrees with the cost estimates in the CAR report for new technologies, the 

addition of safety mandates into the costs, and various other assumptions. Many commenters 

402 Kim Hill, Debbie Menk, and Adam Cooper, “Contribution of the Automotive Industry to the Economies of All 

Fifty States and the United States,” The Center for Automotive Research, Ann Arbor MI, April 2010. Available at 

http://www.cargroup.org/?module=Publications&event=View&pubID=16. Docket No. NHTSA-2010-0131. 
                                                      

 

836 

stated that they expected vehicle sales to increase as a result of the final rule, and cited an 

analysis conducted by Ceres and Citigroup Global Markets Inc.403 that examined the impact on 

automotive sales in 2020, with a baseline assumption of an industry fuel economy standard of 42 

mpg, a $4.00 price of gasoline, a 12.2 percent discount rate and an assumption that buyers value 

48% of fuel savings over seven years in purchasing vehicles. The main finding on sales was that 

light vehicle sales were predicted to increase by 6% from 16.3 million to 17.3 million in 2020. 

That analysis has subsequently been revised to predict a 4% increase from 15.8 million to 16.4 

million.404 Elasticity is not provided in the report but it states that they use a complex model of 

price elasticity and cross elasticities developed by GM. A fuel price risk factor405 was utilized. 

Little rationale was provided for the baseline assumptions, but sensitivity analyses were 

examined around the price of fuel ($2, $4, and $7 per gallon), the discount rate (5.2%, 12.2%, 

17.2%), purchasers consider fuel savings over (3, 7, or 15 years), fuel price risk factor of (30%, 

70%, or 140%), and VMT of (10,000, 15,000, and 20,000 in the first year and declining 

thereafter). 

The UAW, along with NRDC and the National Wildlife Foundation, also submitted reports 

indicating their assessment that the additional technology content needed to meet higher fuel 

economy standards would lead to considerable sales and employment growth. For example, the 

2010 UAW/NRDC/Center for American Progress study, “Driving Growth,” concluded that if 75 

percent of the additional content needed for the vehicle fleet to reach an average 40 mpg by 2020 

was produced in the U.S., as many as 150,000 jobs would be created.406 Similarly, the 2011 

UAW/NRDC/NWF study, “Supplying Ingenuity,” found that 504 facilities across 43 states 

employing over 500,000 people are devoted to researching, developing, or producing clean-car 

technologies, and that 67 percent of these jobs are related to advanced conventional technologies 

such as better engines and transmissions and components like electric power steering and high 

strength steel. 

Based on all of the above, what does NHTSA believe the likely impact on vehicle sales 

attributable to this final rule will be? 

403 “U.S. Autos, CAFE and GHG Emissions”, March 2011, Citi Ceres, UMTRI, Baum and Associates, Meszler 

Engineering Services, and the Natural Resources Defense Council, available at 

http://www.ceres.org/resources/reports/fuel-economy-focus (last accessed August 1, 2012) 404 “U.S. Autos, CAFE and GHG Emissions”, March 2011, Citi Ceres, UMTRI, Baum and Associates, Meszler 

Engineering Services, and the Natural Resources Defense Council, available at 

http://www.ceres.org/resources/reports/fuel-economy-focus (last accessed August 1, 2012) 405 Fuel price risk factor measures the rate at which consumers are willing to trade reductions in fuel costs for 

increases in purchase price. For example, a fuel price risk factor of 1.0 would indicate the consumers would be 

willing to pay $1 for an improvement in fuel economy that resulted in reducing by $1 the present value of the 

savings in fuel costs. 

406 UAW/NRDC/Center for American Progress, “Driving Growth: How Clean Cars and Climate Policy Can Create 

Jobs,” March 2010. NHTSA-2010-0131 
837 

While NHTSA conducted and considered a variety of vehicle sales “cases” as presented above, 

we do not believe that we can state with certainty that any given case is “correct” for the 

rulemaking timeframe. Given that this final rule affects multiple years, many years in the future, 

and that during that time there will be a dynamic situation occurring with dramatically changing 

fuel economy levels and technology being added to vehicles, we anticipate that consumers’ 

consideration of fuel economy will evolve over time. NHTSA believes that there is much 

uncertainty in how much consumers’ consideration of fuel economy will change as a result of 

this final rule alone, as compared to other rules such as the MYs 2012-2016 CAFE and GHG 

emissions rules and the Fuel Economy Labeling rule, or manufacturers’ marketing efforts. We 

anticipate that manufacturers will be tracking consumers’ behavior and marketing their products 

to affect consumer behavior, as they always have. We have made several simplifying 

assumptions in order to estimate the potential impact on sales, but as discussed above, there are 

uncertainties in how this final rule will affect sales and employment. We note, as is likely evident 

in the table above, that the impact on sales in this analysis is heavily impacted by the difference 

between manufacturers’ beliefs of how consumers value fuel savings and consumers’ valuation 

of fuel savings. 

This uncertainty, however, supports our conclusion in Section IV.F of the preamble that higher 

standards than the ones finalized in this rulemaking may not be economically practicable. The 

agency has tried to grapple with potential sales impacts as an important aspect of economic 

practicability, but reaching no definitive conclusion, believes that a conservative approach will 

be most likely to help us avoid setting standards that are beyond what would be economically 

practicable, and thus beyond the maximum feasible levels. NHTSA will monitor sales trends 

going forward, and anticipates that the intervening years between this final rule and the future 

rulemaking to develop and establish final standards for MYs 2022-2025 will provide significant 

additional insight into the questions of how consumers value fuel savings associated with 

increased fuel economy, how manufacturers believe consumers value that fuel savings, and 

corresponding effects on vehicle sales attributable to CAFE standards. 

As discussed elsewhere in the preamble and FRIA, the literature provides mixed evidence that 

consumers consistently value future fuel savings consistent with shorter payback periods and/or 

higher discount rate than the full lifetime value of fuel savings over the useful life of vehicles 

discounted as the social discount rates. That also provides an explanation for one of the potential 

reasons that manufacturers do not voluntarily provide all of the fuel saving technologies that are 

cost-effective and available, on a societal basis considered over the lifetime of the vehicle. In the 

past, consumers have not been willing to pay the additional price for such fuel economy 

improvements. One question is whether consumers will place a greater value on fuel savings as a 

result of this rule, and only as a result of this rule. In the past, large spikes in gasoline prices and 

consistently high gasoline prices have spurred consumers to consider fuel economy more 

prevalent in their purchasing decisions. The agency believes that the new and improved fuel 

economy labels and the large increase in fuel economy required as a result of the MY 2012-2016 
838 

fuel economy standards, may all have an impact on consumer valuation of fuel savings. 

However, these effects are not due to this rule. This final rule with its very large increase in 

average fuel economy, as well as manufacturers marketing these increased fuel economy levels, 

should also have a significant effect on consumers’ realization that fuel economy is changing 

rapidly and significantly. As a result, we believe consumers will pay more attention to fuel 

savings as a result of this final rule assuming that fuel prices do not decrease significantly, but 

there is uncertainty whether all sales impacts will be the result of this final rule alone. It is 

possible that consumers will not demand increased fuel economy even when such increases 

would reduce overall costs for them. Some vehicle owners may also react to persistently higher 

vehicle costs by owning fewer vehicles, and keeping existing vehicles in service for somewhat 

longer. For these consumers, the possibility exists that there may be permanent sales losses, 

compared with a situation in which vehicle prices are lower. There is a wide variety in the 

number of miles that owners drive per year. Some drivers only drive 5,000 miles per year and 

others drive 25,000 miles or more. Rationally those that drive many miles have more incentive to 

buy vehicles with high fuel economy levels. In summary, there are a variety of types of 

consumers that are in different financial situations and drive different mileages per year. Since 

consumers are different and use different reasoning in purchasing vehicles, and we do not yet 

have an account of the distribution of their preferences or how that may change over time as a 

result of this rulemaking, the answer is quite ambiguous. Some may be induced by better fuel 

economy to purchase vehicles more often to keep up with technology, some may purchase no 

new vehicles because of the increase in vehicle price, and some may purchase fewer vehicles and 

hold onto their vehicles longer. There is great uncertainty about how consumers value fuel 

economy, and for this reason, the impact of this fuel economy proposal on sales is uncertain. 

While it is difficult to determine how consumers will react to fuel economy improvements 

attributable to the final rule, we believe that it is likely that consumers will learn more about and 

increasingly value fuel economy improvements in the future, but we also believe that 

manufacturers and consumers are unlikely to place identical valuation on fuel economy 

benefits. We believe for the reasons discussed above that manufacturers will behave more 

conservatively in their assumptions of how consumers value fuel economy than how on average 

consumers will actually behave. 

Some commenters stated that sales will increase as a result of the rule, as evidenced above in the 

above discussion of comments from Ceres and the UAW. Others, including NADA, expressed 

concern that sales may fall. 

How does NHTSA plan to address this issue in the future? 

NHTSA is currently sponsoring work to develop a vehicle choice model for potential use in the 

agency’s future rulemaking analyses—this work may help to better estimate the market’s 
                                                      

 

839 

effective valuation of future fuel economy improvements. This rule did not rely on a vehicle 

choice model. With an integrated market share model, the CAFE model would estimate how the 

sales volumes of individual vehicle models would change in response to changes in fuel 

economy levels and prices throughout the light vehicle market, possibly taking into account 

interactions with the used vehicle market. Having done so, the model would replace the sales 

estimates in the original market forecast with those reflecting these model-estimated shifts, 

repeating the entire modeling cycle until converging on a stable solution. We sought comment on 

the potential for this approach to help the agency estimate sales effects. Several commenters 

wanted the agency to either have the vehicle choice model go through a full peer review (the 

Alliance) or to be provided for public comment and review (NRDC) before being used. There 

was wide disparity in the comments on the concept of using a vehicle choice model to estimate 

the impacts on sales. The Alliance supported the use of a vehicle choice model. The American 

Fuel and Petrochemical Manufacturers407 stated that it was concerned that the analysis is not 

based on a model that considered consumer choices and the impacts on different industries and 

individual that would be affected. The Natural Resources Defense Council (NRDC)408 and Union 

of Concerned Scientists (UCS)409 did not support the use of a consumer choice model and stated 

that the agencies should not rely on a highly uncertain and idealized consumer choice model. 

NRDC stated that a consumer choice model could only rely on stated or revealed preferences 

based on existing vehicles in the market place and such a model is inappropriate for standards 

that drive the use of new technology. In response, NHTSA agrees that further work on the 

vehicle choice model is necessary, and is continuing to develop it. Section IV.C.4 of the 

preamble discusses the current progress with the choice model and next steps, and we refer the 

reader there for more information. 

Potential Impact on Employment in the Automotive Industry in the Short Run 

There are three potential areas of employment in the automotive industry that fuel economy 

standards could affect.410 We briefly outline those areas here. 

1.	 The first is the hiring of additional engineers by automobile companies and their 

suppliers to do research and development and testing on new technologies to determine 

their capabilities, durability, platform introduction, etc. The agency anticipates that there 

may be some level of additional job creation due to the added research and development, 

overall program management, and subsequent sales efforts required to market vehicles 

that have been redesigned for significant improvements in fuel economy, especially for 

revolutionary technologies such as hybrid and electric vehicles. In this respect, the final 

407 See EPA Docket EPA-HQ-OAR-2010-0799-9485. 408 See EPA Docket EPA-HQ-OAR-2010-0799-0284. 409 Id. 410 For a general analysis of the potentially complex employment effects of regulation, see Morgenstern, Richard D., 

William A. Pizer, and Jhih-Shyang Shih. “Jobs Versus the Environment: An Industry-Level Perspective.” Journal 

of Environmental Economics and Management 43 (2002): 412-436 (Docket EPA-HQ-OAR-2010-0799). 
                                                      

 

840 

rule will likely have a positive effect on employment. At the same time, the levels of 

added employment are uncertain. In addition, it is not clear how much of this effort will 

be accomplished by added employment and how much by diverting existing employees 

to focus on CAFE instead of other company priorities such as improved acceleration 

performance, styling, marketing, new vehicle concepts, etc. 

2.	 The second area is the impact that new technologies would have on production 

employment, both at suppliers and at auto assemblers. Added parts, like turbochargers, or 

complexity of assembly could have a positive impact on employment. The use of more 

exotic steels, aluminum, or other materials to save weight could affect the number of 

welds or attachment methods It is uncertain to what extent new CAFE technologies 

would require added steps in the assembly process that would necessitate new hiring, but 

generally when content is added, the number of employees in the supplier industry and on 

the assembly line goes up. 

3.	 The third area is the potential impact that sales gains or losses could have on production 

employment. This area is potentially much more sensitive to change than the first two 

areas discussed above, although for reasons discussed above its estimation is highly 

uncertain. An increase in sales, produced for example by consumer attention to overall 

costs and learning over time, would have a positive effect on employment. A decrease in 

sales, produced by increases in initial costs, would have a negative effect. 

We received a number of comments (from the Defour Group and some private individuals) 

asserting that there will be decreases in employment as a result of the costs of the rule, and a 

number of comments (from the United Auto Workers, environmental organizations, sustainable 

business groups, some private individuals, and others) asserting increases in employment, based 

on the development of advanced technologies and the reduction in net costs due to fuel savings. 

An assessment by the Defour Group predicts a loss of 155,000 jobs in manufacturing and supply, 

plus another 50,000 in distribution.411 A study by Ceres predicts job gains of 43,000 in the auto 

industry and 484,000 economy-wide.412 Some comments cite a study by the Natural Resources 

Defense Council, National Wildlife Federation, and United Auto Workers that 150,000 auto 

workers already are working to supply clean, fuel-efficient technologies.413 The differences in 

results for quantitative employment impacts are mainly due to difference in the price impacts. 

Estimates of decreases in employment commonly come from studies that use cost estimates 

higher than those estimated by the agencies, and sometimes lower benefits estimates, resulting in 

411 Walton, Thomas F., and Dean Drake, Defour Group LLC (February 13, 2012). “Comments on the Notice of
 

Proposed Rulemaking and Preliminary Regulatory Impact Analysis for MY 2017 to 2025 Fuel Economy Standards.” 

Docket EPA-HQ-OAR-2010-0799-9319.
 412 Management Information Services, Inc. (July 2011). “More Jobs per Gallon: How Strong Fuel Economy/GHG
 

Standards Will Fuel American Jobs.” Boston, MA: Ceres. Docket EPA-HQ-OAR-2010-0799-0709.
 413 Natural Resources Defense Council, National Wildlife Federation, and United Auto Workers (August 2011). 

“Supplying Ingenuity: U.S. Suppliers of Clean, Fuel-Efficient Vehicle Technologies,” available at 

http://www.nrdc.org/transportation/autosuppliers/files/SupplierMappingReport.pdf (last accessed August 1, 2012). 

(Docket EPA-HQ-OAR-2010-0799)
 
                                                      

841 

reductions in vehicle sales. For instance, some comments from individuals cite the National 

Automobile Dealers Association and Center for Automotive Research for cost estimates of 

$5,000 to $6,000 per vehicle, much higher than those estimated by the agencies. Those studies 

commonly look at the employment associated with vehicle sales, but not the employment 

associated with producing the technologies needed to comply with the standards, or changes in 

labor intensity of production. Analyses that find increases in employment commonly start with 

increased vehicle sales as a result of the rule. Many of these analyses also note that even without 

increased unit sales, employment is likely to rise due to the additional technology content of the 

vehicles sold.414 In both cases, “multiplier” effects, which extend employment impacts beyond 

the auto sector to impacts on suppliers, other sectors, and expenditure changes by workers, lead 

to large estimates, either positive or negative, of the employment effects of the rule. We received 

the suggestion to include in our analysis an alternative scenario where there is less than full 

employment; the implication of less than full employment is that multiplier effects are more 

likely. While we examined all of these different employment estimates, we decided to continue 

using our methodology from previous analyses, with some updates to our method of calculating 

the impacts. 

In order to obtain an estimate of potential job increases per unit sales increase, we examined 

recent U.S. employment (original equipment manufacturers and suppliers) and U.S. production. 

Total employment in 2000 reached a peak in the Motor Vehicle and Parts Manufacturing sector 

of the economy averaging 1,313,500 workers (NAICS codes of 3361, 2, 3). Then there was a 

steady decline to 1,096,900 in 2006 and more rapid decreases in 2008, and 2009. Employment in 

2009 averaged 664,000, employment in 2010 averaged 675,000 and employment in the first six 

months of 2011 has averaged 699,000. Table VII-19 shows how many vehicles are produced by 

the average worker in the industry. Averaging the information shown for the even years of 2000­

2010, the average U.S. domestic employee produces 11.3 vehicles (the same number as in 2008 

and 2010). Thus, assuming that a projected sales gain or loss divided by 11.3 would be one 

method of estimating the potential employment gain or loss in any one year. This provides a 

measurement in job years. This method underestimates the number of jobs per vehicle sold under 

the rule, because it does not take into account the additional employment associated with the 

additional fuel-saving technologies. 

We also examined the employment impact for production and non-supervisory workers from the 

Bureau of Labor Statistics to see if there was a more direct link between their employment level 

and production than the white collar workers. There is a closer link between light vehicle 

production in the U.S. and the number of production and non-supervisory workers (for example, 

from 2002 to 2010, production fell by 44 percent; the number of production and non-supervisory 

workers in the industry fell by 44 percent and the number of white collar workers fell by 31 

414 UAW/NRDC/Center for American Progress, “Driving Growth: How Clean Cars and Climate Policy Can 

Create Jobs,” March 2010, p.11 
 

842 

percent). However, in some years (2004 and 2006) the white-collar jobs had a higher percentage 

loss than the blue-collar jobs. In this analysis, the agency examines all jobs in the industry. 
 

                                                      

843 

Table VII-19 

U.S. Light Duty Vehicle Production and Employment 

U.S. Light Vehicle 

Production 

Motor Vehicle and 

Parts U.S. 

Employment415 

Production per 

Employee 

2000 12,773,714 1,313,500 9.7 

2002 13,568,385 1,151,300 11.8 

2004 13,527,309 1,112,700 12.2 

2006 12,855,845 1,069,800 11.7 

2008 9,870,473 875,400 11.3 

2010 7,597,147 674,600 11.3 

Total/Average 70,192,873 6,197,300 11.3 

The Administration projects that full employment will return in 2018.416 When the economy is at 

full employment, a fuel economy regulation is unlikely to have much impact on net overall U.S. 

employment; instead, labor would primarily be shifted from one sector to another. These shifts in 

employment impose an opportunity cost on society, approximated by the wages of the 

employees, as regulation diverts workers from other activities in the economy. In this situation, 

any effects on net employment are likely to be transitory as workers change jobs (e.g., some 

workers may need to be retrained or require time to search for new jobs, while shortages in some 

sectors or regions could bid up wages to attract workers). On the other hand, if a regulation 

comes into effect during a period of high unemployment, a change in labor demand due to 

regulation may affect net overall U.S. employment because the labor market is not in 

equilibrium. Schmalansee and Stavins point out that net positive employment effects are 

possible in the near term when the economy is at less than full employment due to the potential 

hiring of idle labor resources by the regulated sector to meet new requirements (e.g., to install 

new equipment) and new economic activity in sectors related to the regulated sector longer run, 

the net effect on employment is more difficult to predict and will depend on the way in which the 

related industries respond to the regulatory requirements. This program is expected to affect 

employment in the regulated sector (auto manufacturing) and other sectors directly affected by 

the final rule: auto parts suppliers, auto dealers, the fuel supply market (which will face reduced 

petroleum production due to reduced fuel demand but which may see additional demand for 

electricity or other fuels). As discussed in the CAR and Ceres reports above, each of these 

415 U.S. employment data is from the Bureau of Labor Statistics, available at 

http://data.bls.gov/timeseries/CES3133600101?data_tool=XGtable (last accessed Aug. 10, 2012) 416 Based on the Congressional Budget Office January 2012 Report, “The Budget and Economic Outlook, Fiscal 

Years 2012-2022,” which predicted unemployment levels of 5.5% in 2018. See 

http://www.cbo.gov/publication/42905 (last accessed Aug. 10, 2012) 
 

                                                      

 

844 

sectors could potentially have ripple effects throughout the rest of the economy. These ripple 

effects depend much more heavily on the state of the economy than do the direct effects. As 

noted above, though, in a full-employment economy, any changes in employment will result 

from people changing jobs or voluntarily entering or exiting the workforce. In a full-employment 

economy, employment impacts of this proposal will change employment in specific sectors, but 

it will have small, if any, effect on aggregate employment. 

This rule would take effect in 2017 through 2025; by then, the current high unemployment may 

be moderated or ended. The Congressional Budget Office has predicted full employment by 

2018.417 To the extent that full employment is achieved, increases in employment are not 

possible. For that reason, this analysis does not include multiplier effects, but instead focuses on 

employment impacts in the most directly affected industries. Those sectors are likely to face the 

most concentrated employment impacts. 

Table VII-20 shows the potential cumulative impact on auto sector employment over the MY 

2017-2025 period in job years, without considering or quantifying the ripple effect. This table 

takes the results from sales and divides by 11.3 to obtain the impact on auto sector employment. 

To estimate the proportion of domestic employment affected by the change in sales, we use data 

from Ward’s Automotive Group for total car and truck production in the U.S. compared to total 

car and truck sales in the U.S. For the period 2001-2010, the proportion is 66.7 percent. We thus 

weight sales by this factor to get an estimate of the effect on U.S. employment in the motor 

vehicle manufacturing sector due to this rule. As in the sales analysis, the table shows the 

potential impact for the preferred alternative for both the MY 2010 baseline and for the MY 2008 

baseline at the 3 percent and 7 percent discount rates for 6 different cases. 

Since the impact of this final rule on sales is very difficult to predict, and sales have the largest 

potential effect on employment, the impact of this final rule on employment is also very difficult 

to predict. As with sales, the impact on employment is heavily affected by the difference 

between manufacturers’ investments in fuel-saving technologies418 and consumers’ valuation of 

fuel savings. However, since any negative impact of the rule on unit sales is partially offset by 

increased employment per vehicle sold, it is highly unlikely that the rule would lead to 

significant job losses in the short term in the automotive industry. 

417 Based on the Congressional Budget Office January 2012 Report, “The Budget and Economic Outlook, Fiscal 

Years 2012-2022,” which predicted unemployment levels of 5.5% in 2018. See 

http://www.cbo.gov/publication/42905 (last accessed Aug. 10, 2012). 418 As discussed above, these investments are affected both by manufacturers’ beliefs about consumers’ 

valuation of fuel economy, and by competitive dynamics, since the industry is composed of multiple firms, each of 

which considers the case where a competitor that doesn’t invest ends up in a better position due to gas prices at the 

low end of the expected distribution. 
 

                                                      

 

 

845 

Table VII-20 

Analysis of Alternative Scenarios in Automotive Sector Employment419 (in Thousands of Job 

Years Over the 9-Year Period 2017-2025) 

Passenger Cars and Light Trucks Combined 

Preferred Alternative
 

Years Fuel Valued 

by Manufacturers 

Years Fuel 

Valued by 

Consumers 

MYs 2017-2025 

Employment Impact (3% 

discount rate) (000’s) 

MYs 2017-2025 

Employment Impact (7% 

discount rate) (000’s) 

2008 Baseline 

0 Flat 3 yr. 54 45 

0 Flat 5 yr. 223 191 

1 yr. * 1 yr. * -160 -138 

1 yr. 3 yr. -21 -26 

3 yr. * 3 yr. * -31 -32 

5 yr. * 5 yr. * 0 -2 

2010 Baseline 

0 Flat 3 yr. 59 51 

0 Flat 5 yr. 225 193 

1 yr. * 1 yr. * -143 -155 

1 yr. 3 yr. -3 -8 

3 yr. * 3 yr. * -18 -19 

5 yr. * 5 yr. * 7 6 

* These scenarios are presented as theoretical cases. NHTSA believes it is unlikely that 

manufacturers and consumers would value improvements in fuel economy identically, 

and believes that on average, manufacturers will behave more conservatively in their 

assumptions of how consumers value fuel economy than how on average consumers will 

actually behave. NHTSA expects that in practice the number of years fuel is valued by 

manufacturers will be shorter than the number of years fuel is valued by consumers. 

Scrappage Rates 

The effect of this rule on the use and scrappage of older vehicles will be related to its effects on 

new vehicle prices, the fuel efficiency of new vehicle models, and the total sales of new 

vehicles. If the value of fuel savings resulting from improved fuel efficiency to the typical 

potential buyer of a new vehicle outweighs the average increase in new models’ prices, sales of 

new vehicles will rise, while scrappage rates of used vehicles will increase slightly. This will 

419 The analysis does not reflect the likely positive impact in industry employment due to a change in vehicle content 

resulting from this rule. 
 

846 

cause the “turnover” of the vehicle fleet – that is, the retirement of used vehicles and their 

replacement by new models – to accelerate slightly, thus accentuating the anticipated effect of 

the rule on fleet-wide fuel consumption and CO2 emissions. However, if potential buyers value 

future fuel savings resulting from the increased fuel efficiency of new models at less than the 

increase in their average selling price, sales of new vehicles will decline, as will the rate at which 

used vehicles are retired from service. This effect will slow the replacement of used vehicles by 

new models, and thus partly offset the anticipated effects of the final rules on fuel use and 

emissions. 

Because the agencies are uncertain about how the value of projected fuel savings from the final 

rules to potential buyers will compare to their estimates of increases in new vehicle prices, we 

have not attempted to estimate explicitly the effects of the rule on scrappage of older vehicles 

and the turnover of the vehicle fleet. 
                                                       

 

847 

VIII. BENEFITS FROM IMPROVED FUEL ECONOMY 

A. Accounting for the Fuel Economy Rebound Effect 

The rebound effect refers to the increase in vehicle use that results when an increase in fuel 

efficiency lowers the cost of driving, which encourages people to drive slightly more. Because 

this additional driving consumes fuel and produces emissions, it results in smaller fuel savings 

and reductions in emissions than would otherwise be expected to result from the standards 

established by this rulemaking. Thus the magnitude of the rebound effect is an important 

determinant of the actual fuel savings and emission reductions that are likely to result from 

adopting stricter fuel economy or emissions standards, and is an important parameter affecting 

EPA’s and NHTSA’s evaluation of the final standards for MY 2017-25 cars and light trucks. 

Ideally, the rebound effect is measured directly by estimating the change in vehicle use, during 

some time period that results from a change in vehicle fuel efficiency.420 Because data on 

vehicle use and fuel efficiency for the same sample of vehicles or time periods are rarely 

available, however, the rebound effect is often measured by analyzing the response of vehicle 

use to variation in fuel cost per mile driven, which depends on both vehicle fuel efficiency and 

fuel prices.421 Other studies estimate the response of vehicle use or fuel consumption to variation 

in the price per gallon of gasoline, but these provide only limited guidance about the magnitude 

of the fuel economy rebound effect. 

When expressed as a positive percentage, the elasticity of vehicle use with respect to fuel 

efficiency or fuel cost per mile driven expresses the percentage increase in vehicle use that 

results from a one percent increase in fuel efficiency or reduction in fuel cost per mile. For 

example, a 10 percent rebound effect means that a 20 percent increase in fuel efficiency or 

reduction in fuel cost per mile is expected to result in a 2 percent increase in VMT. The rebound 

effect also measures the fraction of fuel savings that would otherwise be expected to result from 

an increase in fuel efficiency, but is offset by increased vehicle use. 

The fuel economy rebound effect for light-duty vehicles has been the subject of extensive 

research since the early 1980s. Although these studies have reported a wide range of estimates 

of its exact magnitude, they generally conclude that a significant rebound effect occurs when fuel 

420 Vehicle fuel efficiency is more often measured in terms of fuel consumption (gallons per mile) rather than fuel 

economy (miles per gallon) in rebound estimates. 

421 Fuel cost per mile is equal to the price of fuel in dollars per gallon divided by fuel economy in miles per gallon 

(or multiplied by fuel consumption in gallons per mile), so this figure declines when a vehicle’s fuel efficiency 

increases. 
                                                      

 

 

 

848 

efficiency improves or the cost per mile of driving decreases.422 The most common approach to 

estimating its magnitude has been to analyze household survey data on vehicle use, fuel 

efficiency or consumption, fuel prices, and other variables that influence travel behavior. Other 

studies have used annual data on vehicle use, fuel prices, fuel economy, and other factors 

affecting motor vehicle travel for the U.S. as a whole, or combined such data for individual 

states, to estimate the rebound effect.423 The following sections review these previous studies 

and summarize recent work on the rebound effect, and explain the basis for the 10 percent 

rebound effect EPA and NHTSA use in this rulemaking. Because of changes in available 

measures and data limitations, most studies of the rebound effect rely on data drawn from the 

period from 1966 through approximately the year 2000. While some older studies provide 

valuable information on the potential magnitude of the rebound effect, those that include more 

recent information may provide more reliable estimates of how this rule will affect future driving 

behavior. 

Summary of Past Research on the Rebound Effect 

To provide a more comprehensive overview of previous estimates of the rebound effect, EPA 

and NHTSA reviewed 27 studies of the rebound effect conducted from 1983 through 2011. The 

agencies then performed a detailed analysis of the 87 separate estimates of the long-run rebound 

effect reported in these studies, which is summarized in Table VIII-1 below.424 As the table 

indicates, estimates of the long-run rebound effect range from as low as 6 percent to as high as 

75 percent, with a mean value of 22 percent. Limiting the sample to estimates reported in 

published studies of the rebound effect narrows their range and increases their mean estimate 

slightly. 

422 Some studies estimate that the long-run rebound effect is significantly larger than the immediate response to 

increased fuel efficiency. Although their estimates of the adjustment period required for the rebound effect to reach 

its long-run magnitude vary, this long-run effect could be more appropriate for evaluating the fuel savings and 

emissions reductions resulting from stricter standards that would apply throughout the lifetime of future model year 

vehicles. 

423 In effect, these studies treat U.S. states as a data “panel” by applying appropriate estimation procedures to data 

consisting of each year’s average values of these variables for the separate states. 

424 In some cases, NHTSA derived estimates of the overall rebound effect from more detailed results reported in the 

studies. For example, where studies estimated different rebound effects for households owning different numbers 

of vehicles but did not report an overall value, the agency computed a weighted average of the reported values using 

the distribution of households among vehicle ownership categories. 
 

 

 

 

 

 

 

 

 

849 

Table VIII-1
 

Summary Statistics for Estimates of the Rebound Effect 

Category 

Number 

of 

Studies 

Number 

of 

Estimates 

Range Distribution 

Low High Median Mean Std. 

Deviation 

All Estimates 27 87 6% 75% 19% 22% 13% 

Published Estimates 20 68 7% 75% 19% 23% 13% 

Authors' Preferred Estimates 20 20 9% 75% 22% 22% 15% 

U.S. Time-Series Estimates 7 34 7% 45% 14% 18% 9% 

Household Survey Estimates 17 38 6% 75% 22% 25% 15% 

Pooled U.S. State Estimates 3 15 8% 58% 22% 23% 12% 

Constant Rebound Effect 18 48 6% 75% 16% 22% 15% 

Variable Rebound Effect: 

Reported Estimates 

 Updated to Current Conditions 

12 

12 

37 

37 

10% 

7% 

45% 

56% 

20% 

16% 

22% 

19% 

9%

12% 
                                                      

850 

Table VIII-1 shows that the type of data used to estimate the rebound effect has an important 

effect on its estimated magnitude. While studies using national and state data on aggregate 

vehicle use have found relatively consistent long-run estimates of the rebound effect, household 

surveys display more variability. The 34 estimates derived from analysis of U.S. aggregate timeseries data produce a mean estimate of 18 percent for the long-run rebound effect, while the 

mean of 15 estimates based on state data is somewhat higher (23 percent). A recurring problem 

with studies that use national or state-level aggregate data on vehicle use is that their measures of 

fuel efficiency are invariably constructed from data on aggregate fuel consumption and the same 

aggregate vehicle use measure used as their dependent variables. This means that their measures 

of fuel efficiency are mathematically related to their dependent variables, and that the usual 

statistical techniques for minimizing the effect of such joint causality cannot be fully effective. 

At the same time, their measures of aggregate VMT and average fuel economy reflect the 

shifting of travel among vehicles with different fuel economy levels during the time period 

(usually a year) they span, which means that both variables already incorporate the effect the 

model is attempting to measure. For these reasons, estimates of the rebound effect based on 

national or state aggregate VMT data need to be interpreted cautiously. 

In contrast, the mean of 38 estimates based on household survey data is slightly larger than those 

based on national and state aggregate data, and there is wider variation in survey-based 

estimates. There are several possible explanations for this wider variability in estimates based on 

survey data. One explanation is that some of these studies do not include vehicle age as an 

explanatory variable, so any correlation between vehicle age and fuel efficiency may cause their 

estimates of the latter’s effect to be less reliable. Another explanation is that most of these 

studies find that the magnitude of the rebound effect differs according to the number of vehicles 

a household owns, and the average number of vehicles owned per household differs among the 

surveys used to derive these estimates. Still another possibility is that it some of these studies 

cannot distinguish the impact of residential location on vehicle use from that of fuel prices, since 

households that reside in urban areas are likely to face slightly higher fuel prices. 

Another important distinction among studies of the rebound effect is whether they assume that 

the effect is constant, or varies over time in response to changes in fuel costs, personal income, 

or vehicle ownership levels. Most studies using aggregate annual data for the U.S. assume a 

constant rebound effect, although some of these studies test whether the effect can vary as 

changes in retail fuel prices or average fuel efficiency alter fuel cost per mile driven. Many 

studies using household survey data estimate significantly different rebound effects for 

households owning varying numbers of vehicles, with most finding that the rebound effect is 

larger among households that own more vehicles.425 Finally, one recent study using state-level 

425 Six of the household survey studies evaluated in Table VIII-1 found that the rebound effect varies in relation to 

the number of household vehicles. Of those six studies, four found that the rebound effect rises with higher vehicle 

ownership, and two found that it declines. 
                                                      

 

 

 

 

 

 

851 

data concludes that the rebound effect varies directly in response to changes in personal income 

and the degree of urbanization of U.S. cities, as well as fuel costs. As Table VIII-1 shows, the 48 

estimates assuming a constant rebound effect produce a mean of 22 percent, identical to that of 

the 37 estimates reported in studies that allowed the rebound effect to vary in response to fuel 

prices, vehicle ownership, or household income. When they are updated to reflect current fuel 

prices, income levels, and patterns of automobile ownership, estimates from studies allowing the 

rebound effect to vary average 19 percent. 

More Recent Research on the Rebound Effect 

Some recent studies indicate that the rebound effect has decreased over time as incomes have 

increased and (until recently) fuel costs as a share of total travel costs have declined.426 One 

reason the rebound effect might vary over time is that the responsiveness of vehicle use to the 

fuel component of driving costs will be larger when it represents a larger proportion of the total 

cost of driving. Similarly, as incomes rise the sensitivity of vehicle use to changes in fuel costs 

may decrease if people view the cost of time spent driving – which is likely to be related to their 

income levels – as a larger component of the total cost. 

Small and Van Dender combined time series data for individual states to estimate the rebound 

effect, and used a specification that allowed its magnitude to vary in response to changes in fuel 

costs and income levels.427 For the time period from 1966-2001, their study found a long-run 

rebound effect of 22 percent, which is consistent with previously published studies. For the most 

recent five year period (1997-2001), however, their estimate of the long-run rebound effect 

declined to 11 percent. Furthermore, when these authors updated their estimate through 2004, 

the long-run rebound effect for the most recent five year period (2000-2004) declined further to 6 

percent.428 Finally, using their model to project the future rebound effect for the period 2010­

2030 produced estimates even below the 6 percent figure for a range of gasoline price and 

426 While real gasoline prices have varied over time, fuel costs (which reflect both fuel prices and fuel efficiency) as 

a share of total vehicle operating costs declined substantially from the mid-1970s until the mid-2000s when the share 

increased modestly (see Greene (2010)). Note that two studies discussed in this section, Small and Van Dender 

(2007) and Hymel, Small, and Van Dender (2010), find that the rebound effect is more strongly dependant on 

income than fuel costs. A third study, Greene (2010), did not directly test the effect of fuel cost on rebound, but 

found evidence supporting the strong effect from income. Although several studies have shown that the rebound 

effect rises with household vehicle ownership (see section 4.2.5.1), which generally increases with income, these 

findings indicate that income has had a negative effect on rebound. 

427 Small, K. and K. Van Dender, 2007a. “Fuel Efficiency and Motor Vehicle Travel: The Declining Rebound 

Effect”, The Energy Journal, vol. 28, no. 1, pp. 25-51. Available at 

http://www.socsci.uci.edu/~ksmall/Rebound_Working_Paper_corrected.pdf (last accessed August 1, 2012) 

428 Small, K. and K. Van Dender, 2007b. “Long Run Trends in Transport Demand, Fuel Price Elasticities and 

Implications of the Oil Outlook for Transport Policy,” OECD/ITF Joint Transport Research Centre Discussion 

Papers 2007/16, OECD, International Transport Forum. Available at http://trid.trb.org/view.aspx?id=868421 (last 

accessed August 1, 2012) 
                                                      

 

 

 

852 

income projections, although these projections extended well outside the range of historical 

experience over which it was estimated.429 More recently, Hymel extended the Small and Van 

Dender model to incorporate the effect of traffic congestion on vehicle use.430 While controlling 

for congestion increased their estimates of the rebound effect significantly, this more recent 

study also found that the rebound effect appeared to be declining over time. For the time period 

from 1966-2004, Hymel, Small, and Van Dender estimated a long-run rebound effect of 24 

percent, while for the year 2004 their estimate was 13 percent. 

Recent research conducted by Greene under contract to EPA lends further support the hypothesis 

that the magnitude of the rebound effect may be declining over time.431 Using national aggregate 

data on vehicle use for the period 1966-2007, Greene found that fuel prices had a statistically 

significant impact on VMT, yet increases in average fuel efficiency by themselves did not. 

Greene also tested Small and Van Dender’s specification allowing the elasticity of fuel cost per 

mile to decrease with increasing income, and confirmed their finding that the rebound effect 

appears to be declining over time. Using Greene’s preferred functional form, the projected 

rebound effect is approximately 12 percent in 2007, but declines to 10 percent in 2010 and 

further to 8 percent in 2030. Again, however, these forecasts extrapolate Greene’s results well 

outside the range of historical experience from which they were derived. 

More recent research provides conflicting evidence on the magnitude of the rebound effect. 

Bento et al. analyzed data on household vehicle ownership and use from the 2001 National 

Household Travel Survey using a complex model of household purchases, ownership, retirement, 

and use of both new and used vehicles.432 These authors estimated that the rebound effect varied 

widely among households owning different types and ages of automobiles and having different 

demographic characteristics, averaging 34 percent for all households. Gillingham used a large 

sample of vehicles registered in California and detailed estimates of local fuel prices to estimate 

elasticities of vehicle use with respect to gasoline prices and fuel economy. His estimate of the 

429 Report by Kenneth A. Small of University of California at Irvine to EPA, “The Rebound Effect from Fuel 

Efficiency Standards: Measurement and Projection to 2030”, June 12, 2009 (Docket EPA-HQ-OAR- 2010-0799­

0797). 

430 Hymel, Kent M., Kenneth A. Small, and Kurt Van Dender, “Induced demand and rebound effects in road 

transport,” Transportation Research Part B: Methodological, Volume 44, Issue 10, December 2010, Pages 1220­

1241, ISSN 0191-2615, DOI: 10.1016/j.trb.2010.02.007. 

431Greene, David, “Rebound 2007: Analysis of National Light-Duty Vehicle Travel Statistics,” March, 2010. 

Available at http://www.eurociss.eu/fileadmin/user_upload/Redaktion/Seco@home/nachhaltiger_Energiekonsum/Literatur/rebound_effekt/Green 

e_2010.pdf (last accessed August 1, 2012) 

432 Bento, Antonio M., Lawrence H. Goulder, Mark R. Jacobsen, and Roger H. von Haefen, “Distributional and 

Efficiency Impacts of Increased US Gasoline Taxes,” American Economic Review 99 (2009), pp. 1–37. For 

information on the 2001 National Household Travel Survey, see http://nhts.ornl.gov/introduction.shtml#2001 (last 

accessed July 17, 2012). 
 

 

                                                      

 

853 

former elasticity was -0.17, while his corresponding estimate of the elasticity of vehicle use with 

respect to fuel economy was 0.06.433 

West and Pickrell used a large sample of vehicles from the 2009 National Household Travel 

Survey to analyze vehicle use decisions among households that own multiple vehicles.434 

Controlling for vehicle type and age as well as for household characteristics and location, they 

estimated that the fuel economy rebound effect ranged from 0-9 percent among single-vehicle 

households, 10-26 percent among households owning two vehicles, and 26-34 percent among 

three-vehicle households. Most recently, Su435 used quantile regression analysis to analyze 

variation in the rebound effect among households included in the 2009 National Household 

Travel Survey. Su’s estimates of the rebound effect varied from 11 to 19 percent depending on 

the total number of miles driven annually by members of the household, with the smallest values 

applying to households at the extremes of the distribution of annual vehicle use, and the largest 

values to households in the middle of that distribution. 

Basis for Rebound Effect Used by EPA and NHTSA in this Rule 

As the preceding discussion indicates, estimates of the historical magnitude of the rebound effect 

and its projected future value diverge widely, and there is some evidence that the magnitude of 

the rebound effect appears to be declining over time. NHTSA requires a single point estimate 

for the rebound effect as an input to its central analysis, although a range of estimates can be 

used to test the sensitivity to uncertainty about its exact magnitude. Based on a combination of 

historical estimates of the rebound effect, more recent research, and evidence that its magnitude 

may be declining, NHTSA used a rebound effect of 10 percent to analyze the impacts of this 

final rule (i.e., we assume a 10 percent increase in fuel economy resulting from these standards 

would result in a 1 percent increase in VMT), with a range of 5-25 percent for NHTSA’s 

sensitivity testing. 

As Table VIII-1 indicates, the 10 percent estimate is toward the low end of the range reported in 

previous research, and also below many recent estimates of the rebound effect. However, other 

recent research – particularly that conducted by Hymel, Small and Van Dender, Small and Van 

Dender, and Greene – reports evidence that the magnitude of the rebound effect is declining over 

time. As a consequence, the agencies concluded that a value on the low end of the historical 

433 Gillingham, Kenneth. “The Consumer Response to Gasoline Price Changes: Empirical Evidence and Policy 

Implications.” Ph.D. diss., Stanford University, 2011. 

434 West, Rachel, and Don Pickrell, “Factors Affecting Vehicle Use in Multiple-Vehicle Households,” 

http://onlinepubs.trb.org/onlinepubs/conferences/2011/NHTS1/West.pdf (last accessed July 17, 2012). For 

information on the 2009 National Household Travel Survey, see http://nhts.ornl.gov/introduction.shtml (last 

accessed July 17, 2012).

435 Su, Qing, “A Quantile Regression Analysis of the Rebound Effect: Evidence from the 2009 National Household 

Transportation Survey in the United States,” Energy Policy 45 (2012), pp. 368-377. Available at 

http://www.sciencedirect.com/science/article/pii/S0301421512001620 (last accessed August 1, 2012) 
 

                                                      

 

854 

estimates reported in Table VIII-1 is likely to provide a more reliable estimate of its magnitude 

during the future period spanned by the lifetimes of the vehicles that are subject to this rule. The 

10 percent estimate lies within the 10-30 percent range of estimates for the historical rebound 

effect reported in most previous research, and at the upper end of the 5-10 percent range of 

estimates for the future rebound effect derived from recent studies by Small and Van Dender and 

by Greene. Thus the 10 percent value is not based on a single estimate drawn from particular 

studies, but instead represents a reasonable compromise between historical estimates of the 

rebound effect and forecasts of its projected future value. 

On-Road Fuel Economy Adjustment 

Actual fuel economy levels achieved by vehicles in on-road driving fall significantly short of 

their levels measured under the laboratory-like test conditions used by EPA to establish its 

published fuel economy ratings for different models. In analyzing the fuel savings from 

alternative passenger car and light truck CAFE standards, the agency adjusts the actual fuel 

economy performance of each passenger car and light truck model downward from its rated 

value to reflect the expected size of this on-road fuel economy “gap.” In December 2006, EPA 

adopted changes to its regulations on fuel economy labeling, which were intended to bring 

vehicles’ rated fuel economy levels closer to their actual on-road fuel economy levels.436 

Supplemental analysis reported by EPA as part of its Final Rule indicates that actual on-road fuel 

economy for light-duty vehicles averages 20 percent lower than published fuel economy 

levels.437 For example, if the overall EPA fuel economy rating of a light truck is 20 mpg, the onroad fuel economy actually achieved by a typical driver of that vehicle is expected to be 16 mpg 

(20*.80). The agency has employed EPA’s revised estimate of this on-road fuel economy gap in 

its analysis of the fuel savings resulting from alternative CAFE standards for MY 2017-2025 

passenger cars and light trucks. 

An analysis conducted by NHTSA confirmed that EPA’s estimate of a 20 percent gap between 

test and on-road fuel economy is well-founded. The agency used data on the number of 

passenger cars and light trucks of each model year that were in service (registered for use) during 

each calendar year from 2000 through 2006, average fuel economy for passenger cars and light 

trucks produced during each model year, and estimates of average miles driven per year by cars 

and light trucks of different ages during each calendar year over that period. These data were 

436 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy 

Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969, 

http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Day-27/a9749.pdf (last accessed on August 1, 2012). 437 EPA, Final Technical Support Document: Fuel Economy Labeling of Motor Vehicle Revisions to Improve 

Calculation of Fuel Economy Estimates, Office of Transportation and Air Quality EPA420-R-06-017 December 

2006, Chapter II, http://www.epa.gov/fueleconomy/420r06017.pdf (last accessed on August 1, 2012). 
 

 

                                                      

 

 

855 

combined to develop estimates of the usage-weighted average fuel economy that the U.S. 

passenger car and light truck fleets would have achieved during each year from 2000 through 

2006 under test conditions. 

B. Benefits to Vehicle Buyers from Improving Fuel Economy 

The main source of economic benefits from raising CAFE standards is the value of the resulting 

fuel savings over the lifetimes of vehicles that are required to achieve higher fuel economy. The 

annual fuel savings under each alternative CAFE standard are measured by the difference 

between total annual fuel consumption by passenger cars or light trucks with the fuel economy 

they are expected to achieve in on-road driving under that alternative standard, and their annual 

fuel consumption with the fuel economy levels – again adjusted for differences between test and 

actual on-road driving conditions – they would achieve under the baseline alternative. The sum 

of these discounted annual fuel savings over each calendar year that cars or light trucks produced 

during a model year are expected to remain in service represents their cumulative lifetime fuel 

savings with that alternative CAFE standard in effect. 

Vehicle Survival Rates 

These annual fuel savings depend on the number of vehicles that remain in use during each year 

of a model year’s lifetimes. The number of passenger cars or light trucks manufactured during a 

model year that remains in service during each subsequent calendar year is estimated by 

multiplying the original number expected to be produced during that model year by the 

proportion of vehicles expected to remain in service to the age they will have reached during that 

year. The proportions of passenger cars and light trucks expected to remain in service at each 

age up to their maximum lifetimes (30 and 37 years, respectively) are shown in Table VIII-2.438 

These “survival rates,” which are estimated from experience with recent model-year vehicles, are 

slightly different than the survival rates used in past NHTSA analyses, since they reflect recent 

increases in durability and usage of more recent passenger car and light truck models.439 

438 The maximum age of cars and light trucks was defined as the age when the number remaining in service declines 

below two percent of those originally produced. Based on an examination of recent registration data for previous 

model years, these maximum ages are 30 years for passenger cars and 37 years for light trucks. 439 The survival rates were calculated from R.L. Polk, National Vehicle Population Profile (NVPP), 1977-2010; see 

NHTSA, “Vehicle Survival and Travel Mileage Schedules,” Office of Regulatory Analysis and Evaluation, NCSA, 

January 2006, pp. 9-11, Docket No. 22223-2218, for a description of the methodology used. Polk’s NVPP is an 
 

                                                                                                                                                                              

 

 

856 

Vehicle Use 

Annual fuel savings during each year of a model year’s lifetime also depend on the number of 

miles that the remaining vehicles in use are driven. For the analysis supporting this final rule, 

NHTSA developed updated estimates of average annual miles driven by household vehicles at 

each age using the Federal Highway Administration’s 2009 National Household Transportation 

Survey (NHTS), which began in March 2008 and continued through April 2009. These updated 

estimates differ from those employed in previous NHTSA analyses, which were based on the 

previous 2001 NHTS.440 

The agency’s revised estimates of car and light truck use also differ from its previous estimates 

because they incorporate the number of fleet vehicles in service during 2008 and their average 

use, derived from various editions of the U.S. Energy Information Administration’s Annual 

Energy Outlook. Fleet vehicles, which include those purchased by corporations and government 

agencies for use by employees as well as rental vehicles, are driven more intensively than 

household vehicles. Thus incorporating their presence in the light-duty fleet and higher annual 

usage raises NHTSA’s estimates of vehicle use at low ages; however, fleet vehicles typically 

enter the used vehicle market and are purchased by households before reaching age 6, so 

including them does not change the estimates of vehicle use derived from the NHTS after that 

age. 

Table VIII-3 reports NHTSA’s updated estimates of average car and light truck use, not adjusted 

for vehicle survival rates. The estimated total number of miles driven by passenger cars or light 

trucks produced in a given model year over the course of the vehicles’ lifetimes is estimated by 

annual census of passenger cars and light trucks registered for on-road operation in the United States as of Jul 1 each 

year. NVPP registration data from vehicle model years 1977 to 2010 were used to develop the survival rates 

reported in Table VIII-2. Survival rates were averaged for the five most recent model years to reach each age up to 

30 years, and polynomial models were fitted to these data using regression analysis to develop smooth relationships 

between age and the proportion of cars or light trucks surviving to that age. 

440 See also NHTSA, “Vehicle Survival and Travel Mileage Schedules,” Office of Regulatory Analysis and 

Evaluation, January 2006, pp. 15-17 (Docket NHTSA-2009-0062-0012.1). The original source of information on 

annual use of passenger cars and light trucks by age used in this analysis is the 2001 National Household Travel 

Survey (NHTS), jointly sponsored by the Federal Highway Administration, Bureau of Transportation Statistics, and 

National Highway Traffic Safety Administration. A process similar to that described in this document was used to 

develop estimates of the average number of miles driven by household vehicles at each age using the sample of 

approximately 300,000 vehicles included in the 2009 National Household Travel Survey. 
                                                      

 

857 

multiplying these age-specific estimates of average car and light truck use by the number of 

vehicles projected to remain in service during that year. 

Applying the survival rates of Table VIII-2 to the age-dependent VMT estimates of Table VIII-3 

yields the survival-adjusted VMT projections shown in Table VIII-4. The VMT schedules 

shown in Tables VIII-3 and VIII-4 are specific to vehicles of MY 2017 and are intended to be 

illustrative of the VMT schedules in the analysis of this rule’s impact; however, VMT schedules 

vary by model year, for which further explanation and detail are provided in the subsequent 

section “adjusting vehicle use.” The sum of the survival-weighted mileage in Table VIII-4 over 

the 30-year maximum lifetime of MY 2017 passenger cars is 218,546 miles; over the 37-year 

maximum lifetime of light trucks, this value is 248,024 miles. Fuel savings and other benefits 

resulting from higher CAFE standards for passenger cars and light trucks are calculated over 

their respective lifetimes and total expected mileage. It should be noted, however, that survivalweighted mileage is extremely low (less than 1,000 miles per year) after age 22 for cars and after 

age 27 for light trucks, and thus has little impact on lifetime fuel savings or other benefits from 

higher fuel economy, particularly after discounting those benefits to their present values. 

In interpreting the survival and annual mileage estimates reported in Tables VIII-2, VIII-3, and 

VIII-4, it is important to understand that vehicles are considered to be of age 1 during the 

calendar year that coincides with their model year. For example, model year 2017 vehicles will 

be considered to be of age 1 during calendar year 2017. This convention is used in order to 

account for the fact that vehicles produced during a model year are typically first offered for sale 

in June through September of the preceding calendar year, depending on manufacturer). Thus 

virtually all of the vehicles produced during a model year will be in use for some or all of the 

calendar year coinciding with their model year, and they are considered to be of age 1 during that 

441 year.

441 As an illustration, virtually the entire production of model year 2017 cars and light trucks will have been sold by 

the end of calendar year 2017, so those vehicles are defined to be of age 1 during calendar year 2017. Model year 

2017 vehicles are subsequently defined to be of age 2 during calendar year 2018, age 3 during calendar year 2019, 

and so on. One complication arises because registration data are typically collected for July 1 of each calendar year, 

so not all vehicles produced during a model year will appear in registration data until the calendar year when they 

have reached age 2 (and sometimes age 3) under this convention. 
858 

Table VIII-2
 

Survival Rates by Vehicle Age 

for Passenger Cars and Light Trucks 

Vehicle Age 

Estimated Survival 

Fraction 

Passenger Cars 

Estimated Survival 

Fraction 

Light Trucks 

1 1.0000 1.0000 

2 0.9878 0.9776 

3 0.9766 0.9630 

4 0.9614 0.9428 

5 0.9450 0.9311 

6 0.9298 0.9152 

7 0.9113 0.8933 

8 0.8912 0.8700 

9 0.8689 0.8411 

10 0.8397 0.7963 

11 0.7999 0.7423 

12 0.7556 0.6916 

13 0.7055 0.6410 

14 0.6527 0.5833 

15 0.5946 0.5350 

16 0.5311 0.4861 

17 0.4585 0.4422 

18 0.3832 0.3976 

19 0.3077 0.3520 

20 0.2414 0.3092 

21 0.1833 0.2666 

22 0.1388 0.2278 

23 0.1066 0.2019 

24 0.0820 0.1750 

25 0.0629 0.1584 

26 0.0514 0.1452 

27 0.0420 0.1390 

28 0.0337 0.1250 

29 0.0281 0.1112 

30 0.0235 0.1028 

31 0.0933 

32 0.0835 

33 0.0731 

34 0.0619 

35 0.0502 

36 0.0384 

37 0.0273 
859 

Adjusting Vehicle Use 

The average number of miles driven by passenger cars and light trucks of each age varies from year to 

year in the Volpe model, in response to changes in the real price of gasoline. The reference year for 

determining baseline annual mileage by vehicle age and the accompanying price of gasoline is 2008, 

the year when most households participating in the 2009 National Household Travel Survey (NHTS) 

were interviewed. To account for the effect on vehicle use of subsequent increases in fuel prices, the 

estimates of annual vehicle use derived from the 2009 NHTS and EIA’s estimates of fleet vehicle use 

(as described above) were first adjusted to reflect the forecasts of gasoline prices for future years 

reported in the AEO 2012 Early Release. 

This adjustment accounts for the difference between the average price per gallon of fuel projected for 

each year over the expected lifetimes of model year 2017-2025 passenger cars and light trucks, and the 

average price that prevailed in 2008. The elasticity of annual vehicle use with respect to fuel cost per 

mile corresponding to the 10% fuel economy rebound effect used in this analysis (i.e., an elasticity of ­

0.10) was applied to the percent difference between each future year’s fuel prices and those prevailing 

in 2008 to adjust the estimates of vehicle use for that baseline year to reflect the effect of future 

changes in future fuel prices. 

In addition, the agency’s initial estimates of light-duty vehicles use (which include both household and 

fleet vehicles, as discussed above) are adjusted to account for differences in the fuel economy of 

vehicles in use during 2008 and projected fuel economy levels for future model years. For example, 

the fuel economy of cars and light trucks produced during model year 2017 is projected to be higher 

than those of the model years making up the light-duty vehicle fleet during 2008, even under the 

baseline alternative considered for this final rule (which assumes that the MY 2016 standard is 

extended to apply to subsequent model years). 

Thus the annual number of miles driven by MY 2017 cars and light trucks is projected to be higher at 

each age throughout their lifetimes than for vehicles of that same age in use during 2008. Again for 

example, MY 2017 light trucks are expected to be driven more in the year 2021, when they will have 

reached age five, than were MY 2004 light trucks during 2008, when they were also of age five. The 

magnitude of this adjustment depends on the difference between the (on-road) fuel economy projected 

for MY 2017 light trucks, and that achieved by MY 2004 light trucks, since the adjustment applies the 

10% fuel economy rebound effect to this difference. As a consequence, the magnitude of this 

adjustment differs for cars and light trucks produced during each model year from 2017 through 2025, 

and also varies each year of their projected lifetimes. Moreover, its magnitude differs among the 

regulatory alternatives evaluated for this final rule, because the fuel economy levels of MY 2017-25 

cars and light trucks differ among each of these alternatives. 
 

                                                      

 

 

860 

Finally, the estimates of annual miles driven by passenger cars and light trucks at each age were 

also adjusted to reflect projected future growth in average use of vehicles at all ages during their 

expected lifetimes. Increases in the average number of miles cars and trucks are driven each 

year have been an important source of historical growth in total car and light truck use, and are 

expected to represent an important source of future growth in total light-duty vehicle travel as 

well. As an illustration of the importance of growth in average vehicle use, the total number of 

miles driven by passenger cars increased 1.5 percent annually from 1985 through 2005, while the 

total number of cars registered for in the U.S. grew by only about 0.3 percent annually.442,443 

Further, the AEO 2012 Early Release Reference Case forecasts of total car and light truck use 

and of the number of cars and light trucks in use suggest that their average annual use will 

continue to increase gradually from 2010 through 2030. For this analysis, annual growth in 

vehicle miles traveled was assumed to average 0.6% per year annually. Thus in effect, there are 

a large number of VMT schedules used in the Volpe model, changing each year and changing by 

alternative because of the rebound effect. 

442 Calculated from data reported in FHWA, Highway Statistics, Table vm201in files “Summary to 1995”, and 

annual editions ranging from 1996 to 2005, available at http://www.fhwa.dot.gov/policy/ohpi/hss/hsspubs.cfm (last 

accessed August 1, 2012). 

443 A slight increase in the fraction of new passenger cars remaining in service beyond age 10 has accounted for a 

small share of growth in the U.S. automobile fleet. The fraction of new automobiles remaining in service to various 

ages was computed from R.L. Polk vehicle registration data for 1977 through 2005 by the agency’s Center for 

Statistical Analysis. 
861 

Table VIII-3
 

Example Rebound-Adjusted Annual Vehicle-Miles Traveled (VMT) 

by Age for MY 2017 Passenger Cars and Light Trucks 

Not Adjusted for Survival 

Vehicle Age Example VMT 

Passenger Cars 

Example VMT 

Light Trucks 

1 16,467 18,628 

2 16,323 18,396 

3 16,147 18,215 

4 15,890 17,930 

5 15,669 17,682 

6 15,397 17,287 

7 15,110 16,951 

8 14,809 16,489 

9 14,481 16,036 

10 14,175 15,602 

11 13,770 15,059 

12 13,437 14,634 

13 13,022 14,109 

14 12,647 13,622 

15 12,222 13,032 

16 11,800 12,513 

17 11,401 12,065 

18 11,016 11,580 

19 10,629 11,110 

20 10,221 10,703 

21 9,879 10,353 

22 9,602 10,138 

23 9,460 9,884 

24 9,171 9,878 

25 8,970 9,710 

26 8,769 9,728 

27 8,648 9,801 

28 8,501 9,850 

29 8,405 9,900 

30 8,365 9,949 

31 9,999 

32 10,049 

33 10,099 

34 10,150 

35 10,200 

36 10,251 

37 10,303 
862 

Table VIII-4
 

Example Rebound-Adjusted Annual Vehicle-Miles Traveled (VMT) 

by Age for MY 2017 Passenger Cars and Light Trucks 

Adjusted for Survival 

Vehicle Age Example VMT 

Passenger Cars 

Example VMT 

Light Trucks 

1 16,467 18,628 

2 16,125 17,983 

3 15,769 17,540 

4 15,277 16,904 

5 14,808 16,463 

6 14,316 15,821 

7 13,770 15,141 

8 13,198 14,345 

9 12,582 13,487 

10 11,903 12,423 

11 11,014 11,178 

12 10,153 10,120 

13 9,187 9,043 

14 8,254 7,946 

15 7,267 6,972 

16 6,267 6,083 

17 5,227 5,335 

18 4,221 4,604 

19 3,271 3,911 

20 2,467 3,309 

21 1,811 2,761 

22 1,332 2,309 

23 1,008 1,996 

24 752 1,729 

25 565 1,538 

26 451 1,413 

27 363 1,363 

28 286 1,231 

29 237 1,100 

30 197 1,023 

31 933 

32 839 

33 738 

34 628 

35 512 

36 394 

37 281 
                                                      

863 

Estimating Annual Fuel Consumption 

NHTSA estimated annual fuel consumption during each year of the expected lifetimes of model 

year 2017-2025 cars and light trucks with alternative CAFE standards in effect by dividing the 

total number of miles that a model year’s surviving vehicles are driven by the fuel economy that 

they are expected to achieve under each alternative standard.444 Lifetime fuel consumption by 

each model year’s cars and light trucks is the sum of the annual use by the vehicles produced 

during that model year that are projected to remain in service during each year of their expected 

lifetimes. In turn, the savings in lifetime fuel consumption by MY 2017-2025 cars and light 

trucks that would result from alternative increases in CAFE standards is the difference between 

their lifetime fuel use at the fuel economy level they are projected to attain under the baseline, 

and their lifetime fuel use at the higher fuel economy level they are projected to achieve under 

each alternative standard. 

NHTSA’s analysis values the economic benefits to vehicle owners and to the U.S. economy that 

result from future fuel savings over the full expected lifetimes of MY 2017-2025 passenger cars 

and light trucks. This reflects the agency’s assumption that while the purchasers of new vehicles 

might not realize the full lifetime benefits of improved fuel economy, subsequent owners of 

those vehicles will continue to experience the resulting fuel savings until they are retired from 

service. Of course, not all vehicles produced during a model year remain in service for the 

complete lifetimes (30 years for passenger cars or 37 years for light trucks) of each model year. 

Due to the pattern of vehicle retirements with increasing age, the expected or average lifetimes of 

typical representative cars and light trucks are approximately half of these figures. 

Economic Benefits from Reduced Fuel Consumption 

The economic value of fuel savings resulting from alternative CAFE standards is estimated by 

applying the Reference Case projections of future fuel prices from the Energy Information 

Administration’s Annual Energy Outlook 2012 Early Release to each future year’s estimated fuel 

savings. The AEO 2012 Early Release Reference Case projections of future fuel prices, which is 

reported in Table VIII-5a, represents retail prices per gallon of fuel, including federal, state, and 

any applicable local taxes. While the retail price of fuel is the proper measure for valuing fuel 

savings from the perspective of vehicle owners, two adjustments to the retail prices are necessary 

in order to accurately reflect the economic value of fuel savings to the U.S. economy. NHTSA 

utilizes AEO Reference Case fuel price projections in the impact analysis of each of the 

444 The total number of miles that vehicles are driven each year is slightly different under each alternative as a result 

of the fuel economy “rebound effect,” which is discussed in detail elsewhere in this chapter. 
                                                      

864 

alternative fuel economy scenarios examined; this approach implicitly assumes that the CAFE 

standards will have no impact on fuel prices. 

First, federal, state, and local taxes are excluded from the social value of fuel savings because 

these do not reflect costs of resources used in fuel production, and thus do not reflect resource 

savings that would result from reducing fuel consumption. Instead, fuel taxes simply represent 

resources that are transferred from purchasers of fuel to road and highway users, since fuel taxes 

primarily fund construction and maintenance of those facilities. Any reduction in local, state, or 

federal fuel tax payments by fuel purchasers will reduce government revenues by the same 

amount, thus ultimately reducing the value of government-financed services by approximately 

that same amount. The benefit derived from lower taxes to individuals is thus likely to be offset 

exactly by a reduction in the value of services funded using those tax revenues. 

Second, the economic cost of externalities generated by U.S. consumption and imports of 

petroleum products will be reduced in proportion to fuel savings resulting from higher CAFE 

standards. The estimated economic value of these externalities, which is discussed in detail in 

the subsequent section of this chapter, is converted into its per-gallon equivalent and added to the 

pre-tax price of gasoline in order to measure this additional benefit to society for each gallon of 

fuel saved. This also allows the magnitude of these externalities to be easily compared to the 

value of the resources saved by reducing fuel production and use, which represents the most 

important component of the social benefits from saving gasoline. 

Table VIII-5a illustrates the adjustment of projected retail fuel prices to remove the value of fuel 

taxes and add the value of economic externalities from petroleum imports and use. AEO 2012 

Early Release Reference Case fuel price projections are available through 2040; however, 

NHTSA’s analysis of the value of fuel savings over the lifetimes of MY 2017-2025 cars and 

light trucks requires fuel price projections beyond this horizon, as calendar year 2061 is the last 

year during which a significant number of MY 2025 vehicles are projected to remain in 

service.445 To obtain fuel price projections for the years 2041 through 2061, the agency assumes 

that retail fuel prices will continue to increase after 2040 at the average rates reported in the AEO 

2012 Early Release Reference Case projections over the period from 2010 through 2040 (in 

445 The agency defines the maximum lifetime of vehicles as the highest age at which more than 2 percent of those 

originally produced during a model year remain in service. In the case of light-duty trucks, this occurs at vehicle 

age of 37 years. 
 

                                                      

865 

constant-dollar terms).446 As Table VIII-5a shows, the projected retail price (including taxes) of 

gasoline expressed in 2010 dollars rises steadily over the projection period, from $3.43 in 2011 

to $5.81 in 2061. 

The agency has updated its estimates of gasoline taxes (all expressed in 2010 dollars) for federal 

taxes ($0.18 per gallon) state taxes ($0.22 per gallon), and local taxes ($0.02 per gallon), 

consistent with tax rates used by EIA in the AEO 2012 Early Release. NHTSA followed EIA’s 

assumptions that state and local gasoline taxes will keep pace with inflation in nominal terms, 

and thus remain at current levels when expressed in constant 2010 dollars. Federal gasoline 

taxes, however, are projected by EIA to remain unchanged in nominal terms, and thus decline 

throughout future years when expressed in constant 2010 dollars. NHTSA also incorporated this 

assumption in its projections. These differing assumptions about the likely future behavior of 

federal and state/local fuel taxes are consistent with recent historical experience, which reflects 

the fact that federal motor fuel taxes as well as most state and local fuel taxes are specified on a 

cents-per-gallon basis (some state taxes are levied as a percentage of the wholesale price of fuel), 

and typically require legislation to change. 

446 The average rate of growth is calculated as: ((AEO-forecasted 2040 fuel price)/(AEO 2010 fuel price))^(1/30), 

which yields an average growth rate of approximately 1.47%. 
 

866 

Table VIII-5a 

Adjustment of Projected Retail Gasoline Prices 

to Reflect the Economic Value of Fuel Savings 

Year 

AEO 2012 Projection 

of Retail Gasoline 

Price, Including 

Federal, State, and 

Local Taxes 

Projected Federal, State, 

and Local Taxes 

Projected Gasoline Price, 

Excluding Taxes 

(2010 $/gallon) (2010 $/gallon) (2010 $/gallon) 

2010 $2.76 $0.42 $2.34 

2011 $3.43 $0.42 $3.01 

2012 $3.31 $0.41 $2.90 

2013 $3.28 $0.41 $2.87 

2014 $3.41 $0.41 $3.00 

2015 $3.53 $0.40 $3.13 

2016 $3.57 $0.40 $3.17 

2017 $3.64 $0.40 $3.24 

2018 $3.66 $0.39 $3.27 

2019 $3.70 $0.39 $3.31 

2020 $3.75 $0.39 $3.36 

2021 $3.77 $0.38 $3.39 

2022 $3.76 $0.38 $3.38 

2023 $3.77 $0.38 $3.39 

2024 $3.81 $0.38 $3.43 

2025 $3.84 $0.37 $3.47 

2026 $3.86 $0.37 $3.49 

2027 $3.88 $0.37 $3.51 

2028 $3.91 $0.37 $3.54 

2029 $3.93 $0.37 $3.56 

2030 $3.96 $0.36 $3.60 

2031 $4.08 $0.36 $3.72 

2032 $3.96 $0.36 $3.60 

2033 $3.98 $0.36 $3.62 

2034 $4.01 $0.35 $3.66 

2035 $4.04 $0.35 $3.69 

2036 $4.06 $0.35 $3.71 

2037 $4.13 $0.35 $3.78 

2038 $4.20 $0.34 $3.85 

2039 $4.21 $0.34 $3.87 
 

867 

2040 $4.27 $0.34 $3.93 

2041 $4.34 $0.34 $4.00 

2042 $4.40 $0.34 $4.06 

2043 $4.46 $0.33 $4.13 

2044 $4.53 $0.33 $4.20 

2045 $4.60 $0.33 $4.27 

2046 $4.66 $0.33 $4.34 

2047 $4.73 $0.33 $4.41 

2048 $4.80 $0.33 $4.48 

2049 $4.87 $0.32 $4.55 

2050 $4.94 $0.32 $4.62 

2051 $5.02 $0.32 $4.70 

2052 $5.09 $0.32 $4.77 

2053 $5.17 $0.32 $4.85 

2054 $5.24 $0.31 $4.93 

2055 $5.32 $0.31 $5.01 

2056 $5.40 $0.31 $5.09 

2057 $5.48 $0.31 $5.17 

2058 $5.56 $0.31 $5.25 

2059 $5.64 $0.31 $5.33 

2060 $5.72 $0.30 $5.42 

2061 $5.81 $0.30 $5.50 

Impact of Increased Fuel Economy on Fuel Tax Revenues 

While NHTSA excludes fuel taxes from the estimation of net social benefits due to the fact that 

taxes are transfer payments, the agency recognizes the importance of fuel tax revenue in 

policymakers’ budgetary decisions. By applying projected fuel tax rates to estimates of gallons 

of fuel saved for each of the calendar years in which vehicles of model years covered by this rule 

are expected to remain on the road, the agency developed approximate schedules shown in 

Tables VIII-5b and VIII-5c documenting the net changes in fuel tax revenues under the preferred 

alternative at federal, state, and local levels. The projections in Tables VIII-5b and VIII-5c are 

consistent with the aforementioned AEO assumptions regarding the relationship of real future 

fuel tax rates to their present levels. 
868 

Table VIII-5b 

Projected Annual Net Decrease in Fuel Tax Revenue 

Resulting From MY 2017-2025 CAFE Standards 

(Millions of 2010$, 3% Discount Rate) 

Year Baseline 

Fleet Federal State Local 

2011 2010 

2008 

$0 -

$1 

$0 -

$2 

$0 -

$0 

2012 2010 

2008 

$3 -

$5 

$4 -

$6 

$0 -

$1 

2013 2010 

2008 

$10 -

$14 

$13 -

$18 

$1 -

$2 

2014 2010 

2008 

$28 -

$27 

$36 -

$35 

$3 -

$3 

2015 2010 

2008 

$55 -

$44 

$75 -

$61 

$7 -

$6 

2016 2010 

2008 

$96 -

$72 

$132 -

$99 

$12 -

$9 

2017 2010 

2008 

$148 -

$116 

$204 -

$159 

$19 -

$14 

2018 2010 

2008 

$209 -

$187 

$307 -

$275 

$28 -

$25 

2019 2010 

2008 

$335 -

$312 

$492 -

$457 

$45 -

$42 

2020 2010 

2008 

$490 -

$481 

$719 -

$706 

$65 -

$64 

2021 2010 

2008 

$644 -

$640 

$1,011 -

$1,006 

$92 -

$91 

2022 2010 

2008 

$832 -

$848 

$1,307 -

$1,333 

$119 -

$121 

2023 2010 

2008 

$1,041 -

$1,062 

$1,636 -

$1,669 

$149 -

$152 

2024 2010 

2008 

$1,277 -

$1,296 

$2,007 -

$2,036 

$182 -

$185 

2025 2010 

2008 

$1,402 -

$1,435 

$2,372 -

$2,429 

$216 -

$221 

2026 2010 

2008 

$1,307 -

$1,335 

$2,212 -

$2,259 

$201 -

$205 

2027 2010 

2008 

$1,219 -

$1,240 

$2,064 -

$2,099 

$188 -

$191 

2028 2010 

2008 

$1,125 -

$1,144 

$1,904 -

$1,936 

$173 -

$176 

2029 2010 

2008 

$1,038 -

$1,051 

$1,757 -

$1,778 

$160 -

$162 

2030 2010 

2008 

$876 -

$883 

$1,607 -

$1,619 

$146 -

$147 

2031 2010 

2008 

$787 -

$792 

$1,444 -

$1,452 

$131 -

$132 

2032 2010 

2008 

$708 -

$712 

$1,299 -

$1,305 

$118 -

$119 
869 

2033 2010 

2008 

$633 -

$637 

$1,161 -

$1,168 

$106 -

$106 

2034 2010 

2008 

$515 -

$517 

$1,029 -

$1,035 

$94 -

$94 

2035 2010 

2008 

$451 -

$453 

$901 -

$906 

$82 -

$82 

2036 2010 

2008 

$384 -

$387 

$783 -

$787 

$71 -

$72 

2037 2010 

2008 

$323 -

$325 

$670 -

$675 

$61 -

$61 

2038 2010 

2008 

$269 -

$270 

$568 -

$571 

$52 -

$52 

2039 2010 

2008 

$221 -

$222 

$475 -

$478 

$43 -

$43 

2040 2010 

2008 

$179 -

$179 

$391 -

$393 

$36 -

$36 

2041 2010 

2008 

$142 -

$143 

$317 -

$318 

$29 -

$29 

2042 2010 

2008 

$111 -

$111 

$253 -

$254 

$23 -

$23 

2043 2010 

2008 

$86 -

$86 

$200 -

$200 

$18 -

$18 

2044 2010 

2008 

$66 -

$66 

$157 -

$157 

$14 -

$14 

2045 2010 

2008 

$51 -

$51 

$124 -

$124 

$11 -

$11 

2046 2010 

2008 

$40 -

$40 

$99 -

$98 

$9 -

$9 

2047 2010 

2008 

$32 -

$32 

$81 -

$80 

$7 -

$7 

2048 2010 

2008 

$26 -

$26 

$66 -

$66 

$6 -

$6 

2049 2010 

2008 

$21 -

$21 

$55 -

$54 

$5 -

$5 

2050 2010 

2008 

$17 -

$17 

$46 -

$45 

$4 -

$4 

2051 2010 

2008 

$14 -

$14 

$39 -

$38 

$4 -

$3 

2052 2010 

2008 

$11 -

$11 

$32 -

$31 

$3 -

$3 

2053 2010 

2008 

$9 -

$9 

$26 -

$25 

$2 -

$2 

2054 2010 

2008 

$7 -

$7 

$21 -

$20 

$2 -

$2 

2055 2010 

2008 

$5 -

$5 

$16 -

$15 

$1 -

$1 

2056 2010 

2008 

$4 -

$4 

$13 -

$12 

$1 -

$1 

2057 2010 

2008 

$3 -

$3 

$10 -

$9 

$1 -

$1 

2058 2010 

2008 

$2 -

$2 

$7 -

$6 

$1 -

$1 

2059 2010 

2008 

$1 -

$1 

$4 -

$4 

$0 -

$0 

2060 2010 

2008 

$1 -

$1 

$2 -

$2 

$0 -

$0 
 

870 

2061 2010 

2008 

$0 -

$0 

$1 -

$1 

$0 -

$0 

Total $17,260 -

$17,339 

$30,151 -

$30,313 

$2,741 -

$2,756 

Table VIII-5c
 

Projected Annual Net Decrease in Fuel Tax Revenue 

Resulting From MY 2017-2025 CAFE Standards 

(Millions of 2010$, 7% Discount Rate) 

Year Baseline 

Fleet Federal State Local 

2011 2010 

2008 

$0 -

$1 

$0 -

$2 

$0 -

$0 

2012 2010 

2008 

$3 -

$5 

$4 -

$6 

$0 -

$1 

2013 2010 

2008 

$10 -

$14 

$13 -

$18 

$1 -

$2 

2014 2010 

2008 

$28 -

$26 

$36 -

$34 

$3 -

$3 

2015 2010 

2008 

$53 -

$43 

$74 -

$59 

$7 -

$5 

2016 2010 

2008 

$93 -

$69 

$127 -

$95 

$12 -

$9 

2017 2010 

2008 

$142 -

$111 

$195 -

$152 

$18 -

$14 

2018 2010 

2008 

$199 -

$179 

$292 -

$263 

$27 -

$24 

2019 2010 

2008 

$319 -

$298 

$468 -

$437 

$43 -

$40 

2020 2010 

2008 

$464 -

$458 

$680 -

$672 

$62 -

$61 

2021 2010 

2008 

$605 -

$605 

$951 -

$951 

$86 -

$86 

2022 2010 

2008 

$775 -

$794 

$1,218 -

$1,248 

$111 -

$113 

2023 2010 

2008 

$962 -

$984 

$1,512 -

$1,547 

$137 -

$141 

2024 2010 

2008 

$1,170 -

$1,189 

$1,838 -

$1,869 

$167 -

$170 

2025 2010 

2008 

$1,272 -

$1,305 

$2,152 -

$2,209 

$196 -

$201 

2026 2010 

2008 

$1,142 -

$1,170 

$1,933 -

$1,980 

$176 -

$180 

2027 2010 

2008 

$1,027 -

$1,048 

$1,739 -

$1,773 

$158 -

$161 

2028 2010 

2008 

$914 -

$931 

$1,547 -

$1,576 

$141 -

$143 

2029 2010 

2008 

$813 -

$825 

$1,376 -

$1,396 

$125 -

$127 
871 

2030 2010 

2008 

$662 -

$668 

$1,213 -

$1,225 

$110 -

$111 

2031 2010 

2008 

$573 -

$577 

$1,050 -

$1,058 

$95 -

$96 

2032 2010 

2008 

$497 -

$500 

$910 -

$917 

$83 -

$83 

2033 2010 

2008 

$428 -

$432 

$785 -

$791 

$71 -

$72 

2034 2010 

2008 

$336 -

$338 

$671 -

$676 

$61 -

$61 

2035 2010 

2008 

$283 -

$285 

$567 -

$571 

$52 -

$52 

2036 2010 

2008 

$233 -

$235 

$475 -

$479 

$43 -

$44 

2037 2010 

2008 

$189 -

$191 

$393 -

$396 

$36 -

$36 

2038 2010 

2008 

$152 -

$153 

$321 -

$323 

$29 -

$29 

2039 2010 

2008 

$121 -

$121 

$259 -

$261 

$24 -

$24 

2040 2010 

2008 

$94 -

$95 

$206 -

$207 

$19 -

$19 

2041 2010 

2008 

$72 -

$72 

$161 -

$162 

$15 -

$15 

2042 2010 

2008 

$54 -

$55 

$124 -

$124 

$11 -

$11 

2043 2010 

2008 

$41 -

$41 

$94 -

$94 

$9 -

$9 

2044 2010 

2008 

$30 -

$30 

$71 -

$71 

$6 -

$6 

2045 2010 

2008 

$22 -

$22 

$54 -

$54 

$5 -

$5 

2046 2010 

2008 

$17 -

$17 

$41 -

$41 

$4 -

$4 

2047 2010 

2008 

$13 -

$13 

$32 -

$32 

$3 -

$3 

2048 2010 

2008 

$10 -

$10 

$26 -

$25 

$2 -

$2 

2049 2010 

2008 

$8 -

$8 

$21 -

$20 

$2 -

$2 

2050 2010 

2008 

$6 -

$6 

$17 -

$16 

$2 -

$1 

2051 2010 

2008 

$5 -

$5 

$13 -

$13 

$1 -

$1 

2052 2010 

2008 

$4 -

$4 

$11 -

$10 

$1 -

$1 

2053 2010 

2008 

$3 -

$3 

$8 -

$8 

$1 -

$1 

2054 2010 

2008 

$2 -

$2 

$6 -

$6 

$1 -

$1 

2055 2010 

2008 

$2 -

$2 

$5 -

$5 

$0 -

$0 

2056 2010 

2008 

$1 -

$1 

$4 -

$3 

$0 -

$0 

2057 2010 

2008 

$1 -

$1 

$3 -

$3 

$0 -

$0 
 

                                                      

872 

2058 2010 

2008 

$1 -

$1 

$2 -

$2 

$0 -

$0 

2059 2010 

2008 

$0 -

$0 

$1 -

$1 

$0 -

$0 

2060 2010 

2008 

$0 -

$0 

$1 -

$1 

$0 -

$0 

2061 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Total $13,850 -

$13,943 

$23,699 -

$23,882 

$2,154 -

$2,171 

Benefits from Additional Driving 

The increase in travel associated with the rebound effect produces additional benefits to vehicle 

owners, which reflect the value to drivers and other vehicle occupants of the added (or more 

desirable) social and economic opportunities that become accessible with additional travel. As 

evidenced by the fact that they elect to make more frequent or longer trips when the cost of 

driving declines, the benefits from this added travel exceed drivers’ added outlays for the fuel it 

consumes (measured at the improved level of fuel economy resulting from stricter CAFE 

standards).447 The amount by which the benefits from this increased driving travel exceed its 

increased fuel costs measures the net benefits they receive from the additional travel, usually are 

referred to as increased consumer surplus. 

NHTSA’s analysis estimates the economic value of the increased consumer surplus provided by 

added driving using the conventional approximation, which is one half of the product of the 

decline in vehicle operating costs per vehicle-mile and the resulting increase in the annual 

number of miles driven. Because it depends on the extent of improvement in fuel economy, the 

value of benefits from increased vehicle use changes by model year and varies among alternative 

CAFE standards. Under even those alternatives that would impose the highest standards, 

however, the magnitude of benefits from additional vehicle use represents a small fraction of the 

total benefits from requiring cars and light trucks to achieve higher fuel economy. 

Benefits due to reduced refueling frequency 

447 These benefits are included in the value of fuel savings reported throughout this analysis. 
                                                      

873 

Direct estimates of the value of extended vehicle range are not available in the literature, so 

NHTSA conducted a study to estimate those benefits resulting from this rule. The benefits were 

determined by calculating the reduction in the required annual number of refueling cycles due to 

improved fuel economy assuming no fuel tank downsizing in response to improvements in fuel 

economy, and assessing the economic value of the resulting benefits. Chief among these benefits 

is the time that owners save by spending less time both in search of fueling stations and in the act 

of pumping and paying for fuel. As follow-up to that work, NHTSA conducted an analysis of 

the MY 2010 fleet to determine how manufacturers balanced vehicle range and fuel tank 

downsizing as fuel economy increases. 

The economic value of refueling time savings was calculated by applying DOT-recommended 

valuations for travel time savings to estimates of how much time is saved.448 The value of travel 

time depends on average hourly valuations of personal and business time, which are functions of 

total hourly compensation costs to employers. The total hourly compensation cost to employers, 

inclusive of benefits, in 2010$ is $29.68.449 Table VIII-6 demonstrates the agency’s approach to 

estimating the value of travel time ($/hour) for both urban and rural (intercity) driving. This 

approach relies on the use of DOT-recommended weights that assign a lesser valuation to 

personal travel time than to business travel time, as well as weights that adjust for the 

distribution between personal and business travel. 

448 See http://ostpxweb.dot.gov/policy/Data/VOT97guid.pdf and 

http://ostpxweb.dot.gov/policy/Data/VOTrevision1_2-11-03.pdf (last accessed August 1, 2012).
 449 Total hourly employer compensation costs for 2010 (average of quarterly observations across all occupations for 

all civilians). See http://www.bls.gov/ect/ (last accessed April 27, 2012). 
874 

Table VIII-6
 

Estimating the Value of Travel Time for Urban and Rural (Intercity) Travel ($/hour) 

Urban Travel 

Personal travel Business Travel Total 

Wage Rate ($/hour) $29.68 $29.68 --

DOT-Recommended Value of Travel Time 

Savings, as % of Wage Rate 50% 100% --

Hourly Valuation (=Wage Rate * DOTRecommended Value) $14.84 $29.68 --

% of Total Urban Travel 94.4% 5.6% 100% 

Hourly Valuation (Adjusted for % of Total 

Urban Travel) $14.01 $1.66 $15.67 

Rural (Intercity) Travel 

Personal travel Business Travel Total 

Wage Rate ($/hour) $29.68 $29.68 --

DOT-Recommended Value of Travel Time 

Savings, as % of Wage Rate 70% 100% --

Hourly Valuation (=Wage Rate * DOTRecommended Value) $20.77 $3.86 --

% of Total Rural Travel 87.0% 13.0% 100% 

Hourly Valuation (Adjusted for % of Total 

Rural Travel) $18.07 $3.86 $21.93 
 

875 

The estimates of the hourly value of urban and rural travel time ($15.67 and $21.93, 

respectively) shown in Table VIII-6 must be adjusted to account for the nationwide ratio of 

urban to rural driving. By applying this adjustment (as shown in Table VIII-7), an overall 

estimate of the hourly value of travel time – independent of urban or rural status – may be 

produced. Note that the calculations above assume only one adult occupant per vehicle. To fully 

estimate the average value of vehicle travel time, the agency must account for the presence of 

additional adult passengers during refueling trips. NHTSA applies such an adjustment as shown 

in Table VIII-7; this adjustment is performed separately for passenger cars and for light trucks, 

yielding occupancy-adjusted valuations of vehicle travel time during refueling trips for each 

fleet. Note that children (persons under age 16) are excluded from average vehicle occupancy 

counts, as it is assumed that the opportunity cost of children’s time is zero. 
                                                      

 

 

 

876 

Table VIII-7
 

Estimating the Value of Travel Time for Light-Duty Vehicles ($/hour) 

Unweighted 

Value of Travel 

Time ($/hour) 

Weight (% of 

Total Miles 

Driven)450 

Weighted Value 

of Travel Time 

($/hour) 

Urban Travel $15.67 67.1% $10.51 

Rural Travel $21.93 32.9% $7.22 

Total -- 100.0% $17.73 

Passenger Cars Light Trucks 

Average Vehicle Occupancy 

During Refueling Trips 

(persons)451 1.21 1.23 

Weighted Value of Travel Time 

($/hour) $17.73 $17.73 

Occupancy-Adjusted Value of 

Vehicle Travel Time During 

Refueling Trips ($/hour) $21.45 $21.81 

The agency estimated the amount of refueling time saved using (preliminary) survey data 

gathered as part of our 2010-2011 National Automotive Sampling System’s Tire Pressure 

Monitoring System (TPMS) study.452 The study was conducted at fueling stations nationwide, 

450 Weights used for urban vs. rural travel are computed using cumulative 2011 estimates of urban vs. rural miles 

driven provided by the Federal Highway Administration. Available at 

http://www.fhwa.dot.gov/policyinformation/travel_monitoring/tvt.cfm (last accessed April 27, 2012). 451 Source: National Automotive Sampling System 2010-2011 Tire Pressure Monitoring System (TPMS) study. See 

next page for further background on the TPMS study. TPMS data are preliminary at this time and rates are subject 

to change pending availability of finalized TPMS data. Average occupancy rates shown here are specific to 

refueling trips, and do not include children under 16 years of age. 

452 TPMS data are preliminary and not yet published. Estimates derived from TPMS data are therefore preliminary 

and subject to change. Observational and interview data are from distinct subsamples, each consisting of 
                                                                                                                                                                              

 

877 

and researchers made observations regarding a variety of characteristics of thousands of 

individual fueling station visits from August, 2010 through April, 2011.453 Among these 

characteristics of fueling station visits is the total amount of time spent pumping and paying for 

fuel. From a separate sample (also part of the TPMS study), researchers conducted interviews at 

the pump to gauge the distances that drivers travel in transit to and from fueling stations, how 

long that transit takes, and how many gallons of fuel are being purchased. 

NHTSA focused on the interview-based responses in which respondents indicated the primary 

reason for the refueling trip was due to a low reading on the gas gauge.454 This restriction was 

imposed so as to exclude distortionary effects of those who refuel on a fixed (e.g., weekly) 

schedule and may be unlikely to alter refueling patterns as a result of increased driving range. 

The relevant TPMS survey data on average refueling trip characteristics are presented below in 

Table VIII-8. 

Table VIII-8
 

Average Refueling Trip Characteristics for Passenger Cars and Light Trucks 

Gallons of 

Fuel 

Purchased 

Round-Trip 

Distance 

to/from 

Fueling 

Station 

(miles) 

Round-Trip 

Time to/from 

Fueling 

Station 

(minutes) 

Time to Fill 

and Pay 

(minutes) 

Total 

Time 

(minutes) 

Passenger Cars 9.8 0.97 2.28 4.10 6.38 

Light Trucks 13.0 1.08 2.53 4.30 6.83 

As an illustration of how we estimate the value of extended refueling range, assume a small light 

truck model has an average fuel tank size of approximately 20 gallons, and a baseline actual onroad fuel economy of 24 mpg (its assumed level in the absence of a higher CAFE standard for 

approximately 7,000 vehicles. For more information on the National Automotive Sampling System and to access 

TPMS data when they are made available, see http://www.nhtsa.gov/NASS. 453 The data collection period for the TPMS study ranged from 08/10/2010 to 04/15/2011.
 454 Approximately 60 percent of respondents indicated “gas tank low” as the primary reason for the refueling trip in
 

question. 
                                                      

 

 

878 

the given model year). TPMS survey data indicate that drivers who indicated the primary reason 

for their refueling trips was a low reading on the gas gauge typically refuel when their tanks are 

35 percent full (i.e. as shown in Table VIII-8, with 7.0 gallons in reserve, and purchasing 13 

gallons in the refueling trip). By this measure, a typical driver would have an effective driving 

range of 312 miles (= 13.0 gallons x 24 mpg) before he or she is likely to refuel. Increasing this 

model’s actual on-road fuel economy from 24 to 25 mpg would therefore extend its effective 

driving range to 325 miles (= 13.0 gallons x 25 mpg). Assuming that the truck is driven 12,000 

miles/year,455 this 1 mpg improvement in actual on-road fuel economy reduces the expected 

number of refueling trips per year from 38.5 (= 12,000 miles per year / 312 miles per refueling) 

to 36.9 (= 12,000 miles per year / 325 miles per refueling), or by 1.6 refuelings per year. If a 

typical fueling cycle for a light truck requires a total of 6.83 minutes, then the annual value of 

time saved due to that 1 mpg improvement would amount to $3.97 (= (6.83/60) x $21.81 x 1.6). 

In the central analysis, this calculation was repeated for each future calendar year that light-duty 

vehicles of each model year affected by the CAFE standards considered in this rule would 

remain in service. The resulting cumulative lifetime valuations of time savings account for both 

the reduction over time in the number of vehicles of a given model year that remain in service 

and the reduction in the number of miles (VMT) driven by those that stay in service. We also 

adjust the value of time savings that will occur in future years both to account for expected 

annual growth in real wages456 and to apply a discount rate to determine the net present value of 

time saved.457 A further adjustment is made to account for evidence from the interview-based 

portion of the TPMS study which suggests that 40 percent of refueling trips are for reasons other 

than a low reading on the gas gauge; it is therefore assumed that only 60 percent of the 

theoretical refueling time savings will be realized, as it was assumed that owners who refuel on a 

fixed schedule will continue to do. NHTSA sought feedback from peer reviewers regarding the 

455 Source of annual vehicle mileage: U.S. Department of Transportation, Federal Highway Administration, 2009 

National Household Travel Survey (NHTS). See http://nhts.ornl.gov/2009/pub/stt.pdf (table 22, p.48). 12,000 

miles/year is an approximation of a light duty vehicle’s annual mileage during its initial decade of use (the period in 

which the bulk of benefits are realized). The VOLPE model estimates VMT by model year and vehicle age, taking 

into account the rebound effect, secular growth rates in VMT, and fleet survivability; these complexities are omitted 

in the above example for simplicity. 

456 A 1.1 percent annual rate of growth in real wages is used to adjust the value of travel time per vehicle ($/hour) for 

future years for which a given model is expected to remain in service. This rate is supported by a BLS analysis of 

growth in real wages from 2000 – 2009. See http://www.bls.gov/opub/ted/2011/ted_20110224.htm (last accessed 

August 1, 2012) 

457 Note that here, as elsewhere in the analysis, discounting is applied on a mid-year basis. For example, at a 3% 

discount rate, the sequence of discount factors is calculated as: {1/((1+0.03)^(0.5)), 1/((1+0.03)^(1.5)), ... , 

1/((1+0.03)^(T – 0.5))}. NHTSA utilized mid-year discounting to reflect the fact that a given model year’s vehicles 

are sold over the course of one or more years, therefore costs and benefits do not begin to fully accrue on January 1st 

of the model year. 
                                                      

 

879 

NPRM analysis of refueling time savings and has updated its analysis and discussion to address 

peer reviewers’ comments.458 

Manufacturers’ decisions regarding vehicles’ fuel tank sizes are integral to the realized value of 

this benefit. At vehicle redesign, manufacturers typically redesign fuel tanks based on a variety 

of considerations including driving range, cargo and passenger space (utility), mass targets, 

safety, and other factors. As fuel economy increases, manufacturers may opt at the time of 

vehicle redesign to downsize vehicles’ fuel tanks. Downsizing the fuel tanks of more fuelefficient vehicles offers a number of advantages: 

 Reduced vehicle mass459 

o May improve vehicle performance 

o Improves fuel economy, thereby reducing CAFE compliance costs 

 Reduced vehicle manufacturing costs 

o Lower material costs in fuel tank manufacturing 

o Lower material costs in evaporative emissions canisters 

 May allow additional space for cargo and/or passengers 

 May allow additional space for other vehicle equipment and/or more crush space for 

safety 

Manufacturers need not wait until vehicle redesign to reduce the effective size of fuel tanks; by 

changing the length of the fill tube, effective tank volume may be adjusted during model refresh 

years, thereby allowing the realization of some of the above listed benefits. 

In the NPRM, the agency stated that manufacturers might resize fuel tanks at redesign to 

maintain similar range; however, in the quantitative valuation of refueling time savings benefit, 

the agency did not integrate this assumption. Rather, NHTSA included in the NPRM a request 

for manufacturer comment on this assumption. No comments were received on this issue in 

response to the NPRM. However, in the peer review of the study, a commenter suggested that 

the quality of NHTSA’s analysis of refueling time savings benefits could be improved by the 

inclusion of analysis of the relationship between fuel economy and vehicle range among the 

458 Peer review materials, peer reviewer backgrounds, comments, and NHTSA responses are available at Docket 

NHTSA-2012-0001. 

459 For example, for a vehicle with a 15 gallon fuel tank and a 400 mile range, increasing fuel economy from 40 to 

60 mpg (an increase of 50%), downsizing the fuel tank to maintain a range of 400 miles would enable a mass 

reduction of approximately 51 pounds based on the reduction in the amount of fuel alone (based on an 8.3 gallon 

reduction in fuel tank volume and a gasoline density of 6.073 lbs/gallon). If the fuel tank was not downsized, the 

range of the vehicle would increase to 600 miles. 
                                                      

 

880 

baseline fleets upon which the agency developed the 2017-2025 CAFE standards, and (if 

appropriate) the integration of the results of the suggested analysis into the estimation of the 

value of the refueling time savings benefit. NHTSA performed such a study based on the 2010 

baseline fleet data, discussed further below. 

NHTSA also consulted with engineering experts at EDAG in the context of the NHTSA-funded 

lightweight future vehicle study460 regarding expectations of the volume of the fuel tanks of 

future vehicles affected by this rule. The EDAG engineers involved in this study expressed the 

joint opinion that fuel tank downsizing is certain to occur as fuel economy increases, for reasons 

consistent with those stated above. The future lightweight Honda Accord designed by EDAG 

features a 14.6 percent decrease in fuel tank size relative to the baseline 2011 model. Recent 

redesigns of the MY 2013 Ford Fusion and MY 2012 Toyota Camry show evidence that 

manufacturers are downsizing fuel tanks. The MY 2013 Ford Fusion has a 16.5 gallon tank, 

versus the 17.5 gallon tank in the MY 2012 Fusion. Similarly the MY 2012 Toyota Camry has a 

17.0 gallon tank, versus the 18.5 gallon tank in the MY 2011 Camry. 

If manufacturers elect to reduce fuel tank size in response to improved fuel economy to maintain 

range, the value of the refueling time savings benefit will be reduced because the number of trips 

to fueling stations will not be reduced as much as estimated assuming no fuel tank downsizing. 

It is important to note that NHTSA recognizes and (discussed in detail later in this analysis) 

accounts for the fact that reductions to fuel tank volume – even if to the point that average 

vehicle range remains unchanged while fuel economy rises – will not eliminate the value of the 

refueling time savings benefit, as there remains a time savings due to the reduction in time 

required to pump fuel into smaller tanks. The agency believes that annual refreshes of fuel tank 

size during the years in-between model redesigns are unlikely; therefore, while the downsizing of 

fuel tanks would decrease the realized value of the refueling time savings benefit, it would not 

eliminate it. 

NHTSA performed a quantitative analysis based on manufacturers’ 2010 vehicle market data, 

regressing vehicle range (in miles) against fuel economy (measured in miles per gallon). 

Regressions were performed for each regulatory subclass of vehicles, and limited to exclude 

diesel, E85, and compressed natural gas vehicles, though hybrid gasoline-electric vehicles were 

460 See Docket No. NHTSA-2010-0131 for the lightweight future vehicle study and peer review feedback of that 

study. 
       

             

         

           

       

Vehicle Range (Miles) vs. Fuel Economy (MPG)
 

MY 2010 Compact Passenger Cars
 

Range, in Miles

900

800

700

600

500

400

300

200

100

‐

y = 7.0675x + 266.05

 ‐ 10 20 30 40 50 60 70 80

Fuel Economy, in Miles Per Gallon

881 

included in the sample. As an illustration, figure VIII-1 presents the scatter plot and trend line 

for MY 2010 compact passenger cars. 

Figure VIII-1 

NHTSA’s analysis of range versus fuel economy across each regulatory subclass within the MY 

2010 fleet indicate that vehicles of a given subclass tend to cluster together within a narrow 

bound; in the above example, the driving ranges of compact passenger cars are mostly clustered 

between 400 and 600 miles. Across all subclasses of the 2010 fleet, vehicles exhibit a minimum 

300 mile range in all cases, which NHTSA assumed to be the minimum level of driving range 

acceptable to owners. 
                                                      

 

882 

NHTSA assumed that the relationship between fuel economy and range exhibited in the MY 

2010 data is indicative of that of future fleets. Consumers are increasingly prioritizing fuel 

economy in vehicle purchasing decisions461; NHTSA assumes that consumers also place some 

value on vehicle range such that all other things equal, a consumer would prefer a vehicle of 

greater range. NHTSA is unaware of studies suggesting vehicle owners’ future preferences for 

vehicle range. Therefore, NHTSA assumed that automakers will manufacture vehicles of MYs 

2017-2025 with ranges that are consistent with the subclass-specific regression equations as 

shown below in Table VIII-9. 462 

Table VIII-9
 

Regression-based Predictive Functions of Vehicle Range 

Based on MY 2010 Fleet 

Regulatory 

Class 

Technology 

Class 

Predicted Range (miles) as Function 

of Fuel Economy (mpg) Sample Size 

PC Subcompact = 365.63 + 2.6121*(FE) 95 

PC Subcompact Perf = 295.48 + 5.6996*(FE) 100 

PC Compact = 266.05 + 7.0675*(FE) 105 

PC Compact Perf = 242.18 + 7.9258*(FE) 56 

PC Midsize = 24.427 + 16.877*(FE) 92 

PC Midsize Perf = 133.41 + 13.22*(FE) 58 

PC Large = 93.157 + 15.099*(FE) 46 

PC Large Perf = 149.85 + 14.037*(FE) 71 

PC Small LT = 189.81 + 9.867*(FE) 42 

PC Midsize LT = 211.45 + 11.421*(FE) 32 

LT Small LT = 200.39 + 9.6627*(FE) 41 

LT Midsize = 190.38 + 12.295*(FE) 169 

LT Large = 294.16 + 11.76*(FE) 108 

LT Minivan = 458.19 + 1.8684*(FE) 14 

For example, the average range of the MY 2010 compact passenger cars depicted in Figure VIII1 is 501.93 miles, with average fuel economy of 33.38 mpg, which implies a representative 

vehicle’s fuel tank size of 15.04 gallons. If this representative vehicle’s fuel economy rises by 

461 See “High gas prices motivate drivers to change direction” (Consumer Reports, May 2012). Available at:
 

http://www.consumerreports.org/content/cro/en/cars/fuel-economy-survey-high-gas-prices-impact-drivers.html (last 

accessed August 1, 2012) 

462 The study of the relationship between range and fuel economy has not been peer reviewed. Peer reviewers 

requested its inclusion and offered suggestions on methods; however, it was developed only recently and as such the 

approach and results have not been peer reviewed. 
 

883 

10% to 36.71 mpg while holding the fuel tank size constant, range would grow to 552.12 miles, 

an increase of 50.19 miles. However, the linear trend equation shown in Figure VIII-1 offers an 

alternate prediction of the vehicle’s range that implicitly includes tank downsizing as follows: 

predicted range = 266.05 + 7.0675*(33.38 mpg) = 525.5 miles, or an increase of 23.57 miles. 

Vehicle range of 525.5 miles with fuel economy of 36.71 mpg implies a fuel tank size of 14.31 

gallons, a 4.82 percent reduction in fuel volume. Of the 50.19 mile increase in vehicle range that 

would occur if the fuel tank size remained constant, only 23.57 miles of this increase are 

expected to be achieved due to the relationship between fuel economy and range seen in the 

sample of vehicles included in the regression. Thus, 26.62 miles (= 50.19 miles – 23.57 miles), 

or 53.0% of the possible range increase for compact passenger cars is not expected to be 

achieved. 

NHTSA repeated the calculations expressed in the example of the preceding paragraph across all 

vehicle regulatory subclasses to estimate the percentage of possible range increase that is not 

expected to be achieved due to reduction in fuel tank volume. This percentage varies greatly by 

regulatory subclass, as shown in Table VIII-10. Note that in each class, improvements to fuel 

economy led to gains in vehicle range; it is only the amount of increase that was the subject of 

this analysis. The values presented in Table VIII-10 should be interpreted as “although this 

vehicle’s range is expected to increase in response to gains in fuel economy, NHTSA anticipates 

it will grow by X percent less than it otherwise would if the manufacturer were to hold constant 

the volume of the fuel tank.” 
 

 

 

 

 

 

 

 

 

884 

Table VIII-10 

Potential Vehicle Range Increase “Lost” 

Due to Fuel Tank Downsizing 

Regulatory Class Technology Class 

% of Possible Range 

Gain Not Expected to 

be Achieved due to 

Fuel Tank Downsizing 

PC Subcompact 80.1% 

PC Subcompact Perf. 65.5% 

PC Compact 53.0% 

PC Compact Perf. 55.7% 

PC Midsize 4.6% 

PC Midsize Perf. 31.5% 

PC Large 19.6% 

PC Large Perf. 34.1% 

PC Small LT 38.6% 

PC Midsize LT 41.0% 

LT Small LT 42.2% 

LT Midsize 40.1% 

LT Large 55.0% 

LT Minivan 90.5% 

NHTSA then created a composite sales-weighted estimate using data from each of the above 

subclasses across model years 2017 – 2025. These values ranged from a low of 40.45 percent to 

a high of 41.71 percent, for an overall average of 40.91 percent across all nine model years. In 

the CAFE model, the refueling time savings benefits are initially calculated without any 

adjustment for the expected reductions in fuel tank size. The above analysis led NHTSA to 

conclude that those initial calculations overestimate the value of this benefit by up to 40.91 

percent, and that some downward adjustment to the refueling time savings benefit calculation is 

therefore necessary. 

In addition to considering the downward adjustment in refueling benefits that result from fuel 

tank resizing, it is also necessary to account for the refueling time savings benefit resulting from 

less time is required to pump fuel into smaller tanks. NHTSA researched the magnitude of this 

time savings as follows. 
                                                      

885 

Taking a MY 2025 passenger car as representative of the future fleet (note that of the model 

years affected by this rule, MY 2025 vehicles are projected to see the greatest reduction in fuel 

tank volume, and therefore is the model year that would see the maximum time savings benefit) 

NHTSA proceeded as follows. If the average tank size of the MY 2025 passenger cars remains 

the same (16.71 gallons) as that of the total MY 2010 passenger car sample utilized in the 

regression analysis discussed earlier, NHTSA assumed that refueling trips would continue to 

require 6.38 minutes as shown in Table VIII-8. The projected difference in fuel economy 

between the MY 2025 baseline and preferred alternative levels is 14.05 mpg (= 52.87 mpg – 

38.82 mpg).463 If fuel tank volume remains constant at 16.71 gallons, range will increase by 

234.78 miles (= 14.05 mpg x 16.71 gallons). As discussed above, NHTSA’s regression analysis 

projects that 40.91 percent (96.05 miles) of this increase in range will not occur as a result of fuel 

tank downsizing. The projected increase in vehicle range is 138.73 miles (= 234.78 miles – 

96.05 miles), resulting in a vehicle with range of 787.41 miles (= baseline range of 648.68 miles 

+ 138.73 miles). The implied volume of this vehicle’s fuel tank is 14.89 gallons (= 787.41 miles 

/ 52.87 mpg). Assuming that all refueling trips occur when the remaining volume of fuel tank 

capacity reaches 35 percent464, the typical volume of fuel pumped in the baseline case is 10.86 

gallons, versus 9.68 gallons when accounting for the expected decrease in fuel tank volume. At 

an assumed fuel flow rate of 5 gallons per minute, this expected reduction of 1.18 gallons of fuel 

pumped per refueling cycle saves 14.2 seconds. Note that this particular benefit accrues to all 

refueling cycles, which NHTSA subsequently accounted for in aggregation of this benefit to 

fleet-wide levels. 

To account for this additional time savings across the lifetimes of all nine model years affected 

by this rule, NHTSA assumed that on average, one-half (or 7.1 seconds) of the 14.2 seconds of 

time saved (estimated above using an MY 2025 vehicle) would be realized by each vehicle 

affected by this rule, due to the fact that the required standards in MYs 2017 through 2024 are 

below those of MY 2025. Accounting for the additional time savings resulting from pumping 

fuel into smaller fuel tanks increases the estimated refueling time savings benefits. This increase 

partially offsets the 40.91 percent downward adjustment mentioned above, equivalent to a 

reduction in this downward adjustment from 40.91 to 30 percent. Therefore, NHTSA applied a 

30 percent downward adjustment to the calculation of refueling time savings benefits to address 

the net loss to the refueling time savings benefit stemming from expected reductions in fuel tank 

volume. 

463 2008 market baseline values. Fuel economy values cited in this example are not adjusted for the on-road fuel 

economy gap.

464 Average percentage of fuel remaining in the tank at the time of refueling, derived from TPMS study data. 
886 

Tables VIII-15, VIII-16, and VIII-17 provide an illustration of the derivation of the lifetime net 

present value of refueling time savings for the MY 2025 fleet of passenger cars, assuming the 

rate of increase in fuel economy as per the preferred alternative relative to the baseline for the 

same model year. Tables VIII-15 and VIII-16 present the underlying assumptions behind the 

results presented in Table VIII-13. This example is illustrative only; the CAFE model calculates 

this benefit at a combined (passenger car and light truck) level using the average of VMTweighted parameters, after which the results are prorated to passenger car and light truck fleets, 

respectively. The VMT schedule used in this example assumes that all vehicles sold in the given 

model year rely on internal combustion engines; in the CAFE model, the fleet contains a mix of 

vehicles utilizing alternate engine technologies that result in a variety of individualized VMT 

schedules. Due to these simplifications that were made to allow an empirical example, the 

results of this example cannot be compared to the actual CAFE model output of this benefit’s 

value. 
 

 

887 

Table VIII-11 

Economic Values Used in Example of Estimation of Lifetime Net Present Value 

of MY 2025 Passenger Car Refueling Time Savings 

Sales of MY 2025 Passenger Cars: 10,403,216 Discount Rate: 7% 

Achieved MPG, Preferred 

Alternative (with AC adjustment): 52.87 Achieved MPG, Baseline (with AC adjustment): 38.82 

Actual On-Road MPG, Preferred 

Alternative: 42.30 Actual On-Road MPG, Baseline: 31.06 

Average Fuel Tank Size (gallons): 15 Refueling Occurs When Tank 

Reaches (% capacity): 35% 

Effective (pre-refueling) Driving 

Range, Preferred Alternative: 412.4 Effective (pre-refueling) Driving 

Range, Baseline: 302.8 

Refueling Trips Due To Low Fuel 

Tank: 60% Average Length of Refueling Trip (minutes): 6.38 

Value of Passenger Car VehicleHour Travel Time (2010$): $21.45 Annual Real Wage Growth: 1.1% 

Downward Adjustment (Fuel 

Tank Downsizing) 30% 
 

888 

Table VIII-12 

Vehicle Survival Rates and VMT Schedules for MY 2025 Passenger Cars, 

Preferred Alternative vs. Baseline Scenario
 

Year 

Vehicle 

Survival 

Rate 

# of Surviving 

Vehicles 

Annual VMT, 

Baseline 

(per-vehicle) 

Annual 

VMT, 

Preferred 

Alternative 

(per-vehicle) 

Fleetwide VMT, 

Baseline 

Fleetwide VMT, 

Preferred 

Alternative 

2025 1.0000 10,403,216 17,724 18,423 184,387,678,460 191,657,976,381 

2026 0.9878 10,276,729 17,374 18,057 178,550,547,046 185,563,005,391 

2027 0.9766 10,159,648 16,984 17,657 172,551,611,407 179,384,465,403 

2028 0.9614 10,002,032 16,465 17,133 164,683,094,482 171,368,925,896 

2029 0.9450 9,831,518 15,936 16,590 156,672,716,399 163,102,588,141 

2030 0.9298 9,673,212 15,472 16,095 149,668,308,257 155,690,761,683 

2031 0.9113 9,480,433 14,802 15,400 140,327,351,991 145,996,762,371 

2032 0.8912 9,271,226 14,134 14,699 131,043,042,530 136,273,478,975 

2033 0.8689 9,039,106 13,405 13,942 121,164,982,564 126,020,813,260 

2034 0.8397 8,735,700 12,620 13,116 110,248,033,165 114,577,073,354 

2035 0.7999 8,321,437 11,631 12,097 96,789,557,953 100,668,514,534 

2036 0.7556 7,860,995 10,666 11,086 83,841,922,242 87,147,640,829 

2037 0.7055 7,339,528 9,612 9,997 70,544,136,903 73,371,277,040 

2038 0.6527 6,789,723 8,571 8,920 58,194,584,700 60,564,684,003 

2039 0.5946 6,185,596 7,546 7,850 46,677,776,167 48,556,027,723 

2040 0.5311 5,524,792 6,507 6,766 35,951,650,655 37,380,791,547 

2041 0.4585 4,769,646 5,428 5,639 25,891,022,963 26,895,142,492 

2042 0.3832 3,986,365 4,384 4,549 17,474,865,697 18,132,961,005 

2043 0.3077 3,201,267 3,397 3,522 10,874,793,876 11,275,665,401 

2044 0.2414 2,511,309 2,562 2,658 6,434,927,545 6,674,183,168 

2045 0.1833 1,906,752 1,881 1,948 3,585,715,105 3,715,050,194 

2046 0.1388 1,443,739 1,384 1,431 1,998,341,807 2,065,405,996 

2047 0.1066 1,108,644 1,048 1,076 1,161,337,021 1,193,232,839 

2048 0.0820 853,341 782 803 667,085,947 685,009,777 

2049 0.0629 654,799 587 601 384,215,034 393,631,876 

2050 0.0514 534,886 469 480 250,655,802 256,507,046 

2051 0.0420 436,421 377 385 164,581,433 168,020,813 

2052 0.0337 350,469 298 304 104,330,170 106,510,435 

2053 0.0281 292,844 246 251 72,021,805 73,526,898 

2054 0.0235 244,693 205 209 50,045,382 51,091,218 
 

 

 

 

 

 

 

 

 

 

 

 

                                                      

889 

Table VIII-13
 

Estimation of Lifetime Net Present Value of Refueling Time Savings for MY 2025 Passenger Cars, Preferred
 

Alternative vs. Baseline Scenario 

Year # of Refueling 

Trips, Baseline 

# of Refueling 

Trips, Preferred 

Alternative 

# of Fewer 

Refueling Trips 

Due To Higher 

CAFE Standard (x 

60% adjustment) 

# of Fewer 

Hours 

Spent 

Refueling 

Value of 

Vehicle-hour 

travel time in 

given year 

(2010$)465 

Value of Time Saved 

(2010$, 7% Discount 

Rate) 

2025 464,718,653 144,191,805 86,515,083 9,199,437 $25.14 $223,557,075 

2026 449,940,000 139,694,276 83,816,566 8,912,495 $25.41 $204,641,557 

2027 434,958,715 134,865,047 80,919,028 8,604,390 $25.69 $186,673,215 

2028 415,523,204 128,316,055 76,989,633 8,186,564 $25.98 $167,815,076 

2029 395,479,575 121,906,707 73,144,024 7,777,648 $26.26 $150,641,612 

2030 377,507,904 116,747,454 70,048,472 7,448,488 $26.55 $136,311,391 

2031 354,002,583 109,405,779 65,643,467 6,980,089 $26.84 $120,695,860 

2032 330,426,256 102,322,177 61,393,306 6,528,155 $27.14 $106,656,975 

2033 305,566,320 94,561,419 56,736,852 6,033,019 $27.44 $93,132,411 

2034 277,818,352 86,257,929 51,754,758 5,503,256 $27.74 $80,270,002 

2035 244,093,866 75,537,979 45,322,788 4,819,323 $28.04 $66,418,182 

2036 211,309,412 65,564,963 39,338,978 4,183,045 $28.35 $54,470,432 

2037 177,905,463 55,055,129 33,033,077 3,512,517 $28.66 $43,216,955 

2038 146,852,945 45,325,249 27,195,150 2,891,751 $28.98 $33,617,387 

2039 117,735,208 36,410,591 21,846,354 2,322,996 $29.30 $25,516,368 

2040 90,638,289 28,086,217 16,851,730 1,791,901 $29.62 $18,597,380 

2041 65,213,432 20,287,480 12,172,488 1,294,341 $29.95 $12,692,699 

2042 43,967,516 13,740,399 8,244,239 876,637 $30.28 $8,122,554 

2043 27,340,433 8,571,813 5,143,088 546,882 $30.61 $4,787,771 

2044 16,183,085 5,067,221 3,040,333 323,289 $30.95 $2,674,225 

2045 9,007,990 2,833,254 1,699,952 180,762 $31.29 $1,412,801 

2046 5,008,050 1,591,150 954,690 101,515 $31.63 $749,677 

2047 2,893,266 941,861 565,117 60,091 $31.98 $419,292 

2048 1,660,963 541,980 325,188 34,578 $32.33 $227,972 

2049 954,451 314,357 188,614 20,056 $32.68 $124,936 

2050 621,960 205,790 123,474 13,129 $33.04 $77,278 

2051 407,405 136,099 81,659 8,683 $33.41 $48,290 

2052 258,259 86,275 51,765 5,504 $33.78 $28,923 

2053 178,283 59,558 35,735 3,800 $34.15 $18,866 

2054 123,882 41,384 24,831 2,640 $34.52 $12,386 

Lifetime Net Present Value of Refueling Time Savings (2010$): $1,743,629,547 

Adjusted for Expected Fuel Tank Downsizing and Resulting Secondary Time Savings (2010$): $1,220,540,683 

465 Value of refueling time is adjusted upward from 2010 level of $21.45 to account for annual real wage growth of 1.1%. 
                                                      

 

890 

Table VIII-13 demonstrates the progressive decrease over time in the value of future years’ 

benefits due to the decline in the number of surviving vehicles, the reduction in miles that those 

vehicles are driven, and discounting of future benefits. Over the 30-year lifetime of the 

passenger car fleet in this example, the net present value of discounted benefits is about $1,221 

million. About 84 percent of that benefit is realized by the end of the fleet’s first decade of 

service. Again, the preceding example of Tables VIII-15, VIII-16, and VIII-17 is intended to be 

illustrative only of the logic applied in the CAFE model’s estimation of refueling time savings; 

due to simplifications made for the sake of allowing this empirical example, this value differs 

somewhat from the value of refueling time savings calculated within the CAFE model. 

Since a reduction in the expected number of annual refueling trips leads to a decrease in miles 

driven to and from fueling stations, we can also calculate the value of consumers’ fuel savings 

associated with this decrease. As shown in Table VIII-8, the typical incremental round-trip 

mileage per refueling cycle is 1.08 miles for light trucks and 0.97 miles for passenger cars. 

Going back to the earlier example of a light truck model, a decrease of 1.6 in the number of 

refuelings per year leads to a reduction of 1.73 miles driven per year (= 1.6 refuelings x 1.08 

miles driven per refueling). Again, if this model’s actual on-road fuel economy was 24 mpg, the 

reduction in miles driven yields an annual savings of approximately 0.07 gallons of fuel (= 1.73 

miles / 24 mpg), which at $3.77/gallon466 results in a savings of $0.27 per year to the owner. 

Note that this example is illustrative only of the approach NHTSA uses to quantify this benefit; 

in practice, the societal value of this benefit must exclude fuel taxes (as they are transfer 

payments) from the calculation, and must be modeled using fuel price forecasts specific to each 

year the given fleet will remain in service. 

The annual savings to each consumer shown in the above example may seem like a small 

amount, but the reader should recognize that the valuation of the cumulative lifetime benefit of 

this savings to owners is determined separately for passenger car and light truck fleets and then 

aggregated to show the net benefit across all light-duty vehicles – which is much more 

significant at the macro level. Calculations of benefits realized in future years are adjusted for 

expected real growth in the price of gasoline, for the decline in the number of vehicles of a given 

model year that remain in service as they age, for the decrease in the number of miles (VMT) 

driven by those that stay in service, and for the percentage of refueling trips that occur for 

466 Estimate of $3.77/gallon is in 2010$. This figure is an average of forecasted cost per gallon (including taxes, as 

individual consumers consider reduced tax expenditures to be savings) for motor gasoline for years 2017 to 2027. 

Source of price forecasts: U.S. Energy Information Administration, Annual Energy Outlook Early Release 2012 (see 

Table VIII-5a). 
891 

reasons other than a low reading on the gas gauge; a discount rate is also applied in the valuation 

of future benefits. NHTSA considered using this direct estimation approach to quantify the 

value of this benefit by model year, however concluded that the value of this benefit is implicitly 

captured in the separate measure of overall valuation of fuel savings. Therefore direct estimates 

of this benefit are not added to net benefits calculations. 

We note that there are other benefits resulting from the reduction in miles driven to and from 

fueling stations, such as a reduction in greenhouse gas emissions – CO2 in particular – which, as 

per the case of fuel savings discussed in the preceding paragraph are implicitly accounted for 

elsewhere in the CAFE model. 

Special mention must be made with regard to the value of refueling time savings benefits to 

owners of electric and plug-in electric (both referred to here as EV) vehicles. EV owners who 

routinely drive daily distances that do not require recharging on-the-go may eliminate the need 

for trips to fueling or charging stations. It is likely that early adopters of EVs will factor this 

benefit into their purchasing decisions and maintain driving patterns that require once-daily athome recharging (a process which takes two to six hours for a full charge). However, EV 

owners who regularly or periodically need to drive distances further than the fully-charged EV 

range may need to recharge at fixed locations. A distributed network of charging stations (e.g., 

in parking lots, at parking meters) may allow some EV owners to recharge their vehicles while at 

work or while shopping, yet the lengthy charging cycles of current charging technology may 

pose a cost to owners due to the value of time spent waiting for EVs to charge. Moreover, EV 

owners who primarily recharge their vehicles at home will still experience some level of 

inconvenience due to their vehicle being either unavailable for unplanned use, or to its range 

being limited during this time should they interrupt the charging process. Therefore, at present 

EVs hold potential in offering significant time savings to owners with driving patterns optimally 

suited for EV characteristics. If fast-charging technologies emerge and a widespread network of 

fast-charging stations is established, it is expected that a larger segment of EV vehicle owners 

will fully realize the potential refueling time savings benefits that EVs offer. This is an area of 

significant uncertainty. Although one peer reviewer requested NHTSA elaborate quantitatively 

on refueling time savings in relation to EVs, the particular characteristics of EVs and the synergy 

or lack thereof with regard to EV uptake by owners for whom driving patterns are optimally 

suited to the realization of refueling time savings limit NHTSA from rigorously addressing this 

topic within the scope of this analysis. 
 

                                                      

 

892 

C. Other Economic Benefits from Reducing U.S. Petroleum Use 

Reducing fuel use by requiring cars and light trucks to attain higher fuel economy also produces 

wider benefits to the U.S. economy by lowering the cost of economic externalities that result 

from U.S. petroleum consumption and imports, including reducing the price of petroleum, 

lowering the potential costs from disruption in the flow of oil imports, and possibly reducing 

outlays to support U.S. military activities to secure the flow of oil imports and to cushion the 

economy against their possible interruption by maintaining the Strategic Petroleum Reserve. 

Reducing fuel consumption also lowers the economic costs of environmental externalities 

resulting from fuel production and use, including reducing the impacts on human health impacts 

from emissions of criteria air pollutants, and reducing future economic damages from potential 

changes in the global climate caused by greenhouse gas emissions. 

Economic Externalities from U.S. Petroleum Imports 

U.S. consumption and imports of petroleum products imposes costs on the domestic economy 

that are not reflected in the market price for crude petroleum, or in the prices paid by consumers 

of petroleum products such as gasoline. These costs include (1) higher prices for petroleum 

products resulting from the effect of U.S. oil import demand on the world oil price; (2) the risk of 

disruptions to the U.S. economy caused by sudden reductions in the supply of imported oil to the 

U.S.; and (3) expenses for maintaining a U.S. military presence to secure imported oil supplies 

from unstable regions, and for maintaining the strategic petroleum reserve (SPR) to cushion 

against resulting price increases.467 

Higher U.S. consumption and imports of crude oil or refined petroleum products can raise the 

magnitude of these external economic costs, thus increasing the true economic cost of supplying 

transportation fuels above the resource costs of producing them. Conversely, reducing fuel 

consumption by requiring motor vehicles to achieve higher fuel economy will lower U.S. 

consumption and imports of crude petroleum and refined fuels, thus lowering the values of these 

external costs. Any reduction in their value that results from requiring improved vehicle fuel 

467 See, e.g., Bohi, Douglas R. and W. David Montgomery (1982). Oil Prices, Energy Security, and Import Policy 

Washington, DC: Resources for the Future, Johns Hopkins University Press; Bohi, D. R., and M. A. Toman (1993). 

"Energy and Security: Externalities and Policies," Energy Policy 21:1093-1109; and Toman, M. A. (1993) (Docket 

NHTSA-2009-0062-24). "The Economics of Energy Security: Theory, Evidence, Policy," in A. V. Kneese and J. L. 

Sweeney, eds. (1993) (Docket NHTSA-2009-0062-23). Handbook of Natural Resource and Energy Economics, Vol. 

III. Amsterdam: North-Holland, pp. 1167-1218. 
 

                                                      

 

 

 

 

893 

economy represents an additional economic benefit of raising CAFE standards, over and above 

the economic value of saving fuel itself. 

Increased U.S. petroleum consumption can impose higher costs on all purchasers of petroleum 

products, because the U.S. is a sufficiently large purchaser of foreign oil supplies that changes in 

U.S. demand can affect the world petroleum price. The effect of U.S. petroleum demand on 

world oil prices is determined by the degree of OPEC monopoly power over global oil supplies, 

and the degree of monopsony power over world oil demand that the U.S. exercises. The 

importance of these two factors means that increases in domestic demand for petroleum products 

that are met through higher oil imports can cause the price of oil in the world market to rise, 

which imposes economic costs on all other purchasers in the global petroleum market in excess 

of the higher prices paid by U.S. consumers.468 Conversely, reducing U.S. oil imports can lower 

the world petroleum price, and thus generate benefits to other oil purchasers by reducing these 

“monopsony costs.” 

Although the degree of current OPEC monopoly power is subject to considerable debate, the 

consensus appears to be that OPEC remains able to exercise some degree of control over the 

response of world oil supplies to variation in world oil prices, so that the world oil market does 

not behave competitively.469 The extent of U.S. monopsony power is determined by a complex 

set of factors including the relative importance of U.S. imports in the world oil market, and the 

sensitivity of petroleum supply and demand to its world price among other participants in the 

international oil market. Most evidence appears to suggest that variation in U.S. demand for 

imported petroleum continues to exert some influence on world oil prices, although this 

influence appears to be limited.470 

468 For example, if the U.S. imports 10 million barrels of petroleum per day at a world oil price of $80 per barrel, its 

total daily import bill is $800 million. If increasing imports to 11 million barrels per day causes the world oil price 

to rise to $81 per barrel, the daily U.S. import bill rises to $891 million. The resulting increase of $91 million per 

day ($891 million minus $800 million) is attributable to increasing daily imports by only 1 million barrels. This 

means that the incremental cost of importing each additional barrel is $91, or $10 more than the newly-increased 

world price of $81 per barrel. This additional $10 per barrel represents a cost imposed on all other purchasers in the 

global petroleum market by U.S. buyers, in excess of the price they pay to obtain those additional imports. 

469 For a summary see Leiby, Paul N., Donald W. Jones, T. Randall Curlee, and Russell Lee, Oil Imports: An 

Assessment of Benefits and Costs, ORNL-6851, Oak Ridge National Laboratory, November 1, 1997, at 17. 

Available at http://www.esd.ornl.gov/eess/energy_analysis/files/ORNL6851.pdf (last accessed August 1, 2012) 470 Id., at 18-19. 
 

                                                      

 

 

894 

In analyzing benefits from increased light truck CAFE standards for model years 2005-07 and 

2008-11, NHTSA relied on a 1997 study by Oak Ridge National Laboratories (ORNL) to 

estimate the value of reduced economic externalities from petroleum consumption and 

imports.471 ORNL subsequently updated its estimates of the value of these externalities, using 

the analytic framework developed in its original 1997 study in conjunction with recent estimates 

of the variables and parameters that determine their value. 472 These include world oil prices, 

current and anticipated future levels of OPEC petroleum production, U.S. oil import levels, the 

estimated responsiveness of regional oil supplies and demands to prices in different regions of 

the world, and the likelihood of oil supply disruptions. ORNL prepared its updated estimates of 

oil import externalities for use by EPA in evaluating the benefits of reductions in U.S. oil 

consumption and imports expected to result from its Renewable Fuel Standard Rule of 2007 

(RFS)473. 

The updated ORNL study was subjected to a detailed peer review, and was subsequently revised 

by ORNL to reflect the reviewers’ comments and recommendations. Specifically, reviewers 

recommended that ORNL increase its estimates of the sensitivity of oil supply by non-OPEC 

producers and oil demand by nations other than the U.S. to changes in the world oil price, as well 

as reduce its estimate of the sensitivity of U.S. gross domestic product (GDP) to potential sudden 

increases in world oil prices.474 These revisions significantly changed ORNL’s estimates of 

some components of the external costs of U.S. petroleum imports, and NHTSA used the revised 

values in its evaluation of proposed CAFE standards for MY 2012-16 passenger cars and light 

trucks.475 

At the request of EPA, ORNL provided further revisions to its earlier estimates of external costs 

from U.S. oil imports to reflect changes in the outlook for world petroleum prices (using various 

editions of EIA’s Annual Energy Outlook), as well as continuing changes in the structure and 

characteristics of global petroleum supply and demand. ORNL provided updates of its earlier 

471 Leiby, Paul N., Donald W. Jones, T. Randall Curlee, and Russell Lee, Oil Imports: An Assessment of Benefits 

and Costs, ORNL-6851, Oak Ridge National Laboratory, November 1, 1997. Available at 

http://www.esd.ornl.gov/eess/energy_analysis/files/ORNL6851.pdf (last accessed August 1, 2012) 472 Leiby, Paul N. "Estimating the Energy Security Benefits of Reduced U.S. Oil Imports," Oak Ridge National 

Laboratory, ORNL/TM-2007/028, Revised July 23, 2007. Available at 

http://www.esd.ornl.gov/eess/energy_analysis/files/Leiby2007%20Estimating%20the%20Energy%20Security%20B
 

enefits%20of%20Reduced%20U.S.%20Oil%20Imports%20ornl-tm-2007-028%20rev2007Jul25.pdf (last accessed 

August 1, 2012). 

473 Federal Register Vol.72, #83, May 1, 2007 pp.23,900-24,014 474 Peer Review Report Summary: Estimating the Energy Security Benefits of Reduced U.S. Oil Imports, ICF, Inc., 

September 2007. Docket NHTSA-2009-0059-0160.

475 Leiby, Paul N. "Estimating the Energy Security Benefits of Reduced U.S. Oil Imports," Oak Ridge National
 

Laboratory, ORNL/TM-2007/028, Final Report, 2008. 
                                                      

 

895 

estimates to EPA in 2010 and 2011, and NHTSA used these estimates in its evaluations of final 

CAFE standards for MY 2012-16, and proposed standards for MY 2017-25 cars and light 

trucks.476 More recently, ORNL has once again supplied revised estimates of external costs 

from U.S. petroleum imports to EPA, and NHTSA has elected to use these most recently updated 

values in evaluating alternative CAFE standards for this final rule.477 

These most recent revisions increase ORNL’s estimates of the monopsony cost associated with 

U.S. oil imports in the year 2025 to $3.25 to $16.69 per barrel, with a most likely estimate of 

$9.77 per barrel of petroleum imported into the U.S. (expressed in 2010 dollars). These 

estimates imply that each gallon of fuel saved as a result of adopting higher CAFE standards that 

is reflected in lower U.S. imports of crude petroleum (or, presumably, refined petroleum 

products) will reduce the monopsony costs imposed by U.S. oil imports by $0.077 to $0.397 per 

gallon, with the actual value most likely to be $0.233 per gallon saved (again in 2010 dollars). 

These figures represent the reduced value of payments from U.S. oil purchasers to foreign oil 

suppliers that results when lower U.S. oil demand reduces the world price of petroleum, beyond 

the savings from reduced purchases of petroleum itself.478 Consistency with NHTSA’s use of 

estimates of the global benefits from reducing emissions of CO2 and other greenhouse gases in 

this analysis, however, requires the use of a global perspective for assessing their net value. 

From this perspective, reducing these payments simply results in a transfer of resources from 

foreign oil suppliers to U.S. purchasers (or more properly, in a savings in the value of resources 

previously transferred from U.S. purchasers to foreign producers), and provides no real savings 

in resources to the global economy. Thus NHTSA’s analysis of the benefits from adopting the 

higher CAFE standards it proposed for MY 2017-2025 cars and light trucks excluded the 

reduced value of monopsony payments by U.S. oil consumers that might result from lower fuel 

consumption by these vehicles. 

In comments on those proposed standards, ACEEE stated that not including an estimate for 

monopsony value was a “departure from previous rules,” and argued that monopsony effects 

should be counted among the final rule’s economic benefits, because (1) reduction in the price of 

476 Paul N. Leiby, "Energy Security Estimate Updated to AEO 2009," Oak Ridge National Laboratory, undated; and 

Paul N. Leiby, “Approach to Estimating the U.S. Oil Security Premium for the Proposed 2017-2025 Light -Duty 

Vehicle GHG/Fuel Economy Rule,” Oak Ridge National Laboratory, October 14, 2011.

477 Paul N. Leiby, "Estimating the U.S. Oil Security Premium for the 2017-2025 Light -Duty Vehicle GHG/Fuel 

Economy Rule", Oak Ridge National Laboratory (ORNL), July 15, 2012.

478 The reduction in payments from U.S. oil purchasers to domestic petroleum producers is not included as a benefit,
 

since it represents a transfer that occurs entirely within the U.S. economy.
 
 

                                                      

 

896 

petroleum would bring a net benefit in terms of job creation due to the low labor intensity of the 

energy sector, and (2) reduced demand means that the most expensive sources of petroleum are 

not used, which also reduces the price of all petroleum.479 CFA commented simply that the 

monopsony effect is a true consumption externality, and should be included for the final rule at a 

value of $0.30/gallon.480 SAFE suggested that even if reducing domestic demand for oil does 

not necessarily lead to lower fuel prices, it might lead to production levels that are adjusted 

downward based on expectations that increased fuel economy will reduce aggregate demand.481 

UCS argued that if the purpose of the CAFE program is conserve energy and improve energy 

security by raising fuel economy standards, NHTSA must include a value for the monopsony 

effect in the final rule or risk “abdication of [its] statutory responsibility.”482 

In fact, NHTSA previously excluded any reduction in these monopsony costs resulting from 

lower U.S. fuel consumption in its analyses of CAFE standards for MY 2008-11 light trucks, 

MY 2011 passenger cars and light trucks, and MY 2012-16 cars and light trucks. The rationale 

for doing so – namely that these costs represent a financial transfer rather than a use of real 

economic resources, and that reducing them does not provide a savings in the use of economic 

resources – is thus well-established, remains sound, and is consistent with the global perspective 

of NHTSA’s analysis of this final rule. The agency also notes that job “creation” is not among 

the economic benefits attributable to higher CAFE standards (and in any case increased 

employment represents the consumption of additional economic resources, which is an economic 

cost), and that any reduction in the price of petroleum that continues to be purchased after a 

decline in total demand also represents a financial transfer rather than a true economic benefit. 

In response to the assertion by CFA, the monopsony effect does not meet the definition of a 

consumption externality, because it is transmitted completely through the price mechanism and 

does not directly affect the welfare of individuals or the production functions of firms. Further, 

the economic benefit resulting from any decline in production levels of crude petroleum is 

already accounted for in the agency’s estimates of the (pre-tax) value of fuel savings. Finally, by 

excluding any reduction in monopsony payments from its analysis of benefits from higher fuel 

economy, the agency is simply being consistent with the usual principles of economic analysis 

and with OMB guidelines for conducting regulatory analysis, and is thus in no way failing to 

meet its statutory responsibilities. Thus NHTSA has continued to do so in its analysis of the 

alternative CAFE standards considered in this final rule. 

479 ACEEE, Docket No. NHTSA-2010-0131-0062, at 1-2. 480 CFA, Docket No. NHTSA-2010-0131-0073, at 16, 54-55. 481 SAFE, Docket No. NHTSA-2010-0131-0259, at 4. 482 UCS, Docket No. EPA-HQ-OAR-2010-0799-9567, at 6-7. 
897 

The second component of external economic costs imposed by U.S. petroleum imports arises 

partly because an increase in oil prices triggered by a disruption in the supply of imported oil 

reduces the level of output that the U.S. economy can produce. The reduction in potential U.S. 

economic output depends on the extent and duration of the increases in petroleum product prices 

that result from a disruption in the supply of imported oil, as well as on whether and how rapidly 

these prices return to pre-disruption levels. Even if prices for imported oil return completely to 

their original levels, however, economic output will be at least temporarily reduced from the 

level that would have been possible without a disruption in oil supplies. 

Because supply disruptions and resulting price increases tend to occur suddenly rather than 

gradually, they can also impose costs on businesses and households for adjusting their use of 

petroleum products more rapidly than if the same price increase had occurred gradually over 

time. These adjustments impose costs because they temporarily reduce economic output even 

below the level that would ultimately be reached once the U.S. economy completely adapted to 

higher petroleum prices. The additional costs to businesses and households reflect their inability 

to adjust prices, output levels, and their use of energy and other resources quickly and smoothly 

in response to rapid changes in prices for petroleum products. 

Since future disruptions in foreign oil supplies are an uncertain prospect, each of these disruption 

costs must be adjusted by the probability that the supply of imported oil to the U.S. will actually 

be disrupted. The “expected value” of these costs – the product of the probability that an oil 

import disruption will occur and the costs of reduced economic output and abrupt adjustment to 

sharply higher petroleum prices – is the appropriate measure of their magnitude. Any reduction 

in the expected value of these costs resulting from a measure that lowers U.S. oil imports 

represents an additional benefit to the U.S. economy beyond the direct value of savings from 

reduced purchases of petroleum products. 

While the vulnerability of the U.S. economy to oil price shocks is widely believed to depend on 

total petroleum consumption rather than on the level of oil imports, variation in imports is still 

likely to have some effect on the magnitude of price increases resulting from a disruption of 

import supply. In addition, changing the quantity of petroleum imported into the U.S. may also 

affect the probability that such a disruption will occur. If either the size of the likely price 

increase or the probability that U.S. oil supplies will be disrupted is affected by the volume of 
                                                      

 

 

898 

U.S. oil imports, the expected value of the economic costs resulting from potential supply 

disruptions will also depend on the level of imports.483 

Businesses and households use a variety of market mechanisms, including oil futures markets, 

energy conservation measures, and technologies that permit rapid fuel switching to “insure” 

against higher petroleum prices and reduce their costs for adjusting to sudden price increases. 

While the availability of these market mechanisms has probably reduced the potential costs of 

disruptions to the supply of imported oil over time, consumers of petroleum products are 

unlikely to take account of costs they impose on others, so these costs are probably not fully 

reflected in the price of imported oil. Thus changes in oil import levels probably continue to 

affect the expected cost to the U.S. economy from potential oil supply disruptions, although this 

component of oil import costs is likely to be significantly smaller than estimated by studies 

conducted in the wake of the oil supply disruptions that occurred during the 1970s. 

In its analysis of benefits from the higher CAFE standards it previously proposed for MY 2017­

25, NHTSA employed ORNL’s 2011 estimates of costs from potential disruptions in global oil 

supplies and resulting price increases for petroleum products. These ranged from $0.081 to 

$0.278 for each gallon of fuel saved that ultimately results in a reduction in U.S. petroleum 

imports, with a most likely value of $0.174 per gallon (these figures are in 2009 dollars for 

consistency with those reported in the agency’s preliminary RIA). The agency noted that unlike 

the reduction in monopsony payments, lowering these expected disruption costs by reducing 

petroleum imports represents a real savings in the use of economic resources. Thus it contributes 

economic benefits in addition to the savings in resource costs for producing fuel itself that results 

from higher fuel economy. 

In response, several environmental groups and other NGOs commented that the standards would 

have significant energy security benefits in terms of avoiding macroeconomic disruption. UCS 

stated that “No other federal policy has delivered greater oil savings, energy security benefits, or 

greenhouse gas emissions reductions to the country,” and requested that we monetize improved 

energy security through reduced oil consumption and lower carbon emissions for the final rule 

analysis.484 EDF described a study by Jamie Fine that found “that cost savings from avoided 

483 Leiby, Paul N. "Estimating the Energy Security Benefits of Reduced U.S. Oil Imports," Oak Ridge National 

Laboratory, ORNL/TM-2007/028, Final Report, 2008. The exact dependence of disruption costs on the volume of 

U.S. petroleum imports is demonstrated in equations (12) and (13), p. 38, and the accompanying discussion on pp. 

37-39.
 484 UCS, Docket No. EPA-HQ-OAR-2010-0799-9567, at 5-6. 
 

                                                      

 

899 

gasoline and diesel use in the event of an energy price shock in 2020 could be in the range of 

$2.4 to $5.2 billion for the state of California alone” under California’s plan to reduce GHGs to 

1990 levels by 2020, and requested that the agencies at least report a range of estimates for 

benefits associated with energy security.485 EDF suggested that the agencies “consider cost 

estimation proposals such as that included in Sen. Richard Lugar’s (R-Ind.) Practical Energy and 

Climate Plan, S. 3464,” which “included both an extensive list of potential impacts of energy 

security to be considered and an alternative approximation valuation methodology for the 

“external cost of petroleum use” (i.e. this does not include the actual fuel savings).”486 EDF 

stated that “For inputs that the agencies cannot quantify, the final rule should include a list and 

explain that the benefits of the rule are likely undervalued due to such factors.”487 SAFE 

commented simply that electrification of the fleet is good for energy security because it reduces 

the risk of macroeconomic disruptions, as a domestic fuel source.488 

In response to these comments, the agency notes that its estimate of benefits from reducing U.S. 

petroleum consumption and imports incorporates both the potential economic cost of oil supply 

disruptions and the reduced probability that such disruptions will occur, exactly as advocated by 

UCS and other commenters. In addition, the agency analyzes the sensitivity of its benefit 

estimates to plausible variation in the per-gallon value of reduced macroeconomic disruption 

costs that result from lowering U.S. petroleum consumption and imports. Thus NHTSA feels 

that it has anticipated and responded fully to the comments it received on this issue. 

ORNL’s most recently updated and revised estimates of the increase in expected costs associated 

with oil supply disruptions to the U.S. and the resulting rapid increase in prices for petroleum 

products amount to $4.03 to $11.92 per barrel of oil imported into the U.S. in the year 2025, with 

a most likely estimate of $8.26 per barrel of imports (all figures are in 2010 dollars).489 

According to these estimates, each gallon of fuel saved that results in a reduction in U.S. 

petroleum imports (either crude petroleum or refined fuel) will reduce the expected costs of oil 

supply disruptions to the U.S. economy by $0.096 to $0.284, with the actual value most likely to 

be $0.197 per gallon (again in 2010 dollars). Unlike the reduction in monopsony payments that 

results from lower U.S. petroleum imports, however, the reduction in these expected disruption 

costs represents a real savings in resources, and thus contributes economic benefits in addition to 

the savings in resource costs for fuel production that would result from increasing fuel economy. 

485 EDF, Docket No. NHTSA-2010-0131-0302, at 3-4, 15. 486 Id. at 15. 487 Id. 488 SAFE, Docket No. NHTSA-2010-0131-0259, at 6-7. 489 Paul N. Leiby, "Estimating the U.S. Oil Security Premium for the 2017-2025 Light -Duty Vehicle GHG/Fuel 

Economy Rule", Oak Ridge National Laboratory (ORNL), July 15, 2012.
 
900 

NHTSA employs these values in its evaluation of the economic benefits from adopting higher 

CAFE standards for MY 2017-2025 cars and light trucks. 

The third component of the external economic costs of importing oil into the U.S. includes 

government outlays for maintaining a military presence to secure the supply of oil imports from 

potentially unstable regions of the world and protect against their interruption. Some analysts 

also include outlays for maintaining the U.S. Strategic Petroleum Reserve (SPR) as an additional 

cost of U.S. dependence on oil imports, since the SPR is intended to cushion the U.S. economy 

against the consequences of disruption in the supply of imported oil. 

NHTSA believes that while costs for U.S. military security may vary over time in response to 

long-term changes in the actual level of oil imports into the U.S., these costs are unlikely to 

decline in response to any reduction in U.S. oil imports resulting from raising future CAFE 

standards for light-duty vehicles. U.S. military activities in regions that represent vital sources of 

oil imports also serve a broader range of security and foreign policy objectives than simply 

protecting oil supplies, and as a consequence are unlikely to vary significantly in response to 

changes in the level of oil imports prompted by higher standards. 

Neither the Congress nor the Executive Branch has ever attempted to calibrate U.S. military 

expenditures, force levels, or deployments to any oil market variable, or to some calculation of 

the projected economic consequences of hostilities in the Persian Gulf. Instead, changes in U.S. 

force levels, deployments, and thus military spending in that region have been largely governed 

by political events, emerging threats, and other military and political considerations, rather than 

by shifts in U.S. oil consumption or imports. NHTSA thus concluded that the levels of U.S. 

military activity and expenditures are likely to remain unaffected by even relatively large 

changes in light duty vehicle fuel consumption. As a consequence, the agency’s analysis of this 

rule does not include savings in budgetary outlays to support U.S. military activities among the 

benefits of higher fuel economy and the resulting fuel savings. 

However, the agency conducted a sensitivity analysis of the potential effect of assuming that 

some reduction in military spending would result from fuel savings and reduced petroleum 

imports in order to investigate its impacts on the standards and fuel savings. Using estimates of 

total U.S. military costs for securing Persian Gulf oil supplies and the volume of imports from 

that region in 2004 reported by Delucchi and Murphy, the agency estimated the potential savings 

in military outlays under the assumption that those would decline in exact proportion to any 
 

 

                                                      

 

901 

reduction in U.S. petroleum imports. Under that assumption, the estimated savings in military 

spending would range from $0.03 to $0.17 (in 2010 dollars) for each gallon of fuel saved as a 

result of higher CAFE standards that in turn resulted in lower U.S. imports of petroleum from the 

Persian Gulf.490 If the Persian Gulf region is assumed to be the marginal source of supply for 

U.S. imports of crude petroleum and refined products, then each gallon of fuel saved might 

reduce U.S. military outlays by some amount within the above range. NHTSA selected a value 

of $0.12 per gallon for its sensitivity analysis involving the military security component, slightly 

above the midpoint of the range identified by Delucchi and Murphy. 

In both written comments and at the agencies’ public hearings, many commenters expressed their 

beliefs that these standards will have significant benefits for U.S. energy and national security. 

A number of commenters, including consumer advocacy and environmental organizations, 

organizations representing labor, and state and local governments, as well as energy security 

advocates and numerous private individuals, urged NHTSA to quantify to the extent possible, a 

military component of the energy security benefits associated with this rulemaking. Some 

commenters recognized that deriving a single estimate of the energy security benefits from 

reduced military costs as a result of the rule would be difficult, and suggested that even 

providing a range of potential savings would be useful. The American Petroleum Institute 

commented that military expenditures will not likely change with a reduction in U.S. oil imports, 

and therefore should not be included in the assessment of this rulemaking. 

NHTSA examined possible approaches to estimating the military component of energy security 

benefits from this final rule, and found that research addressing this question faces two major 

challenges. The first is the difficulty of correctly attributing specific military programs and 

expenditures to oil the goal of protecting petroleum supplies, rather than to other objectives. The 

second challenge arises in estimating whether and how extensively these costs would be likely to 

vary if U.S petroleum consumption or imports could be reduced. 

Recent studies commonly estimate that there are substantial U.S. military costs associated with 

the mission of securing oil supplies, but do not identify specific cost reductions that would be 

likely to result from reductions in U.S. oil consumption or imports. At one extreme, the Council 

on Foreign Relations noted that substantial foreign policy-related military missions will continue 

over the next 20 years even in the absence of any need to secure imported petroleum supplies for 

the U.S. From this perspective, even eliminating U.S. petroleum consumption and imports 

would not result in significant reductions in military spending. In their previously cited study, 

Delucchi and Murphy deducted costs they attributed to missions other than securing petroleum 

490 Mark A. Delucchi and James J. Murphy. “US Military Expenditures to Protect the Use of Persian Gulf Oil for 

Motor Vehicles.” Energy Policy, Volume 36, Issue 6, June 2008, pages 2253-2264. Available at 

http://www.sciencedirect.com/science/article/pii/S0301421508001262 (last accessed August 1, 2012). The 

estimates reported here were converted to 2010 dollars using the change in the GDP price deflator. 
 

                                                      

 

902 

supplies from the total cost of Persian Gulf military programs, and arrived at estimates of 

military spending to secure U.S. oil interests ranging from $18 to $59 billion in 2004 (expressed 

in 2010 dollars).491 

In another recent study, RAND considered force reductions and cost savings that could be 

achieved if oil security were no longer a consideration.492 Using two different approaches and 

guided by the history of post Cold-War force reductions and a detailed examination of the 

current U.S. allocation of defense resources, RAND concluded that $75–$91 billion, or 12–15 

per cent of the U.S. defense budget in 2009, could be reduced if U.S. dependence on imported oil 

were eliminated entirely. However, the study also concluded that the reduction in military costs 

from a partial reduction in the U.S. dependence on imported oil would be minimal. In another 

study, Stern developed an estimate of military cost for Persian Gulf force projection using an 

activity-based allocation method to distinguish costs related to securing oil imports.493 He used 

information on actual naval force deployments rather than budgets to guide his cost allocation, 

focusing on the costs of aircraft carrier deployment. For the 1976–2007 period, Stern estimated 

average military costs for securing U.S. petroleum imports of $212 billion annually and $500 

billion for 2007 alone, and argued that these costs could potentially be reduced as a consequence 

of lower U.S. oil imports. 

Although these recent studies provide useful insights into the military components of U.S. 

energy security, they do not provide an estimate of potential savings in military spending from 

reduced U.S. petroleum imports that the agency regards as sufficiently reliable for use in this 

rulemaking. Even studies that carefully attribute specific missions to the objective of securing 

international oil production and distribution offer little guidance about the degree to which 

incremental reductions in U.S. dependence on imported oil would reduce or eliminate those 

missions or programs. While NHTSA will continue to review newer studies in an attempt to 

estimate a military spending component of U.S. energy security benefits, the agency continues to 

exclude military cost savings from its estimate of energy security benefits used to analyze the 

impacts of this final rule. 

Similarly, while the ideal size of the Strategic Petroleum Reserve from the standpoint of its 

potential influence on domestic oil prices during a supply disruption may be related to the level 

of U.S. oil consumption and imports, its actual size has not appeared to vary in response to 

recent changes in oil imports. Thus while the budgetary costs for maintaining the Reserve are 

491 Mark A. Delucchi and James J. Murphy. “US Military Expenditures to Protect the Use of Persian Gulf Oil for 

Motor Vehicles.” Energy Policy, Volume 36, Issue 6, June 2008, pages 2253-2264. The estimates reported by the 

authors were converted to 2010 dollars using the change in the GDP price deflator.

492 Keith Crane et al., “Does Imported Oil Threaten U.S. National Security?” Santa Monica, CA, The RAND 

Corporation, 2009. Research brief available at http://www.rand.org/pubs/research_briefs/2009/RAND_RB9448.pdf 

(last accessed August 1, 2012) 

493 R.J. Stern, “United States cost of military force projection in the Persian Gulf, 1976–2007”, Energy Policy, 2010. 
 

                                                      

 

 

 

903 

similar to other external costs in that they are not likely to be reflected in the market price for 

imported oil, these costs do not appear to have varied in response to changes in oil import levels. 

As a result, the agency’s analysis of benefits from these final CAFE standards for MY 2017­

2025 does not include cost savings from maintaining a smaller SPR among the external benefits 

of reducing gasoline consumption and petroleum imports. This view concurs with that of the 

recent ORNL study of economic costs from U.S. oil imports, which concludes that savings in 

government outlays to maintain the U.S. petroleum reserves are unlikely to result from 

reductions in consumption of petroleum products and oil imports on the scale of those resulting 

from the increases in CAFE standards considered for MY 2017-25. 

The Impact of Fuel Savings on U.S. Petroleum Imports 

Based on a detailed analysis of differences in fuel consumption, petroleum imports, and imports 

of refined petroleum products among the Reference Case, High Economic Growth, and Low 

Economic Growth Scenarios presented in the Energy Information Administration’s Annual 

Energy Outlook 2009, NHTSA estimates that approximately 50 percent of the reduction in fuel 

consumption resulting from adopting higher CAFE 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.494 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.495 Thus on balance, each 

gallon of fuel saved as a consequence of higher CAFE standards is anticipated to reduce total 

U.S. imports of crude petroleum or refined fuel by 0.95 gallons.496 

The Economic Value of Reducing CO2 Emissions 

NHTSA has taken the economic benefits of reducing CO2 emission into account in this 

rulemaking, both in developing alternative CAFE standards and in assessing the economic 

benefits of each alternative that was considered. Since direct estimates of the economic benefits 

from reducing CO2 or other GHG emissions are generally not reported in published literature on 

494 Differences in forecasted annual U.S. imports of crude petroleum and refined products among the Reference,
 

High Oil Price, and Low Oil Price scenarios analyzed in EIA’s Annual Energy Outlook 2011 range from 35-74
 

percent of differences in projected annual gasoline and diesel fuel consumption in the U.S. These differences
 

average 53 percent over the forecast period spanned by AEO 2011. 495Differences in forecasted annual U.S. imports of crude petroleum among the Reference, High Oil Price, and Low 

Oil Price scenarios analyzed in EIA’s Annual Energy Outlook 2011 range from 67-104 percent of differences in
 

total U.S. refining of crude petroleum, and average 90 percent over the forecast period spanned by AEO 2011. 496 This figure is calculated as 0.50 + 0.50*0.9 = 0.50 + 0.45 = 0.95.
 
904 

the impacts of climate change, these benefits are typically assumed to be the “mirror image” of 

the estimated incremental costs resulting from an increase in those emissions. Thus, the benefits 

from reducing CO2 emissions are usually measured by the savings in estimated economic 

damages that an equivalent increase in emissions would otherwise have caused. 

The “social cost of carbon” (SCC) is intended to be a monetary measure of the incremental 

damage resulting from increased carbon dioxide (CO2) emissions, including losses in 

agricultural productivity, the economic damages caused by adverse effects on human health, 

property losses and damages resulting from sea level rise, and changes in the economic value of 

ecosystem services. The SCC is usually expressed in dollars per additional metric ton of CO2 

emissions occurring during a specified year, and is higher for more distant future years because 

the damages caused by an additional ton of emissions increase with larger existing 

concentrations of CO2 in the earth’s atmosphere. Reductions in CO2 emissions that are projected 

to result from lower fuel consumption, refining, and distribution during each future year are 

multiplied by the estimated SCC appropriate for that year, which is used to represent the value of 

eliminating each ton of CO2 emissions, to determine the total economic benefit from reduced 

emissions during that year. These benefits are then discounted to their present value as usual, 

using a discount rate that is consistent with that used to develop the estimate of the SCC itself. 

For these final MY 2017-2021 and augural MY 2022-2025 standards, NHTSA has relied on 

estimates of the SCC developed by a federal interagency working group convened for the 

specific purpose of developing new estimates to be used by U.S. federal agencies in regulatory 

evaluations. Under Executive Order 12866, federal agencies are required, to the extent permitted 

by law, “to assess both the costs and the benefits of the intended regulation and, recognizing that 

some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a 

reasoned determination that the benefits of the intended regulation justify its costs.” The group’s 

purpose in developing new estimates of the SCC was to allow federal agencies to incorporate the 

social benefits of reducing carbon dioxide (CO2) emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global emissions, as 

most federal regulatory actions can be expected to have. 

The interagency group convened on a regular basis to consider public comments, explore the 

technical literature in relevant fields, and discuss key inputs and assumptions in order to generate 

SCC estimates. Agencies that actively participated in the interagency process included the 

Environmental Protection Agency, and the Departments of Agriculture, Commerce, Energy, 

Transportation, and Treasury. This process was convened by the Council of Economic Advisers 

and the Office of Management and Budget, with active participation and regular input from the 
 

905 

Council on Environmental Quality, National Economic Council, Office of Energy and Climate 

Change, and Office of Science and Technology Policy. The main objective of this process was 

to develop a range of SCC values using a defensible set of input assumptions that are grounded 

in the existing literature. In this way, key uncertainties and model differences can more 

transparently and consistently inform the range of SCC estimates used in the rulemaking process. 

The interagency group developed its estimates of the SCC estimates while clearly 

acknowledging the many uncertainties involved, and with a clear understanding that they should 

be updated over time to reflect increasing knowledge of the science and economics of climate 

impacts. Technical experts from numerous agencies met on a regular basis to consider public 

comments, explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values using a 

defensible set of input assumptions grounded in the existing scientific and economic literature. In 

this way, key uncertainties and model differences transparently and consistently can inform the 

range of SCC estimates used in the rulemaking process. 

The group ultimately selected four SCC values for use in regulatory analyses. Three values are 

based on the average SCC from three integrated assessment models, using discount rates of 2.5, 

3, and 5 percent. The fourth value, which represents the 95th percentile SCC estimate across all 

three models at a 3 percent discount rate, is included to represent the possibility of higher-thanexpected impacts from temperature change that lie further out in the tails of the distribution of 

SCC estimates. Table VIII-14 summarizes the interagency group’s estimates of the SCC during 

various future years. The SCC estimates reported in the table assume that the marginal damages 

from increased emissions are constant for small departures from the baseline emissions path, an 

approximation that is reasonable for policies that have effects on emissions that are small relative 

to cumulative global carbon dioxide emissions. 
906 

Table VIII-14 

Social Cost of CO2 Emissions, 2010 – 2050 (2007 dollars) 

Discount Rate 5% 3% 2.5% 3% 

Source Average Average Average 95th Percentile 

2010 $4.7 $21.4 $35.1 $64.9 

2015 $5.7 $23.8 $38.4 $72.8 

2020 $6.8 $26.3 $41.7 $80.7 

2025 $8.2 $29.6 $45.9 $90.4 

2030 $9.7 $32.8 $50.0 $100.0 

2035 $11.2 $36.0 $54.2 $109.7 

2040 $12.7 $39.2 $58.4 $119.3 

2045 $14.2 $42.1 $61.7 $127.8 

2050 $15.7 $44.9 $65.0 $136.2 

As Table VIII-14 shows the four SCC estimates selected by the interagency group for use in 

regulatory analyses are $5, $21, $35, and $65 (in 2007 dollars) for emissions occurring in the 

year 2010. The first three estimates are based on the average SCC across models and socioeconomic and emissions scenarios at the 5, 3, and 2.5 percent discount rates, respectively. The 

fourth value is included to represent the higher-than-expected impacts from temperature change 

further out in the tails of the SCC distribution. For this purpose, the group elected to use the 

SCC value for the 95th percentile at a 3 percent discount rate. 

Table VIII-14 cites values in 2007 dollars to maintain consistency with the interagency group’s 

reported estimates, as well as with the values reported in NHTSA’s final CAFE rulemaking for 

MYs 2012-2016 and in the agency’s analysis of proposed CAFE standards for MY 2017-25. 

However, the agency updated these values to 2010 dollars for the current rulemaking; to 

illustrate the results, the SCC estimates for emissions occurring in the year 2020 used in this final 

regulatory analysis are $7, $27, $43, and $84. 

The central value identified by the interagency group is the average SCC across models at the 3 

percent discount rate. For example, the $27 per metric ton value reported immediately above 

represents this central value for emissions occurring in the year 2020 (in 2010 dollars). To 

capture the uncertainties involved in regulatory impact analysis, however, the group emphasized 

the importance of considering the full range of estimated SCC values. As the table also shows, 

the SCC estimates also rise over time; for example, the central value increases to $34 per ton of 

CO2 in 2030 and to $41 per ton of CO2 by 2040 when expressed in 2007 dollars. 
                                                      

907 

Details of the process used by the interagency group to develop its SCC estimates, complete 

results including year-by-year estimates of each of the four values, and a thorough discussion of 

their intended use and limitations is provided in the document Social Cost of Carbon for 

Regulatory Impact Analysis Under Executive Order 12866, Interagency Working Group on 

Social Cost of Carbon, United States Government, February 2010.497 

The agencies received a number of lengthy, detailed comments on the SCC values recommended 

by the interagency group and the process it used to develop them. Most of these comments 

addressed the topics of incorporating updated knowledge about climate impacts, more fully 

considering the potential for catastrophic impacts, valuing the population’s presumed aversion to 

the risk of significant climate impacts on economic well-being, and the discount rate used to 

convert distant future economic impacts to their present values. EDF, NRDC, and IPI each urged 

the agency to revise its estimates of the SCC to incorporate recent improvements in 

understanding the range and severity of economic impacts from climate change. 

NRDC and EDF noted that the three integrated assessment models used by the federal 

interagency group to develop the SCC estimates used to analyze the proposed rule have been 

updated to reflect recent estimates of climate sensitivity to GHG accumulations and to expand 

the range of monetized economic damages resulting from climate change, and encouraged the 

agency to update its estimates of the SCC using these newest versions of these models. NRDC 

further recommended that these models be updated to reflect recent research identifying adverse 

climate impacts on agricultural productivity. EDF and IPI recommended that the agency provide 

a complete listing of known and potential economic damages resulting from climate change, 

identify which of these were monetized in the interagency group’s estimates of the SCC, and 

explicitly note which of them were excluded. NRDC urged NHTSA to develop “multipliers” 

that could be applied to reductions in the use value of natural resources and ecosystem services 

to account for accompanying reductions in their non-use values. 

All three commenters urged the agency to revise its SCC estimates to more fully reflect the 

potential for catastrophic economic damages resulting from future climate change. NRDC 

recommended doing so by integrating such damages directly into the three integrated assessment 

497 This document is available at 

http://www2.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/sem_finalrule_appendix15a.pdf (last 

accessed August 1, 2012) or Docket No. NHTSA-2010-0131. 
908 

models used by the interagency group, while IPI recommended adjusting those models’ 

estimates of benefits from reducing GHG emissions to account for their undervaluation of the 

risk and magnitude of catastrophic damages. EDF urged revisions to the mathematical form of 

the models’ functions relating GHG accumulations to changes in global climate indicators and 

resulting economic damages, in order to remedy what EDF views as their underestimation of the 

probability that such damages will result. 

NRDC also recommended that the agency report the magnitude of extremely low-probability 

economic damages in order to inform the public and decision-makers about the impact of 

catastrophic scenarios. NRDC further urged the agency to conduct sensitivity analysis of the 

SCC using various “equity weights,” which would increase the value of climate damages likely 

to be experienced by lower-income regions of the world. 

IPI, EDF, and NRDC each urged the agency to incorporate the economic value of the 

population’s aversion to the risk of large losses in welfare in its SCC estimates. Specifically, the 

commenters recommended that the SCC be revised to include a measure of the typical 

consumer’s willingness to sacrifice current consumption to avoid being exposed to the risk of a 

large welfare loss from potential climate change. Including such a “risk premium,” which would 

be in addition to the conventional expected value of damages from different degrees of potential 

climate change, could increase the agency’s estimates of the SCC significantly. IPI noted that 

such a risk premium could be approximated by reducing the discount rate applied to future 

climate-related economic damages if it could not be estimated directly, while NRDC referred the 

agency to published research describing a recently-developed alternative method for 

incorporating the value of risk aversion. 

All three of the same commenters urged NHTSA to base its estimates of the SCC on lower 

discount rates than those the interagency group applied to future economic damages, which 

would increase the agency’s SCC values. NRDC noted that OMB Circular A-4 recommends a 

1% rate as a lower bound for discounting where future benefits or costs will be experienced by 

future generations, and also pointed out that short-term interest rates are currently well below 

this figure. As an alternative, NRDC recommended using declining future discount rates to 

account for more fully for long-run uncertainty about interest rates than the procedure used by 

the interagency group. EDF similarly encouraged the agency to reduce the discount rates 

incorporated in the interagency group’s SCC estimates below 3%, and also to consider using 

declining discount rates to account more appropriately for scientific and economic uncertainty 

surrounding the correct social discount rate for use over long time periods. 
 

909 

Finally, NRDC noted than an alternative to using the SCC to value reductions in GHG emissions 

would be to estimate the cost of achieving the final reduction in emissions necessary to reach a 

target emissions level (or “marginal abatement cost”) that is consistent with the maximum 

acceptable degree of climate change. While NRDC acknowledged that the determination of 

what constitutes an acceptable degree of climate change would ultimately be a political decision, 

the associated level of emissions and the marginal cost of reducing emissions to that level from 

today’s baseline could be determined scientifically with reasonable accuracy and allowing some 

margin for error. 

The agency appreciates the careful thought and detailed analyses that are reflected in the 

extensive comments it received on the SCC. In the time frame for evaluating and adopting this 

final rule, however, NHTSA judged that it would be impractical to replicate the detailed process 

the federal interagency group used to produce its recommended values for the SCC, and to 

develop the updated input assumptions and revised modeling procedures advocated by the 

commenters. Recognizing this, the agency has elected to continue using the interagency group’s 

recommended SCC values to estimate the economic benefits stemming from the reductions in 

GHG emissions that are projected to result from this final rule. 

Benefits from Reducing Emissions of Criteria Air Pollutants 

Car and light truck use, fuel refining, and fuel distribution and retailing also generate emissions 

of certain criteria air pollutants, including carbon monoxide (CO), hydrocarbon compounds 

(usually referred to as “volatile organic compounds,” or VOC), nitrogen oxides (NOx), fine 

particulate matter (PM2.5), and sulfur dioxide (SO2). While reductions in fuel refining and 

distribution that result from lower fuel consumption will reduce emissions of criteria pollutants, 

additional vehicle use associated with the rebound effect from higher fuel economy will increase 

emissions of these pollutants. Thus the net effect of stricter CAFE standards on total emissions 

of each criteria pollutant depends on the relative magnitudes of reduced emissions in fuel 

refining and distribution, and increases in emissions from vehicle use. Because the relationship 

between emission rates (emissions per gallon refined of fuel or mile driven) in fuel refining and 

vehicle use is different for each criteria pollutant, the net effect of fuel savings from increased 

CAFE standards on total emissions of each pollutant is likely to differ. 
 

                                                      

910 

NHTSA estimates the increase in emissions of each criteria air pollutant from additional vehicle 

use by multiplying the increase in total miles driven by cars and light trucks of each model year 

and age by their estimated emission rates per vehicle-mile of each pollutant. These emission 

rates differ between cars and light trucks as well as between gasoline and diesel vehicles, and 

both their values for new vehicles and the rates at which they increase with age and accumulated 

mileage can vary among model years. With the exception of SO2, NHTSA calculated the 

increase in emissions of these criteria pollutants from added car and light truck use by 

multiplying the estimated increases in their vehicles’ use during each year over their expected 

lifetimes by per-mile emission rates appropriate to each vehicle type, fuel used, model year, and 

age as of that future year. 

These emission rates were developed by U.S. EPA using its recently-developed Motor 

Vehicle Emission Simulator (MOVES 2010). The MOVES model assumes that the permile rates at which these pollutants are emitted are determined by EPA regulations and 

the effectiveness of catalytic after-treatment of engine exhaust emissions, and are thus 

unaffected by changes in car and light truck fuel economy. As a consequence, the effects 

of required increases in fuel economy emissions of these pollutants from car and light 

truck use are determined entirely by the increases in driving that result from the fuel 

economy rebound effect. 

Emission factors in the MOVES database are expressed in the form of grams per vehiclehour of operation. To convert these emission factors to grams per mile for use in 

NHTSA’s calculations, MOVES was run for the year 2050, and was programmed to 

report aggregate emissions from vehicle start and running exhaust. EPA analysts selected 

the year 2050 in order to generate emission factors that were representative of lifetime 

average emission rates for vehicles meeting the agency’s Tier 2 emission standard.498 

Separate estimates were developed for each vehicle type and model year, as well as for 

each state and month, in order to reflect the effects of regional and temporal variation in 

temperature and other relevant variables on emissions. 

The MOVES emissions estimates were then summed to the model year level and divided 

by average distance traveled in order to produce per-mile emission factors for each 

498 Because all light-duty emission rates in MOVES 2010 are assumed to be invariant after MY 2010, a 

calendar-year 2050 run produced a full set of emission rates that reflect anticipated deterioration in the 

effectiveness of vehicles’ emission control systems with increasing age and accumulated mileage for postMY 2010 vehicles. 
 

 

                                                      

 

 

911 

pollutant. The resulting emission rates represent average values across the nation, and 

incorporate typical temperature variations over an entire calendar year. These national 

average rates also reflect county-specific differences in fuel composition, as well as in the 

presence and type of vehicle inspection and maintenance programs.499 

Emission rates for the criteria pollutant SO2 were calculated by NHTSA using average 

fuel sulfur content estimates supplied by EPA, together with the assumption that the 

entire sulfur content of fuel is emitted in the form of SO2. These calculations assumed 

that national average gasoline and diesel sulfur levels would remain at current levels.500 

Total SO2 emissions under each alternative CAFE standard were calculated by applying 

the resulting emission rates directly to annual gasoline and diesel fuel use by cars and 

light trucks that is projected to occur under that alternative. As with other impacts, the 

changes in emissions of criteria air pollutants resulting from alternative increases in 

CAFE standards for MY 2017-2025 cars and light trucks were calculated as the 

difference between emissions under each alternative that would increase CAFE standards 

and emissions under the baseline alternative, which would extend the MY 2016 CAFE 

and EPA GHG emissions standards to apply to future model years. 

Emissions of criteria air pollutants also occur during each phase of fuel production and 

distribution, including crude oil extraction and transportation, fuel refining, and fuel storage and 

transportation. The reduction in emissions during each of these phases depends on the extent to 

which fuel savings result in lower imports of refined fuel, or in reduced domestic fuel refining. 

To a lesser extent, they also depend on whether reductions in domestic gasoline refining are 

reflected in reduced imports of crude oil or in reduced domestic extraction of petroleum. 

NHTSA’s analysis assumes that reductions in imports of refined fuel would reduce criteria 

pollutant emissions during fuel storage and distribution only. Reductions in domestic fuel 

refining using imported crude oil as a feedstock are assumed to reduce emissions during fuel 

refining, storage, and distribution, because each of these activities would be reduced. Finally, 

499 The national mix of fuel types includes county-level market shares of conventional and reformulated gasoline, as
 

well as county-level variation in sulfur content, ethanol fractions, and other fuel properties. Inspection/maintenance 

programs at the county level account for detailed program design elements such as test type, inspection frequency, 

and program coverage by vehicle type and age. 

500 These are 30 and 15 parts per million (ppm, measured on a mass basis) for gasoline and diesel respectively,
 

which produces emission rates of 0.17 grams of SO2 per gallon of gasoline and 0.10 grams per gallon of diesel.
 
 

                                                      

 

 

912 

reduced domestic fuel refining using domestically-produced crude oil is assumed to reduce 

emissions during all four phases of fuel production and distribution.501 

NHTSA estimated the reductions in criteria pollutant emissions from producing and distributing 

fuel that would occur with alternative CAFE standards using emission rates obtained by EPA 

from Argonne National Laboratories’ Greenhouse Gases and Regulated Emissions in 

Transportation (GREET) model.502 The GREET model provides separate estimates of air 

pollutant emissions that occur in four phases of fuel production and distribution: crude oil 

extraction, crude oil transportation and storage, fuel refining, and fuel distribution and storage.503 

EPA modified the GREET model to change certain assumptions about emissions during crude 

petroleum extraction and transportation, as well as to update its emission rates to reflect adopted 

and pending EPA emission standards. The agency converted these emission rates from the mass 

per fuel energy content basis on which GREET reports them to mass per gallon of fuel supplied 

using the estimates of fuel energy content reported by GREET. The resulting emission rates 

were applied to the agency’s estimates of fuel consumption under each alternative CAFE 

standard to develop estimates of total emissions of each criteria pollutant during fuel production 

and distribution. The assumptions about the effects of changes in fuel consumption on domestic 

and imported sources of fuel supply discussed above were then employed to calculate the effects 

of reductions in fuel use from alternative CAFE standards on changes in domestic emissions of 

each criteria pollutant. 

Finally, NHTSA calculated the net changes in domestic emissions of each criteria pollutant by 

summing the increases in its emissions projected to result from increased vehicle use, and the 

reductions in emissions anticipated to result from lower domestic fuel refining and 

distribution.504 As indicated previously, the effect of adopting higher CAFE standards on total 

emissions of each criteria pollutant depends on the relative magnitudes of the resulting reduction 

in emissions from fuel refining and distribution, and the increase in emissions from additional 

501 In effect, this assumes that the distances crude oil travels to U.S. refineries are approximately the same regardless 

of whether it travels from domestic oilfields or import terminals, and that the distances that gasoline travels from 

refineries to retail stations are approximately the same as those from import terminals to gasoline stations. 

502 Argonne National Laboratories, The Greenhouse Gas and Regulated Emissions from Transportation (GREET) 

Model, available at http://greet.es.anl.gov/ (last accessed August 1, 2012). 

503 Emissions that occur during vehicle refueling at retail gasoline stations (primarily evaporative emissions of 

volatile organic compounds, or VOCs) are already accounted for in the “tailpipe” emission factors used to estimate 

the emissions generated by increased light truck use. GREET estimates emissions in each phase of gasoline 

production and distribution in mass per unit of gasoline energy content; these factors are then converted to mass per 

gallon of gasoline using the average energy content of gasoline. 504 All emissions from increased vehicle use are assumed to occur within the U.S., since CAFE standards would 

apply only to vehicles produced for sale in the U.S. 
 

913 

vehicle use. Although these net changes vary significantly among individual criteria pollutants, 

the agency projects that on balance, adopting higher CAFE standards would reduce emissions of 

all criteria air pollutants except carbon monoxide (CO). 

The net changes in domestic emissions of fine particulates (PM2.5) and its chemical precursors 

(such as NOx, SOx, and VOCs) are converted to economic values using estimates of the 

reductions in health damage costs per ton of emissions of each pollutant that is avoided, which 

were developed and recently revised by EPA. These savings represent the estimated reductions 

in the value of damages to human health resulting from lower atmospheric concentrations and 

population exposure to air pollution that occur when emissions of each pollutant that contributes 

to atmospheric PM2.5 concentrations are reduced. The value of reductions in the risk of 

premature death due to exposure to fine particulate pollution (PM2.5) account for a majority of 

EPA’s estimated values of reducing PM2.5 related emissions, although the value of avoiding 

other health impacts related to PM2.5 exposure is also included in these estimates. 

These values do not include a number of unquantified benefits, such as reduction in the welfare 

and environmental impacts of PM2.5 pollution, or reductions in health and welfare impacts 

related to other criteria pollutants (ozone, NO2, and SO2) and air toxics. EPA estimates different 

PM-related per-ton values for reducing emissions from vehicle use than for reductions in 

emissions of that occur during fuel production and distribution. NHTSA applies these separate 

values to its estimates of changes in emissions from vehicle use and fuel production and 

distribution to determine the net change in total economic damages from emissions of these 

pollutants. 

EPA projects that the per-ton values for reducing emissions of criteria pollutants from both 

mobile sources (including motor vehicles) and stationary sources such as fuel refineries and 

storage facilities will increase over time. These projected increases reflect rising income levels, 

which are assumed to increase affected individuals’ willingness to pay for reduced exposure to 

health threats from air pollution, as well as future population growth, which increases population 

exposure to future levels of air pollution. 

D. Added Costs from Congestion, Crashes, and Noise 
914 

While it provides some benefits to drivers, increased vehicle use associated with the fuel 

economy rebound effect can also contribute to increased traffic congestion, motor vehicle 

crashes, and highway noise. Additional vehicle use can contribute to traffic congestion and 

delays by increasing recurring congestion on heavily-traveled roadways during peak travel 

periods, depending on how the additional travel is distributed over the day and on where it 

occurs. By increasing the number of crashes and disabled vehicles, added driving can also 

increase the delays that often result from these incidents, although the extent to which it actually 

does so again depends on when and where the added travel occurs. 

In either case, added delays impose higher costs on drivers and other vehicle occupants in the 

form of increased travel time and operating expenses, and these should be considered as an 

additional economic cost associated with the rebound effect. Because drivers do not take these 

added costs into account in deciding when to make trips or where they travel, they must be 

accounted for separately as a cost of the added driving associated with the rebound effect. 

Increased passenger car and light truck use due to the rebound effect may also increase the costs 

associated with traffic crashes. Drivers presumably take account of the potential costs they (and 

the other occupants of their vehicles) face from the possibility of being involved in a crash when 

they decide to make additional trips. However, they probably do not consider all of the potential 

costs they impose on occupants of other vehicles and on pedestrians when crashes occur, so any 

increase in these “external” crash costs must be considered as another cost of additional reboundeffect driving. 

Like increased delay costs, any increase in these external crash costs caused by added driving is 

likely to depend on the traffic conditions under which it takes place, since crashes are more 

frequent in heavier traffic, but their severity may be reduced by the slower speeds at which 

heavier traffic typically moves. Thus estimates of the increase in external crash costs from the 

rebound effect also need to account for when and where the added driving occurs. 

Finally, added vehicle use from the rebound effect may also increase traffic noise. Noise 

generated by vehicles causes inconvenience, irritation, and potentially even discomfort to 

occupants of other vehicles, to pedestrians and other bystanders, and to residents or occupants of 

surrounding property. Because none of these effects are likely to be taken into account by the 

drivers whose vehicles contribute to traffic noise, they represent additional externalities 

associated with motor vehicle use. 
                                                      

 

 

 

915 

Although there is considerable uncertainty in estimating its value, the added inconvenience and 

irritation caused by increased traffic noise imposes some economic costs on those it affects, and 

these added costs are unlikely to be taken into account by drivers of the vehicles that cause it. 

Thus any increase in noise costs resulting from added vehicle use must be included together with 

other increases in external costs of additional rebound-effect driving. 

NHTSA’s analysis uses estimates of the congestion, crash, and noise costs caused by increased 

travel in automobiles, pickup trucks, and vans developed by the Federal Highway 

Administration.505 These estimates are intended to measure the increases in external costs – that 

is, the “marginal” external costs – from added congestion, property damages and injuries in 

traffic crashes, and noise levels caused by additional usage of cars and light trucks that are borne 

by persons other than their drivers. FHWA’s “Middle” estimates for congestion, accident, and 

noise costs imposed by passenger cars are 5.6 cents, 2.4 cents and 0.1 cents per additional 

vehicle mile when expressed in 2010 dollars.506 For light trucks, FHWA’s estimates correspond 

to 5.0 cents, 2.7 cents, and 0.1 cents per additional vehicle-mile. 

The Federal Highway Administration’s estimates of these costs agree closely with some other 

recent estimates. For example, recent published research conducted by Resources for the Future 

(RFF) estimates marginal congestion and external crash costs for increased light-duty vehicle use 

in the U.S. to be 4.0 and 3.5 cents per vehicle-mile when converted to 2010 dollars.507 These 

estimates incorporate careful adjustments of congestion and crash costs that are intended to 

reflect the traffic conditions under which additional driving is likely to take place, as well as its 

likely effects on both the frequency and severity of motor vehicle crashes. 

FHWA’s estimates of added costs for congestion, crashes , and noise are multiplied by the 

estimated increases in passenger car and light truck use due during each year of the affected 

model years’ lifetimes to yield the estimated increases in congestion, crash, and noise externality 

505 These estimates were developed by FHWA for use in its 1997 Federal Highway Cost Allocation Study, available 

at http://www.fhwa.dot.gov/policy/hcas/final/index.htm. (last accessed on March 15, 2010) 506 Federal Highway Administration, 1997 Federal Highway Cost Allocation Study, Tables V-22, V-23, and V-24, 

http://www.fhwa.dot.gov/policy/hcas/final/index.htm (last accessed on August 1, 2012). The higher congestion 

cost for automobiles than for light trucks reflects the larger fraction of auto than of light truck use that occurs within 

congested urban areas.

507 Ian W.H. Parry and Kenneth A. Small, “Does Britain or the U.S. Have the Right Gasoline Tax?” Discussion 

Paper 02-12, Resources for the Future, March 2002, pp. 19 and Table 1, http://www.rff.org/rff/Documents/RFF-DP02-12.pdf. (last accessed on August 1, 2012) or Docket No. NHTSA-2010-0131. 
                                                      

 

 

 

 

 

 

916 

costs. The resulting yearly estimates are then summed to obtain their lifetime values. The value 

of these increased costs varies among model years and the alternative increases in CAFE 

standards considered in this analysis, because the increases in vehicle use depend on the 

improvements in fuel economy that would result in specific model years under each alternative. 

Minimum Sound Requirements for Hybrid and Electric Vehicles 

NHTSA analyses have found that hybrid vehicles strike pedestrians and bicyclists more often at 

low speed than vehicles with internal combustion engines (ICEs).508 Testing has shown that 

electric and hybrid electric vehicles emit less sound and are quieter at low speeds than vehicles 

with internal combustion engines.509 The Pedestrian Safety Enhancement Act (PSEA) requires 

NHTSA to conduct a rulemaking to require an alert sound for pedestrians to be emitted by all 

types of motor vehicles that are electric vehicles (EVs) or hybrid vehicles (HVs).510 NHTSA is 

in the process of developing a Notice of Proposed Rulemaking to propose sound requirements. 

NHTSA estimates that EVs and HVs are 22 percent more likely to be involved in a crash with a 

pedestrian and 38 percent more likely to be involved in a crash with a pedal cyclist than vehicles 

with internal combustion engines.511 Statistically significant results were found for injuries, but 

not for fatalities. NHTSA’s analysis of the final CAFE standards assumes total fleet penetration 

of strong HEVs, PHEVs, and EVs (the vehicles designated in the minimum sound requirements 

rulemaking as “EVs” and “HVs”) of only 3 percent in MY 2021, and only up to 5 percent in MY 

2025. At this time NHTSA assumes that sound is the only difference between EVs and HVs and 

internal combustion engines causing this increase in pedestrian and pedal cyclist injuries. 

Assuming our eventual sound requirements work as intended, any increase in pedestrian and 

508 Wu et al. (2011) Incidence Rates of Pedestrian And Bicyclist Crashes by Hybrid Electric Passenger Vehicles: An
 

Update, Report No. DOT HS 811 526. Dept. of Transportation, Washington, DC. Available at http://wwwnrd.nhtsa.dot.gov/Pubs/811526.pdf (last accessed July 10, 2012) 509 Garay-Vega et al.(2010) Quieter Cars and the Safety of Blind Pedestrians: Phase I, Report No. DOT HS 811 304,
 

U.S. Dept. of Transportation, Washington, DC. Available at 

http://www.nhtsa.gov/DOT/NHTSA/NVS/Crash%20Avoidance/Technical%20Publications/2010/811304rev.pdf. 

(last accessed July 10, 2012). 

510 Pub. L. 111-373, 124 Stat. 4086 (Jan. 4, 2011). 511 Wu et al. (2011) Incidence Rates of Pedestrian And Bicyclist Crashes by Hybrid Electric Passenger Vehicles: An
 

Update, Report No. DOT HS 811 526. Dept. of Transportation, Washington, DC. Available at http://wwwnrd.nhtsa.dot.gov/Pubs/811526.pdf (last accessed July 10, 2012). 
 

917 

pedal cyclist injuries brought about by an increase in hybrid or electric vehicle sales to meet 

CAFE standards should likely be neutralized. 

E. Additional Maintenance and Repair Costs 

The NPRM analysis of this rule noted areas where increases and decreases in maintenance costs 

were possible, but did not quantify these costs and requested comment on this topic. One 

example of an area of potential cost savings is the lack of need for oil changes in electric 

vehicles. Separately, increased use of low rolling resistance tires to improve fuel economy may 

result in an increase in maintenance costs, as such tires are more expensive to replace. 

The National Automobile Dealers Association (NADA) offered comment on the issue of 

maintenance and other costs, stating that the final rule should evaluate the potential impact on a 

vehicle’s total cost of ownership, to include maintenance costs. In response, NHTSA identified a 

select list of technologies for which sufficient data on periodicity and cost exist to support 

quantification of changes in vehicle maintenance costs within the central analysis. This list 

includes costs associated with low rolling resistance tires, diesel fuel filters, and benefits 

resulting from electric vehicle characteristics that eliminate the need for oil changes as well as 

engine air filter changes. 

To estimate maintenance costs, NHTSA looked at vehicle models for which there exists a 

version with fuel-efficiency-improving technology and a version with the corresponding baseline 

technology. The difference between maintenance costs for the two models represent a cost 

which the agencies assumed to be attributable to this rulemaking. By comparing the 

manufacturer recommended maintenance schedule of the items being compared, we were able to 

estimate the differences in maintenance intervals for the two. With estimates of the costs per 

maintenance event, we are able to put together a picture of the maintenance cost differences 

associated with the “new” technology. 

The full list of technologies considered is shown in Chapter 3 of the joint TSD, along with the 

maintenance interval comparisons, and costs per maintenance event. A summary of the costs is 

shown in Table VIII-15 below. 
                                                      

918 

Table VIII-15 

Maintenance Event Costs and Intervals (2010 dollars)512 

New Technology Reference Case 

Cost per 

Maintenance 

Event 

Maintenance 

Interval 

(miles) 

Low rolling resistance tires (level 1) Standard tires $6.44 40,000 

Low rolling resistance tires (level 2) Standard tires $43.52 40,000 

Diesel fuel filter replacement Gasoline vehicle $49.25 20,000 

EV oil change Gasoline vehicle -$38.67 7,500 

EV air filter replacement Gasoline vehicle -$28.60 30,000 

EV engine coolant replacement Gasoline vehicle -$51.20 100,000 

EV spark plug replacement Gasoline vehicle -$83.00 105,000 

EV battery coolant replacement Gasoline vehicle $93.20 150,000 

EV battery health check Gasoline vehicle $38.67 15,000 

The maintenance intervals are used along with yearly VMT tables to determine which year(s) 

maintenance events occur (note: the VMT schedule will vary depending on the vehicle class). 

The cost of maintenance events applied to a vehicle is also a function of the survival rate of that 

vehicle class. Once all of the maintenance event costs are tabulated, they are multiplied by the 

survival rate of that vehicle class to determine the average cost per vehicle in that class. Lastly, 

the net present value of the average costs is calculated based on the year they occurred and the 

discount rate chosen (e.g., 3% or 7%). 

Repair costs during the warranty period that are identifiably different for new technologies were 

included in the central analysis for the final rule. In the final rule, as in the NPRM, repair costs 

during the warranty period that are common for all vehicles remain a component of the indirect 

cost multiplier. A sensitivity analysis was added to this FRIA to examine repair costs in the 

post-warranty period, discussed further in Chapter X. 

F. The Discount Rate 

512 All maintenance interval, hours required, and part(s) cost differentials between reference and control cases were 

sourced from the ALLDATA subscription database (www.alldatapro.com) in January through February of 2012, 

unless noted otherwise in the text. Note: negative values represent savings resulting from forms of maintenance 

required by gasoline vehicles that are not required by EVs. 
 

                                                      

919 

Discounting future fuel savings and other benefits is intended to account for the reduction in 

their value to society when they are deferred until some future date, rather than received 

immediately. The discount rate expresses the percent decline in the value of these benefits – as 

viewed from today’s perspective – for each year they are deferred into the future. In evaluating 

the benefits from alternative increases in CAFE standards for MY 2017-2025 passenger cars and 

light trucks, NHTSA separately estimated benefits at both 3% and 7% discount rates per year. 

Inclusion of the 7% discount rate in this rulemaking’s central analysis is a departure from the 

previous rulemaking, in which the 7% discount rate was treated as a separate sensitivity analysis. 

The primary reason that NHTSA selected 3 percent as the appropriate rate for discounting future 

benefits from increased CAFE standards is that most or all of vehicle manufacturers’ costs for 

complying with higher CAFE standards are likely to be reflected in higher sales prices for their 

new vehicle models. By increasing sales prices for new cars and light trucks, CAFE regulation 

will thus primarily affect vehicle purchases and other private consumption decisions. Both 

economic theory and OMB guidance on discounting indicate that the future benefits and costs of 

regulations that mainly affect private consumption should be discounted at the social rate of time 

preference.513 Also of note is that OMB guidance indicates that savers appear to discount future 

consumption at an average real (that is, adjusted to remove the effect of inflation) rate of about 3 

percent when they face little risk about its likely level, which makes it a reasonable estimate of 

the social rate of time preference.514 

One important exception to the 3 percent discount rate matches the rates used to discount 

benefits from reducing CO2 emissions from the years in which reduced emissions occur, which 

span the lifetimes of MY 2017-2025 cars and light trucks, to their present values. In order to 

ensure consistency in the derivation and use of the interagency group’s estimates of the unit 

values of reducing CO2 emissions, the benefits from reducing those emissions during each future 

year are discounted using the same “intergenerational” discount rates that were used to derive 

each of the alternative unit values of reducing CO2 emissions. As Table VIII-14 above shows, 

these rates are 5 percent for the interagency group’s lowest estimate of the SCC, 3 percent for its 

central and highest estimates, and 2.5 percent for the estimate lying between the group’s central 

and highest estimates. 

513 Id. 514 Office of Management and Budget, Circular A-4, “Regulatory Analysis,” September 17, 2003, 33. Available at
 

http://www.whitehouse.gov/sites/default/files/omb/assets/regulatory_matters_pdf/a-4.pdf (last accessed August 1, 

2012) or Docket No. NHTSA-2010-0131. 
                                                      

 

920 

Because there is some uncertainty about the extent to which vehicle manufacturers will be able 

to recover their costs for complying with higher CAFE standards by increasing vehicle sales 

prices, however, NHTSA elected to include a 7 percent discount rate in the central analysis, 

whereas historically variation of the discount rate has been reserved for sensitivity analyses. 

OMB guidance indicates that the real economy-wide opportunity cost of capital is the 

appropriate discount rate to apply to future benefits and costs when the primary effect of a 

regulation is “...to displace or alter the use of capital in the private sector,” and estimates that 

this rate currently averages about 7 percent.515 NHTSA received comment from the Union of 

Concerned Scientists supporting the use of 3 and 7 percent discount rates in the NPRM central 

analysis, while the American Petroleum Institute noted that were NHTSA to utilize a higher 

discount rate of 15 percent516 that the estimated net present value of lifetime fuel savings would 

be substantially lower. 

All costs and benefits are discounted to the time that the vehicle is purchased or the model year. 

Thus from a consumer perspective, costs occur when the vehicle is purchased, while fuel savings 

occur throughout the lifetime of the vehicle and are discounted back to the time the vehicle was 

purchased. From the manufacturers’ perspective, the costs are assigned to the model year that 

the countermeasure is added to the vehicle. Thus, all costs and benefits are assumed to occur 

either in the model year or are discounted back to the model year for which the vehicle is 

produced. When we accumulate MY 2017-2025 total costs or benefits, we simply add together 

the present discounted values for each model year. We do not further discount those model year 

values to any set year (e.g. we do not discount all the values to 2017 or to 2012). All costs and 

benefits are in 2010 dollars. 

This is the first CAFE rulemaking wherein the agency has included operating costs other than 

outlays for fuel purchases in its analysis of the costs and benefits of new standards. In past 

CAFE rulemakings, reported monetized costs of new standards included only the costs (on an 

MSRP basis) of technology estimated to be added in response to the new standards. All other 

monetized impacts occur as incremental changes to social costs between the baseline and 

regulatory alternatives, and were reported as benefits and, if negative, as negative benefits (i.e., 

disbenefits). 

515 Id. 516 Suggested as a potential discount rate due to the use of a 15 percent discount rate in the Annual Energy Outlook
 

2011 evaluation of the cost-effectiveness of fuel-efficiency-improving technologies in new vehicles.
 
921 

In considering how to report monetized impacts on different costs to own and operate a new 

vehicle, the agency has more generally revisited its approach to categorizing different monetized 

effects as either costs or benefits. Noting that OMB guidance generally calls for agencies to treat 

positive monetized impacts as benefits, and negative monetized impacts as costs, NHTSA 

revised its reporting of costs and benefits to follow this approach. Thus, for example, while we 

have previously treated monetized damages related to additional congestion, accidents, and noise 

attributable to the rebound effect as negative benefits, we now report those impacts as social 

costs. This change in reporting in no way changes the agency’s resultant calculations of net 

benefits which has always correctly accounted for the sign of monetized impacts. 

However, NHTSA notes that, while straightforward in principle, the concept of categorizing 

negative monetized impacts as costs and positive negative monetized impacts as benefits is 

subject to considerable practical complications. For example, in NHTSA’s current analysis, 

monetized impacts on highway fatalities change sign between model years and between 

passenger car and light truck fleets. Also, disaggregation of criteria pollutant emissions would 

lead increased tailpipe emissions to be treated as costs, and reduced upstream emissions to be 

treated as benefits. For future fuel economy rulemaking analysis, NHTSA plans to further 

consider how best to report monetized impacts as either costs or benefits. 

As noted in the Executive Summary, the following conventions pertaining to the presentation of 

costs are consistent throughout the FRIA, including the subsequent tables in Chapter VIII: 

- Tables that exclusively present costs display all costs as positive values. 

- Tables that contain a mix of costs and benefits that are aggregated to a net or total value 

display costs as parenthesized values to aid the reader in following the summation logic. 
 

 

 

 

                                                      

922 

F. Summary of Values used to Estimate Benefits 

Table VIII-16 summarizes the economic values used to estimate benefits. 

Table VIII-16 

Economic Values Used for Benefits Computations (2010 dollars) 

Fuel Economy Rebound Effect 10% 

“Gap” between Test and On-road MPG for liquid-fueled Vehicles 20% 

“Gap” between Test and On-road Wall Electricity Consumption for 

Electric and Plug-in Hybrid Electric Vehicles 30% 

Value of refueling time per ($ per vehicle-hour) $ 21.62 

Average Percentage of Tank Refilled During Refueling Stop 65% 

Annual growth in average vehicle use (through 2030) 0.6% 

Fuel Prices (2017-2061 average, $/gallon) 

Retail gasoline price $3.76 

Pre-tax gasoline price $3.42 

Economic Benefits from Reducing Oil Imports ($/gallon) 

"Monopsony" Component 

Price Shock Component 

Military Security Component

Total Economic Costs ($/gallon) 

$ 0.00 

$ 0.197 in 2025 

$ 0.00 

$ 0.197 in 2025 

Emission Damage Costs (weighted, $/ton or $/metric ton) 

Carbon monoxide $ 0 

Volatile organic compounds (VOC) $ 1,700 

Nitrogen oxides (NOx) $ 6,700 

Particulate matter (PM2.5) $ 306,500 

Sulfur dioxide (SO2) $ 39,600 

Carbon dioxide (CO2) emissions in 2010 $ 22 

Annual Increase in CO2 Damage Cost Variable 

External Costs from Additional Automobile Use ($/vehicle-mile) 

Congestion

Accidents

Noise 

Total External Costs 

 $ 0.056 

 $ 0.024 

$ 0.001 

$ 0.081 

External Costs from Additional Light Truck Use ($/vehicle-mile) 

Congestion 

Accidents

Noise 

Total External Costs 

$0.050 

 $0.027 

$0.001 

$0.078 

Discount Rates Applied to Future Benefits517 3%, 7% 

517 Future benefits from reducing CO2 emissions are discounted using the same “intergenerational” discount rates 

that were used to derive each of the alternative SCC estimates used to value reductions in those emissions. As Table 

VIII-14 shows, these rates are 5 percent for the interagency group’s lowest estimate of the SCC, 3 percent for its 

central and highest estimates, and 2.5 percent for the estimate lying between the group’s central and highest 

estimates. 
                                                      

 

 

923 

G. Benefits Estimates 

Benefits were calculated separately for passenger cars and light trucks under each alternative 

CAFE requirement for each model year covered by this rule. In Tables VIII-17 and VIII-18, the 

societal costs and benefits for passenger car and light truck CAFE standards under the preferred 

alternative are shown for model years 2011 - 2025. These tables include undiscounted values 

(where available) as well as their net present values discounted to the given model year at 3 

percent and 7 percent. Positive values in these tables reflect net reductions in fuel consumption 

or emissions and their resulting economic impacts, which represent benefits from the proposal, 

while negative values represent increasing emissions, congestion, noise or crash severity and 

their added costs. The net social benefit from these societal impacts is shown on the Total line in 

each table. 

The preferred alternative for passenger cars would save 107.9 or 108.3 (2010 and 2008 baseline 

fleets, respectively) billion gallons of fuel and prevent 2,341 or 2,317 (2010 and 2008 baseline 

fleets, respectively) million metric tons of CO2 emissions over the lifetimes of the passenger cars 

sold during model years 2011 through 2025, compared to the fuel savings and emissions 

reductions that would occur if the standards remained at the adjusted baseline for MYs 2017­

2025. The preferred alternative for light trucks would save 61.5 or 62.8 (2010 and 2008 baseline 

fleets, respectively) billion gallons of fuel and prevent 1,323 or 1,369 (2010 and 2008 baseline 

fleets, respectively) million metric tons of CO2 emissions over the lifetimes of the light trucks 

sold during those model years, compared to the fuel savings and emissions reductions that would 

occur if the standards remained at the adjusted baseline for MYs 2017-2025. 

The sum of the net present values of societal benefits resulting from the implementation of the 

preferred alternative for passenger cars and light trucks is $595.6 and $604.7 (2010 and 2008 

baseline fleets, respectively) billion518 over the lifetimes of MY 2011-25 fleets. This estimate of 

societal benefits includes direct impacts from lower fuel consumption as well as externalities, 

and also reflects offsetting societal costs resulting from the rebound effect. This estimate does 

not include technology costs. Fuel savings account for 80.8 percent and CO2 emissions account 

for 8.3 percent of net societal benefits. 

518 The estimates of $595.6 and $604.7 billion are based on a 3% discount rate for valuing future impacts. In the 

case of a 7% discount rate, the sum of the net present are estimated at $476.1 and $483.4 (2010 and 2008 baseline 

fleets, respectively) billion. 
 

                                                      

 

924 

Tables VIII-19 and VIII-20 summarize the net societal costs and benefits, excluding technology 

costs, for all alternatives for passenger cars and light trucks for each model year at the 3 percent 

and 7 percent discount rates, respectively. Benefit levels parallel the increasing stringency of the 

various alternatives that were examined. Tables VIII-19 and 20 demonstrate that the 7 percent 

annual increase scenario produces net societal benefits that exceed the other alternatives; this is 

due to the fact that this scenario requires the highest achieved levels of fuel economy. However, 

as technology costs are not included in these tables, this result masks the high compliance costs 

associated with achieving the fuel economy levels required by this scenario. Tables VIII-21 and 

VIII-22 demonstrate the impact of the inclusion of technology costs, after which the Max Net 

Benefits and Total Cost = Total Benefits scenarios are estimated to exceed all other scenarios’ 

total net benefits. Note that the “Max Net Benefits” scenario optimizes to maximize the total net 

benefits of each individual model year, not all model years as a whole, therefore while it 

generally exhibits greater total net benefits across the sum of all model years in relation to other 

scenarios, this is not required by the model. The Total Costs = Total Benefits scenario is 

estimated to achieve total net benefits very similar to those of the Max Net Benefits scenario, as 

it allows technologies that are cost effective to pay for some technologies that are not cost 

effective. 

Table VIII-23 summarizes the fuel savings, in gallons, from all alternatives for passenger cars 

and light trucks. Similarly, Table VIII-24 presents the net change in electricity consumption 

from all alternatives for passenger cars and light trucks. Both Tables VIII-23 and VIII-24 

separate the Max Net Benefits and Total Cost = Total Benefit alternatives into their 3 and 7 

percent discount rate counterparts, as the choice of the discount rate can produce differing results 

for these two alternatives. 

Note that under several of the alternatives, a net decrease in electricity consumption is projected 

for the passenger car fleet in MY 2017. This result may seem counterintuitive due to trends that 

suggest increased use of HEV, PHEV, and EV technologies. This result can be explained by 

several factors. For certain alternatives, the stringency increases were gradual enough that the 

CAFE model did not add any EVs in this model year. Also, there were two EVs in the MY 2008 

fleet, on which the baseline fleet was developed, that were not in the MY 2010 baseline fleet.519 

Application of the AC adjustment in the baseline scenario and the greater application of the AC 

adjustment in the alternative scenarios decreased vehicle energy consumption, therefore reducing 

electricity consumption in the various alternatives relative to the baseline. 

519 BMW’s Mini-E and Tesla’s Roadster were both part of the MY 2008 fleet. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

 

925 

Table VIII-17520
 

Lifetime Benefits for Preferred Alternative by Model Year 

 (2010 dollars, in millions) 

MY 2011 Passenger Cars
 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$0 -

$271 

$0 -

$218 

$0 -

$171 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$0 -

$36 

$0 -

$29 

$0 -

$23 

Refueling Time Value 2010 

2008 

$0 -

$2 

$0 -

$2 

$0 -

$1 

Petroleum Market 

Externalities 

2010 

2008 

$0 -

$14 

$0 -

$11 

$0 -

$9 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

$0 -

($14) 

$0 -

($11) 

$0 -

($9) 

Accident Costs 2010 

2008 

$0 -

($6) 

$0 -

($5) 

$0 -

($4) 

Noise Costs 2010 

2008 

$0 -

($0) 

$0 -

($0) 

$0 -

($0) 

Value of Reduced 

Fatalities 

2010 

2008 

$0 -

($0) 

$0 -

($0) 

$0 -

($0) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$0 -

$25 

$0 -

$20 

$0 -

$20 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

NOX 2010 

2008 

$0 -

$1 

$0 -

$1 

$0 -

$1 

PM 2010 

2008 

$0 -

$4 

$0 -

$3 

$0 -

$3 

SOX 2010 

2008 

$0 -

$4 

$0 -

$3 

$0 -

$2 

Total 2010 

2008 

$0 -

$337 

$0 -

$271 

$0 -

$217 

520 The CAFE model estimates maintenance costs and relative value losses in discounted terms only. In the 

“undiscounted value” column of Tables VIII-17 and VIII-18, the 3% discounted values for these categories are 

substituted. Discounted CO2 benefits are presented at the 3% discount rate only, in keeping with the application of 

inter-generational discounting. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

926 

MY 2012 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$580 -

$941 

$464 -

$754 

$363 -

$590 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$61 -

$104 

$49 -

$83 

$38 -

$65 

Refueling Time Value 2010 

2008 

$23 -

$36 

$18 -

$29 

$15 -

$23 

Petroleum Market 

Externalities 

2010 

2008 

$33 -

$53 

$27 -

$43 

$22 -

$34 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

($27) - 

($44) 

($22) - 

($36) 

($17) - 

($28) 

Accident Costs 2010 

2008 

($12) - 

($19) 

($9) ­

($15) 

($7) ­

($12) 

Noise Costs 2010 

2008 

($0) ­

($1) 

($0) ­

($1) 

($0) ­

($1) 

Value of Reduced 

Fatalities 

2010 

2008 

$0 -

($0) 

$0 -

($0) 

$0 -

($0) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$54 -

$87 

$42 -

$69 

$42 -

$69 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$1 -

$1 

$1 -

$1 

$0 -

$1 

NOX 2010 

2008 

$2 -

$3 

$1 -

$2 

$1 -

$2 

PM 2010 

2008 

$9 -

$15 

$8 -

$12 

$6 -

$10 

SOX 2010 

2008 

$8 -

$13 

$7 -

$11 

$5 -

$8 

Total 2010 

2008 

$731 -

$1,189 

$586 -

$953 

$468 -

$761 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

927 

MY 2013 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$1,347 -

$2,088 

$1,080 -

$1,670 

$846 -

$1,305 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$141 -

$221 

$113 -

$177 

$88 -

$138 

Refueling Time Value 2010 

2008 

$53 -

$84 

$43 -

$68 

$34 -

$54 

Petroleum Market 

Externalities 

2010 

2008 

$77 -

$117 

$62 -

$95 

$49 -

$75 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

($64) - 

($93) 

($51) - 

($75) 

($41) - 

($59) 

Accident Costs 2010 

2008 

($27) - 

($41) 

($22) - 

($33) 

($17) - 

($26) 

Noise Costs 2010 

2008 

($1) ­

($2) 

($1) ­

($1) 

($1) ­

($1) 

Value of Reduced 

Fatalities 

2010 

2008 

($11) - 

($1) 

($9) ­

($1) 

($7) ­

($1) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$125 -

$195 

$99 -

$154 

$99 -

$154 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$2 -

$3 

$1 -

$2 

$1 -

$2 

NOX 2010 

2008 

$4 -

$6 

$3 -

$5 

$3 -

$4 

PM 2010 

2008 

$21 -

$33 

$18 -

$27 

$14 -

$22 

SOX 2010 

2008 

$19 -

$29 

$15 -

$23 

$12 -

$19 

Total 2010 

2008 

$1,685 -

$2,639 

$1,352 -

$2,110 

$1,081 -

$1,685 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

928 

MY 2014 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$3,522 -

$3,331 

$2,819 -

$2,669 

$2,206 -

$2,090 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$339 -

$351 

$271 -

$281 

$212 -

$220 

Refueling Time Value 2010 

2008 

$134 -

$137 

$108 -

$111 

$86 -

$87 

Petroleum Market 

Externalities 

2010 

2008 

$198 -

$186 

$160 -

$150 

$127 -

$119 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

($154) - 

($150) 

($124) - 

($121) 

($98) - 

($96) 

Accident Costs 2010 

2008 

($68) - 

($66) 

($55) - 

($53) 

($43) - 

($42) 

Noise Costs 2010 

2008 

($3) ­

($3) 

($2) ­

($2) 

($2) ­

($2) 

Value of Reduced 

Fatalities 

2010 

2008 

($13) - 

($1) 

($10) - 

($1) 

($8) ­

($1) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$330 -

$312 

$261 -

$247 

$261 -

$247 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$4 -

$4 

$4 -

$3 

$3 -

$3 

NOX 2010 

2008 

$10 -

$9 

$8 -

$7 

$6 -

$6 

PM 2010 

2008 

$55 -

$52 

$45 -

$42 

$36 -

$34 

SOX 2010 

2008 

$49 -

$46 

$39 -

$37 

$31 -

$29 

Total 2010 

2008 

$4,402 -

$4,208 

$3,523 -

$3,371 

$2,816 -

$2,695 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

929 

MY 2015 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$6,053 -

$4,978 

$4,846 -

$3,990 

$3,795 -

$3,127 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$590 -

$517 

$473 -

$415 

$370 -

$326 

Refueling Time Value 2010 

2008 

$234 -

$210 

$189 -

$170 

$150 -

$134 

Petroleum Market 

Externalities 

2010 

2008 

$335 -

$275 

$271 -

$222 

$214 -

$176 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

($262) - 

($222) 

($212) - 

($179) 

($167) - 

($142) 

Accident Costs 2010 

2008 

($117) - 

($98) 

($94) - 

($79) 

($74) - 

($62) 

Noise Costs 2010 

2008 

($5) ­

($4) 

($4) ­

($3) 

($3) ­

($3) 

Value of Reduced 

Fatalities 

2010 

2008 

($15) - 

($1) 

($12) - 

($1) 

($10) - 

($1) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$572 -

$471 

$452 -

$372 

$452 -

$372 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$7 -

$6 

$6 -

$5 

$5 -

$4 

NOX 2010 

2008 

$16 -

$13 

$13 -

$11 

$11 -

$9 

PM 2010 

2008 

$93 -

$76 

$76 -

$63 

$61 -

$50 

SOX 2010 

2008 

$82 -

$68 

$67 -

$55 

$53 -

$43 

Total 2010 

2008 

$7,585 -

$6,289 

$6,071 -

$5,040 

$4,856 -

$4,034 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

930 

MY 2016 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$9,149 -

$6,925 

$7,333 -

$5,556 

$5,748 -

$4,357 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$875 -

$693 

$702 -

$557 

$551 -

$437 

Refueling Time Value 2010 

2008 

$352 -

$300 

$285 -

$243 

$225 -

$192 

Petroleum Market 

Externalities 

2010 

2008 

$500 -

$380 

$404 -

$307 

$320 -

$243 

Maintenance Costs 2010 

2008 

($8) ­

($0) 

($8) ­

($0) 

($6) ­

($0) 

Congestion Costs 2010 

2008 

($400) - 

($311) 

($323) - 

($251) 

($256) - 

($199) 

Accident Costs 2010 

2008 

($177) - 

($136) 

($143) - 

($110) 

($113) - 

($87) 

Noise Costs 2010 

2008 

($7) ­

($6) 

($6) ­

($5) 

($5) ­

($4) 

Value of Reduced 

Fatalities 

2010 

2008 

($27) - 

($12) 

($22) - 

($10) 

($17) - 

($8) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$875 -

$662 

$692 -

$524 

$692 -

$524 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$11 -

$8 

$9 -

$7 

$7 -

$6 

NOX 2010 

2008 

$24 -

$18 

$20 -

$15 

$16 -

$12 

PM 2010 

2008 

$139 -

$105 

$114 -

$87 

$92 -

$69 

SOX 2010 

2008 

$123 -

$94 

$100 -

$76 

$79 -

$60 

Total 2010 

2008 

$11,431 -

$8,722 

$9,158 -

$6,996 

$7,334 -

$5,604 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

931 

MY 2017 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$12,247 -

$10,194 

$9,816 -

$8,178 

$7,696 -

$6,415 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$1,138 -

$969 

$913 -

$778 

$718 -

$611 

Refueling Time Value 2010 

2008 

$472 -

$435 

$382 -

$352 

$302 -

$278 

Petroleum Market 

Externalities 

2010 

2008 

$665 -

$556 

$537 -

$449 

$425 -

$355 

Maintenance Costs 2010 

2008 

($9) ­

($62) 

($9) ­

($62) 

($7) ­

($46) 

Congestion Costs 2010 

2008 

($532) - 

($453) 

($430) - 

($366) 

($341) - 

($290) 

Accident Costs 2010 

2008 

($236) - 

($198) 

($190) - 

($160) 

($151) - 

($127) 

Noise Costs 2010 

2008 

($10) - 

($8) 

($8) ­

($7) 

($6) ­

($5) 

Value of Reduced 

Fatalities 

2010 

2008 

($18) - 

($14) 

($15) - 

($12) 

($12) - 

($9) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($1) 

($0) ­

($1) 

($0) ­

($1) 

CO2 2010 

2008 

$1,185 -

$985 

$937 -

$780 

$937 -

$780 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$15 -

$12 

$12 -

$10 

$10 -

$8 

NOX 2010 

2008 

$32 -

$27 

$27 -

$22 

$22 -

$18 

PM 2010 

2008 

$184 -

$154 

$151 -

$126 

$121 -

$101 

SOX 2010 

2008 

$164 -

$137 

$132 -

$111 

$105 -

$88 

Total 2010 

2008 

$15,296 -

$12,731 

$12,254 -

$10,198 

$9,818 -

$8,177 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

932 

MY 2018 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$17,751 -

$17,633 

$14,240 -

$14,148 

$11,171 -

$11,100 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$1,687 -

$1,696 

$1,355 -

$1,363 

$1,065 -

$1,071 

Refueling Time Value 2010 

2008 

$658 -

$706 

$532 -

$571 

$421 -

$452 

Petroleum Market 

Externalities 

2010 

2008 

$953 -

$953 

$770 -

$771 

$609 -

$610 

Maintenance Costs 2010 

2008 

($12) - 

($138) 

($12) - 

($138) 

($9) ­

($103) 

Congestion Costs 2010 

2008 

($783) - 

($783) 

($634) - 

($634) 

($502) - 

($502) 

Accident Costs 2010 

2008 

($344) - 

($343) 

($278) - 

($278) 

($220) - 

($220) 

Noise Costs 2010 

2008 

($14) - 

($14) 

($11) - 

($11) 

($9) ­

($9) 

Value of Reduced 

Fatalities 

2010 

2008 

($43) - 

($34) 

($35) - 

($28) 

($28) - 

($22) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($5) 

($0) ­

($5) 

($0) ­

($2) 

CO2 2010 

2008 

$1,740 -

$1,724 

$1,377 -

$1,365 

$1,377 -

$1,365 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$21 -

$21 

$17 -

$17 

$14 -

$14 

NOX 2010 

2008 

$46 -

$45 

$38 -

$37 

$31 -

$30 

PM 2010 

2008 

$264 -

$263 

$217 -

$216 

$174 -

$173 

SOX 2010 

2008 

$235 -

$223 

$190 -

$180 

$150 -

$143 

Total 2010 

2008 

$22,157 -

$21,946 

$17,765 -

$17,574 

$14,244 -

$14,099 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

933 

MY 2019 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$27,442 -

$26,327 

$21,997 -

$21,123 

$17,250 -

$16,574 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$2,531 -

$2,457 

$2,032 -

$1,974 

$1,596 -

$1,552 

Refueling Time Value 2010 

2008 

$989 -

$1,009 

$799 -

$816 

$632 -

$646 

Petroleum Market 

Externalities 

2010 

2008 

$1,463 -

$1,416 

$1,182 -

$1,145 

$935 -

$906 

Maintenance Costs 2010 

2008 

($203) - 

($316) 

($203) - 

($316) 

($152) - 

($237) 

Congestion Costs 2010 

2008 

($1,189) - 

($1,162) 

($961) - 

($940) 

($761) - 

($744) 

Accident Costs 2010 

2008 

($526) - 

($509) 

($425) - 

($412) 

($336) - 

($326) 

Noise Costs 2010 

2008 

($21) - 

($21) 

($17) - 

($17) 

($14) - 

($13) 

Value of Reduced 

Fatalities 

2010 

2008 

($81) - 

($85) 

($67) - 

($69) 

($53) - 

($55) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($12) 

($0) ­

($12) 

($0) ­

($5) 

CO2 2010 

2008 

$2,723 -

$2,602 

$2,154 -

$2,061 

$2,154 -

$2,061 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$32 -

$32 

$26 -

$26 

$21 -

$21 

NOX 2010 

2008 

$70 -

$62 

$58 -

$52 

$47 -

$42 

PM 2010 

2008 

$405 -

$398 

$332 -

$326 

$267 -

$261 

SOX 2010 

2008 

$361 -

$326 

$291 -

$264 

$230 -

$208 

Total 2010 

2008 

$33,995 -

$32,523 

$27,200 -

$26,020 

$21,817 -

$20,889 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

934 

MY 2020 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$34,179 -

$36,444 

$27,388 -

$29,219 

$21,473 -

$22,915 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$3,169 -

$3,396 

$2,543 -

$2,726 

$1,997 -

$2,142 

Refueling Time Value 2010 

2008 

$1,232 -

$1,394 

$996 -

$1,127 

$787 -

$891 

Petroleum Market 

Externalities 

2010 

2008 

$1,807 -

$1,951 

$1,460 -

$1,577 

$1,154 -

$1,247 

Maintenance Costs 2010 

2008 

($221) - 

($370) 

($221) - 

($370) 

($165) - 

($276) 

Congestion Costs 2010 

2008 

($1,475) - 

($1,589) 

($1,192) - 

($1,285) 

($943) - 

($1,017) 

Accident Costs 2010 

2008 

($653) - 

($701) 

($528) - 

($566) 

($418) - 

($448) 

Noise Costs 2010 

2008 

($27) - 

($29) 

($22) - 

($23) 

($17) - 

($18) 

Value of Reduced 

Fatalities 

2010 

2008 

($77) - 

($79) 

($63) - 

($64) 

($50) - 

($51) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($40) 

($0) ­

($40) 

($0) ­

($18) 

CO2 2010 

2008 

$3,434 -

$3,638 

$2,718 -

$2,880 

$2,718 -

$2,880 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$40 -

$45 

$33 -

$36 

$26 -

$29 

NOX 2010 

2008 

$87 -

$83 

$72 -

$69 

$58 -

$56 

PM 2010 

2008 

$499 -

$541 

$410 -

$443 

$329 -

$355 

SOX 2010 

2008 

$446 -

$398 

$360 -

$322 

$285 -

$254 

Total 2010 

2008 

$42,441 -

$45,082 

$33,954 -

$36,049 

$27,236 -

$28,941 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

935 

MY 2021 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$42,652 -

$42,927 

$34,184 -

$34,414 

$26,802 -

$26,986 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$3,897 -

$3,943 

$3,125 -

$3,163 

$2,453 -

$2,484 

Refueling Time Value 2010 

2008 

$1,542 -

$1,655 

$1,247 -

$1,338 

$987 -

$1,059 

Petroleum Market 

Externalities 

2010 

2008 

$2,243 -

$2,282 

$1,813 -

$1,845 

$1,434 -

$1,459 

Maintenance Costs 2010 

2008 

($453) - 

($327) 

($453) - 

($327) 

($337) - 

($244) 

Congestion Costs 2010 

2008 

($1,849) - 

($1,874) 

($1,495) - 

($1,515) 

($1,183) - 

($1,199) 

Accident Costs 2010 

2008 

($816) - 

($824) 

($659) - 

($666) 

($521) - 

($527) 

Noise Costs 2010 

2008 

($33) - 

($34) 

($27) - 

($27) 

($21) - 

($22) 

Value of Reduced 

Fatalities 

2010 

2008 

($113) - 

($82) 

($93) - 

($67) 

($74) - 

($53) 

Relative Value Loss (EVs) 2010 

2008 

($4) ­

($50) 

($4) ­

($50) 

($2) ­

($22) 

CO2 2010 

2008 

$4,336 -

$4,339 

$3,435 -

$3,439 

$3,435 -

$3,439 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$50 -

$52 

$41 -

$42 

$33 -

$34 

NOX 2010 

2008 

$104 -

$97 

$86 -

$81 

$70 -

$66 

PM 2010 

2008 

$626 -

$630 

$513 -

$516 

$412 -

$414 

SOX 2010 

2008 

$542 -

$464 

$438 -

$375 

$346 -

$297 

Total 2010 

2008 

$52,721 -

$53,198 

$42,152 -

$42,562 

$33,833 -

$34,171 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

936 

MY 2022 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$47,359 -

$49,330 

$37,949 -

$39,532 

$29,745 -

$30,987 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$4,324 -

$4,483 

$3,466 -

$3,593 

$2,719 -

$2,819 

Refueling Time Value 2010 

2008 

$1,714 -

$1,908 

$1,387 -

$1,543 

$1,097 -

$1,221 

Petroleum Market 

Externalities 

2010 

2008 

$2,473 -

$2,606 

$2,000 -

$2,107 

$1,582 -

$1,667 

Maintenance Costs 2010 

2008 

($573) - 

($429) 

($573) - 

($429) 

($427) - 

($319) 

Congestion Costs 2010 

2008 

($2,057) - 

($2,148) 

($1,662) - 

($1,736) 

($1,315) - 

($1,373) 

Accident Costs 2010 

2008 

($906) - 

($945) 

($732) - 

($763) 

($579) - 

($603) 

Noise Costs 2010 

2008 

($37) - 

($39) 

($30) - 

($31) 

($24) - 

($25) 

Value of Reduced 

Fatalities 

2010 

2008 

($121) - 

($63) 

($99) - 

($52) 

($79) - 

($42) 

Relative Value Loss (EVs) 2010 

2008 

($6) ­

($59) 

($6) ­

($59) 

($3) ­

($26) 

CO2 2010 

2008 

$4,873 -

$5,044 

$3,863 -

$3,999 

$3,863 -

$3,999 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$55 -

$59 

$45 -

$48 

$36 -

$39 

NOX 2010 

2008 

$114 -

$110 

$95 -

$92 

$77 -

$75 

PM 2010 

2008 

$688 -

$717 

$565 -

$587 

$453 -

$471 

SOX 2010 

2008 

$595 -

$511 

$481 -

$413 

$380 -

$326 

Total 2010 

2008 

$58,496 -

$61,085 

$46,748 -

$48,845 

$37,528 -

$39,215 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

937 

MY 2023 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$54,131 -

$53,933 

$43,369 -

$43,216 

$33,988 -

$33,869 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$4,945 -

$4,936 

$3,962 -

$3,955 

$3,106 -

$3,101 

Refueling Time Value 2010 

2008 

$1,924 -

$2,048 

$1,557 -

$1,656 

$1,232 -

$1,310 

Petroleum Market 

Externalities 

2010 

2008 

$2,801 -

$2,826 

$2,265 -

$2,285 

$1,791 -

$1,808 

Maintenance Costs 2010 

2008 

($731) - 

($479) 

($731) - 

($479) 

($545) - 

($357) 

Congestion Costs 2010 

2008 

($2,353) - 

($2,354) 

($1,901) - 

($1,902) 

($1,503) - 

($1,504) 

Accident Costs 2010 

2008 

($1,035) - 

($1,034) 

($836) - 

($835) 

($661) - 

($660) 

Noise Costs 2010 

2008 

($42) - 

($42) 

($34) - 

($34) 

($27) - 

($27) 

Value of Reduced 

Fatalities 

2010 

2008 

($143) - 

($70) 

($117) - 

($58) 

($93) - 

($46) 

Relative Value Loss (EVs) 2010 

2008 

($7) ­

($71) 

($7) ­

($71) 

($3) ­

($31) 

CO2 2010 

2008 

$5,632 -

$5,572 

$4,467 -

$4,420 

$4,467 -

$4,420 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$62 -

$64 

$51 -

$53 

$41 -

$42 

NOX 2010 

2008 

$129 -

$119 

$108 -

$99 

$88 -

$81 

PM 2010 

2008 

$778 -

$777 

$639 -

$636 

$513 -

$510 

SOX 2010 

2008 

$675 -

$538 

$546 -

$435 

$432 -

$344 

Total 2010 

2008 

$66,766 -

$66,762 

$53,335 -

$53,376 

$42,826 -

$42,861 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

938 

MY 2024 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$62,329 -

$61,299 

$49,915 -

$49,111 

$39,105 -

$38,484 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$5,658 -

$5,594 

$4,529 -

$4,479 

$3,549 -

$3,511 

Refueling Time Value 2010 

2008 

$2,186 -

$2,300 

$1,768 -

$1,861 

$1,399 -

$1,472 

Petroleum Market 

Externalities 

2010 

2008 

$3,208 -

$3,200 

$2,594 -

$2,588 

$2,052 -

$2,048 

Maintenance Costs 2010 

2008 

($834) - 

($483) 

($834) - 

($483) 

($621) - 

($359) 

Congestion Costs 2010 

2008 

($2,697) - 

($2,678) 

($2,178) - 

($2,164) 

($1,722) - 

($1,711) 

Accident Costs 2010 

2008 

($1,189) - 

($1,175) 

($959) - 

($949) 

($758) - 

($750) 

Noise Costs 2010 

2008 

($49) - 

($48) 

($39) - 

($39) 

($31) - 

($31) 

Value of Reduced 

Fatalities 

2010 

2008 

($137) - 

($57) 

($113) - 

($48) 

($90) - 

($38) 

Relative Value Loss (EVs) 2010 

2008 

($32) - 

($110) 

($32) - 

($110) 

($14) - 

($48) 

CO2 2010 

2008 

$6,531 -

$6,368 

$5,182 -

$5,055 

$5,182 -

$5,055 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$72 -

$74 

$59 -

$60 

$47 -

$48 

NOX 2010 

2008 

$144 -

$129 

$120 -

$107 

$98 -

$87 

PM 2010 

2008 

$887 -

$873 

$728 -

$715 

$584 -

$572 

SOX 2010 

2008 

$688 -

$487 

$556 -

$393 

$440 -

$311 

Total 2010 

2008 

$76,765 -

$75,771 

$61,294 -

$60,578 

$49,219 -

$48,652 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

939 

MY 2025 Passenger Cars 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$66,899 -

$68,186 

$53,557 -

$54,598 

$41,946 -

$42,764 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$6,091 -

$6,171 

$4,872 -

$4,937 

$3,815 -

$3,867 

Refueling Time Value 2010 

2008 

$2,276 -

$2,461 

$1,841 -

$1,991 

$1,457 -

$1,575 

Petroleum Market 

Externalities 

2010 

2008 

$3,418 -

$3,578 

$2,763 -

$2,894 

$2,186 -

$2,289 

Maintenance Costs 2010 

2008 

($931) - 

($418) 

($931) - 

($418) 

($698) - 

($313) 

Congestion Costs 2010 

2008 

($2,893) - 

($2,968) 

($2,335) - 

($2,396) 

($1,846) - 

($1,894) 

Accident Costs 2010 

2008 

($1,275) - 

($1,304) 

($1,029) - 

($1,052) 

($813) - 

($831) 

Noise Costs 2010 

2008 

($52) - 

($53) 

($42) - 

($43) 

($33) - 

($34) 

Value of Reduced 

Fatalities 

2010 

2008 

($123) - 

($8) 

($101) - 

($8) 

($81) - 

($7) 

Relative Value Loss (EVs) 2010 

2008 

($42) - 

($221) 

($42) - 

($221) 

($18) - 

($96) 

CO2 2010 

2008 

$7,068 -

$7,055 

$5,611 -

$5,602 

$5,611 -

$5,602 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$78 -

$87 

$64 -

$71 

$51 -

$56 

NOX 2010 

2008 

$145 -

$132 

$121 -

$108 

$99 -

$86 

PM 2010 

2008 

$957 -

$987 

$783 -

$801 

$627 -

$636 

SOX 2010 

2008 

$708 -

$137 

$573 -

$110 

$453 -

$87 

Total 2010 

2008 

$82,324 -

$83,820 

$65,703 -

$66,972 

$52,756 -

$53,787 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

940 

MY 2011 – 2025 Passenger Cars Combined 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$385,638 -

$384,807 

$308,958 -

$308,396 

$242,134 -

$241,733 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$35,445 -

$35,567 

$28,403 -

$28,510 

$22,279 -

$22,367 

Refueling Time Value 2010 

2008 

$13,789 -

$14,684 

$11,151 -

$11,877 

$8,821 -

$9,397 

Petroleum Market 

Externalities 

2010 

2008 

$20,173 -

$20,391 

$16,308 -

$16,490 

$12,899 -

$13,045 

Maintenance Costs 2010 

2008 

($3,976) - 

($3,022) 

($3,976) - 

($3,022) 

($2,966) - 

($2,254) 

Congestion Costs 2010 

2008 

($16,735) - 

($16,844) 

($13,521) - 

($13,612) 

($10,693) - 

($10,766) 

Accident Costs 2010 

2008 

($7,380) - 

($7,398) 

($5,960) - 

($5,976) 

($4,712) - 

($4,726) 

Noise Costs 2010 

2008 

($302) - 

($303) 

($244) - 

($245) 

($193) - 

($194) 

Value of Reduced 

Fatalities 

2010 

2008 

($922) - 

($507) 

($756) - 

($418) 

($603) - 

($334) 

Relative Value Loss (EVs) 2010 

2008 

($91) - 

($570) 

($91) - 

($570) 

($40) - 

($247) 

CO2 2010 

2008 

$39,479 -

$39,078 

$31,291 -

$30,987 

$31,291 -

$30,987 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$448 -

$469 

$368 -

$383 

$295 -

$306 

NOX 2010 

2008 

$926 -

$854 

$770 -

$707 

$628 -

$574 

PM 2010 

2008 

$5,607 -

$5,624 

$4,599 -

$4,600 

$3,690 -

$3,680 

SOX 2010 

2008 

$4,694 -

$3,473 

$3,795 -

$2,806 

$3,001 -

$2,219 

Total 2010 

2008 

$476,792 -

$476,302 

$381,093 -

$380,914 

$305,831 -

$305,789 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

 

941 

Table VIII-18521
 

Lifetime Benefits for Preferred Alternative by Model Year

 (2010 dollars, in millions) 

MY 2011 Light Trucks
 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Refueling Time Value 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Petroleum Market 

Externalities 

2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Maintenance Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Congestion Costs 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Accident Costs 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Noise Costs 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Value of Reduced 

Fatalities 

2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

NOX 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

PM 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

SOX 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

Total 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

521 The CAFE model estimates maintenance costs and relative value losses in discounted terms only. In the 

“undiscounted value” column of Tables VIII-17 and VIII-18, the 3% discounted values for these categories are 

substituted. Discounted CO2 benefits are presented at the 3% discount rate only, in keeping with the application of 

inter-generational discounting. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

942 

MY 2012 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$104 -

$109 

$83 -

$85 

$65 -

$65 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$6 -

$10 

$5 -

$8 

$4 -

$6 

Refueling Time Value 2010 

2008 

$4 -

$4 

$3 -

$3 

$2 -

$3 

Petroleum Market 

Externalities 

2010 

2008 

$6 -

$6 

$5 -

$5 

$4 -

$4 

Maintenance Costs 2010 

2008 

($1) ­

($0) 

($1) ­

($0) 

($1) ­

($0) 

Congestion Costs 2010 

2008 

($3) ­

($3) 

($2) ­

($3) 

($2) ­

($2) 

Accident Costs 2010 

2008 

($2) ­

($2) 

($1) ­

($1) 

($1) ­

($1) 

Noise Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Value of Reduced 

Fatalities 

2010 

2008 

$3 -

($0) 

$2 -

($0) 

$2 -

($0) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$10 -

$10 

$8 -

$8 

$8 -

$8 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

NOX 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

PM 2010 

2008 

$2 -

$2 

$1 -

$1 

$1 -

$1 

SOX 2010 

2008 

$1 -

$2 

$1 -

$1 

$1 -

$1 

Total 2010 

2008 

$130 -

$138 

$104 -

$108 

$83 -

$85 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

943 

MY 2013 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$513 -

$156 

$402 -

$122 

$311 -

$94 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$57 -

$14 

$44 -

$11 

$34 -

$8 

Refueling Time Value 2010 

2008 

$13 -

$6 

$10 -

$5 

$8 -

$4 

Petroleum Market 

Externalities 

2010 

2008 

$28 -

$9 

$22 -

$7 

$18 -

$5 

Maintenance Costs 2010 

2008 

($2) ­

($0) 

($2) ­

($0) 

($1) ­

($0) 

Congestion Costs 2010 

2008 

($16) - 

($5) 

($13) - 

($4) 

($10) - 

($3) 

Accident Costs 2010 

2008 

($9) ­

($3) 

($7) ­

($2) 

($5) ­

($2) 

Noise Costs 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

Value of Reduced 

Fatalities 

2010 

2008 

$8 -

($0) 

$6 -

($0) 

$5 -

($0) 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$48 -

$15 

$37 -

$11 

$37 -

$11 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$1 -

$0 

$1 -

$0 

$0 -

$0 

NOX 2010 

2008 

$1 -

$0 

$1 -

$0 

$1 -

$0 

PM 2010 

2008 

$8 -

$2 

$6 -

$2 

$5 -

$2 

SOX 2010 

2008 

$7 -

$2 

$6 -

$2 

$4 -

$1 

Total 2010 

2008 

$657 -

$198 

$515 -

$154 

$407 -

$121 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

944 

MY 2014 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$1,125 -

$128 

$889 -

$100 

$691 -

$77 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$122 -

$9 

$97 -

$7 

$75 -

$6 

Refueling Time Value 2010 

2008 

$33 -

$5 

$27 -

$4 

$21 -

$3 

Petroleum Market 

Externalities 

2010 

2008 

$62 -

$7 

$49 -

$6 

$39 -

$4 

Maintenance Costs 2010 

2008 

($3) ­

($0) 

($3) ­

($0) 

($3) ­

($0) 

Congestion Costs 2010 

2008 

($40) - 

($4) 

($32) - 

($3) 

($25) - 

($2) 

Accident Costs 2010 

2008 

($20) - 

($2) 

($16) - 

($2) 

($13) - 

($1) 

Noise Costs 2010 

2008 

($1) ­

($0) 

($1) ­

($0) 

($0) ­

($0) 

Value of Reduced 

Fatalities 

2010 

2008 

$13 -

$0 

$10 -

$0 

$8 -

$0 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$106 -

$12 

$83 -

$9 

$83 -

$9 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$1 -

$0 

$1 -

$0 

$1 -

$0 

NOX 2010 

2008 

$3 -

$0 

$2 -

$0 

$2 -

$0 

PM 2010 

2008 

$17 -

$2 

$14 -

$2 

$11 -

$1 

SOX 2010 

2008 

$15 -

$2 

$12 -

$1 

$10 -

$1 

Total 2010 

2008 

$1,433 -

$161 

$1,132 -

$125 

$899 -

$98 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

945 

MY 2015 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$2,148 -

$760 

$1,695 -

$595 

$1,316 -

$459 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$211 -

$83 

$167 -

$65 

$130 -

$50 

Refueling Time Value 2010 

2008 

$69 -

$18 

$55 -

$14 

$43 -

$11 

Petroleum Market 

Externalities 

2010 

2008 

$118 -

$40 

$94 -

$32 

$74 -

$25 

Maintenance Costs 2010 

2008 

($3) ­

($0) 

($3) ­

($0) 

($2) ­

($0) 

Congestion Costs 2010 

2008 

($71) - 

($24) 

($57) - 

($19) 

($45) - 

($15) 

Accident Costs 2010 

2008 

($37) - 

($13) 

($29) - 

($10) 

($23) - 

($8) 

Noise Costs 2010 

2008 

($1) ­

($0) 

($1) ­

($0) 

($1) ­

($0) 

Value of Reduced 

Fatalities 

2010 

2008 

$13 -

$44 

$11 -

$35 

$8 -

$27 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$205 -

$73 

$159 -

$56 

$159 -

$56 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$3 -

$1 

$2 -

$1 

$2 -

$1 

NOX 2010 

2008 

$6 -

$2 

$5 -

$2 

$4 -

$1 

PM 2010 

2008 

$32 -

$11 

$26 -

$9 

$21 -

$7 

SOX 2010 

2008 

$29 -

$10 

$23 -

$8 

$18 -

$6 

Total 2010 

2008 

$2,719 -

$1,006 

$2,145 -

$787 

$1,702 -

$622 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

946 

MY 2016 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$3,055 -

$1,401 

$2,408 -

$1,098 

$1,869 -

$849 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$315 -

$144 

$249 -

$113 

$193 -

$88 

Refueling Time Value 2010 

2008 

$91 -

$38 

$72 -

$30 

$57 -

$23 

Petroleum Market 

Externalities 

2010 

2008 

$165 -

$75 

$132 -

$59 

$103 -

$47 

Maintenance Costs 2010 

2008 

($3) ­

($0) 

($3) ­

($0) 

($2) ­

($0) 

Congestion Costs 2010 

2008 

($100) - 

($43) 

($80) - 

($34) 

($63) - 

($27) 

Accident Costs 2010 

2008 

($52) - 

($23) 

($42) - 

($19) 

($33) - 

($14) 

Noise Costs 2010 

2008 

($2) ­

($1) 

($2) ­

($1) 

($1) ­

($1) 

Value of Reduced 

Fatalities 

2010 

2008 

$17 -

$23 

$14 -

$18 

$11 -

$14 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$294 -

$135 

$228 -

$104 

$228 -

$104 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$4 -

$2 

$3 -

$1 

$2 -

$1 

NOX 2010 

2008 

$8 -

$4 

$6 -

$3 

$5 -

$2 

PM 2010 

2008 

$45 -

$20 

$36 -

$16 

$29 -

$13 

SOX 2010 

2008 

$41 -

$19 

$32 -

$15 

$25 -

$12 

Total 2010 

2008 

$3,877 -

$1,794 

$3,055 -

$1,405 

$2,424 -

$1,111 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

947 

MY 2017 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$4,222 -

$3,312 

$3,328 -

$2,602 

$2,584 -

$2,016 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$432 -

$329 

$341 -

$259 

$265 -

$201 

Refueling Time Value 2010 

2008 

$113 -

$88 

$90 -

$70 

$71 -

$55 

Petroleum Market 

Externalities 

2010 

2008 

$224 -

$177 

$179 -

$140 

$140 -

$110 

Maintenance Costs 2010 

2008 

($4) ­

($17) 

($4) ­

($17) 

($3) ­

($12) 

Congestion Costs 2010 

2008 

($137) - 

($102) 

($109) - 

($81) 

($85) - 

($63) 

Accident Costs 2010 

2008 

($72) - 

($55) 

($57) - 

($44) 

($45) - 

($34) 

Noise Costs 2010 

2008 

($3) ­

($2) 

($2) ­

($2) 

($2) ­

($1) 

Value of Reduced 

Fatalities 

2010 

2008 

$30 -

$32 

$24 -

$25 

$19 -

$20 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$412 -

$323 

$320 -

$250 

$320 -

$250 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$5 -

$4 

$4 -

$3 

$3 -

$3 

NOX 2010 

2008 

$11 -

$8 

$9 -

$7 

$7 -

$6 

PM 2010 

2008 

$61 -

$48 

$50 -

$39 

$40 -

$31 

SOX 2010 

2008 

$55 -

$44 

$44 -

$35 

$35 -

$27 

Total 2010 

2008 

$5,351 -

$4,189 

$4,216 -

$3,287 

$3,348 -

$2,606 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

948 

MY 2018 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$5,724 -

$7,758 

$4,510 -

$6,098 

$3,501 -

$4,726 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$483 -

$687 

$381 -

$540 

$296 -

$419 

Refueling Time Value 2010 

2008 

$136 -

$195 

$108 -

$155 

$85 -

$122 

Petroleum Market 

Externalities 

2010 

2008 

$301 -

$413 

$240 -

$329 

$188 -

$258 

Maintenance Costs 2010 

2008 

($0) ­

($90) 

($0) ­

($90) 

($0) ­

($66) 

Congestion Costs 2010 

2008 

($182) - 

($238) 

($145) - 

($189) 

($114) - 

($148) 

Accident Costs 2010 

2008 

($96) - 

($129) 

($77) - 

($102) 

($60) - 

($80) 

Noise Costs 2010 

2008 

($4) ­

($5) 

($3) ­

($4) 

($2) ­

($3) 

Value of Reduced 

Fatalities 

2010 

2008 

$60 -

$85 

$47 -

$67 

$37 -

$52 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$565 -

$765 

$439 -

$592 

$439 -

$592 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$7 -

$9 

$5 -

$7 

$4 -

$6 

NOX 2010 

2008 

$14 -

$19 

$12 -

$16 

$10 -

$13 

PM 2010 

2008 

$82 -

$111 

$67 -

$90 

$53 -

$72 

SOX 2010 

2008 

$75 -

$102 

$59 -

$81 

$47 -

$64 

Total 2010 

2008 

$7,163 -

$9,684 

$5,644 -

$7,591 

$4,483 -

$6,025 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

949 

MY 2019 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$14,720 -

$14,453 

$11,573 -

$11,354 

$8,971 -

$8,795 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$1,311 -

$1,298 

$1,031 -

$1,021 

$800 -

$792 

Refueling Time Value 2010 

2008 

$309 -

$363 

$246 -

$289 

$193 -

$226 

Petroleum Market 

Externalities 

2010 

2008 

$753 -

$764 

$599 -

$607 

$469 -

$476 

Maintenance Costs 2010 

2008 

($34) - 

($172) 

($34) - 

($172) 

($25) - 

($128) 

Congestion Costs 2010 

2008 

($455) - 

($441) 

($362) - 

($350) 

($284) - 

($275) 

Accident Costs 2010 

2008 

($245) - 

($239) 

($194) - 

($190) 

($152) - 

($149) 

Noise Costs 2010 

2008 

($9) ­

($9) 

($7) ­

($7) 

($6) ­

($5) 

Value of Reduced 

Fatalities 

2010 

2008 

($1) ­

$106 

($1) ­

$84 

($1) ­

$66 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$1,477 -

$1,442 

$1,143 -

$1,115 

$1,143 -

$1,115 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$17 -

$17 

$13 -

$14 

$11 -

$11 

NOX 2010 

2008 

$36 -

$35 

$30 -

$29 

$24 -

$24 

PM 2010 

2008 

$207 -

$205 

$168 -

$166 

$134 -

$133 

SOX 2010 

2008 

$188 -

$188 

$150 -

$150 

$117 -

$117 

Total 2010 

2008 

$18,274 -

$18,010 

$14,355 -

$14,109 

$11,396 -

$11,198 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

950 

MY 2020 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$19,530 -

$20,909 

$15,363 -

$16,435 

$11,913 -

$12,736 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$1,742 -

$1,857 

$1,370 -

$1,460 

$1,063 -

$1,133 

Refueling Time Value 2010 

2008 

$385 -

$547 

$307 -

$436 

$241 -

$341 

Petroleum Market 

Externalities 

2010 

2008 

$982 -

$1,095 

$782 -

$872 

$613 -

$683 

Maintenance Costs 2010 

2008 

$11 -

($222) 

$11 -

($222) 

$8 -

($165) 

Congestion Costs 2010 

2008 

($600) - 

($634) 

($477) - 

($504) 

($374) - 

($395) 

Accident Costs 2010 

2008 

($323) - 

($343) 

($257) - 

($273) 

($201) - 

($214) 

Noise Costs 2010 

2008 

($12) - 

($13) 

($10) - 

($10) 

($7) ­

($8) 

Value of Reduced 

Fatalities 

2010 

2008 

$29 -

$184 

$23 -

$146 

$18 -

$114 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$1,987 -

$2,110 

$1,540 -

$1,634 

$1,540 -

$1,634 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$22 -

$24 

$18 -

$20 

$14 -

$16 

NOX 2010 

2008 

$46 -

$51 

$39 -

$42 

$32 -

$34 

PM 2010 

2008 

$273 -

$294 

$222 -

$239 

$177 -

$191 

SOX 2010 

2008 

$247 -

$270 

$196 -

$215 

$154 -

$168 

Total 2010 

2008 

$24,321 -

$26,129 

$19,127 -

$20,489 

$15,190 -

$16,270 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

951 

MY 2021 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$27,045 -

$28,495 

$21,244 -

$22,380 

$16,459 -

$17,333 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$2,495 -

$2,520 

$1,958 -

$1,978 

$1,517 -

$1,533 

Refueling Time Value 2010 

2008 

$475 -

$750 

$378 -

$597 

$296 -

$468 

Petroleum Market 

Externalities 

2010 

2008 

$1,360 -

$1,480 

$1,082 -

$1,178 

$848 -

$923 

Maintenance Costs 2010 

2008 

($97) - 

($213) 

($97) - 

($213) 

($72) - 

($158) 

Congestion Costs 2010 

2008 

($829) - 

($860) 

($658) - 

($683) 

($516) - 

($535) 

Accident Costs 2010 

2008 

($447) - 

($466) 

($355) - 

($370) 

($278) - 

($290) 

Noise Costs 2010 

2008 

($17) - 

($17) 

($13) - 

($14) 

($10) - 

($11) 

Value of Reduced 

Fatalities 

2010 

2008 

$117 -

$169 

$93 -

$134 

$73 -

$105 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$2,777 -

$2,910 

$2,150 -

$2,255 

$2,150 -

$2,255 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$34 -

$33 

$27 -

$26 

$22 -

$21 

NOX 2010 

2008 

$46 -

$69 

$40 -

$57 

$34 -

$46 

PM 2010 

2008 

$416 -

$396 

$334 -

$322 

$264 -

$258 

SOX 2010 

2008 

$343 -

$365 

$273 -

$291 

$214 -

$228 

Total 2010 

2008 

$33,718 -

$35,632 

$26,455 -

$27,940 

$20,999 -

$22,177 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

952 

MY 2022 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$29,963 -

$32,550 

$23,527 -

$25,555 

$18,220 -

$19,783 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$2,779 -

$2,890 

$2,179 -

$2,267 

$1,686 -

$1,755 

Refueling Time Value 2010 

2008 

$550 -

$858 

$438 -

$683 

$343 -

$536 

Petroleum Market 

Externalities 

2010 

2008 

$1,500 -

$1,677 

$1,193 -

$1,335 

$935 -

$1,046 

Maintenance Costs 2010 

2008 

($157) - 

($260) 

($157) - 

($260) 

($117) - 

($193) 

Congestion Costs 2010 

2008 

($917) - 

($981) 

($728) - 

($779) 

($570) - 

($610) 

Accident Costs 2010 

2008 

($495) - 

($531) 

($393) - 

($422) 

($308) - 

($330) 

Noise Costs 2010 

2008 

($18) - 

($20) 

($15) - 

($16) 

($11) - 

($12) 

Value of Reduced 

Fatalities 

2010 

2008 

$132 -

$173 

$105 -

$138 

$82 -

$108 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$3,111 -

$3,363 

$2,412 -

$2,608 

$2,412 -

$2,608 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$37 -

$37 

$30 -

$30 

$23 -

$24 

NOX 2010 

2008 

$52 -

$77 

$45 -

$64 

$38 -

$52 

PM 2010 

2008 

$453 -

$448 

$365 -

$365 

$289 -

$292 

SOX 2010 

2008 

$377 -

$414 

$300 -

$329 

$235 -

$258 

Total 2010 

2008 

$37,366 -

$40,696 

$29,299 -

$31,897 

$23,257 -

$25,317 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

953 

MY 2023 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$33,986 -

$35,146 

$26,664 -

$27,581 

$20,636 -

$21,344 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$3,222 -

$3,157 

$2,523 -

$2,474 

$1,951 -

$1,914 

Refueling Time Value 2010 

2008 

$626 -

$914 

$498 -

$728 

$390 -

$570 

Petroleum Market 

Externalities 

2010 

2008 

$1,688 -

$1,795 

$1,342 -

$1,429 

$1,052 -

$1,120 

Maintenance Costs 2010 

2008 

($215) - 

($276) 

($215) - 

($276) 

($159) - 

($205) 

Congestion Costs 2010 

2008 

($1,040) - 

($1,059) 

($826) - 

($840) 

($646) - 

($658) 

Accident Costs 2010 

2008 

($562) - 

($574) 

($446) - 

($456) 

($349) - 

($357) 

Noise Costs 2010 

2008 

($21) - 

($21) 

($16) - 

($17) 

($13) - 

($13) 

Value of Reduced 

Fatalities 

2010 

2008 

$154 -

$169 

$123 -

$135 

$96 -

$106 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$3,567 -

$3,668 

$2,766 -

$2,847 

$2,766 -

$2,847 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$41 -

$39 

$33 -

$32 

$26 -

$26 

NOX 2010 

2008 

$61 -

$83 

$52 -

$68 

$44 -

$56 

PM 2010 

2008 

$502 -

$479 

$404 -

$390 

$320 -

$312 

SOX 2010 

2008 

$424 -

$443 

$337 -

$352 

$264 -

$276 

Total 2010 

2008 

$42,432 -

$43,963 

$33,239 -

$34,446 

$26,378 -

$27,337 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

954 

MY 2024 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$37,829 -

$39,348 

$29,665 -

$30,870 

$22,949 -

$23,883 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$3,558 -

$3,507 

$2,783 -

$2,746 

$2,151 -

$2,123 

Refueling Time Value 2010 

2008 

$737 -

$1,032 

$586 -

$822 

$460 -

$644 

Petroleum Market 

Externalities 

2010 

2008 

$1,868 -

$1,993 

$1,486 -

$1,586 

$1,164 -

$1,244 

Maintenance Costs 2010 

2008 

($367) - 

($318) 

($367) - 

($318) 

($273) - 

($236) 

Congestion Costs 2010 

2008 

($1,158) - 

($1,182) 

($919) - 

($938) 

($719) - 

($734) 

Accident Costs 2010 

2008 

($624) - 

($641) 

($495) - 

($508) 

($387) - 

($398) 

Noise Costs 2010 

2008 

($23) - 

($24) 

($18) - 

($19) 

($14) - 

($15) 

Value of Reduced 

Fatalities 

2010 

2008 

$190 -

$185 

$151 -

$147 

$119 -

$116 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$4,008 -

$4,145 

$3,110 -

$3,219 

$3,110 -

$3,219 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$44 -

$44 

$36 -

$35 

$28 -

$28 

NOX 2010 

2008 

$70 -

$91 

$60 -

$76 

$50 -

$62 

PM 2010 

2008 

$546 -

$530 

$441 -

$432 

$350 -

$346 

SOX 2010 

2008 

$468 -

$491 

$372 -

$391 

$292 -

$307 

Total 2010 

2008 

$47,145 -

$49,203 

$36,891 -

$38,542 

$29,279 -

$30,589 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

955 

MY 2025 Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$39,253 -

$43,879 

$30,768 -

$34,404 

$23,792 -

$26,605 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$3,714 -

$3,926 

$2,902 -

$3,069 

$2,240 -

$2,370 

Refueling Time Value 2010 

2008 

$765 -

$1,133 

$609 -

$902 

$478 -

$708 

Petroleum Market 

Externalities 

2010 

2008 

$1,921 -

$2,200 

$1,529 -

$1,751 

$1,198 -

$1,373 

Maintenance Costs 2010 

2008 

($372) - 

($349) 

($372) - 

($349) 

($276) - 

($259) 

Congestion Costs 2010 

2008 

($1,202) - 

($1,317) 

($953) - 

($1,044) 

($745) - 

($817) 

Accident Costs 2010 

2008 

($648) - 

($714) 

($514) - 

($566) 

($402) - 

($443) 

Noise Costs 2010 

2008 

($24) - 

($26) 

($19) - 

($21) 

($15) - 

($16) 

Value of Reduced 

Fatalities 

2010 

2008 

$199 -

$69 

$159 -

$56 

$124 -

$44 

Relative Value Loss (EVs) 2010 

2008 

($0) ­

($0) 

($0) ­

($0) 

($0) ­

($0) 

CO2 2010 

2008 

$4,198 -

$4,665 

$3,259 -

$3,624 

$3,259 -

$3,624 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$45 -

$48 

$37 -

$39 

$29 -

$31 

NOX 2010 

2008 

$73 -

$100 

$62 -

$83 

$52 -

$68 

PM 2010 

2008 

$558 -

$585 

$451 -

$476 

$358 -

$382 

SOX 2010 

2008 

$481 -

$543 

$383 -

$432 

$300 -

$339 

Total 2010 

2008 

$48,962 -

$54,741 

$38,302 -

$42,857 

$30,394 -

$34,009 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

956 

MY 2011 – 2025 Combined Light Trucks 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$219,216 -

$228,405 

$172,120 -

$179,279 

$133,273 -

$138,764 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$20,449 -

$20,433 

$16,030 -

$16,018 

$12,405 -

$12,398 

Refueling Time Value 2010 

2008 

$4,304 -

$5,951 

$3,428 -

$4,738 

$2,688 -

$3,715 

Petroleum Market 

Externalities 

2010 

2008 

$10,975 -

$11,731 

$8,734 -

$9,336 

$6,845 -

$7,318 

Maintenance Costs 2010 

2008 

($1,248) - 

($1,917) 

($1,248) - 

($1,917) 

($926) - 

($1,423) 

Congestion Costs 2010 

2008 

($6,749) - 

($6,890) 

($5,359) - 

($5,470) 

($4,196) - 

($4,283) 

Accident Costs 2010 

2008 

($3,632) - 

($3,734) 

($2,884) - 

($2,965) 

($2,257) - 

($2,321) 

Noise Costs 2010 

2008 

($134) - 

($138) 

($107) - 

($109) 

($84) - 

($86) 

Value of Reduced 

Fatalities 

2010 

2008 

$963 -

$1,239 

$766 -

$985 

$600 -

$772 

Relative Value Loss (EVs) 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

CO2 2010 

2008 

$22,766 -

$23,636 

$17,653 -

$18,333 

$17,653 -

$18,333 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$259 -

$258 

$209 -

$209 

$167 -

$167 

NOX 2010 

2008 

$427 -

$540 

$362 -

$447 

$301 -

$364 

PM 2010 

2008 

$3,201 -

$3,133 

$2,584 -

$2,550 

$2,053 -

$2,041 

SOX 2010 

2008 

$2,751 -

$2,893 

$2,189 -

$2,303 

$1,716 -

$1,805 

Total 2010 

2008 

$273,547 -

$285,542 

$214,478 -

$223,738 

$170,238 -

$177,564 
957 

Table VIII-19a 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 Dollars) 

(3 percent discount rate) 

Passenger Cars Baseline 

Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $20,689 - $18,741 $12,254 - $10,198 $17,765 - $17,574 $27,200 - $26,020 $33,954 - $36,049 $42,152 - $42,562 $46,748 - $48,845 $53,335 - $53,376 

2% Annual Increase 2010 2008 $8,977 - $12,014 $5,525 - $6,520 $8,826 - $10,731 $13,448 - $14,799 $19,114 - $20,410 $23,513 - $24,251 $26,074 - $27,443 $29,865 - $31,598 3% Annual Increase 2010 2008 $24,685 - $25,764 $9,411 - $8,909 $13,796 - $15,743 $21,259 - $22,170 $28,868 - $31,031 $33,284 - $35,691 $37,424 - $40,899 $43,259 - $44,670 4% Annual Increase 2010 2008 $35,934 - $36,252 $13,198 - $12,645 $18,531 - $20,818 $28,210 - $28,082 $37,660 - $38,050 $45,900 - $44,835 $50,547 - $50,544 $56,353 - $55,744 5% Annual Increase 2010 2008 $27,421 - $30,279 $16,484 - $15,203 $23,022 - $23,965 $34,714 - $32,163 $44,452 - $44,194 $51,999 - $52,721 $57,119 - $57,897 $63,662 - $63,191 6% Annual Increase 2010 2008 $30,860 - $36,489 $19,113 - $18,564 $26,126 - $27,731 $39,433 - $35,730 $47,135 - $47,522 $56,275 - $55,973 $61,102 - $64,028 $68,802 - $69,833 7% Annual Increase 2010 2008 $39,545 - $43,870 $22,902 - $21,974 $30,384 - $31,536 $42,841 - $40,099 $50,331 - $51,105 $57,772 - $58,897 $65,569 - $67,765 $71,624 - $73,017 Max Net Benefits 2010 2008 $49,287 - $59,360 $26,396 - $26,838 $30,389 - $31,817 $41,694 - $37,807 $48,303 - $46,399 $53,834 - $52,907 $57,936 - $56,548 $62,893 - $60,247 Total Cost = Total Benefit 2010 2008 $51,454 - $69,971 $27,167 - $32,162 $30,950 - $36,121 $42,444 - $40,770 $49,441 - $49,708 $55,375 - $55,967 $60,272 - $61,113 $66,907 - $66,126 
958 

Table VIII-19b 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 Dollars) 

(3 percent discount rate) 

Light Trucks Baseline 

Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $6,949 - $2,578 $4,216 - $3,287 $5,644 - $7,591 $14,355 - $14,109 $19,127 - $20,489 $26,455 - $27,940 $29,299 - $31,897 $33,239 - $34,446 

2% Annual Increase 2010 2008 $20,274 - $12,537 $9,556 - $7,238 $10,313 - $10,031 $14,786 - $14,251 $16,731 - $18,222 $18,586 - $21,708 $20,354 - $24,188 $22,641 - $25,620 3% Annual Increase 2010 2008 $24,025 - $15,272 $11,518 - $9,812 $12,786 - $13,491 $18,916 - $20,460 $23,617 - $26,553 $28,471 - $31,656 $31,222 - $34,518 $34,985 - $36,868 4% Annual Increase 2010 2008 $24,385 - $17,953 $11,941 - $12,561 $14,500 - $17,254 $21,825 - $25,977 $27,850 - $33,036 $34,141 - $38,954 $37,014 - $42,103 $40,909 - $45,336 5% Annual Increase 2010 2008 $24,820 - $20,811 $13,062 - $14,325 $15,664 - $20,232 $24,698 - $30,367 $31,408 - $39,429 $38,261 - $45,100 $41,514 - $48,756 $46,895 - $51,825 6% Annual Increase 2010 2008 $29,393 - $28,927 $14,922 - $16,700 $17,620 - $22,634 $25,988 - $32,702 $33,101 - $42,764 $40,612 - $48,775 $44,169 - $52,832 $49,386 - $54,878 7% Annual Increase 2010 2008 $30,499 - $31,866 $16,037 - $18,069 $19,046 - $25,104 $27,927 - $34,680 $35,629 - $43,360 $42,825 - $50,609 $45,795 - $54,378 $50,715 - $57,563 Max Net Benefits 2010 2008 $32,524 - $52,468 $16,152 - $25,077 $18,407 - $28,772 $26,632 - $35,322 $32,819 - $43,215 $39,890 - $49,009 $42,703 - $51,544 $47,224 - $53,744 Total Cost = Total Benefit 2010 2008 $34,126 - $53,329 $16,823 - $25,785 $18,984 - $29,355 $26,018 - $36,061 $33,323 - $43,353 $40,566 - $48,755 $42,656 - $51,248 $47,114 - $53,735 
959 

Table VIII-19c 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 Dollars) 

(3 percent discount rate) 

Passenger Cars and Light 

Trucks Baseline Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $27,638 - $21,319 $16,470 - $13,485 $23,409 - $25,166 $41,555 - $40,129 $53,081 - $56,538 $68,607 - $70,502 $76,047 - $80,742 $86,574 - $87,822 

2% Annual Increase 2010 2008 $29,251 - $24,551 $15,081 - $13,758 $19,139 - $20,762 $28,235 - $29,050 $35,846 - $38,632 $42,099 - $45,959 $46,428 - $51,631 $52,506 - $57,218 3% Annual Increase 2010 2008 $48,710 - $41,036 $20,929 - $18,721 $26,582 - $29,234 $40,175 - $42,631 $52,485 - $57,585 $61,755 - $67,347 $68,646 - $75,417 $78,244 - $81,538 4% Annual Increase 2010 2008 $60,320 - $54,204 $25,139 - $25,206 $33,031 - $38,072 $50,035 - $54,059 $65,509 - $71,086 $80,041 - $83,789 $87,561 - $92,647 $97,262 - $101,080 5% Annual Increase 2010 2008 $52,240 - $51,090 $29,546 - $29,528 $38,685 - $44,197 $59,412 - $62,529 $75,860 - $83,623 $90,260 - $97,821 $98,633 - $106,653 $110,557 - $115,016 6% Annual Increase 2010 2008 $60,253 - $65,417 $34,035 - $35,264 $43,745 - $50,365 $65,421 - $68,432 $80,235 - $90,286 $96,887 - $104,748 $105,271 - $116,860 $118,188 - $124,711 7% Annual Increase 2010 2008 $70,044 - $75,736 $38,940 - $40,043 $49,430 - $56,640 $70,767 - $74,780 $85,960 - $94,465 $100,596 - $109,506 $111,364 - $122,143 $122,339 - $130,580 Max Net Benefits 2010 2008 $81,811 - $111,828 $42,547 - $51,915 $48,796 - $60,588 $68,326 - $73,129 $81,122 - $89,614 $93,723 - $101,915 $100,639 - $108,093 $110,117 - $113,991 Total Cost = Total Benefit 2010 2008 $85,580 - $123,300 $43,990 - $57,947 $49,934 - $65,476 $68,462 - $76,831 $82,764 - $93,061 $95,941 - $104,722 $102,929 - $112,362 $114,021 - $119,861 
960 

Table VIII-20a 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 dollars) 

(7 percent discount rate) 

Passenger Cars Baseline 

Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $16,554 - $14,995 $9,818 - $8,177 $14,244 - $14,099 $21,817 - $20,889 $27,236 - $28,941 $33,833 - $34,171 $37,528 - $39,215 $42,826 - $42,861 

2% Annual Increase 2010 2008 $7,183 - $9,611 $4,431 - $5,229 $7,081 - $8,610 $10,797 - $11,889 $15,340 - $16,393 $18,873 - $19,479 $20,935 - $22,045 $23,990 - $25,388 3% Annual Increase 2010 2008 $19,759 - $20,630 $7,540 - $7,145 $11,061 - $12,632 $17,053 - $17,800 $23,162 - $24,912 $26,711 - $28,652 $30,039 - $32,833 $34,741 - $35,869 4% Annual Increase 2010 2008 $28,771 - $29,020 $10,576 - $10,136 $14,859 - $16,698 $22,629 - $22,540 $30,214 - $30,542 $36,841 - $35,991 $40,575 - $40,575 $45,247 - $44,756 5% Annual Increase 2010 2008 $21,949 - $24,222 $13,211 - $12,185 $18,463 - $19,220 $27,857 - $25,812 $35,675 - $35,476 $41,741 - $42,326 $45,860 - $46,488 $51,124 - $50,763 6% Annual Increase 2010 2008 $24,703 - $29,187 $15,319 - $14,876 $20,952 - $22,239 $31,644 - $28,672 $37,837 - $38,147 $45,188 - $44,960 $49,066 - $51,453 $55,300 - $56,157 7% Annual Increase 2010 2008 $31,658 - $35,092 $18,358 - $17,609 $24,369 - $25,292 $34,387 - $32,184 $40,409 - $41,034 $46,400 - $47,335 $52,717 - $54,515 $57,627 - $58,758 Max Net Benefits 2010 2008 $37,545 - $47,213 $20,050 - $21,141 $23,179 - $24,234 $31,292 - $28,409 $37,107 - $34,245 $41,535 - $38,969 $44,028 - $41,764 $47,140 - $44,980 Total Cost = Total Benefit 2010 2008 $41,185 - $55,976 $21,775 - $25,823 $24,820 - $29,002 $34,069 - $32,753 $39,691 - $39,931 $44,471 - $44,968 $48,407 - $49,105 $53,756 - $53,139 
961 

Table VIII-20b 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 dollars) 

(7 percent discount rate) 

Light Trucks Baseline 

Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $5,515 - $2,037 $3,348 - $2,606 $4,483 - $6,025 $11,396 - $11,198 $15,190 - $16,270 $20,999 - $22,177 $23,257 - $25,317 $26,378 - $27,337 

2% Annual Increase 2010 2008 $16,050 - $9,927 $7,576 - $5,740 $8,180 - $7,962 $11,732 - $11,309 $13,279 - $14,469 $14,752 - $17,231 $16,158 - $19,198 $17,975 - $20,333 3% Annual Increase 2010 2008 $19,029 - $12,094 $9,136 - $7,782 $10,146 - $10,707 $15,010 - $16,233 $18,750 - $21,077 $22,598 - $25,122 $24,781 - $27,392 $27,766 - $29,255 4% Annual Increase 2010 2008 $19,315 - $14,222 $9,472 - $9,963 $11,503 - $13,695 $17,317 - $20,609 $22,109 - $26,221 $27,097 - $30,906 $29,377 - $33,404 $32,464 - $35,965 5% Annual Increase 2010 2008 $19,662 - $16,485 $10,362 - $11,361 $12,427 - $16,054 $19,598 - $24,088 $24,940 - $31,294 $30,372 - $35,786 $32,952 - $38,687 $37,217 - $41,118 6% Annual Increase 2010 2008 $23,287 - $22,896 $11,838 - $13,241 $13,980 - $17,956 $20,620 - $25,938 $26,283 - $33,948 $32,238 - $38,713 $35,059 - $41,933 $39,194 - $43,555 7% Annual Increase 2010 2008 $24,162 - $25,239 $12,722 - $14,332 $15,112 - $19,918 $22,160 - $27,512 $28,295 - $34,421 $33,999 - $40,173 $36,356 - $43,166 $40,256 - $45,693 Max Net Benefits 2010 2008 $25,442 - $40,427 $12,996 - $19,317 $14,620 - $22,280 $21,119 - $27,739 $25,957 - $32,651 $31,305 - $36,932 $33,341 - $38,916 $37,045 - $40,273 Total Cost = Total Benefit 2010 2008 $27,029 - $42,211 $13,344 - $20,451 $15,059 - $23,291 $20,645 - $28,613 $26,462 - $34,426 $32,200 - $38,707 $33,856 - $40,682 $37,389 - $42,651 
962 

Table VIII-20c 

Present Value of Lifetime Net Social Benefits by Alternative 

(Millions of 2010 dollars) 

(7 percent discount rate) 

Passenger Cars and Light 

Trucks Baseline Fleet 

MYs 

2011­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $22,069 - $17,032 $13,166 - $10,783 $18,727 - $20,124 $33,213 - $32,087 $42,426 - $45,211 $54,833 - $56,348 $60,785 - $64,532 $69,203 - $70,198 

2% Annual Increase 2010 2008 $23,233 - $19,537 $12,007 - $10,970 $15,261 - $16,572 $22,529 - $23,197 $28,619 - $30,862 $33,625 - $36,710 $37,093 - $41,243 $41,965 - $45,721 3% Annual Increase 2010 2008 $38,789 - $32,724 $16,676 - $14,926 $21,207 - $23,339 $32,064 - $34,032 $41,913 - $45,989 $49,309 - $53,774 $54,820 - $60,225 $62,507 - $65,124 4% Annual Increase 2010 2008 $48,087 - $43,241 $20,049 - $20,099 $26,362 - $30,392 $39,946 - $43,149 $52,324 - $56,763 $63,938 - $66,897 $69,952 - $73,978 $77,711 - $80,721 5% Annual Increase 2010 2008 $41,610 - $40,706 $23,573 - $23,546 $30,890 - $35,274 $47,454 - $49,900 $60,615 - $66,770 $72,113 - $78,112 $78,812 - $85,175 $88,341 - $91,881 6% Annual Increase 2010 2008 $47,989 - $52,083 $27,157 - $28,117 $34,932 - $40,195 $52,264 - $54,610 $64,120 - $72,094 $77,425 - $83,673 $84,125 - $93,386 $94,494 - $99,711 7% Annual Increase 2010 2008 $55,821 - $60,331 $31,080 - $31,941 $39,480 - $45,210 $56,546 - $59,696 $68,704 - $75,455 $80,399 - $87,508 $89,073 - $97,680 $97,883 - $104,451 Max Net Benefits 2010 2008 $62,987 - $87,640 $33,046 - $40,459 $37,799 - $46,514 $52,411 - $56,147 $63,064 - $66,896 $72,840 - $75,901 $77,369 - $80,680 $84,185 - $85,253 Total Cost = Total Benefit 2010 2008 $68,213 - $98,187 $35,119 - $46,274 $39,879 - $52,293 $54,714 - $61,366 $66,154 - $74,358 $76,671 - $83,675 $82,263 - $89,787 $91,144 - $95,790 
963 

Table VIII-21a 

Present Value of Net Total Benefits522 by Alternative 

Passenger Cars, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $16,084 - $15,483 $9,416 - $8,199 $13,568 - $13,985 $21,234 - $20,495 $26,378 - $27,589 $32,776 - $31,972 $36,420 - $36,638 $41,844 - $40,151 

2% Annual Increase 2010 2008 $7,117 - $9,874 $4,232 - $5,331 $6,531 - $8,589 $10,138 - $11,656 $14,680 - $15,830 $17,942 - $18,749 $19,989 - $21,298 $23,190 - $24,718 3% Annual Increase 2010 2008 $19,277 - $21,381 $7,314 - $7,275 $10,673 - $12,606 $16,558 - $17,794 $22,832 - $24,399 $26,530 - $27,826 $29,774 - $31,830 $34,727 - $35,202 4% Annual Increase 2010 2008 $26,894 - $29,883 $9,742 - $10,209 $13,778 - $16,490 $21,395 - $22,116 $28,807 - $29,209 $35,276 - $33,965 $38,974 - $38,093 $43,676 - $41,787 5% Annual Increase 2010 2008 $21,136 - $25,074 $12,354 - $12,205 $17,214 - $18,744 $25,446 - $25,053 $32,535 - $32,290 $37,898 - $37,110 $41,265 - $40,209 $45,142 - $43,088 6% Annual Increase 2010 2008 $24,160 - $28,507 $14,610 - $14,216 $19,528 - $20,769 $28,592 - $26,847 $33,347 - $33,894 $37,787 - $37,005 $40,853 - $39,222 $42,173 - $41,017 7% Annual Increase 2010 2008 $28,128 - $33,093 $16,277 - $16,351 $21,048 - $22,223 $28,525 - $28,170 $33,794 - $34,235 $37,088 - $34,744 $35,898 - $34,555 $35,654 - $36,321 Max Net Benefits 2010 2008 $35,083 - $44,682 $18,917 - $19,061 $21,712 - $22,648 $28,376 - $25,708 $33,486 - $31,396 $37,674 - $36,022 $40,620 - $39,004 $44,191 - $41,840 Total Cost = Total Benefit 2010 2008 $36,631 - $49,921 $19,495 - $19,298 $22,054 - $22,676 $28,016 - $25,954 $33,493 - $32,184 $37,066 - $36,553 $40,554 - $39,957 $43,089 - $43,119 

522 This table is from a societal perspective, thus, while technology costs are included, civil penalties are deleted from the costs because 

payment (from manufacturers to the U.S. Treasury). 
964 

Table VIII-21b 

Present Value of Net Total Benefits by Alternative 

Light Trucks, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $5,383 - $2,183 $3,332 - $2,786 $4,613 - $6,591 $12,064 - $12,286 $15,893 - $17,890 $21,798 - $24,294 $24,365 - $27,657 $27,847 - $29,905 

2% Annual Increase 2010 2008 $15,272 - $11,272 $7,462 - $6,473 $8,228 - $8,886 $12,270 - $12,713 $13,973 - $16,150 $15,587 - $19,183 $17,158 - $21,296 $19,264 - $22,671 3% Annual Increase 2010 2008 $18,335 - $13,904 $9,099 - $8,830 $10,342 - $12,051 $15,833 - $18,215 $19,619 - $23,337 $23,778 - $27,692 $26,270 - $30,138 $29,612 - $32,260 4% Annual Increase 2010 2008 $18,355 - $16,058 $9,340 - $10,957 $11,614 - $15,033 $18,173 - $22,492 $22,906 - $28,268 $28,415 - $32,879 $30,879 - $35,556 $34,226 - $38,344 5% Annual Increase 2010 2008 $18,929 - $18,060 $10,346 - $12,245 $12,552 - $17,261 $20,052 - $25,692 $24,325 - $32,252 $29,464 - $36,316 $31,968 - $38,733 $36,249 - $41,242 6% Annual Increase 2010 2008 $22,825 - $23,696 $11,917 - $13,803 $14,130 - $18,720 $20,636 - $26,893 $25,173 - $33,021 $30,354 - $37,356 $33,126 - $39,899 $37,188 - $41,269 7% Annual Increase 2010 2008 $23,032 - $26,379 $12,338 - $15,007 $14,724 - $20,657 $21,669 - $27,875 $26,214 - $32,915 $31,613 - $37,608 $33,874 - $39,609 $37,765 - $40,940 Max Net Benefits 2010 2008 $22,957 - $37,863 $12,048 - $19,134 $14,041 - $22,325 $20,683 - $27,959 $25,041 - $32,331 $30,738 - $36,993 $33,051 - $39,161 $36,667 - $40,882 Total Cost = Total Benefit 2010 2008 $24,453 - $38,052 $12,561 - $19,464 $14,464 - $22,615 $20,294 - $28,399 $25,134 - $32,008 $31,031 - $36,242 $32,770 - $38,274 $36,340 - $40,140 
965 

Table VIII-21c 

Present Value of Net Total Benefits by Alternative 

Combined, (3% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $21,466 - $17,666 $12,748 - $10,986 $18,181 - $20,576 $33,299 - $32,781 $42,271 - $45,479 $54,574 - $56,266 $60,785 - $64,295 $69,691 - $70,056 

2% Annual Increase 2010 2008 $22,389 - $21,146 $11,693 - $11,804 $14,759 - $17,475 $22,408 - $24,370 $28,653 - $31,980 $33,528 - $37,931 $37,147 - $42,594 $42,453 - $47,389 3% Annual Increase 2010 2008 $37,613 - $35,285 $16,413 - $16,106 $21,015 - $24,656 $32,391 - $36,009 $42,452 - $47,736 $50,308 - $55,519 $56,044 - $61,967 $64,339 - $67,462 4% Annual Increase 2010 2008 $45,249 - $45,941 $19,082 - $21,167 $25,393 - $31,523 $39,568 - $44,607 $51,713 - $57,477 $63,691 - $66,844 $69,853 - $73,649 $77,902 - $80,131 5% Annual Increase 2010 2008 $40,065 - $43,134 $22,700 - $24,450 $29,766 - $36,004 $45,498 - $50,746 $56,859 - $64,542 $67,362 - $73,426 $73,232 - $78,942 $81,391 - $84,330 6% Annual Increase 2010 2008 $46,986 - $52,203 $26,527 - $28,019 $33,658 - $39,489 $49,227 - $53,740 $58,520 - $66,915 $68,141 - $74,362 $73,979 - $79,121 $79,361 - $82,285 7% Annual Increase 2010 2008 $51,159 - $59,472 $28,616 - $31,358 $35,773 - $42,879 $50,194 - $56,046 $60,008 - $67,150 $68,701 - $72,352 $69,772 - $74,164 $73,418 - $77,262 Max Net Benefits 2010 2008 $58,040 - $82,546 $30,965 - $38,194 $35,753 - $44,974 $49,059 - $53,667 $58,527 - $63,727 $68,412 - $73,015 $73,671 - $78,165 $80,858 - $82,722 Total Cost = Total Benefit 2010 2008 $61,084 - $87,973 $32,057 - $38,762 $36,517 - $45,290 $48,309 - $54,354 $58,627 - $64,192 $68,098 - $72,796 $73,324 - $78,231 $79,429 - $83,259 
966 

Table VIII-22a 

Present Value of Net Total Benefits523 by Alternative 

Passenger Cars, (7% Discount Rate) 

(Millions of 2010 Dollars)

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $11,949 - $11,737 $6,980 - $6,178 $10,047 - $10,510 $15,852 - $15,365 $19,660 - $20,481 $24,458 - $23,581 $27,200 - $27,008 $31,335 - $29,635 

2% Annual Increase 2010 2008 $5,323 - $7,471 $3,137 - $4,041 $4,786 - $6,468 $7,486 - $8,746 $10,905 - $11,814 $13,301 - $13,976 $14,849 - $15,900 $17,314 - $18,507 3% Annual Increase 2010 2008 $14,352 - $16,247 $5,442 - $5,511 $7,938 - $9,494 $12,353 - $13,423 $17,127 - $18,279 $19,956 - $20,787 $22,388 - $23,764 $26,209 - $26,401 4% Annual Increase 2010 2008 $19,731 - $22,651 $7,120 - $7,700 $10,106 - $12,370 $15,815 - $16,573 $21,362 - $21,701 $26,217 - $25,121 $29,001 - $28,125 $32,570 - $30,798 5% Annual Increase 2010 2008 $15,664 - $19,016 $9,081 - $9,186 $12,656 - $13,999 $18,589 - $18,703 $23,758 - $23,571 $27,641 - $26,715 $30,006 - $28,800 $32,603 - $30,659 6% Annual Increase 2010 2008 $18,003 - $21,204 $10,816 - $10,528 $14,354 - $15,276 $20,802 - $19,789 $24,050 - $24,518 $26,700 - $25,992 $28,817 - $26,647 $28,671 - $27,340 7% Annual Increase 2010 2008 $20,241 - $24,315 $11,733 - $11,986 $15,033 - $15,978 $20,071 - $20,255 $23,871 - $24,164 $25,717 - $23,182 $23,045 - $21,304 $21,657 - $22,062 Max Net Benefits 2010 2008 $24,764 - $32,845 $13,320 - $13,675 $15,368 - $15,848 $21,168 - $18,165 $24,603 - $21,813 $27,428 - $25,060 $29,321 - $27,258 $31,633 - $29,550 Total Cost = Total Benefit 2010 2008 $26,362 - $35,926 $14,103 - $12,958 $15,923 - $15,556 $19,641 - $17,938 $23,744 - $22,408 $26,161 - $25,555 $28,689 - $27,949 $29,937 - $30,132 

523 This table is from a societal perspective, thus, while technology costs are included, civil penalties are deleted from the costs because 

payment (from manufacturers to the U.S. Treasury). 
967 

Table VIII-22b 

Present Value of Net Total Benefits by Alternative 

Light Trucks, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 $3,948 - $1,641 $2,464 - $2,105 $3,453 - $5,025 $9,105 - $9,374 $11,956 - $13,671 $16,342 - $18,531 $18,323 - $21,076 $20,986 - $22,796 

2% Annual Increase 2010 2008 $11,048 - $8,662 $5,482 - $4,975 $6,095 - $6,816 $9,217 - $9,771 $10,521 - $12,396 $11,753 - $14,705 $12,963 - $16,306 $14,598 - $17,384 3% Annual Increase 2010 2008 $13,340 - $10,725 $6,718 - $6,800 $7,702 - $9,267 $11,927 - $13,987 $14,753 - $17,861 $17,906 - $21,158 $19,829 - $23,011 $22,393 - $24,647 4% Annual Increase 2010 2008 $13,285 - $12,327 $6,872 - $8,360 $8,617 - $11,474 $13,664 - $17,123 $17,166 - $21,453 $21,371 - $24,832 $23,243 - $26,856 $25,781 - $28,974 5% Annual Increase 2010 2008 $13,771 - $13,734 $7,646 - $9,281 $9,315 - $13,083 $14,952 - $19,414 $17,857 - $24,117 $21,574 - $27,002 $23,405 - $28,664 $26,572 - $30,536 6% Annual Increase 2010 2008 $16,719 - $17,665 $8,833 - $10,344 $10,490 - $14,043 $15,268 - $20,129 $18,355 - $24,205 $21,980 - $27,294 $24,016 - $29,000 $26,996 - $29,946 7% Annual Increase 2010 2008 $16,695 - $19,752 $9,023 - $11,270 $10,790 - $15,471 $15,901 - $20,707 $18,880 - $23,977 $22,787 - $27,172 $24,435 - $28,397 $27,306 - $29,071 Max Net Benefits 2010 2008 $15,931 - $26,414 $8,896 - $13,589 $10,305 - $16,072 $15,296 - $20,667 $18,402 - $23,400 $22,360 - $26,590 $23,916 - $28,294 $26,723 - $29,552 Total Cost = Total Benefit 2010 2008 $17,355 - $26,935 $9,082 - $14,130 $10,540 - $16,551 $14,920 - $20,951 $18,273 - $23,081 $22,666 - $26,195 $23,970 - $27,707 $26,616 - $29,056 
968 

Table VIII-22c 

Present Value of Net Total Benefits by Alternative 

Combined, (7% Discount Rate) 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 $15,897 - $13,379 $9,444 - $8,284 $13,500 - $15,535 $24,957 - $24,739 $31,616 - $34,152 $40,800 - $42,112 $45,523 - $48,085 $52,320 - $52,431 

2% Annual Increase 2010 2008 $16,372 - $16,133 $8,620 - $9,016 $10,881 - $13,285 $16,703 - $18,517 $21,426 - $24,211 $25,054 - $28,681 $27,812 - $32,206 $31,912 - $35,892 3% Annual Increase 2010 2008 $27,692 - $26,972 $12,160 - $12,311 $15,640 - $18,761 $24,279 - $27,411 $31,880 - $36,140 $37,862 - $41,945 $42,217 - $46,776 $48,602 - $51,047 4% Annual Increase 2010 2008 $33,016 - $34,978 $13,992 - $16,060 $18,723 - $23,844 $29,479 - $33,696 $38,528 - $43,154 $47,588 - $49,952 $52,244 - $54,981 $58,351 - $59,772 5% Annual Increase 2010 2008 $29,435 - $32,750 $16,727 - $18,467 $21,971 - $27,081 $33,541 - $38,117 $41,615 - $47,688 $49,215 - $53,718 $53,411 - $57,464 $59,175 - $61,195 6% Annual Increase 2010 2008 $34,722 - $38,869 $19,649 - $20,872 $24,845 - $29,319 $36,071 - $39,917 $42,405 - $48,723 $48,680 - $53,287 $52,833 - $55,647 $55,667 - $57,286 7% Annual Increase 2010 2008 $36,936 - $44,067 $20,756 - $23,256 $25,823 - $31,449 $35,973 - $40,962 $42,752 - $48,141 $48,504 - $50,355 $47,480 - $49,701 $48,963 - $51,133 Max Net Benefits 2010 2008 $40,695 - $59,259 $22,216 - $27,264 $25,673 - $31,920 $36,464 - $38,832 $43,005 - $45,212 $49,788 - $51,650 $53,237 - $55,552 $58,356 - $59,101 Total Cost = Total Benefit 2010 2008 $43,718 - $62,861 $23,185 - $27,089 $26,463 - $32,107 $34,561 - $38,889 $42,017 - $45,489 $48,827 - $51,749 $52,659 - $55,657 $56,553 - $59,188 
969 

Table VIII-23a 

Liquid Fuel Savings over Lifetimes of Model Year 2011-2025 Passenger Cars with Alternative Increases in C

(Millions of gallons) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 6,093 - 5,501 3,547 - 2,949 5,106 - 5,073 7,826 - 7,524 9,672 - 10,365 11,993 - 12,117 13,215 - 13,828 14,983 - 15,005 

2% Annual Increase 2010 2008 2,632 - 3,538 1,596 - 1,896 2,531 - 3,111 3,886 - 4,361 5,489 - 5,931 6,711 - 6,968 7,417 - 7,861 8,456 - 8,980 3% Annual Increase 2010 2008 4,498 - 4,954 2,725 - 2,581 3,964 - 4,560 6,127 - 6,407 8,257 - 8,898 9,452 - 10,139 10,568 - 11,560 12,166 - 12,533 4% Annual Increase 2010 2008 6,695 - 6,939 3,817 - 3,649 5,324 - 6,006 8,167 - 8,096 10,802 - 10,921 13,100 - 12,758 14,328 - 14,304 15,867 - 15,716 5% Annual Increase 2010 2008 8,073 - 8,891 4,764 - 4,382 6,615 - 6,904 10,126 - 9,275 12,905 - 12,903 15,011 - 15,323 16,585 - 16,889 18,437 - 18,451 6% Annual Increase 2010 2008 9,064 - 10,716 5,519 - 5,353 7,504 - 8,000 11,503 - 10,273 13,922 - 13,811 16,769 - 16,711 18,150 - 19,655 20,834 - 21,685 7% Annual Increase 2010 2008 11,633 - 12,885 6,618 - 6,337 8,751 - 9,174 12,632 - 11,686 14,967 - 15,211 17,207 - 18,453 20,381 - 22,239 22,867 - 23,933 Max Net Benefits (3% Discount Rate) 

2010 2008 

14,530 -

17,484 

7,627 -

7,963 

8,737 -

9,379 

12,615 -

11,480 

14,642 -

14,063 

16,186 -

15,872 

17,307 -

16,854 

18,649 -

17,819 

Max Net Benefits (7% Discount Rate) 

2010 2008 

13,815 -

17,387 

7,226 -

7,811 

8,296 -

8,889 

11,286 -

10,522 

13,605 -

12,702 

15,221 -

14,334 

16,022 -

15,266 

17,014 -

16,293 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

15,169 -

20,614 

7,851 -

9,965 

8,895 -

11,053 

12,896 -

12,455 

14,937 -

15,193 

16,720 -

16,982 

18,078 -

18,446 

20,255 -

19,837 

524 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios

scenarios are not impacted by choice of discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both M

Cost = Total Benefit scenarios. 
970 

Total Cost = Total Benefit (7% 2010 15,169 ­ 7,851 ­ 8,895 ­ 12,896 ­ 14,937 ­ 16,720 ­ 18,078 ­ 20,255 ­ Discount Rate) 2008 20,614 9,965 11,053 12,455 15,193 16,982 18,446 19,837 
971 

Table VIII-23b 

Liquid Fuel Savings over Lifetimes of Model Year 2011-2025 Light Trucks 

with Alternative Increases in CAFE Standards

(Millions of gallons) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 2,041 - 750 1,219 - 954 1,640 - 2,211 4,215 - 4,084 5,575 - 5,864 7,697 - 7,929 8,444 - 8,986 9,482 - 9,616 

2% Annual Increase 2010 2008 6,151 - 3,689 2,828 - 2,095 3,045 - 2,911 4,359 - 4,102 4,886 - 5,214 5,376 - 6,155 5,849 - 6,800 6,455 - 7,127 3% Annual Increase 2010 2008 7,259 - 4,510 3,408 - 2,847 3,766 - 3,910 5,541 - 5,890 6,889 - 7,591 8,229 - 8,971 8,955 - 9,715 9,959 - 10,280 4% Annual Increase 2010 2008 7,376 - 5,326 3,530 - 3,660 4,265 - 5,017 6,381 - 7,496 8,099 - 9,459 9,851 - 11,049 10,588 - 11,846 11,622 - 12,654 5% Annual Increase 2010 2008 7,493 - 6,168 3,857 - 4,177 4,602 - 5,881 7,238 - 8,776 9,318 - 11,391 11,304 - 12,900 12,215 - 13,950 13,707 - 14,701 6% Annual Increase 2010 2008 8,851 - 8,561 4,397 - 4,864 5,164 - 6,588 7,605 - 9,448 9,799 - 12,727 12,017 - 14,353 12,971 - 15,550 14,422 - 16,049 7% Annual Increase 2010 2008 9,181 - 9,475 4,730 - 5,273 5,616 - 7,322 8,216 - 10,050 10,808 - 12,723 12,926 - 14,802 13,724 - 15,992 15,102 - 16,936 Max Net Benefits (3% Discount Rate) 

2010 2008 

9,805 -

15,617 

4,762 -

7,393 

5,399 -

8,432 

7,848 -

10,280 

9,758 -

12,991 

11,735 -

14,531 

12,448 -

15,153 

13,673 -

15,681 

Max Net Benefits (7% Discount Rate) 

2010 2008 

9,673 -

15,206 

4,828 -

7,180 

5,404 -

8,227 

7,843 -

10,161 

9,694 -

12,048 

11,589 -

13,521 

12,230 -

14,134 

13,475 -

14,481 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

10,271 -

15,875 

4,953 -

7,592 

5,561 -

8,598 

7,660 -

10,479 

9,937 -

13,211 

11,936 -

14,679 

12,463 -

15,302 

13,664 -

15,902 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

10,271 -

15,875 

4,953 -

7,592 

5,561 -

8,598 

7,660 -

10,479 

9,937 -

13,211 

11,936 -

14,679 

12,463 -

15,302 

13,664 -

15,902 
972 

Table VIII-23c 

Liquid Fuel Savings over Lifetimes of Model Year 2011-2025 

Passenger Cars and Light Trucks Combined 

with Alternative Increases in CAFE Standards

(Millions of gallons) 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 8,134 - 6,251 4,766 - 3,904 6,746 - 7,285 12,041 - 11,608 15,247 - 16,230 19,690 - 20,045 21,659 - 22,815 24,466 - 24,621 

2% Annual Increase 2010 2008 8,784 - 7,227 4,424 - 3,992 5,576 - 6,022 8,244 - 8,463 10,375 - 11,145 12,086 - 13,123 13,266 - 14,661 14,911 - 16,107 3% Annual Increase 2010 2008 11,757 - 9,464 6,132 - 5,428 7,730 - 8,470 11,668 - 12,297 15,146 - 16,489 17,681 - 19,110 19,523 - 21,275 22,125 - 22,813 4% Annual Increase 2010 2008 14,070 - 12,265 7,347 - 7,309 9,588 - 11,023 14,548 - 15,592 18,901 - 20,380 22,951 - 23,807 24,916 - 26,150 27,489 - 28,370 5% Annual Increase 2010 2008 15,566 - 15,059 8,621 - 8,560 11,217 - 12,785 17,365 - 18,051 22,223 - 24,294 26,314 - 28,223 28,801 - 30,839 32,144 - 33,152 6% Annual Increase 2010 2008 17,914 - 19,278 9,916 - 10,217 12,668 - 14,589 19,108 - 19,721 23,721 - 26,538 28,786 - 31,064 31,121 - 35,205 35,256 - 37,734 7% Annual Increase 2010 2008 20,814 - 22,360 11,348 - 11,610 14,367 - 16,496 20,848 - 21,736 25,775 - 27,934 30,133 - 33,255 34,105 - 38,231 37,969 - 40,869 Max Net Benefits (3% Discount Rate) 

2010 2008 

24,335 -

33,102 

12,389 -

15,356 

14,136 -

17,811 

20,463 -

21,760 

24,401 -

27,054 

27,921 -

30,403 

29,755 -

32,007 

32,322 -

33,500 

Max Net Benefits (7% Discount Rate) 

2010 2008 

23,487 -

32,593 

12,054 -

14,991 

13,700 -

17,116 

19,129 -

20,683 

23,299 -

24,750 

26,810 -

27,856 

28,253 -

29,399 

30,489 -

30,774 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

25,440 -

36,489 

12,804 -

17,557 

14,456 -

19,650 

20,557 -

22,935 

24,874 -

28,405 

28,656 -

31,661 

30,540 -

33,747 

33,918 -

35,739 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

25,440 -

36,489 

12,804 -

17,557 

14,456 -

19,650 

20,557 -

22,935 

24,874 -

28,405 

28,656 -

31,661 

30,540 -

33,747 

33,918 -

35,739 
973 

Table VIII-24a 

Net Change in Electricity Consumption over Lifetimes of Model Year 2011-2025 

Passenger Cars with Alternative Increases in CAFE Standards525 (in GW-h) 

Passenger Cars Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,949.6 272.1 - 2,310.8 349.5 - 3,100.3 366.6 - 3,747.2 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 2,120.8 0.0 - 2,667.7 272.1 - 2,959.9 349.5 - 3,725.6 354.8 - 4,180.1 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,442.0 272.1 - 1,800.5 349.5 - 2,563.3 366.6 - 3,012.2 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 73.5 - 1,562.7 347.6 - 1,926.5 638.8 - 2,694.9 692.1 - 4,778.0 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 2,061.4 - 542.3 2,720.8 - 7,208.8 3,691.9 - 10,168.0 5,601.8 - 10,687.4 7,261.1 - 13,416.6 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 460.9 2,043.7 - 722.7 3,285.9 - 4,885.1 10,267.7 - 18,022.2 10,568.1 - 35,074.0 24,997.5 - 48,022.8 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 2,478.3 6,390.9 - 4,364.5 8,121.4 - 9,222.4 10,992.8 - 26,094.0 33,649.0 - 57,940.9 48,359.2 - 66,198.7 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

32.0 -

 1,806.7 

11,498.8 -

 10,940.9 

14,406.0 -

 15,351.4 

14,865.4 -

 16,358.0 

16,048.4 -

 17,690.9 

17,136.1 -

 19,094.8 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

35.9 -

 1,813.9 

2,069.5 -

 6,478.5 

8,503.8 -

 10,208.3 

9,583.3 -

 10,730.2 

9,927.1 -

 11,684.2 

10,135.5 -

 12,398.6 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,274.3 

35.9 -

 14,822.4 

12,875.2 -

 17,142.9 

13,844.7 -

 22,018.9 

16,294.3 -

 23,290.6 

17,533.1 -

 26,328.6 

27,801.7 -

 29,438.9 

525 The choice of a 3 or 7 percent discount rate can impact the results of the Max Net Benefits and Total Cost = Total Benefits scenarios

scenarios are not impacted by choice of discount rate. Results for both 3 and 7 percent discount rates are therefore presented for both M

Cost = Total Benefit scenarios. 
974 

Total Cost = Total Benefit (7% 2010 0.0 ­ 0.0 - 35.9 ­ 12,875.2 ­ 13,844.7 ­ 16,294.3 ­ 17,533.1 ­ 27,801.7 ­ Discount Rate) 2008 0.0 14,274.3 14,822.4 17,142.9 22,018.9 23,290.6 26,328.6 29,438.9 
975 

Table VIII-24b 

Net Change in Electricity Consumption over Lifetimes of Model Year 2011-2025 

Light Trucks with Alternative Increases in CAFE Standards 

(in GW-h) 

Light Trucks Baseline Fleet MYs 2011 ­ 2016 MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 0.2 - 0.0 0.2 - 0.0 0.2 - 0.0 0.2 - 206.5 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 487.2 - 1,160.2 485.4 - 1,151.8 497.8 - 1,159.1 532.7 - 1,362.6 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 0.0 - 0.0 0.0 - 0.0 540.4 - 7,952.7 538.1 - 8,220.3 551.4 - 9,244.6 585.1 - 9,425.2 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - 0.0 33.0 - 239.8 32.8 - 230.5 4,341.9 - 1,399.0 4,325.8 - 1,713.8 4,435.7 - 3,719.9 5,299.1 - 6,955.8 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 0.0 

35.7 -

 250.5 

35.6 -

 241.1 

592.9 -

 12,967.5 

671.4 -

 12,932.8 

689.1 -

 13,068.0 

690.8 -

 13,076.7 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 0.0 

35.7 -

 250.5 

35.6 -

 241.1 

35.5 -

 5,338.1 

35.4 -

 5,342.0 

36.3 -

 5,412.8 

35.9 -

 5,427.5 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 45.8 

35.7 -

 299.2 

35.6 -

 288.3 

519.8 -

 13,443.1 

517.6 -

 13,387.7 

1,253.5 -

 13,468.4 

1,254.9 -

 13,461.2 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 45.8 

35.7 -

 299.2 

35.6 -

 288.3 

519.8 -

 13,443.1 

517.6 -

 13,387.7 

1,253.5 -

 13,468.4 

1,254.9 -

 13,461.2 
976 

Table VIII-24c 

Net Change in Electricity Consumption over Lifetimes of Model Year 2011-2025 

Passenger Cars and Light Trucks Combined 

 with Alternative Increases in CAFE Standards

(in GW-h) 

Passenger Cars & Light 

Trucks 

Baseline 

Fleet 

MYs 

2011 ­

2016 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Preferred Alternative 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,949.6 272.1 - 2,310.8 349.5 - 3,100.3 366.6 - 3,747.2 

2% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 2,120.8 0.0 - 2,667.7 272.1 - 2,959.9 349.5 - 3,725.6 354.8 - 4,180.1 3% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 0.0 - 1,442.0 272.1 - 1,800.5 349.5 - 2,563.3 366.6 - 3,012.2 4% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 0.0 - 542.3 73.7 - 1,562.7 347.8 - 1,926.5 639.0 - 2,694.9 692.3 - 4,984.5 5% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 0.0 - 277.8 2,061.4 - 542.3 3,208.0 - 8,369.0 4,177.3 - 11,319.7 6,099.6 - 11,846.5 7,793.9 - 14,779.2 6% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 32.0 - 460.9 2,043.7 - 722.7 3,826.2 - 12,837.8 10,805.8 - 26,242.5 11,119.6 - 44,318.6 25,582.6 - 57,448.0 7% Annual Increase 2010 2008 0.0 ­ 0.0 0.0 - (7.7) 65.0 - 2,718.1 6,423.7 - 4,595.0 12,463.4 - 10,621.4 15,318.7 - 27,807.8 38,084.7 - 61,660.8 53,658.3 - 73,154.5 Max Net Benefits (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

67.8 -

 2,057.2 

11,534.4 -

 11,182.0 

14,999.0 -

 28,318.9 

15,536.9 -

 29,290.8 

16,737.6 -

 30,759.0 

17,826.8 -

 32,171.5 

Max Net Benefits (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 1,312.3 

71.6 -

 2,064.5 

2,105.1 -

 6,719.6 

8,539.3 -

 15,546.4 

9,618.7 -

 16,072.2 

9,963.4 -

 17,097.0 

10,171.4 -

 17,826.0 

Total Cost = Total Benefit (3% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,320.1 

71.6 -

 15,121.7 

12,910.8 -

 17,431.2 

14,364.5 -

 35,462.0 

16,811.9 -

 36,678.3 

18,786.6 -

 39,797.0 

29,056.6 -

 42,900.2 

Total Cost = Total Benefit (7% Discount Rate) 

2010 2008 

0.0 ­

0.0 

0.0 -

 14,320.1 

71.6 -

 15,121.7 

12,910.8 -

 17,431.2 

14,364.5 -

 35,462.0 

16,811.9 -

 36,678.3 

18,786.6 -

 39,797.0 

29,056.6 -

 42,900.2 
977 

H. Social Benefits, Private Benefits, and Potential Unquantified Consumer Welfare 

Impacts of the Final MY 2017-2021 and Augural 2022-2025 Standards 

There are two viewpoints for evaluating the costs and benefits of the increase in CAFE 

standards: the private perspective of vehicle buyers themselves on the higher fuel economy 

levels that the rule would require, and the economy-wide or “social” perspective on the costs and 

benefits of requiring higher fuel economy. In order to appreciate how these viewpoints may 

diverge, it is important to distinguish between costs and benefits that are “private” and costs and 

benefits that are “social,” The agency’s analysis of benefits and costs from requiring higher fuel 

efficiency, presented above, includes several categories of benefits (identified as “social 

benefits”) that are not limited to automobile purchasers, and that extend throughout the U.S. 

economy. Examples of these benefits include reductions in the energy security costs associated 

with U.S. petroleum imports, and in the economic damages expected to result from air pollution 

(including but not limited to climate change). In contrast, other categories of benefits— 

principally future fuel savings projected to result from higher fuel economy, but also for example 

time savings—will be experienced exclusively by the initial purchasers and subsequent owners 

of vehicle models whose fuel economy manufacturers elect to improve (“private benefits”). 

The economy-wide or “social” benefits from requiring higher fuel economy represent an 

important share of the total economic benefits from raising CAFE standards. At the same time, 

NHTSA estimates that benefits to vehicle buyers themselves will significantly exceed vehicle 

manufacturers’ costs for complying with the stricter fuel economy standards this rule establishes. 

In short, consumers will benefit on net. Since the agency also assumes that the costs of new 

technologies manufacturers will employ to improve fuel economy will ultimately be borne by 

vehicle buyers in the form of higher purchase prices, NHTSA concludes that the benefits to 

potential vehicle buyers from requiring higher fuel efficiency will far outweigh the costs they 

will be required to pay to obtain it. NHTSA recognizes that this conclusion raises certain issues, 

addressed directly below. 

As an illustration, Tables VIII-25 and VIII-26 report the agency’s estimates of the average 

lifetime values of fuel savings for MY 2017-2025 passenger cars and light trucks calculated 

using future retail fuel prices (that is, inclusive of fuel taxes), which are those likely to be used 

by vehicle buyers to project the value of fuel savings they expect from higher fuel economy. The 

tables compare NHTSA’s estimates of the average lifetime value of fuel savings for cars and 

light trucks to the price increases projected to result from manufacturers’ efforts to recover their 

costs for complying with increased CAFE standards for those model years by increasing 

vehicles’ sales prices. In response to comments received on the Preliminary Regulatory Impact 
                                                      

978 

Analysis (PRIA) requesting that any payback analysis include a broad range of additional 

ownership costs potentially impacted by this rule, Tables VIII-25 and VIII-26 have been updated 

to include, as a separate line item, CAFE-related increases in per-vehicle ownership costs 

including maintenance, insurance, taxes/fees, and financing costs in spite of the fact that 

consumers may not fully factor these additional ownership costs into vehicle purchasing 

decisions.526 Tables VIII-25 and VIII-26 show that the estimates of the present value of lifetime 

fuel savings (discounted at both 3 and 7 percent rates) outweigh projected vehicle price increases 

and increased vehicle ownership costs for both cars and light trucks in every model year, even 

under the assumption that all of manufacturers’ technology outlays are passed on to buyers in the 

form of higher selling prices for new cars and light trucks. By model year 2025, NHTSA 

projects that average lifetime fuel savings will exceed the sum of the average price increase and 

average ownership cost increase by nearly $3,400 (2010 baseline estimate) or $2,900 (2008 

baseline estimate) for cars, and close to $4,700 (2010 baseline estimate) or about $5,200 (2008 

baseline estimate) for light trucks, all assuming a 3 percent discount rate. If applying a 7 percent 

discount rate to these costs and benefits, the net benefit for MY 2025 passenger cars is about 

$2,200 (2010 baseline estimate) or slightly above $1,800 (2008 baseline estimate). For light 

trucks, the corresponding values are about $3,300 and $3,700 (2010 and 2008 baseline estimates, 

respectively). 

526 Further information on NHTSA’s analysis of this rule’s impact on finance, insurance, and tax or fee costs related 

to vehicle purchase and ownership is provided in Chapter VII (see section on vehicle sales impact). 
979 

Table VIII-25a 

Net Present Value of Lifetime527 Fuel Savings vs. Avg. Vehicle Purchase and Ownership Cost In

Under Preferred Alternative, 3% Discount Rate 

Passenger Cars

Passenger Cars Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Value of Fuel Savings 2010 2008 $1,067 - $904 $1,565 - $1,574 $2,402 - $2,325 $2,971 - $3,123 $3,662 - $3,600 $4,005 - $4,045 $4,511 - $4,324 

Average Increase in Purchase Cost 

2010 2008 

($284) ­

($208) 

($424) ­

($377) 

($603) ­

($571) 

($762) ­

($837) 

($934) ­

($1,034) 

($1,024) ­

($1,168) 

($1,129) ­

($1,255) 

Average Increase in Ownership Costs (Maintenance, Insurance, Taxes/Fees, Financing) 

2010 2008 

($115) ­

($90) 

($171) ­

($165) 

($261) ­

($261) 

($326) ­

($374) 

($418) ­

($449) 

($464) ­

($512) 

($521) ­

($551) 

Average Total Increase (Purchase + Ownership Costs) 

2010 2008 

($399) ­

($298) 

($594) ­

($542) 

($864) ­

($832) 

($1,087) ­

($1,211) 

($1,352) ­

($1,483) 

($1,488) ­

($1,680) 

($1,650) ­

($1,806) 

Difference (Fuel Savings less 2010 $668 - $970 - $1,538 - $1,883 - $2,310 - $2,516 - $2,862 - Average Total Increase) 2008 $607 $1,032 $1,493 $1,912 $2,117 $2,365 $2,518 

527 For Tables VIII-25 and VIII-26, the lifetime of vehicles is 30 years for passenger cars and 37 years for light trucks. Note that only a 

fuel savings benefit occurs beyond the first half of a vehicle’s lifetime, due to discounting, and declines in VMT and survival rates as v
980 

Table VIII-25b 

Net Present Value of Lifetime Fuel Savings vs. Avg. Vehicle Purchase and Ownership Cost Incr

Under Preferred Alternative, 3% Discount Rate 

Light Trucks 

Light Trucks Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Value of Fuel Savings 2010 2008 $660 - $501 $906 - $1,204 $2,321 - $2,277 $3,130 - $3,275 $4,337 - $4,388 $4,788 - $4,983 $5,440 - $5,385 

Average Increase in Purchase Cost 

2010 2008 

($158) ­

($87) 

($187) ­

($179) 

($416) ­

($331) 

($596) ­

($470) 

($863) ­

($648) 

($911) ­

($752) 

($1,000) ­

($808) 

Average Increase in Ownership Costs (Maintenance, Insurance, Taxes/Fees, Financing) 

2010 2008 

($64) - 

($37) 

($75) - 

($88) 

($173) ­

($164) 

($237) ­

($228) 

($364) ­

($298) 

($395) ­

($347) 

($441) ­

($374) 

Average Total Increase (Purchase + Ownership Costs) 

2010 2008 

($222) ­

($124) 

($263) ­

($267) 

($589) ­

($495) 

($834) ­

($698) 

($1,227) ­

($947) 

($1,305) ­

($1,099) 

($1,441) ­

($1,182) 

Difference (Fuel Savings less 2010 $438 - $643 - $1,733 - $2,296 - $3,110 - $3,482 - $3,999 - Average Total Increase) 2008 $376 $937 $1,781 $2,577 $3,441 $3,884 $4,203 
981 

Table VIII-26a 

Net Present Value of Lifetime528 Fuel Savings vs. Avg. Vehicle Purchase and Ownership Cost In

Under Preferred Alternative, 7% Discount Rate 

Passenger Cars

Passenger Cars Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Value of Fuel Savings 2010 2008 $838 - $710 $1,229 - $1,237 $1,886 - $1,827 $2,332 - $2,453 $2,875 - $2,827 $3,143 - $3,175 $3,540 - $3,394 

Average Increase in Purchase Cost 

2010 2008 

($284) ­

($208) 

($424) ­

($377) 

($603) ­

($571) 

($762) ­

($837) 

($934) ­

($1,034) 

($1,024) ­

($1,168) 

($1,129) ­

($1,255) 

Average Increase in Ownership Costs (Maintenance, Insurance, Taxes/Fees, Financing) 

2010 2008 

($114) ­

($88) 

($170) ­

($161) 

($256) ­

($252) 

($320) ­

($363) 

($406) ­

($438) 

($450) ­

($499) 

($503) ­

($537) 

Average Total Increase (Purchase + Ownership Costs) 

2010 2008 

($398) ­

($296) 

($594) ­

($539) 

($859) ­

($824) 

($1,082) ­

($1,200) 

($1,340) ­

($1,473) 

($1,474) ­

($1,666) 

($1,632) ­

($1,792) 

Difference (Fuel Savings less 2010 $439 - $635 - $1,028 - $1,250 - $1,535 - $1,669 - $1,909 - Average Total Increase) 2008 $414 $698 $1,003 $1,253 $1,354 $1,508 $1,602 

528 For Tables VIII-25 and VIII-26, the lifetime of vehicles is 30 years for passenger cars and 37 years for light trucks. Note that only a 

fuel savings benefit occurs beyond the first half of a vehicle’s lifetime, due to discounting, and declines in VMT and survival rates as v
982 

Table VIII-26b 

Net Present Value of Lifetime Fuel Savings vs. Avg. Vehicle Purchase and Ownership Cost Incr

Under Preferred Alternative, 7% Discount Rate 

Light Trucks 

Light Trucks Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

Value of Fuel Savings 2010 2008 $513 - $389 $704 - $935 $1,802 - $1,767 $2,429 - $2,542 $3,364 - $3,404 $3,712 - $3,865 $4,216 - $4,175 

Average Increase in Purchase Cost 

2010 2008 

($158) ­

($87) 

($187) ­

($179) 

($416) ­

($331) 

($596) ­

($470) 

($863) ­

($648) 

($911) ­

($752) 

($1,000) ­

($808) 

Average Increase in Ownership Costs (Maintenance, Insurance, Taxes/Fees, Financing) 

2010 2008 

($63) - 

($37) 

($75) - 

($84) 

($171) ­

($156) 

($238) ­

($218) 

($359) ­

($289) 

($387) ­

($336) 

($431) ­

($361) 

Average Total Increase (Purchase + Ownership Costs) 

2010 2008 

($222) ­

($123) 

($263) ­

($263) 

($587) ­

($487) 

($834) ­

($688) 

($1,222) ­

($937) 

($1,298) ­

($1,087) 

($1,431) ­

($1,169) 

Difference (Fuel Savings less 2010 $291 - $442 - $1,215 - $1,595 - $2,142 - $2,414 - $2,785 - Average Total Increase) 2008 $265 $672 $1,279 $1,854 $2,467 $2,777 $3,006 
                                                      

 

983 

Assuming the comparisons in Tables VIII-25 and VIII-26 are accurate, they raise the question of 

why current vehicle purchasing patterns do not result in average fuel economy levels 

approaching those that this rule would require, and why stricter CAFE standards should be 

necessary to increase the fuel economy of new cars and light trucks. They also raise the question 

of why manufacturers do not elect to provide higher fuel economy even in the absence of 

increases in CAFE standards, since the comparisons in the preceding tables suggest that doing so 

would reduce the effective price of purchasing many new vehicle models, and thus increase sales 

of new vehicles. More specifically, why would potential buyers of new vehicles hesitate to make 

investments in vehicles with higher fuel economy that would produce the substantial economic 

returns illustrated by the comparisons presented in Tables VIII-25 and VIII-26? And why would 

manufacturers voluntarily forego opportunities to increase the attractiveness, value, and 

competitive positioning of their passenger car and light truck models by improving their fuel 

economy? 

One explanation for why this situation might persist is that the market for vehicle fuel economy 

does not appear to work perfectly, in which case properly designed CAFE standards would be 

expected to increase consumer welfare. Some of these imperfections might stem from standard 

market failures, such as limited availability of information to consumers about the value of 

higher fuel economy.529 However, such information is increasingly available and has become 

easier to obtain, and new fuel economy labels will provide a wide range of information about the 

economic and environmental benefits of increased fuel economy. Other explanations point to 

phenomena observed in the field of behavioral economics, including loss aversion, inadequate 

consumer attention to long-term savings, or a lack of salience of relevant benefits (such as fuel 

savings, or time savings associated with refueling) to consumers at the time they make 

purchasing decisions. Both theoretical and empirical research suggests that many consumers are 

unwilling to make energy-efficient investments even when those investments appear to pay off in 

the relatively short-term530. This research is in line with related findings that consumers may 

undervalue benefits or costs that are less salient, or that they will realize only in the future.531 

529 “Out of Sight, Out of Mind: The Effects of Expenses on Mutual Fund Flows,” Journal of Business vol. 78, no. 6, 

pp. 2095-2020. Available at 

http://faculty.haas.berkeley.edu/odean/papers/MutualFunds/Out%20of%20Sight%200112281.pdf (last accessed 

August 1, 2012) or Docket No. NHTSA-2010-0131.

530 Jaffe, A. B., and Stavins, R. N. (1994). The Energy Paradox and the Diffusion of Conservation Technology. 

Resource and Energy Economics, 16(2); see Hunt Alcott and Nathan Wozny, Gasoline Prices, Fuel Economy, and 

the Energy Paradox (2010, available at http://www.sciencedirect.com/science/article/B6VFJ-45DMPNK7/2/0d3440e9948aab163f984aeb7c8472a7 (last accessed August 1, 2012). 531 Hossain, Janjim, and John Morgan (2009). “. . . Plus Shipping and Handling: Revenue (Non) Equivalence in 

Field Experiments on eBay,” Advances in Economic Analysis and Policy vol. 6; Barber, Brad, Terrence Odean, and 

Lu Zheng (2005). Available at http://faculty.haas.berkeley.edu/rjmorgan/eBay.pdf (last accessed August 1, 2012) or 

Docket No. NHTSA-2010-0131. 
984 

Many commenters on the agency’s proposed CAFE standards for MY 2017-25 noted that recent 

poll results and changes in attitudes suggest that consumers are becoming more aware of the 

importance and value of fuel economy, and that this will increasingly be reflected in their future 

vehicle purchasing decisions. NRDC, the Sierra Club, Consumer Federation of America, and 

Consumers’ Union each cited recent polls indicating that consumers are increasingly concerned 

about fuel prices and U.S. energy security, and are increasingly aware that purchasing vehicles 

with higher fuel economy can reduce both their gasoline costs and U.S. dependence on imported 

petroleum. Some of these commenters also noted that recent polls have shown growing support 

for higher CAFE standards as a strategy for increasing the range of vehicle models offering high 

fuel economy, and increased willingness of vehicle buyers to pay for improved fuel economy 

and advanced technologies such as electric vehicles. 

The agency agrees that there appears to be growing awareness of fuel economy generally and 

increased interest in higher fuel economy among vehicle buyers, but notes that some of this may 

reflect the persistence of high fuel prices in recent years. Thus if fuel prices decline from recent 

high levels, some of this increased awareness and willingness to pay for higher fuel economy 

could erode. In addition, if significant failures in the market for fuel economy – such as those 

identified in the preceding discussion – exist, then increased consumer awareness of and interest 

in fuel economy may be inadequate by themselves to result in the levels of fuel economy that 

would be economically desirable. In this case, increased CAFE standards are still likely to be 

necessary to require manufacturers to supply – and buyers to demand – the higher fuel economy 

levels that can be economically justified on the basis of their benefits and costs. 

Previous research provides some support for the agency’s conclusion that the benefits buyers 

will receive from requiring manufacturers to increase fuel economy outweigh the costs they 

would pay to acquire those benefits, even if private markets have not provided that amount of 

fuel economy. For example, some research suggest that many consumers appear unwilling to 

make energy-efficiency investments that appear likely to pay off in the relatively short-term, in 

part because they are deterred by the prospect that those investments require immediate, known 

outlays but produce deferred and uncertain returns. Such “loss aversion” – particularly when 

accompanied by a sense of uncertainty about gains – may make purchasing a more fuel-efficient 

vehicle seem unattractive to some potential buyers, even when doing so is likely to be a sound 

economic decision. As an illustration, Greene et al. (2009) calculate that the expected net present 

value of increasing the fuel economy of a passenger car from 28 to 35 miles per gallon falls from 

$405 when calculated using standard net present value calculations, to nearly zero when 
                                                      

 

 

 

985 

uncertainty regarding future cost savings and buyers’ reluctance to accept the risk of losses are 

taken into account.532 

The well-known finding that as gas prices rise, consumers show more willingness to pay for fuelefficient vehicles is not necessarily inconsistent with the possibility that many consumers 

undervalue potential savings in gasoline costs and fuel economy when purchasing new vehicles. 

In ordinary circumstances, such costs may be a relatively “shrouded” attribute in consumers’ 

decisions, in part because the savings from purchasing a more fuel efficient vehicle are 

cumulative and extend over a significant period of time. At the same time, it may be difficult for 

potential buyers to disentangle the cost of purchasing a more fuel-efficient vehicle from its 

overall purchase price, or to isolate the value of higher fuel economy from accompanying 

differences in other vehicle attributes. This possibility is consistent with recent evidence to the 

effect that many consumers are willing to pay less than $1 upfront to obtain a $1 reduction in the 

discounted present value of future gasoline costs.533 

Some research suggests that the market’s apparent unwillingness to provide more fuel efficient 

vehicles stems from consumers’ inability to value future fuel savings correctly. For example, 

Larrick and Soll (2008) find evidence that consumers do not understand how to translate changes 

in fuel economy, which is denominated in miles per gallon (MPG), into resulting changes in fuel 

consumption, measured for example in gallons per 100 miles travelled or per month or year.534 It 

is true that the recently redesigned fuel economy label should help overcome this difficulty, 

because it draws attention to purely economic effects of fuel economy, but MPG remains a 

prominent measure. Sanstad and Howarth (1994) argue that consumers often resort to imprecise 

but convenient rules of thumb to compare vehicles that offer different fuel economy ratings, and 

that this can cause many buyers to underestimate the value of fuel savings, particularly from 

532 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. Surprisingly, the 

authors find that uncertainty regarding the future price of gasoline appears to be less important than uncertainty 

surrounding the expected lifetimes of new vehicles. (Docket NHTSA–2009–0059–0154). On loss aversion in 

general, and its relationship to prospect theory (which predicts that certain losses will loom larger than probabilistic 

gains of higher expected value), see Kahneman. 533 See, e.g., Alcott and Wozny. On shrouded attributes and their importance, see Gabaix, Xavier, and David 

Laibson. 2006. "Shrouded Attributes, Consumer Myopia, and Information Suppression in Competitive Markets." 

Quarterly Journal of Economics 121(2): 505-540. Available at 

http://www.economics.harvard.edu/faculty/laibson/files/Shrouded.pdf (last accessed August 1, 2012) or Docket No. 

NHTSA-2010-0131. 

534 Larrick, R. P., and J.B. Soll (2008). “The MPG illusion.” Science 320: 1593-1594. Available at 

http://www.sciencemag.org/content/320/5883/1593.full?ijkey=3pScQm7pQBzqs&keytype=ref&siteid=sci (requires 

subscription; last accessed August 1, 2012) or Docket No. NHTSA-2011-0131 
                                                      

986 

significant increases in fuel economy.535 If the behavior identified in these studies is widespread, 

then the agency’s estimates suggesting that the benefits to vehicle owners from requiring higher 

fuel economy significantly exceed the costs of providing it may be consistent with private 

markets not providing that fuel economy level. 

Some commenters endorsed the agency’s analysis of the potential for various sources of market 

failure to inhibit manufacturers from supplying adequate fuel economy levels, and to cause 

potential buyers to underestimate the value of purchasing models that offer higher fuel economy. 

Consumer Federation of America endorsed the agency’s focus on sources of manufacturers’ 

hesitance to offer models with higher fuel economy, as well as on the more commonly cited 

market failures that can make buyers unwilling to invest in higher fuel economy. CFA also 

submitted more detailed discussions of some of these sources of potential market failure in 

support of its general comments. ICCT noted that the combination of uncertainty about the cost 

and effectiveness of new technologies to improve fuel economy with buyers’ aversion to 

potential losses from purchasing higher-priced vehicles offering uncertain fuel savings was 

sufficient to explain the underinvestment in fuel economy, and to justify higher fuel economy 

standards. ICCT also argued that by removing consumers’ option to buy low fuel economy 

vehicles, higher fuel economy standards minimize the effect of aversion on buyers’ willingness 

to invest in higher fuel economy. 

Another possible explanation for the apparent inconsistency between the agency’s claim that the 

typical vehicle buyer will experience net savings from these standards and the fact that the 

average fuel economy of new vehicles sold currently falls well short of the level those standards 

would require is that many of the technologies projected by the agency to be available through 

MY2025 offer significantly improved efficiency per unit of cost, yet were not available for 

application to new vehicles sold currently. Still another is that the value of future savings 

resulting from the proposed standards will vary widely among potential vehicle buyers. These 

differences undoubtedly reflect variation in the amount they drive, differences in their driving 

styles that affect the fuel economy they expect to achieve, and varying expectations about future 

fuel prices, but they may also partly reflect differences in buyers’ understanding of what 

increased fuel economy is likely to mean to them financially, or in buyers’ preferences for 

paying lower prices today versus anticipated savings over the future. 

535 Sanstad, A., and R. Howarth (1994). “ ‘Normal’ Markets, Market Imperfections, and Energy Efficiency.” 

Energy Policy 22(10): 811–818. Available at http://www.sciencedirect.com/science/article/pii/0301421594901392 

(last accessed August 1, 2012) 
987 

Unless the agency has overestimated their average value, however, the fact that the value of fuel 

savings varies among potential buyers cannot explain why typical buyers do not currently 

purchase what appear to be cost- saving increases in fuel economy. A possible explanation for 

this situation is that the effects of differing fuel economy levels are relatively modest when 

compared to those provided by other, more prominent features of new vehicles, such as 

passenger and cargo-carrying capacity, performance, or safety. In this situation, it may simply 

not be in many shoppers’ interest to spend the time and effort necessary to determine the 

economic value of higher fuel economy, to isolate the component of a new vehicle’s selling price 

that is related to its fuel economy, and compare these two (this possibility is consistent with the 

view that fuel economy is a relatively “shrouded” attribute). In this case, the agency’s estimates 

of the average value of fuel savings that will result from requiring cars and light trucks to 

achieve higher fuel economy may be correct, yet those savings may not be large enough to lead a 

sufficient number of buyers to purchase vehicles with higher fuel economy to raise average fuel 

economy above its current levels. 

Defects in the market for cars and light trucks could also lead manufacturers to undersupply fuel 

economy, even in cases where many (informed) buyers would be willing to pay the increased 

prices necessary to provide it. Most obviously, an absence of vigorous competition among 

producers of cars and light trucks may lead manufacturers to undersupply attributes that 

contribute to the overall quality of new vehicles, including fuel economy, because such 

“imperfect” competition reduces producers’ profit incentive to supply the level of fuel economy 

that buyers are willing to pay for. Incomplete or “asymmetric” access to information on vehicle 

attributes such as fuel economy – whereby manufacturers of new vehicles or sellers of used cars 

and light trucks have more complete knowledge of vehicles’ actual fuel economy levels, or of the 

value of purchasing higher fuel economy, than do potential buyers – may also prevent sellers of 

new or used vehicles from capturing its full value. In this situation, the level of fuel efficiency 

provided in the markets for new or used vehicles might remain persistently lower than that 

demanded by potential buyers. 

Constraints on the combinations of fuel economy, carrying capacity, and performance that 

current technologies permit manufacturers to offer in individual vehicle models undoubtedly 

limit the range of fuel economy available within certain vehicle classes, particularly those 

including larger vehicles. However, it is also possible that deliberate decisions by manufacturers 

further limit the range of fuel economy available to buyers within individual vehicle market 

segments, such as large automobiles, SUVs, or minivans. Manufacturers may deliberately limit 

the range of fuel economy levels they offer in those market segments (by choosing not to invest 

in fuel economy and investing instead in providing a range of other vehicle attributes) because 

they underestimate the premiums that prospective buyers of those models are willing to pay for 
                                                      

 

988 

improved fuel economy, and thus mistakenly believe it will be unprofitable for them to offer 

more fuel-efficient models within those segments. Of course, this possibility is most realistic if 

it is also assumed that buyers are imperfectly informed, or if fuel economy savings are not 

sufficiently salient to shoppers in those particular market segments. As an illustration, the range 

of highway fuel economy ratings among current minivan models extends from 22 to 28 mpg, 

while their combined city and highway ratings range only from 18 to 20 mpg.536 If this 

phenomenon is widespread, the average fuel efficiency of their entire new vehicle fleet could 

remain below the levels that potential buyers demand and are willing to pay for. 

Another possible explanation for the paradox posed by buyers’ apparent unwillingness to invest 

in higher fuel economy when it appears to offer such large financial returns is that NHTSA’s 

estimates of benefits and costs from requiring manufacturers to improve fuel efficiency do not 

match potential buyers’ assessment of the likely benefits and costs from purchasing models with 

higher fuel economy ratings. This could occur because the agency’s underlying assumptions 

about some of the factors that affect the value of fuel savings differ from those made by potential 

buyers, because NHTSA has used different estimates for some components of the benefits from 

saving fuel from those of buyers, or simply because the agency has failed to account for some 

potential costs of achieving higher fuel economy. 

For example, buyers may not value increased fuel economy as highly as the agency’s 

calculations suggest, because they have shorter time horizons than the full vehicle lifetimes 

NHTSA uses in these calculations, because they discount future fuel savings using higher rates 

than those prescribed by OMB for evaluating Federal regulations, or they expect to drive 

substantially fewer miles over the course of vehicle ownership than the VMT schedules upon 

which NHTSA based its central cost-benefit analysis. Potential buyers may also anticipate lower 

fuel prices in the future than those forecast by the Energy Information Administration, or may 

expect larger differences between vehicles’ MPG ratings and their own actual on-road fuel 

economy than the 20 percent gap (30 percent for HEVs) the agency estimates. 

To illustrate the first of these possibilities, Table VIII-27 shows the effect of differing 

assumptions about vehicle buyers’ time horizons for assessing the value of future fuel savings. 

Specifically, the table compares the average value of fuel savings from purchasing a MY 2025 

536 This is the range of combined city and highway fuel economy levels from lowest (Toyota Sienna AWD) to 

highest (Honda Odyssey) available for model year 2010; http://www.fueleconomy.gov/feg/bestworstEPAtrucks.htm 

(last accessed September 26, 2011). 
989 

car or light truck when fuel savings are evaluated over different time horizons to the estimated 

increase in its price. 

Unlike Tables VIII-25 and VIII-26, Table VIII-27 looks at the value of fuel savings only for the 

vehicle lifetime as anticipated by the consumer, that is, 14 years for passenger cars and 16 years 

for light trucks. Table VIII-27 shows that over the consumer’s anticipated lifetime of model year 

2025 vehicles, NHTSA projects that average lifetime fuel savings will exceed the average 

purchase price increase of passenger cars by around $3,300 or about $2,900 (2010 and 2008 

baselines, respectively), and that of light trucks by about $4,400 or around $4,900 (2010 and 

2008 baselines, respectively), assuming a 3 percent discount rate. If a 7 percent discount rate is 

applied, fuel savings will exceed average price increases of passenger cars by about $2,500 or 

around $2,100 (2010 and 2008 baselines, respectively), and that of light trucks by around $3,400 

or about $3,800 (2010 and 2008 baselines, respectively). 

If buyers are instead assumed to evaluate fuel savings over a 10-year time horizon, however, the 

present value of fuel savings exceeds the projected price increase for a MY 2025 passenger car 

by about $2,500 under the 2010 baseline fleet analysis and by about $2,100 under the 2008 

baseline fleet analysis, using a 3 percent discount rate. If applying a 7 percent discount rate, 

these figures drop to about $1,900 and $1,600, respectively. The present value of fuel savings 

for a MY 2025 light truck exceeds the projected vehicle price increase by about $3,300 under the 

2010 baseline fleet analysis and somewhat more than $3,600 under the 2008 baseline fleet 

analysis, using a 3 percent discount rate. If applying a 7 percent discount rate, these figures drop 

to about $2,700 and $3,000, respectively. 

Finally, Table VIII-27 shows that under the assumption that buyers value fuel savings only over 

the length of time for which they typically finance new car purchases (slightly more than 5 years 

during 2010), the value of fuel savings, valued according to a 3 percent discount rate, exceeds 

the estimated increase in the price of a MY 2025 passenger car by a bit more than $800, or 

somewhat over $500 in the case of the 2008 baseline analysis. If utilizing a 7 percent discount 

rate, the corresponding values are a bit less than $700 for the 2010 baseline analysis, or about 

$400 in the case of the 2008 baseline analysis. Owners of light trucks will also see a net benefit 

over the course of the average loan term, with the present value of fuel savings exceeding 

purchase price increases by about $1,500 or $1,700 (2010 and 2008 baselines, respectively) at a 

3 percent discount rate, or in the event of a 7 percent discount rate, by about $1,300 or $1,500 

(2010 and 2008 baselines, respectively). 
990 

Table VIII-27 

Value of Fuel Savings vs. Vehicle Price Increases 

with Alternative Assumptions about Vehicle Buyer Time Horizons537,538

Vehicle Measure Baseline Fleet 

3% Discount Rate 7% Discount Rate 

Expected 

Lifetime 

10 

Years 

Average 

Loan 

Term 

Expected 

Lifetime 

10 

Years 

Ave

Lo

Te

MY 2025 

Passenger 

Car 

Fuel Savings 2010 2008 $4,659 - $4,506 $3,820 - $3,694 $2,193 - $2,121 $3,838 - $3,712 $3,293 - $3,186 $2,0

$1

Price Increase 2010 2008 ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,

($1

Difference 2010 2008 $3,298 - $2,929 $2,459 - $2,118 $833 - $545 $2,477 - $2,135 $1,933 - $1,609 $6

$

MY 2025 

Light 

Truck 

Fuel Savings 2010 2008 $5,472 - $5,900 $4,343 - $4,683 $2,525 - $2,722 $4,472 - $4,823 $3,758 - $4,053 $2,3

$2

Price Increase 2010 2008 ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,

($1

Difference 2010 2008 $4,425 - $4,860 $3,296 - $3,643 $1,477 - $1,682 $3,424 - $3,783 $2,711 - $3,013 $1,3

$1

537 In this Table, “expected lifetime” refers to 14 years for passenger cars and 16 years for light trucks.538 The average term on new-vehicle loans made by auto finance companies during 2010 was 63 months; see Board of Governors of the 

Federal Reserve Statistical Release G. 19, Consumer Credit, http://www.federalreserve.gov/releases/g19/Current/ (last accessed Augus

Reserve Board suspended publication of this series in Q1 2011, as “the statistical foundation for [this] series has deteriorated.” In this Fthe most recent data from this series prior to suspension of publication. 
                                                      

 

991 

Potential vehicle buyers may also discount future fuel future savings using higher rates than 

those typically used to evaluate federal regulations. (For some consumers, these high discount 

rates might reflect rational behavior539; for others, they might reflect an excessive focus on the 

short-term and a neglect of the future.) OMB guidance prescribes that future benefits and costs 

of regulations that mainly affect private consumption decisions, as will be the case if 

manufacturers’ costs for complying with higher fuel economy standards are passed on to vehicle 

buyers, should be discounted using a consumption rate of time preference.540 OMB estimates 

that savers currently discount future consumption at an average real or inflation-adjusted rate of 

about 3 percent when they face little risk about its likely level, which makes it a reasonable 

estimate of the consumption rate of time preference. However, vehicle buyers may view the 

value of future fuel savings that results from purchasing a vehicle with higher fuel economy as 

risky or uncertain, or they may instead discount future consumption at rates reflecting their costs 

for financing the higher capital outlays required to purchase more fuel-efficient models. In either 

case, they may discount future fuel savings at rates other than the 3 and 7 percent levels assumed 

in NHTSA’s evaluation. 

Table VIII-28 shows the effect of alternative discount rates on vehicle buyers’ evaluation of the 

fuel savings projected to result from the CAFE standards established by this rule, again using 

MY 2025 passenger cars and light trucks as an example. As Table VIII-27 showed, average 

future fuel savings discounted at the 3 percent consumer rate exceed the agency’s estimated price 

increases by more than $2,900 for MY 2025 passenger cars and by more than $4,400 for MY 

2025 light trucks over the expected vehicle lifetime from the consumer perspective. If vehicle 

buyers instead discount future fuel savings at the average new-car loan rate (5.16%)541, however, 

these differences decline to at most just above $2,800 for cars and slightly above $4,200 for light 

trucks, as Table VIII-28 illustrates. This is a particularly plausible alternative assumption, 

because buyers are likely to finance the increases in purchase prices resulting from compliance 

with higher CAFE standards as part of the process financing the vehicle purchase itself. Finally, 

as the table also shows, discounting future fuel savings using a consumer credit card rate (which 

539 For example, it may be rational for a consumer who drives very few miles per year [and expects this pattern to 

continue well into the future] to place little value on fuel savings, thereby implying a large discount rate. 540 Office of Management and Budget, Circular A-4, “Regulatory Analysis,” September 17, 2003, 33. Available at 

http://www.whitehouse.gov/sites/default/files/omb/assets/regulatory_matters_pdf/a-4.pdf (last accessed August 1, 

2012) or Docket No. NHTSA-2010-0131. 

541 This rate is the average of Global Insight forecasts of auto loan rates, the average of commercial bank auto loan 

and auto finance company loan rates for years 2017 to 2025, adjusted for inflation using Global Insight forecasts of 

the Consumer Price Index. No data on the distribution of commercial bank auto loans vs. auto finance loans were 

identified, therefore NHTSA assumed an equal distribution across these categories. 
                                                      

992 

averaged 13.8% during 2010)542 reduces these differences to no more than $1,500 for a MY 2025 

passenger car and no more than $2,500 for a MY 2025 light truck. Thus even at relatively high 

discount rates, the higher fuel economy levels required by this final rule would generate 

significant net benefits to vehicle buyers. 

542 Ibid. The average interest rate on consumer credit card accounts at commercial banks was 13.78% during 2010. 
993 

Table VIII-28 

Value of Lifetime543 Fuel Savings vs. Vehicle Price Increases 

with Alternative Assumptions about Consumer Discount Rates544

Vehicle Measure Baseline Fleet 

Value at Alternative Discount Rates 

Consumer 

Rate (3%) 

New Car 

Loan Rate 

(5.16%) 

Alternate 

Consumer 

Rate (7%) 

Consumer 

Credit Card 

Rate (13.8%

MY 2025 

Passenger 

Car 

Fuel Savings 2010 2008 $4,659 - $4,506 $4,178 - $4,041 $3,838 - $3,712 $2,818 - $2,725 

Price Increase 2010 2008 ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) ($1,361) ­ ($1,577) 

Difference 2010 2008 $3,298 - $2,929 $2,817 - $2,464 $2,477 - $2,135 $1,457 - $1,148 

MY 2025 

Light 

Truck 

Fuel Savings 2010 2008 $5,472 - $5,900 $4,883 - $5,266 $4,472 - $4,823 $3,252 - $3,507 

Price Increase 2010 2008 ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) ($1,047) ­ ($1,040) 

Difference 2010 2008 $4,425 - $4,860 $3,836 - $4,226 $3,424 - $3,783 $2,205 - $2,467 

543 In this Table, “expected lifetime” refers to 14 years for passenger cars and 16 years for light trucks. 544 The fuel-economy-improving technologies chosen within the CAFE model are to a small extent affected by the choice of the consum

to fuel savings. The CAFE model is run at 3 and 7 percent corresponding discount rates only. Analysis of the effect of alternate discou

fuel savings is therefore slightly less precise to the extent that the CAFE model may have selected a different mix of technologies at the rate. 
                                                      

994 

Combinations of a shorter time horizon and a higher discount rate could further reduce or even 

eliminate the difference between the value of fuel savings and the agency’s estimates of 

increases in vehicle prices. One plausible combination would be for buyers to discount fuel 

savings over the term of a new car loan, using the interest rate on that loan as a discount rate. 

Assuming a 60-month loan at the previously stated rate of 5.16%, the outcomes differ between 

passenger cars and light trucks for MY 2025. For passenger cars, the typical consumer would 

see fuel savings outpace the vehicle price increase by $745 or $460 (2010 and 2008 baselines, 

respectively) in this 60-month period. For consumers of light trucks, these differences are 

$1,066 and $1,040 (2010 and 2008 baselines, respectively). 

Some evidence suggests directly that vehicle buyers may employ combinations of higher 

discount rates and shorter time horizons than the agency assumes; for example, consumers 

surveyed by Kubik (2006) reported that fuel savings would have to be adequate to pay back the 

additional purchase price of a more fuel-efficient vehicle in less than 3 years to persuade a 

typical buyer to purchase it.545 As these comparisons and evidence illustrate, reasonable 

alternative assumptions about how consumers might evaluate the major benefit from requiring 

higher fuel economy can significantly reduce its magnitude from the agency’s estimate. 

Imaginable combinations of shorter time horizons, higher discount rates, and lower expectations 

about future fuel prices or annual vehicle use and fuel savings could make potential buyers 

hesitant or even unwilling to purchase vehicles offering the fuel economy levels this rule will 

require. At the same time, they would also cause vehicle buyers’ collective assessment of how 

the benefits from requiring higher fuel economy compare to the costs they will be required to pay 

for it to differ significantly from NHTSA’s assessment of the aggregate benefits and costs of this 

rule. If consumers’ views about critical variables such as future fuel prices or the appropriate 

discount rate differ sufficiently from the assumptions used by the agency, potential vehicle 

buyers might conclude that the value of fuel savings and other benefits they will experience from 

higher fuel economy are not sufficient to justify the increase in purchase prices they expect to 

pay. 

Table VIII-29 illustrates the effect of variation among potential buyers’ expectations about how 

much they are likely to drive new vehicles over their lifetimes on their evaluation of fuel savings 

projected to result from the CAFE standards this rule establishes, again using MY 2025 

545 Kubik, M. (2006). Consumer Views on Transportation and Energy. Second Edition. Technical Report: National 

Renewable Energy Laboratory. Available at http://www.nrel.gov/docs/fy05osti/36785.pdf or Docket No. NHTSA2010-0131. 
                                                      

 

995 

passenger cars and light trucks as an example. Table VIII-29 compares the perspective of 

potential buyers who expect to drive the lifetime mileage estimate used utilized in the agency’s 

central analysis to those of buyers who expect to drive only 50 and 25 percent of that lifetime 

mileage. While in both cases – even at a 7 percent discount rate – fuel savings are likely to 

outweigh increased prices for light trucks, potential buyers of passenger cars who expect to drive 

only 25 percent of the average figure used in the agency’s analysis might expect no net benefit 

from the higher fuel economy levels the rule requires.546 

546 The 25 percent VMT schedule is an extreme case; by year 14 (the horizon for passenger cars in Table VIII-29), 

only 4 percent of vehicles have cumulative VMT at or below 25 percent of average cumulative VMT. 
996 

Table VIII-29 

Value of Lifetime547 Fuel Savings vs. Vehicle Price Increases 

with Alternative Assumptions about VMT 

Vehicle Measure Baseline Fleet 

3% Discount Rate 7% Discount 

Expected 

VMT 

Schedule 

50% of 

Expected 

VMT 

25% of 

Expected 

VMT 

Expected 

VMT 

Schedule 

50% of 

Expected 

VMT 

MY 2025 

Passenger 

Car 

Fuel Savings 2010 2008 $4,659 - $4,506 $2,498 - $2,469 $1,249 - $1,234 $3,838 - $3,712 $2,022 - $1,998 

Price Increase 2010 2008 ($1,361) - ($1,577) ($1,361) - ($1,577) ($1,361) - ($1,577) ($1,361) - ($1,577) ($1,361) - ($1,577) 

Difference 2010 2008 $3,298 - $2,929 $1,138 - $892 ($112) - ($342) $2,477 - $2,135 $661 - $422 

MY 2025 

Light 

Truck 

Fuel Savings 2010 2008 $5,472 - $5,900 $3,203 - $3,404 $1,601 - $1,702 $4,472 - $4,823 $2,568 - $2,729 

Price Increase 2010 2008 ($1,047) - ($1,040) ($1,047) - ($1,040) ($1,047) - ($1,040) ($1,047) - ($1,040) ($1,047) - ($1,040) 

Difference 2010 2008 $4,425 - $4,860 $2,155 - $2,364 $554 - $662 $3,424 - $3,783 $1,520 - $1,689 

547 In this Table, “expected lifetime” refers to 14 years for passenger cars and 16 years for light trucks. 
997 

Another possibility is that achieving the fuel economy improvements required by stricter fuel 

economy standards might lead manufacturers to forego planned future improvements in 

performance, carrying capacity, safety, or other features of their vehicle models that represent 

important sources of utility to vehicle owners. In extreme cases, manufacturers might even find 

it necessary to change the levels of these attributes that some currently available models offer. 

Although the specific economic values that vehicle buyers attach to individual vehicle attributes 

such as fuel economy, performance, passenger- and cargo-carrying capacity, and other sources of 

vehicles’ utility are difficult to infer from their purchasing decisions and vehicle prices – as 

evidenced by significant variability in findings in economic literature on these topics – changes 

in vehicle attributes can significantly affect the overall utility that vehicles offer to potential 

buyers. Compromises in these or other highly-valued attributes would be viewed by potential 

buyers as an additional cost of improving fuel economy that the agency has failed to 

acknowledge or include in its estimates of the costs of complying with stricter CAFE standards. 

As indicated in its previous discussion of technology costs, NHTSA has approached this 

potential problem by developing cost estimates for fuel economy-improving technologies that 

include allowances for any additional manufacturing costs that would be necessary to maintain 

the reference fleet (or baseline) levels of performance, comfort, capacity, or safety of light-duty 

vehicle models to which those technologies are applied. In doing so, the agency followed the 

precedent established by the 2011 NAS Report on improving fuel economy, which estimated 

“constant performance and utility” costs for technologies that manufacturers could employ to 

increase the fuel efficiency of cars or light trucks. Although NHTSA has revised its estimates of 

manufacturers’ costs for some technologies significantly for use in this rulemaking, these revised 

estimates are still intended to represent costs that would allow manufacturers to maintain the 

performance, carrying capacity, and utility of vehicle models while improving their fuel 

economy. 

The agency readily acknowledges the difficulty of estimating technology costs that include 

adequate provision for the accompanying changes in vehicle design that are necessary to 

maintain performance, capacity, and utility. While NHTSA believe that its cost estimates for 

fuel economy-improving technologies are sufficient to prevent significant compromises in other 

attributes of the vehicle models to which manufacturers apply them, it is possible that these costs 

do not include adequate allowance for the necessary investments by manufacturers to maintain 

baseline levels of these critical vehicle attributes. If this is the case, the true economic costs of 

achieving higher fuel economy would include the opportunity costs to vehicle owners of any 

sacrifices in vehicles’ performance, carrying capacity, and utility that accompanied increases in 

their fuel economy. In that event, the agencies’ estimated technology costs would underestimate 

the true economic costs of complying with stricter fuel economy emission standards. 
                                                      

 

 

998 

Another possible reconciliation of the agency’s claim that the average vehicle buyer will 

experience large fuel savings from the higher CAFE standards this rule establishes with the fact 

that the average fuel economy of vehicles currently purchased falls well short of the new 

standards is that the values consumers place on the future savings they expect to obtain from 

higher fuel economy vary widely. As an illustration, one recent review of consumers’ 

willingness to pay for improved fuel economy found estimates that varied from less than 1% to 

almost ten times the present value of the resulting fuel savings when those are discounted at 7% 

over the vehicle’s expected lifetime.548,549 Although the wide variation in these estimates 

undoubtedly reflects methodological and measurement differences among the studies surveyed, 

it probably also reflects the fact that the expected savings from purchasing a vehicle with higher 

fuel economy vary widely among individuals, because they travel different amounts, have 

different driving styles, or have different expectations about future fuel prices. 

This is likely to be reflected in the fact that many buyers with high valuations of increased fuel 

economy already purchase vehicle models that offer it, while those with lower values of fuel 

economy emphasize other vehicle attributes in their purchasing decisions. A related possibility 

is that because the effects of differing fuel economy levels are relatively unimportant when 

compared to other, more prominent features of new vehicles – passenger and cargo-carrying 

capacity, performance, safety, etc. – it is simply not in many shoppers’ interest to spend the time 

and effort necessary to determine the economic value of higher fuel economy, attempt to isolate 

the component of a new vehicle’s selling price that is related to its fuel economy, and compare 

these two. (This may be so even though more fuel-efficient choices might ultimately prove to be 

in consumers’ economic self-interest.) In either case, although the agency’s estimates of the 

average value of fuel savings that will result from requiring cars and light trucks to achieve 

higher fuel economy may be correct, it may not be large enough to lead a sufficient number of 

buyers to purchase vehicles with higher fuel economy to increase average fuel economy from its 

current levels. 

548 Greene, David L., “How Consumers Value Fuel Economy: A Literature Review,” Draft report to U.S. 

Environmental Protection Agency, Oak Ridge National Laboratory, March, 2010; see Table 10, p. 37. Available at 

http://www.epa.gov/otaq/climate/regulations/420r10008.pdf (last accessed August 1, 2012) or Docket NHTSA2010-0131 

549 Jin-Tan Liu (1988). “Automotive Fuel Economy Improvements and Consumers’ Surplus.” Transportation 

Research Part A 22A(3): 203-218 (Docket EPA-HQ-OAR-2009-0472-0045). The study actually calculated the 

willingness to pay for reduced vehicle operating costs, of which vehicle fuel economy is a major component. 
                                                      

 

 

999 

The agency has been unable to reach a conclusive answer to the question of why the apparently 

large differences between its estimates of benefits from requiring higher fuel economy and the 

costs of supplying it do not result in higher average fuel economy for new cars and light trucks. 

One explanation is that NHTSA’s estimates are reasonable, and the market for fuel economy is 

simply not operating efficiently. For reasons stated above, NHTSA believes that a number of 

imperfections in the relevant market (including the lack of salience of fuel economy benefits and 

an emphasis on the short-term) likely play a key role, thus justifying the conclusion that the 

private benefits are substantial. However, the agency acknowledges that this situation may also 

reflect the fact that some combination of overestimating the value of fuel savings and omitting 

potential reductions in the welfare of vehicle buyers means that it has not fully characterized the 

impact of the CAFE standards this rule establishes on consumers. To recognize this possibility, 

and as part of a sensitivity analysis, this section presents an alternative accounting of the benefits 

and costs of CAFE standards for MY 2017-2025 passenger cars and light trucks and discusses its 

implications. 

Table VIII-30 displays the economic impacts of the rule from the perspective of potential buyers, 

and also reconciles the estimated net benefits of the rule as they are likely to be viewed by 

vehicle buyers with its net benefits to the economy as a whole. As the table shows, the total 

benefits to vehicle buyers (line 6) consists of the value of fuel savings at retail fuel prices (line 

1), the economic value of vehicle occupants’ savings in refueling time (line 2), and the economic 

benefits from added rebound-effect driving (line 3). As the zero entries in line 5 of the table 

suggest, the agency’s estimate of the retail value of fuel savings reported in line 1 is assumed to 

be correct, and no losses in consumer welfare from changes in vehicle attributes (other than those 

from increases in vehicle prices) are assumed to occur. Thus there is no reduction in the total 

private benefits to vehicle owners, so that net private benefits to vehicle buyers (line 6) are equal 

to total private benefits (reported previously in line 4). 

As Tables VIII-30 and VIII-31 (presented at 3 and 7 percent discount rates, respectively) also 

show, the decline in fuel tax revenues (line 7) that results from reduced fuel purchases is in effect 

an external cost from the viewpoint of vehicle buyers, which offsets part of the benefits of fuel 

savings when those are viewed from the economy-wide or “social” perspective.550 Thus the sum 

550 Strictly speaking, fuel taxes represent a transfer of resources from consumers of fuel to government agencies and 

not a use of economic resources. Reducing the volume of fuel purchases simply reduces the value of this transfer, 

and thus cannot produce a real economic cost or benefit. Representing the change in fuel tax revenues in effect as 

an economy-wide cost is necessary to offset the portion of fuel savings included in line 1 that represents savings in 

fuel tax payments by consumers. This prevents the savings in tax revenues from being counted as a benefit from the 

economy-wide perspective. 
                                                      

 

 

1000 

of lines 1 and 7 is the savings in fuel production costs that was reported previously as the value 

of fuel savings at pre-tax prices in the agency’s usual accounting of benefits and costs (see 

Chapter X). Line 8 represents the costs of increased congestion delays, accidents, and noise that 

result from additional driving due to the fuel economy rebound effect. Line 9 represents the net 

change in maintenance costs (during the vehicle warranty period only) resulting from the 

implementation of certain fuel-economy-improving technologies that increase or decrease 

vehicle maintenance expenses. Line 10 represents the loss in social welfare associated with 

decreased operating life of fully electric vehicles due to battery degradation (note, NHTSA 

assumed that EVs reach end-of-life when batteries degrade to 55 percent of their original 

capacity551) and the possibility of replacement. Line 11 represents the aggregate social cost of 

lines 7 through 10. 

Lines 12 and 13 of Tables VIII-30 and VIII-31 report the value of reductions in air pollution and 

climate-related externalities resulting from lower emissions during fuel production and 

consumption, while line 14 reports the savings in petroleum market externalities to the U.S. 

economy from reduced production of crude petroleum and refined fuel. Net social benefits (line 

16) is thus the sum of the social costs summarized in line 11 and the benefits resulting from the 

externalities summarized in line 15. 

Line 17 in both Table VIII-30 and Table VIII-31 shows manufacturers’ technology outlays for 

meeting higher CAFE standards for passenger cars and light trucks, which represent the principal 

cost of requiring higher fuel economy. The net total benefits (line 18) resulting from the rule 

consist of the sum of private (line 6) and social (line 16) benefits, partially offset by the 

technology costs (line 17). 

Tables VIII-30 and VIII-31 highlight several important features of this rule’s economic impacts. 

First, comparing the rule’s net private (line 6) and external (line 15) benefits makes it clear that a 

substantial majority of the benefits from requiring higher fuel economy are experienced by 

vehicle buyers, with only a small share distributed throughout the remainder of the U.S. 

economy. In turn, the vast majority of private benefits stem from fuel savings, which highlights 

the importance of the many assumptions the agency uses to estimate and value future fuel 

savings resulting from higher fuel economy, as well as of the assumption that the rule has no 

551 The assumption of EV end-of-life occurring at 55 percent battery capacity is based on NHTSA analysis of EV 

battery life data developed by the National Renewable Energy Laboratory (NREL). 
1001 

adverse impacts on vehicle buyers. The aggregate external benefits are small compared to total 

technology costs. 

As a consequence, the net economic benefits of the rule closely mirror the benefits to private 

vehicle buyers and the technology costs for achieving higher fuel economy, again highlighting 

the importance of correctly valuing fuel savings from the perspective of those who experience 

them and accounting for any other effects of the rule on the economic welfare of vehicle buyers. 
1002 

Table VIII-30 

Private, Social, and Total Benefits and Costs of MY 2017 – 2025 CAFE Standards 

Passenger Cars and Light Trucks Combined 

in Billions of 2010$ 

(3% Discount Rate) 

Entry Baseline Fleet Model Year 2011-

2016 2017 2018 2019 2020 2021 2022 2023 

1) Value of Fuel Savings (at Retail Fuel Prices) 

2010 2008 

$24.5 -

$18.8 

$14.6 -

$12.0 

$20.8 -

$22.4 

$37.2 -

$36.0 

$47.3 -

$50.5 

$61.3 -

$62.7 

$67.9 -

$71.8 

$77.2 -

$78.0 

2) Savings in Refueling Time 2010 2008 $0.8 - $0.7 $0.5 - $0.4 $0.6 - $0.7 $1.0 - $1.1 $1.3 - $1.6 $1.6 - $1.9 $1.8 - $2.2 $2.1 - $2.4 

3) Consumer Surplus in Additional Driving 

2010 2008 

$2.2 -

$1.7 

$1.3 -

$1.0 

$1.7 -

$1.9 

$3.1 -

$3.0 

$3.9 -

$4.2 

$5.1 -

$5.1 

$5.6 -

$5.9 

$6.5 -

$6.4 

4) Total Private Benefits (=1+2+3) 2010 2008 $27.5 - $21.2 $16.3 - $13.4 $23.2 - $25.1 $41.3 - $40.1 $52.5 - $56.2 $68.0 - $69.8 $75.3 - $79.9 $85.8 - $86.8 

5) Reduction in Private Benefits 2010 2008 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 

6) Net Private Benefits (=4+5) 2010 2008 $27.5 - $21.2 $16.3 - $13.4 $23.2 - $25.1 $41.3 - $40.1 $52.5 - $56.2 $68.0 - $69.8 $75.3 - $79.9 $85.8 - $86.8 

7) Change in Fuel Tax Revenues 2010 2008 ($2.5) ­ ($1.9) ($1.4) ­ ($1.2) ($2.0) ­ ($2.2) ($3.6) ­ ($3.5) ($4.5) ­ ($4.8) ($5.8) ­ ($5.9) ($6.4) ­ ($6.7) ($7.2) ­ ($7.2) 

8) Increased Costs of Congestion, etc. 

2010 2008 

($1.4) ­

($1.0) 

($0.8) ­

($0.6) 

($1.1) ­

($1.2) 

($2.0) ­

($1.9) 

($2.5) ­

($2.6) 

($3.2) ­

($3.2) 

($3.6) ­

($3.7) 

($4.1) ­

($4.0) 

9) Increased Costs of Vehicle Maintenance 

2010 2008 

($0.0) ­

($0.0) 

($0.0) ­

($0.1) 

($0.0) ­

($0.2) 

($0.2) ­

($0.5) 

($0.2) ­

($0.6) 

($0.6) ­

($0.5) 

($0.7) ­

($0.7) 

($0.9) ­

($0.8) 

10) Relative Value Loss (EVs) 2010 2008 $0.0 - $0.0 $0.0 - ($0.0) $0.0 - ($0.0) $0.0 - ($0.0) $0.0 - ($0.0) ($0.0) ­ ($0.0) ($0.0) ­ ($0.1) ($0.0) ­ ($0.1) 

11) Increase in Costs (=7+8+9+10) 2010 2008 ($3.9) ­ ($3.0) ($2.2) ­ ($1.9) ($3.2) ­ ($3.6) ($5.9) ­ ($5.9) ($7.3) ­ ($8.0) ($9.6) ­ ($9.7) ($10.7) ­ ($11.1) ($12.2) ­ ($12.0) 

12) Reduced Health Damages from Criteria Emissions 

2010 2008 

$0.7 -

$0.6 

$0.4 -

$0.4 

$0.6 -

$0.6 

$1.1 -

$1.0 

$1.3 -

$1.4 

$1.8 -

$1.7 

$1.9 -

$1.9 

$2.2 -

$2.1 

13) Reduced Climate Damages from CO2 Emissions 2010 2008 $2.1 - $1.6 $1.3 - $1.0 $1.8 - $2.0 $3.3 - $3.2 $4.3 - $4.5 $5.6 - $5.7 $6.3 - $6.6 $7.2 - $7.3 
1003 

14) Reduced Petroleum Market Externalities 

2010 2008 

$1.2 -

$0.9 

$0.7 -

$0.6 

$1.0 -

$1.1 

$1.8 -

$1.8 

$2.2 -

$2.4 

$2.9 -

$3.0 

$3.2 -

$3.4 

$3.6 -

$3.7 

15) Reduction in Externalities (=11+12+13) 

2010 2008 

$4.0 -

$3.1 

$2.4 -

$2.0 

$3.4 -

$3.7 

$6.1 -

$6.0 

$7.8 -

$8.3 

$10.2 -

$10.4 

$11.4 -

$12.0 

$13.0 -

$13.0 

16) Net Social Benefits =(11+15) 

2010 2008 

$0.1 -

$0.1 

$0.2 -

$0.1 

$0.2 -

$0.1 

$0.3 -

$0.1 

$0.6 -

$0.3 

$0.6 -

$0.7 

$0.7 -

$0.9 

$0.8 -

$1.0 

17) Technology Costs 2010 2008 ($6.2) ­ ($3.7) ($3.7) ­ ($2.5) ($5.2) ­ ($4.6) ($8.3) ­ ($7.3) ($10.8) ­ ($11.1) ($14.0) ­ ($14.2) ($15.3) ­ ($16.4) ($16.9) ­ ($17.8) 

18) Net Total Benefits (6+16+17) 2010 2008 $21.5 - $17.7 $12.7 - $11.0 $18.2 - $20.6 $33.3 - $32.8 $42.3 - $45.5 $54.6 - $56.3 $60.8 - $64.3 $69.7 - $70.1 
1004 

Table VIII-31 

Private, Social, and Total Benefits and Costs of MY 2017 – 2025 CAFE Standards 

Passenger Cars and Light Trucks Combined 

in Billions of 2010$ 

(7% Discount Rate) 

Entry Baseline Fleet Model Year 2011-

2016 2017 2018 2019 2020 2021 2022 2023 

1) Value of Fuel Savings (at Retail Fuel Prices) 

2010 2008 

$19.2 -

$14.7 

$11.4 -

$9.4 

$16.3 -

$17.6 

$29.1 -

$28.1 

$37.0 -

$39.5 

$47.9 -

$49.0 

$53.0 -

$56.1 

$60.3 -

$60.9 

2) Savings in Refueling Time 2010 2008 $0.6 - $0.5 $0.4 - $0.3 $0.5 - $0.6 $0.8 - $0.9 $1.0 - $1.2 $1.3 - $1.5 $1.4 - $1.8 $1.6 - $1.9 

3) Consumer Surplus in Additional Driving 

2010 2008 

$1.7 -

$1.4 

$1.0 -

$0.8 

$1.4 -

$1.5 

$2.4 -

$2.3 

$3.1 -

$3.3 

$4.0 -

$4.0 

$4.4 -

$4.6 

$5.1 -

$5.0 

4) Total Private Benefits (=1+2+3) 2010 2008 $21.5 - $16.6 $12.8 - $10.5 $18.2 - $19.6 $32.3 - $31.3 $41.1 - $44.0 $53.1 - $54.6 $58.9 - $62.4 $67.0 - $67.8 

5) Reduction in Private Benefits 2010 2008 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 $0.0 - $0.0 

6) Net Private Benefits (=4+5) 2010 2008 $21.5 - $16.6 $12.8 - $10.5 $18.2 - $19.6 $32.3 - $31.3 $41.1 - $44.0 $53.1 - $54.6 $58.9 - $62.4 $67.0 - $67.8 

7) Change in Fuel Tax Revenues 2010 2008 ($2.0) ­ ($1.5) ($1.1) ­ ($0.9) ($1.6) ­ ($1.7) ($2.9) ­ ($2.8) ($3.6) ­ ($3.8) ($4.6) ­ ($4.7) ($5.1) ­ ($5.3) ($5.7) ­ ($5.7) 

8) Increased Costs of Congestion, etc. 

2010 2008 

($1.1) ­

($0.8) 

($0.6) ­

($0.5) 

($0.9) ­

($0.9) 

($1.6) ­

($1.5) 

($2.0) ­

($2.0) 

($2.5) ­

($2.5) 

($2.8) ­

($2.9) 

($3.2) ­

($3.2) 

9) Increased Costs of Vehicle Maintenance 

2010 2008 

($0.0) ­

($0.0) 

($0.0) ­

($0.1) 

($0.0) ­

($0.2) 

($0.2) ­

($0.4) 

($0.2) ­

($0.4) 

($0.4) ­

($0.4) 

($0.5) ­

($0.5) 

($0.7) ­

($0.6) 

10) Relative Value Loss (EVs) 2010 2008 $0.0 - $0.0 $0.0 - ($0.0) $0.0 - ($0.0) $0.0 - ($0.0) $0.0 - ($0.0) ($0.0) ­ ($0.0) ($0.0) ­ ($0.0) ($0.0) ­ ($0.0) 

11) Increase in Costs (=7+8+9+10) 2010 2008 ($3.1) ­ ($2.3) ($1.8) ­ ($1.5) ($2.5) ­ ($2.8) ($4.6) ­ ($4.6) ($5.7) ­ ($6.3) ($7.6) ­ ($7.7) ($8.4) ­ ($8.7) ($9.6) ­ ($9.5) 

12) Reduced Health Damages from Criteria Emissions 

2010 2008 

$0.6 -

$0.5 

$0.3 -

$0.3 

$0.5 -

$0.5 

$0.9 -

$0.8 

$1.1 -

$1.1 

$1.4 -

$1.4 

$1.5 -

$1.5 

$1.7 -

$1.6 

13) Reduced Climate Damages from CO2 Emissions 2010 2008 $2.1 - $1.6 $1.3 - $1.0 $1.8 - $2.0 $3.3 - $3.2 $4.3 - $4.5 $5.6 - $5.7 $6.3 - $6.6 $7.2 - $7.3 
1005 

14) Reduced Petroleum Market Externalities 

2010 2008 

$1.0 -

$0.7 

$0.6 -

$0.5 

$0.8 -

$0.9 

$1.4 -

$1.4 

$1.8 -

$1.9 

$2.3 -

$2.4 

$2.5 -

$2.7 

$2.8 -

$2.9 

15) Reduction in Externalities (=11+12+13) 

2010 2008 

$3.6 -

$2.8 

$2.2 -

$1.8 

$3.1 -

$3.3 

$5.6 -

$5.4 

$7.1 -

$7.5 

$9.3 -

$9.4 

$10.3 -

$10.9 

$11.8 -

$11.8 

16) Net Social Benefits =(11+15) 

2010 2008 

$0.5 -

$0.4 

$0.4 -

$0.3 

$0.6 -

$0.5 

$0.9 -

$0.7 

$1.4 -

$1.2 

$1.7 -

$1.8 

$1.9 -

$2.1 

$2.2 -

$2.4 

17) Technology Costs 2010 2008 ($6.2) ­ ($3.7) ($3.7) ­ ($2.5) ($5.2) ­ ($4.6) ($8.3) ­ ($7.3) ($10.8) ­ ($11.1) ($14.0) ­ ($14.2) ($15.3) ­ ($16.4) ($16.9) ­ ($17.8) 

18) Net Total Benefits (6+16+17) 2010 2008 $15.9 - $13.4 $9.4 - $8.3 $13.5 - $15.5 $25.0 - $24.7 $31.6 - $34.2 $40.8 - $42.1 $45.5 - $48.1 $52.3 - $52.4 
                                                      

 

1006 

As discussed in detail previously, it is possible that NHTSA has over or underestimated the value 

of fuel savings to buyers and subsequent owners of the cars and light trucks to which higher 

CAFE standards will apply. It is also possible that the agency has failed to identify and value 

reductions in consumer welfare that could result from buyers’ responses to higher vehicle prices 

or changes in vehicle attributes that manufacturers make as part of their efforts to achieve higher 

fuel economy. To acknowledge these possibilities and examine their potential impact on the 

rule’s benefits and costs, and in order to provide a sensitivity analysis, Tables VIII-32 and VIII33 show the rule’s cumulative economic impacts by model year for MY 2011-2025 passenger 

cars and light trucks under varying assumptions about the agency’s potential misestimation of 

fuel savings and the value of potential changes in vehicle attributes such as performance, 

carrying capacity, or safety. 

Tables VIII-32 and VIII-33 provide examples of effects of both potential overestimation of the 

value of fuel savings to vehicle buyers and the possible omission of welfare losses from changes 

in other vehicle attributes in the entry labeled “Reduction in Private Benefits” (line 5). Although 

the examples reported previously in Tables VIII-25 through VIII-29 illustrated sources of 

possible overestimation of fuel savings using specific alternatives to the agency’s assumptions, 

NHTSA has been unable to determine exactly how buyers’ time horizons or discount rates might 

differ from those assumed in its analysis. Nor has NHTSA analyzed how vehicle buyers’ 

expectations about future fuel prices or differences between fuel economy ratings and actual onroad fuel economy might differ from those it employs to estimate the value of fuel savings. 

Finally, NHTSA has not attempted to project changes in vehicle attributes other than fuel 

economy, or to estimate the economic value of resulting losses in vehicle utility. 

Instead Tables VIII-32 and VIII-33 illustrate, at 3 and 7 percent discount rates, respectively, the 

effect of these possibilities using different assumptions about the fraction of total private benefits 

to vehicle buyers that might be offset by some combination of these factors. It is important to 

note that these assumptions are used merely for the sake of analysis and illustration; there is no 

claim here that they have an empirical basis, or that they are founded in any existing estimates, 

theoretical or empirical, of actual offsets.552 As Tables VIII-32 and VIII-33 show, if there is no 

offset to private benefits, the rule’s total and net private and social benefits are exactly as shown 

in the last column of the corresponding table (Table VIII-24 or VIII-29) above. If, however, 

these factors combine to offset as much as 25% of the agency’s estimate of total private benefits 

(line 5), the rule’s net private (line 6) and net total (line 18) benefits remain substantially 

552 While some empirical evidence suggests that consumers are largely making rational decisions, other evidence 

suggests this is not the case. Since there is not agreement in the literature on this point, it is not possible to estimate 

the potential degree of consumer loss in welfare. 
1007 

positive. If the private savings turn out to be 25% less than projected, the benefits of the rule 

continue to justify the costs by a large measure. If the offset is assumed to be as much as 50%, 

the net total benefits (line 18) would significantly decline, but would remain positive, and the 

benefits would continue to justify the costs by a large measure. 
 

 

 

 

 

 

 

1008 

Table VIII-32 

Effect of Overestimation of Fuel Savings or Omission of Welfare Losses 

on Net Private and Total Benefits of MY 2017-2025 CAFE Standards 

Passenger Cars and Light Trucks Combined 

in Billions of 2010$, (3% Discount Rate) 

Entry Baseline 

Fleet 

Fraction of Private Benefits Offset 

by Overestimation of Fuel Savings 

or Omission of Welfare Losses to 

Vehicle Buyers 

None 25% 50% 

1) Value of Fuel Savings 

(at Retail Fuel Prices) 

2010 

2008 

$531.2 -

$538.1 

$531.2 -

$538.1 

$531.2 -

$538.1 

2) Savings in Refueling Time 2010 

2008 

$14.6 -

$16.6 

$14.6 -

$16.6 

$14.6 -

$16.6 

3) Consumer Surplus 

in Additional Driving 

2010 

2008 

$44.4 -

$44.5 

$44.4 -

$44.5 

$44.4 -

$44.5 

4) Total Private Benefits (=1+2+3) 2010 

2008 

$590.2 -

$599.2 

$590.2 -

$599.2 

$590.2 -

$599.2 

5) Reduction in Private Benefits 2010 

2008 

$0.0 -

$0.0 

$147.6 -

$149.8 

$295.1 -

$299.6 

6) Net Private Benefits (=4+5) 2010 

2008 

$590.2 -

$599.2 

$442.7 -

$449.4 

$295.1 -

$299.6 

7) Change in Fuel Tax Revenues 2010 

2008 

($50.2) ­

($50.4) 

($50.2) ­

($50.4) 

($50.2) ­

($50.4) 

8) Increased Costs of 

Congestion, etc. 

2010 

2008 

($28.1) ­

($27.8) 

($28.1) ­

($27.8) 

($28.1) ­

($27.8) 

9) Increased Costs of 

Vehicle Maintenance 

2010 

2008 

($5.2) ­

($4.9) 

($5.2) ­

($4.9) 

($5.2) ­

($4.9) 

10) Relative Value Loss (EVs) 2010 

2008 

($0.1) ­

($0.6) 

($0.1) ­

($0.6) 

($0.1) ­

($0.6) 

11) Increase in Costs (=7+8+9+10) 2010 

2008 

($83.5) ­

($83.7) 

($83.5) ­

($83.7) 

($83.5) ­

($83.7) 

12) Reduced Health Damages 

from Criteria Emissions 

2010 

2008 

$14.9 -

$14.0 

$14.9 -

$14.0 

$14.9 -

$14.0 

13) Reduced Climate Damages 

from CO2 Emissions 

2010 

2008 

$48.9 -

$49.3 

$48.9 -

$49.3 

$48.9 -

$49.3 

14) Reduced Petroleum 

Market Externalities 

2010 

2008 

$25.0 -

$25.8 

$25.0 -

$25.8 

$25.0 -

$25.8 

15) Reduction in 

Externalities (=11+12+13) 

2010 

2008 

$88.9 -

$89.2 

$88.9 -

$89.2 

$88.9 -

$89.2 

16) Net Social Benefits 

=(11+15) 

2010 

2008 

$5.3 -

$5.4 

$5.3 -

$5.4 

$5.3 -

$5.4 

17) Technology Costs 2010 

2008 

($120.1) ­

($121.4) 

($120.1) ­

($121.4) 

($120.1) ­

($121.4) 

18) Net Total Benefits (6+16+17) 2010 

2008 

$475.5 -

$483.2 

$448.0 -

$454.8 

$300.4 -

$305.0 
 

 

 

 

 

 

 

1009 

Table VIII-33 

Effect of Overestimation of Fuel Savings or Omission of Welfare Losses 

on Net Private and Total Benefits of MY 2017-2025 CAFE Standards 

Passenger Cars and Light Trucks Combined 

in Billions of 2010$, (3% Discount Rate) 

Entry Baseline 

Fleet 

Fraction of Private Benefits Offset 

by Overestimation of Fuel Savings 

or Omission of Welfare Losses to 

Vehicle Buyers 

None 25% 50% 

1) Value of Fuel Savings 

(at Retail Fuel Prices) 

2010 

2008 

$415.1 -

$420.5 

$415.1 -

$420.5 

$415.1 -

$420.5 

2) Savings in Refueling Time 2010 

2008 

$11.5 -

$13.1 

$11.5 -

$13.1 

$11.5 -

$13.1 

3) Consumer Surplus 

in Additional Driving 

2010 

2008 

$34.7 -

$34.8 

$34.7 -

$34.8 

$34.7 -

$34.8 

4) Total Private Benefits (=1+2+3) 2010 

2008 

$461.3 -

$468.4 

$461.3 -

$468.4 

$461.3 -

$468.4 

5) Reduction in Private Benefits 2010 

2008 

$0.0 -

$0.0 

$115.3 -

$117.1 

$230.7 -

$234.2 

6) Net Private Benefits (=4+5) 2010 

2008 

$461.3 -

$468.4 

$346.0 -

$351.3 

$230.7 -

$234.2 

7) Change in Fuel Tax Revenues 2010 

2008 

($39.7) ­

($40.0) 

($39.7) ­

($40.0) 

($39.7) ­

($40.0) 

8) Increased Costs of 

Congestion, etc. 

2010 

2008 

($22.1) ­

($21.9) 

($22.1) ­

($21.9) 

($22.1) ­

($21.9) 

9) Increased Costs of 

Vehicle Maintenance 

2010 

2008 

($3.9) ­

($3.7) 

($3.9) ­

($3.7) 

($3.9) ­

($3.7) 

10) Relative Value Loss (EVs) 2010 

2008 

($0.0) ­

($0.2) 

($0.0) ­

($0.2) 

($0.0) ­

($0.2) 

11) Increase in Costs (=7+8+9+10) 2010 

2008 

($65.8) ­

($65.9) 

($65.8) ­

($65.9) 

($65.8) ­

($65.9) 

12) Reduced Health Damages 

from Criteria Emissions 

2010 

2008 

$11.9 -

$11.2 

$11.9 -

$11.2 

$11.9 -

$11.2 

13) Reduced Climate Damages 

from CO2 Emissions 

2010 

2008 

$48.9 -

$49.3 

$48.9 -

$49.3 

$48.9 -

$49.3 

14) Reduced Petroleum 

Market Externalities 

2010 

2008 

$19.7 -

$20.4 

$19.7 -

$20.4 

$19.7 -

$20.4 

15) Reduction in 

Externalities (=11+12+13) 

2010 

2008 

$80.5 -

$80.8 

$80.5 -

$80.8 

$80.5 -

$80.8 

16) Net Social Benefits 

=(11+15) 

2010 

2008 

$14.8 -

$15.0 

$14.8 -

$15.0 

$14.8 -

$15.0 

17) Technology Costs 2010 

2008 

($120.1) ­

($121.4) 

($120.1) ­

($121.4) 

($120.1) ­

($121.4) 

18) Net Total Benefits (6+16+17) 2010 

2008 

$356.0 -

$361.9 

$360.7 -

$366.3 

$245.4 -

$249.2 
 

1010 

It is important to reemphasize that NHTSA views the estimates of this rule’s economic impacts 

presented in Tables VIII-32 and VIII-33 as illustrative only. The agency has attempted to 

develop the most accurate estimates of the value of fuel savings that are possible. The design of 

the CAFE standards (e.g., the footprint curves), the stringency of the standards, and the lead time 

provided to manufacturers for complying with the new standards have all been tailored to ensure 

that desirable vehicle attributes other than fuel economy will not be compromised. NHTSA has 

also attempted to ensure that its estimates of technology costs include adequate provisions to 

prevent the degradation of performance, safety, or other valuable attributes as consequences of 

manufacturers’ efforts to comply with higher CAFE standards. 

A major lesson is that the benefits of the rule justify the costs even on the assumption that the 

private savings are significantly offset (an assumption that the agency believes to be to be highly 

unlikely). Nevertheless, the agency believes that it is important to acknowledge a degree of 

uncertainty in its estimates of how buyers are likely to value fuel savings, as well as in its 

conclusion that no losses in the performance, utility, or safety of cars and light trucks subject to 

this rule will occur. One conclusion is that even if the private savings are significantly 

overstated, the benefits of this rule continue to exceed the costs. NHTSA is committed to 

developing improved methods for estimating the value of improvements in fuel economy, as well 

as the magnitude and economic consequences of accompanying changes in other vehicle 

attributes, as part of its future CAFE rulemaking activities. 

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Elasticities of the Consumer Demand for Gasoline,” Southern Economic Journal, Vol. 47, 

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Journal 11:3 (1990), pp. 59-73. 
1011 

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Households,” Transportation Research A, Vol. 17A No. 3 (1983), pp. 183-189. 
1012 

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23. Small, Kenneth A., and Kurt Van Dender, “Fuel Efficiency and Motor Vehicle Travel: 

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1013 

IX.	 IMPACT OF WEIGHT REDUCTION ON SAFETY 

The primary goals of CAFE and GHG standards are to reduce fuel consumption and GHG 

emissions from the on-road light-duty vehicle fleet, but in addition to these intended effects, the 

agencies also consider the potential of the standards to affect vehicle safety.553 As a safety 

agency, NHTSA has long considered the potential for adverse safety consequences when 

establishing CAFE standards, and under the CAA, EPA considers factors related to public health 

and human welfare, including safety, in regulating emissions of air pollutants from mobile 

sources. Safety trade-offs associated with fuel economy increases have occurred in the past, 

particularly before NHTSA CAFE standards were attribute- based, and the agencies must be 

mindful of the possibility of future ones. These past safety trade-offs may have occurred because 

manufacturers chose at the time, partly in response to CAFE standards, to build smaller and 

lighter vehicles, rather than adding more expensive fuel-saving technologies while maintaining 

vehicle size and safety, and the smaller and lighter vehicles did not fare as well in crashes as 

larger and heavier vehicles. Historically, as shown in FARS data analyzed by NHTSA, the safest 

cars generally have been heavy and large, while the cars with the highest fatal-crash rates have 

been light and small. The question, then, is whether past is necessarily prologue when it comes to 

potential changes in vehicle size (both footprint and “overhang”) and mass in response to the 

more stringent future CAFE and GHG standards. Manufacturers have stated that they will 

reduce vehicle mass as one of the cost-effective means of increasing fuel economy and reducing 

CO2 emissions in order to meet the standards, and the agencies have incorporated this 

expectation into our modeling analysis supporting the standards. Because the agencies discern a 

historical relationship between vehicle mass, size, and safety, it is reasonable to assume that 

these relationships will continue in the future. The agencies are encouraged by comments to the 

NPRM from the Alliance of Automotive Manufacturers reflecting a commitment to safety stating 

that, while improving the fuel efficiency of the vehicles, the vehicle manufacturers are “mindful 

that such improvements must be implemented in a manner that does not compromise the rate of 

safety improvement that has been achieved to date.” The question of whether vehicle design can 

mitigate the adverse effects of mass reduction is discussed below. 

On May 7, 2010, the National Highway Traffic Safety Administration (NHTSA) and the 

Environmental Protection Agency (EPA) published a joint final rule to establish Corporate 

Average Fuel Economy (CAFE) standards and greenhouse-gas (GHG) emission standards for 

passenger cars and light trucks manufactured in model years (MY) 2012-2016. The standards 

for MY 2012-2016 are “footprint-based,” with footprint being defined as a measure of a 

vehicle’s size, roughly equal to the wheelbase times the average of the front and rear track 

553 In this rulemaking document, “vehicle safety” is defined as societal fatality rates per vehicle miles traveled
 

(VMT), which include fatalities to occupants of all the vehicles involved in the collisions, plus any pedestrians. 
 

                                                      

1014 

widths. Manufacturers are less likely than they were in the past to reduce vehicle footprint in 

order to reduce mass for increased fuel economy. The primary mechanism in this rulemaking for 

mitigating the potential negative effects on safety is the application of footprint-based standards, 

which create a disincentive for manufacturers to produce smaller-footprint vehicles. This is 

because, as footprint decreases, the corresponding fuel economy/GHG emission target becomes 

more stringent. We also believe that the shape of the footprint curves themselves is 

approximately “footprint-neutral,” that is, that it should neither encourage manufacturers to 

increase the footprint of their fleets, nor to decrease it. Several technologies, such as substitution 

of light, high-strength materials for conventional materials during vehicle redesigns, have the 

potential to reduce weight and conserve fuel while maintaining a vehicle’s footprint and 

maintaining or possibly improving the vehicle’s structural strength and handling. 

On November 16, 2011, NHTSA and EPA published a joint Notice of Proposed Rulemaking 

(NPRM) to establish CAFE and GHG standards for passenger cars and light trucks manufactured 

in model years (MY) 2017-2025.554 The proposed standards for MY 2017-2025 are again 

footprint-based. 

In considering what technologies are available for improving fuel economy, including mass 

reduction, an important corollary issue for NHTSA to consider is the potential effect that those 

technologies may have on safety. NHTSA has thus far specifically considered the likely effect 

of mass reduction that maintains footprint on fatal crashes. The relationship between a vehicle’s 

mass, size, and fatality risk is complex, and it varies in different types of crashes. NHTSA, along 

with others, has been examining this relationship for over a decade. The safety chapter of 

NHTSA’s April 2010 final regulatory impact analysis (FRIA) of CAFE standards for MY 2012­

2016 passenger cars and light trucks included a statistical analysis of relationships between 

fatality risk, mass, and footprint in MY 1991-1999 passenger cars and LTVs (light trucks and 

vans), based on calendar year (CY) 1995-2000 crash and vehicle-registration data.555 

The principal findings of NHTSA’s 2010 analysis were that mass reduction in lighter cars, even 

while holding footprint constant, would significantly increase societal fatality risk, whereas mass 

reduction in the heavier LTVs would significantly reduce net societal fatality risk, because it 

would reduce the fatality risk of occupants in lighter vehicles which collide with the heavier 

LTVs. NHTSA concluded that, as a result, any reasonable combination of mass reductions while 

holding footprint constant in MYs 2012-2016 vehicles – concentrated, at least to some extent, in 

554 76 Fed. Reg. 74854 (December 1, 2011). 555 Kahane, C. J. (2010). “Relationships Between Fatality Risk, Mass, and Footprint in Model Year 1991-1999 and 

Other Passenger Cars and LTVs,” Final Regulatory Impact Analysis: Corporate Average Fuel Economy for MY 

2012-MY 2016 Passenger Cars and Light Trucks. Washington, DC: National Highway Traffic Safety 

Administration, pp. 464-542, available at http://www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/CAFE_2012­

2016_FRIA_04012010.pdf (last accessed August 1, 2012) 
 

 

                                                      

 

 

 

 

1015 

the heavier LTVs and limited in the lighter cars – would likely be approximately safety-neutral; 

it would not significantly increase fatalities and might well decrease them. 

NHTSA’s 2010 report partially agreed and partially disagreed with analyses published during 

2003-2005 by Dynamic Research, Inc. (DRI). NHTSA and DRI both found a significant 

protective effect for footprint, and that reducing mass and footprint together (downsizing) on 

smaller vehicles was harmful. DRI’s analyses estimated a significant overall reduction in 

fatalities from mass reduction in all light-duty vehicles if wheelbase and track width were 

maintained, whereas NHTSA’s report showed overall fatality reductions only in the heavier 

LTVs, and benefits only in some types of crashes for other vehicle types. Much of NHTSA’s 

2010 report, as well as recent work by DRI, involved sensitivity tests on the databases and 

models, which generated a range of estimates somewhere between the initial DRI and NHTSA 

results.556 

In April 2010, NHTSA, working closely with EPA and the Department of Energy (DOE), 

commenced a new statistical analysis of the relationships between fatality rates, mass and 

footprint, updating the crash and exposure databases to the latest available model years, refining 

the methodology in response to peer reviews of the 2010 report and taking into account changes 

in vehicle technologies. The previous databases of MYs 1991-1999 vehicles in CYs 1995-2000 

crashes had become outdated as new safety technologies, vehicle designs and materials were 

introduced. The new databases are comprised of MYs 2000-2007 vehicles in CY 2002-2008 

crashes with the most up-to-date possible data, given the processing lead time for crash data and 

the need for enough crash cases to permit statistically meaningful analyses. NHTSA made the 

first version of the new databases available to the public in May 2011 and an updated version in 

April 2012,557 enabling other researchers to analyze the same data and hopefully minimizing 

discrepancies in the results due to inconsistencies across the data used.558 

556 Van Auken, R. M., and Zellner, J. W. (2003). A Further Assessment of the Effects of Vehicle Weight and Size 

Parameters on Fatality Risk in Model Year 1985-98 Passenger Cars and 1986-97 Light Trucks. Report No. DRITR-03-01. Torrance, CA: Dynamic Research, Inc.; Van Auken, R. M., and Zellner, J. W. (2005a). An Assessment of 

the Effects of Vehicle Weight and Size on Fatality Risk in 1985 to 1998 Model Year Passenger Cars and 1985 to 

1997 Model Year Light Trucks and Vans. Paper No. 2005-01-1354. Warrendale, PA: Society of Automotive 

Engineers; Van Auken, R. M., and Zellner, J. W. (2005b). Supplemental Results on the Independent Effects of Curb 

Weight, Wheelbase, and Track on Fatality Risk in 1985-1998 Model Year Passenger Cars and 1986-97 Model Year 

LTVs. Report No. DRI-TR-05-01. Torrance, CA: Dynamic Research, Inc.; Van Auken, R.M., and Zellner, J. W. 

(2011).2012a). Updated Analysis of the Effects of Passenger Vehicle Size and Weight on Safety, Phase I. Report 

No. DRI-TR-11-01. (Docket No. NHTSA-2010-0152-0030). Torrance, CA: Dynamic Research, Inc. 

557 http://www.nhtsa.gov/fuel-economy 558 75 Fed. Reg. 25324 (May 7, 2010); the discussion of planned statistical analyses is on pp. 25395-25396. 
                                                      

 

 

1016 

One way to estimate these effects is via statistical analyses of societal fatality rates per vehicle 

miles traveled (VMT), by vehicles’ mass and footprint, for the current on-road vehicle fleet. The 

basic analytical method used for the 2011-2012 NHTSA reports is the same as in NHTSA’s 2010 

report: cross-sectional analyses of the effect of mass and footprint reductions on the societal 

fatality rate per billion vehicle miles of travel (VMT), while controlling for driver age and 

gender, vehicle type, vehicle safety features, crash times and locations, and other factors. 

Separate logistic regression models are run for three types of vehicles and nine types of crashes. 

Societal fatality rates include occupants of all vehicles in the crash, as well as non-occupants, 

such as pedestrians and cyclists. NHTSA’s 2011-2012 reports559 analyze MYs 2000-2007 cars 

and LTVs in CYs 2002-2008 crashes. Fatality rates were derived from FARS data, 13 State 

crash files, and registration and mileage data from R.L. Polk. 

The most noticeable change in MYs 2000-2007 vehicles from MYs 1991-1999 has been the 

increase in crossover utility vehicles (CUV), which are SUVs of unibody construction, 

sometimes built upon a platform shared with passenger cars. CUVs have blurred the distinction 

between cars and trucks. The new analysis treats CUVs and minivans as a separate vehicle class, 

because they differ in some respects from pickup-truck-based LTVs and in other respects from 

passenger cars. In the 2010 report, the many different types of LTVs were combined into a 

single analysis, and NHTSA believes that this may have made the analyses too complex and 

might have contributed to some of the uncertainty in the results. 

The new database has more accurate VMT estimates than NHTSA’s earlier databases, derived 

from a file of odometer readings by make, model, and model year recently developed by R.L. 

Polk and purchased by NHTSA.560 For the 2011-2012 reports, the relative distribution of crash 

types has been changed to reflect the projected distribution of crashes during the period from 

2017 to 2025, based on the estimated effectiveness of electronic stability control (ESC) in 

reducing the number of fatalities in rollover crashes and crashes with a stationary object. The 

annual target population of fatalities or the annual fatality distribution baseline561 was not 

decreased in the period between 2017 and 2025 for the safety statistics analysis, but is taken into 

559 Kahane, C. J. (2011). “Relationships Between Fatality Risk, Mass, and Footprint in Model Year 2000-2007 

Passenger Cars and LTVs – Preliminary Report,” is available in the NHTSA docket, NHTSA-2010-0152 as item no. 

0023. Kahane, C. J. (2012). “Relationships Between Fatality Risk, Mass, and Footprint in Model Year 2000-2007 

Passenger Cars and LTVs – Final Report,” DOT HS 811-665 is in NHTSA-2010-0131-0336 and will also be in 

docket NHTSA-2010-0152. You can access the docket at http://www.regulations.gov/ by typing ‘NHTSA-2010­

0152’ where it says “enter keyword or ID” and then clicking on “search.” 

560 In the 1991-1999 data base, VMT was estimated only by vehicle class, based on NASS CDS data. 561 MY 2004 -2007 vehicles with fatal crashes occurred in CY 2004-2008 are selected as the annual fatality 

distribution baseline in the Kahane analysis. 
 

                                                      

 

 

 

 

1017 

account later in the Volpe model analysis, since all vehicles in the future will be equipped with 

ESC.562 

For the 2011-2012 reports, vehicles are now grouped into five classes rather than four: 

passenger cars (including both 2-door and 4-door cars) are split in half by median weight; CUVs 

and minivans; and truck-based LTVs, which are also split in half by median weight of the model 

year 2000-2007 vehicles. 

Table IX‐153 presents the 2011 preliminary report’s estimated percent increase in U.S. societal 

fatality risk per ten billion VMT for each 100-pound reduction in vehicle mass, while holding 

footprint constant, for each of the five classes of vehicles. 

Table IX-153
 

Results of 2011 NHTSA Preliminary Report: Fatality Increase (%) per 100-Pound Mass 

Reduction While Holding Footprint Constant 

MY 2000-2007 

CY 2002-2008 

Fatality Increase (%) Per 100-Pound Mass Reduction 

While Holding Footprint Constant 

Point Estimate 95% Confidence Bounds 

Cars < 3,106 pounds 1.44 + .29 to +2.59 

Cars > 3,106 pounds .47 - .58 to +1.52 

CUVs and minivans - .46 -1.75 to + .83 

Truck-based LTVs < 4,594 pounds .52 - .43 to +1.46 

Truck-based LTVs > 4,594 pounds - .39 -1.06 to + .27 

Charles Farmer, Paul E. Green, and Anders Lie, who reviewed NHTSA’s 2010 report, again 

peer-reviewed the 2011 preliminary report.563 In preparing its 2012 final report, NHTSA also 

took into account Wenzel’s564 assessment of the preliminary report and its peer reviews, DRI’s 

562 In the Volpe model, NHTSA assumed that the safety trend would result in 12.6 percent reduction between 2007 

and 2020 due to the combination of ESC, new safety standard, and behavior changes anticipated. 

563 Items 0035 (Lie), 0036 (Farmer) and 0037 (Green) in Docket No. NHTSA-2010-0152. 564 For the 2012 Wenzel reports see: “U.S. DOT/DOE - Final Report - An Analysis of the Relationship between 

Casualty Risk Per Crash and Vehicle Mass and Footprint for Model Year 2000-2007 Light Duty Vehicles”, Docket 
                                                                                                                                                                              

 

 

1018 

analyses published early in 2012, and public comments such as those by ICCT.565 These 

comments prompted supplementary analyses, especially sensitivity tests, discussed below. 

However, the basic analysis of the 2012 final report is almost unchanged from the 2011 

preliminary report, differing only in the addition of some crash data that became available in the 

interim and a minor change in the formula for estimating annual VMT. Table IX-154 presents 

the 2012 final report’s estimated percent increase in U.S. societal fatality risk per ten billion 

VMT for each 100-pound reduction in vehicle mass, while holding footprint constant, for each of 

the five classes of vehicles. 

Table IX-154
 

Results of 2012 NHTSA Final Report: Fatality Increase (%) per 100-Pound Mass Reduction 

While Holding Footprint Constant 

MY 2000-2007 

CY 2002-2008 

Fatality Increase (%) Per 100-Pound Mass Reduction 

While Holding Footprint Constant 

Point Estimate 95% Confidence Bounds 

Cars < 3,106 pounds 1.56 + .39 to +2.73 

Cars > 3,106 pounds .51 - .59 to +1.60 

CUVs and minivans - .37 -1.55 to + .81 

Truck-based LTVs < 4,594 pounds .52 - .45 to +1.48 

Truck-based LTVs > 4,594 pounds - .34 - .97 to + .30 

Only the 1.56 percent risk increase in the lighter cars is statistically significant. There are 

nonsignificant increases in the heavier cars and the lighter truck-based LTVs, and nonsignificant 

societal benefits for mass reduction in CUVs, minivans, and the heavier truck-based LTVs. The 

report concludes that judicious combinations of mass reductions that maintain footprint and are 

proportionately higher in the heavier vehicles are likely to be safety-neutral – i.e., they are 

unlikely to have a societal effect large enough to be detected by statistical analyses of crash data. 

The primarily non-significant results are not due to a paucity of data, but because the societal 

effect of mass reduction while maintaining footprint, if any, is small. 

NHTSA-0131-0315; “Lawrence Berkeley National Laboratory -Assessment of NHTSA Report Relationships Btw 

Fatality Risk Mass and Footprint in MY 2000-2007 PC and LTV”, Docket NHTSA-2010-0131-0315; and a peer 

review of Wenzel’s reports – “Final Report of Peer Review of LBNL Reports”, Docket NHTSA-2010-0131-0328.

565 Item 0258 in Docket No. NHTSA-2010-0131. 
 

1019 

MY 2000-2007 vehicles of all types are heavier and larger than their MY 1991-1999 

counterparts. The average mass of passenger cars increased by 5 percent from 2000 to 2007 and 

the average mass of pickup trucks increased by 19 percent. Other types of vehicles became 

heavier, on the average, by amounts within this range. There are several reasons for these 

increases: during this time, some of the lighter make-models were discontinued; many models 

were redesigned to be heavier and larger; and consumers more often selected stretched versions 

such as crew cabs in their new-vehicle purchases. 

It is interesting to compare the new results to NHTSA’s 2010 analysis of MY 1991-1999 

vehicles in CY 1995-2000, especially the new point estimate to the “actual regression result 

scenario” in the 2010 report: 

Table IX-155
 

2010 Report: MY 1991-1999, CY 1995-2000 Fatality Increase (%) per 100-Pound Mass 

Reduction While Holding Footprint Constant 

Actual Regression Result 

Scenario Upper-Estimate Scenario Lower-Estimate Scenario 

Cars < 2,950 pounds 2.21 2.21 1.02 

Cars > 2,950 pounds 0.90 0.90 0.44 

LTVs < 3,870 pounds 0.17 0.55 0.41 

LTVs > 3,870 pounds -1.90 -0.62 -0.73 

Table IX-156
 

Fatality Increase (%) per 100-Pound Mass Reduction While Holding Footprint Constant 

NHTSA (2010) NHTSA (2012) 

Lighter cars 2.21% 1.56% 

Heavier cars 0.90% 0.51% 

Lighter LTVs 0.17%* 0.52% 

Heavier LTVs -1.90%* -0.34% 

CUV/ minivan -0.37% 

*Includes CUV/minivan 

The new results are directionally similar to the 2010 results: fatality increase in the lighter cars, 

safety benefit in the heavier LTVs. But the effects may have become weaker at both ends. 

(NHTSA does not consider this conclusion to be definitive because of the relatively wide 

confidence bounds of the estimates.) The fatality increase in the lighter cars tapered off from 

2.21 percent to 1.56 percent while the societal fatality-reduction benefit of mass reduction in the 
                                                      

1020 

heaviest LTVs diminished from 1.90 percent to 0.34 percent and is no longer statistically 

significant. 

The agencies believe that the changes may be due to a combination of the characteristics of 

newer vehicles and revisions to the analysis. NHTSA believes, above all, that several light, 

small car models with poor safety performance were discontinued by 2000 or during MYs 2000­

2007. Also, the tendency of light, small vehicles to be driven in a manner that results in high 

crash rates is not as strong as it used to be.566 Both agencies believe that at the other end of the 

weight/size spectrum, blocker beams and other voluntary compatibility improvements in LTVs, 

as well as compatibility-related self-protection improvements to cars, have made the heavier 

LTVs less aggressive in collisions with lighter vehicles (although the effect of mass disparity 

remains). This report’s analysis of CUVs and minivans as a separate class of vehicles may have 

relieved some inaccuracies in the 2010 regression results for LTVs. Interestingly, the new 

actual-regression results are quite close to the previous report’s “lower-estimate scenario,” which 

was an attempt to adjust for supposed inaccuracies in some regressions and for a seemingly 

excessive trend toward higher crash rates in smaller and lighter cars. 

The principal difference between the heavier vehicles, especially truck-based LTVs, and the 

lighter vehicles, especially passenger cars, is that mass reduction has a different effect in 

collisions with another car or LTV. When two vehicles of unequal mass collide, the delta V is 

higher in the lighter vehicle, in the same proportion as the mass ratio. As a result, the fatality 

risk is also higher. Removing some mass from the heavy vehicle reduces delta V in the lighter 

vehicle, where fatality risk is higher, resulting in a large benefit, offset by a small penalty 

because delta V increases in the heavy vehicle, where fatality risk is low – adding up to a net 

societal benefit. Removing some mass from the lighter vehicle results in a large penalty offset 

by a small benefit – adding up to net harm. These considerations drive the overall result: fatality 

increase in the lighter cars, reduction in the heavier LTVs, and little effect in the intermediate 

groups. However, in some types of crashes, especially first-event rollovers and impacts with 

fixed objects, mass reduction is usually not harmful and often beneficial, because the lighter 

vehicles respond more quickly to braking and steering. Offsetting that benefit is the continuing 

historical tendency of lighter and smaller vehicles to be driven less well – although it continues 

to be unknown why that is so, and to what extent, if any, the lightness or smallness of the vehicle 

contributes to people driving it less safely. 

566 Kahane (2012), pp. 30-36. 
 

                                                      

 

1021 

The estimates in Table IX-2 of the model are formulated for each 100-pound reduction in mass; 

in other words, if risk increases by 1 percent for 100 pounds reduction in mass, it would increase 

by 2 percent for a 200-pound reduction, and 3 percent for a 300-pound reduction (more exactly, 

2.01 percent and 3.03 percent, because the effects work like compound interest). Confidence 

bounds around the point estimates will grow wider by the same proportions. 

The regression results are best suited to predict the effect of a small change in mass, leaving all 

other factors, including footprint, the same. With each additional change from the current 

environment, the model may become somewhat less accurate and it is difficult to assess the 

sensitivity to additional mass reduction greater than 100 pounds. The agencies recognize that the 

light-duty vehicle fleet in the MYs 2017-2025 timeframe will be different from the MYs 2000­

2007 fleet analyzed for this study. Nevertheless, one consideration provides some basis for 

confidence in applying the regression results to estimate the effects of mass reductions larger 

than 100 pounds or over longer time periods. This is NHTSA’s fourth evaluation of the effects 

of mass reduction and/or downsizing, comprising databases ranging from MYs 1985 to 2007. 

The results of the four studies are not identical, but they have been consistent up to a point. 

During this time period, many makes and models have increased substantially in mass, 

sometimes as much as 30-40 percent.567 If the statistical analysis has, over the past years, been 

able to accommodate mass increases of this magnitude, perhaps it will also succeed in modeling 

the effects of mass reductions on the order of 10-20 percent, if they occur in the future. 

Revisions to the 2012 analysis: The basic analysis method is unchanged from the 2011 

preliminary report and is basically the same as in NHTSA’s 2010 report: cross-sectional analyses 

of the societal fatality rate per billion vehicle miles of travel (VMT) by mass and footprint, while 

controlling for driver age, gender, and other factors, in separate logistic regressions by vehicle 

class and crash type. “Societal” fatality rates include fatalities to occupants of all the vehicles 

involved in the collisions, plus any pedestrians. The data is now MY 2000-2007 vehicles in CY 

2002-2008, updated from the previous database of MY 1991-1999 vehicles in CY 1995-2000. 

The new data has accurate VMT estimates, derived in part from a file of odometer readings by 

make, model, and model year recently developed by R.L. Polk and purchased by NHTSA.568 

The vehicles are now grouped into three classes rather than two, for the reasons discussed above: 

passenger cars (including both 2-door and 4-door cars); CUVs and minivans; and truck-based 

LTVs. 

567 For example, one of the most popular models of small 4-door sedans increased in curb weight from 1,939 pounds 

in MY 1985 to 2,766 pounds in MY 2007, a 43 percent increase. A high-sales mid-size sedan grew from 2,385 to 

3,354 pounds (41%); a best-selling pickup truck from 3,390 to 4,742 pounds (40%) in the basic model with 2-door 

cab and rear-wheel drive; and a popular minivan from 2,940 to 3,862 pounds (31%). 

568 In the 1991-1999 database, VMT was estimated only by vehicle class, based on NASS CDS data. 
                                                      

 

 

1022 

There are also nine types of crashes rather than the six in the 2010 report; specifically, “collision 

with car” and “collision with LTV” in the previous analysis have been replaced by four types of 

crashes: collision with car, CUV, or minivan < 3,082 pounds; collision with car, CUV, or 

minivan ≥ 3,082 pounds; collision with truck-based LTV < 4,150 pounds; and collision with 

truck-based LTV ≥ 4,150 pounds. Splitting the “other” vehicles into a lighter and a heavier 

group permits more accurate analyses of the mass effect in collisions of two light vehicles. 

Grouping partner-vehicle CUVs and minivans with cars rather than LTVs is more appropriate 

because their front-end profile and rigidity more closely resembles a car than a typical truckbased LTV. 

The curb weight of passenger cars is formulated, as in the 2010 report, as a two-piece linear 

variable in order to estimate one effect of mass reduction in the lighter cars and another effect in 

the heavier cars. The boundary between “lighter” and “heavier” cars is 3,106 pounds (which is 

the median mass of MY 2000-2007 cars in fatal crashes, up from 2,950 in 1991-1999). 

Likewise, for truck-based LTVs, curb weight is a two-piece linear variable with the boundary at 

4,594 pounds (again, the 2000-2007 median, much higher than the median of 3,870 in 1991­

1999). Curb weight is formulated as a simple linear variable for CUVs and minivans: because 

CUVs and minivans account for a much smaller share of new-vehicle sales, there is much less 

crash data available than for cars or truck-based LTVs. 

For a given vehicle class and weight range (if applicable), the regression coefficients for mass 

(while holding footprint constant) in the nine types of crashes are averaged, weighted by the 

number of baseline fatalities that would have occurred for the subgroup MY 2004-2007 vehicles 

in CY 2004-2008 if these vehicles had all been equipped with ESC. The adjustment for ESC, a 

new feature of the analysis, takes into account that the results will be used to analyze effects of 

mass reduction in future vehicles, which will all be ESC-equipped, as required by NHTSA’s 

regulations. A similar adjustment to the baseline fatalities probably should have been applied in 

the 2010 report, but was not. 

Techniques have been added to test significance and to estimate 95% confidence bounds 

(sampling error) for each mass effect and to estimate the combined annual effect of removing 

100 pounds of mass from every vehicle (or of removing different amounts of mass from the 

various classes of vehicles), while holding footprint constant. 

NHTSA considered the near multicollinearity of mass and footprint to be a major issue in the 

2010 report and voiced concern about inaccurately estimated regression coefficients.569 The high 

correlations between mass and footprint and variance inflation factors (VIF) have not changed 

569 Van Auken and Green also discussed the issue in their presentations at the NHTSA Workshop on Vehicle MassSize-Safety in Washington, DC on February 25, 2011, http://www.nhtsa.gov/Laws+&+Regulations/CAFE+­

+Fuel+Economy/NHTSA+Workshop+on+Vehicle+Mass-Size-Safety (last accessed August 1, 2012) 
                                                      

 

 

1023 

from MY 1991-1999 to MY 2000-2007; large vehicles continued to be, on the average, heavier 

than small vehicles to the same extent as in the previous decade.570 Nevertheless, 

multicollinearity appears to be less of a problem in the analysis this time. The “decile” analysis 

comparing fatality rates of vehicles of different mass but nearly identical footprint (modified in 

response to peer-review comments to control for factors such as driver age and gender) largely 

corroborates the main regression results. Whereas perhaps 4 of the 27 basic regressions still 

display possible symptoms of near multicollinearity, namely exceptionally strong coefficients in 

opposite directions for mass and footprint, the positive coefficient goes twice to mass, twice to 

footprint: in short, there appears to be no systematic bias. Separating the CUVs and minivans 

from the other LTVs may also have helped to stabilize the results. NHTSA has no other 

explanation of why multicollinearity became less of a problem, except this: when there are only a 

few (2-4) regressions in each report that seem to display symptoms of multicollinearity, it could 

readily happen by chance that all of them give the positive coefficient to the same variable in one 

report (curb weight in 2010) but split close to 50-50 this time. 

Another issue noted in the 2010 report was the historical trend of lighter and smaller vehicles to 

be less well driven – as evidenced, for example, in the higher odds of culpability for their drivers, 

even after controlling for the driver’s age and gender and the vehicle’s safety technologies. The 

trend contributes to the higher fatality risk of the lighter and smaller vehicles in statistical 

analyses. It is unknown if a vehicle’s lightness or smallness in any way contributes to how 

people drive it or if the trend merely reflects that better drivers, on the average, prefer larger 

vehicles. The trend is still there in the new data, but it appears to have diffused. In the earlier 

database, the trend was attributed primarily to mass, not footprint. Now it is about equally 

attributed to mass and footprint. 

In the 2010 report, largely because of those two issues – multicollinearity and the trend of 

lighter/smaller vehicles to be less well driven – NHTSA supplemented the actual regression 

results with alternative “upper-estimate” and “lower-estimate” scenarios that set aside some of 

the individual regression coefficients and replaced them with a range of estimates derived from 

other sources. Because these issues no longer seem critical, this report presents only a single set 

of estimates based on the actual regression results and it does not include such alternative 

scenarios. 

Calculation of MY 2017-2025 safety impact 

570 Greene, W. H. (1993). Econometric Analysis, Second Edition. New York: Macmillan Publishing Company, pp. 

266-268; Allison, P.D. (1999), Logistic Regression Using the SAS System. Cary, NC: SAS Institute Inc., pp. 48-51. 

VIF scores are in the 6-9 range for curb weight and footprint in NHTSA’s new database – i.e., in the somewhat 

unfavorable 2.5-10 range where near multicollinearity begins to become a concern in logistic regression analyses. 
                                                      

 

 

 

1024 

Neither the CAFE standards nor our analysis mandates mass reduction, or mandates that mass 

reduction occur in any specific manner. However, mass reduction is one of the technology 

applications available to the manufacturers and a degree of mass reduction is used by the Volpe 

model to determine the capabilities of manufacturers and to predict both cost and fuel 

consumption impacts of improved CAFE standards. 

The agency utilized the relationships between weight and safety from Kahane (2012), expressed 

as percentage increases in fatalities per 100-pound weight reduction, and examined the weight 

impacts assumed in this CAFE analysis. However, there are several identifiable safety trends 

already in place or expected to occur in the foreseeable future that are not accounted for in the 

study. For example, there are two important new safety standards that have already been issued 

and will be phasing in after MY 2008. Federal Motor Vehicle Safety Standard No. 126 (49 CFR 

§ 571.126) will require electronic stability control in all new vehicles by MY 2012, and the 

upgrade to Federal Motor Vehicle Safety Standard No. 214 (Side Impact Protection, 49 CFR § 

571.214) will likely result in all new vehicles being equipped with head-curtain air bags by MY 

2014. Additionally, we anticipate continued improvements in driver (and passenger) behavior, 

such as higher safety belt use rates. All of these will tend to reduce the absolute number of 

fatalities. The agency estimated the overall change in calculated fatalities by calendar year after 

adjusting for ESC, Side Impact Protection, and other Federal safety standards and behavioral 

changes projected through this time period. Thus, while the percentage increases in Kahane 

(2012) were applied, the reduced base has resulted in smaller absolute increases than those that 

were predicted in the 2003 report. 

The agency examined the impacts of identifiable safety trends over the lifetime of the vehicles 

produced in each model year. An estimate of these impacts was contained in a previous agency 

report.571 The impacts were estimated on a year-by-year basis, but could be examined in a 

combined fashion. The agency assumed that the safety trends will result in a reduction in the 

target population of fatalities from which the weight impacts are derived. Using this method, we 

found a 9.6 percent reduction in fatality levels between 2010 and 2020 for the combination of 

safety standards and behavioral changes anticipated (ESC, head-curtain air bags, and increase 

belt use). Since the same safety standards are taking effect in the same years, the estimates 

derived from applying Kahane’s percentages to a baseline of 2010 fatalities were thus multiplied 

571 Blincoe, L. and Shankar, U, “The Impact of Safety Standards and Behavioral Trends on Motor Vehicle Fatality 

Rates,” DOT HS 810 777, January 2007. See Table 4 comparing 2020 to 2007 (37,906/43,363 = 12.6% reduction 

(1-.126 = .874). We have updated that analysis to compare predicted 2020 fatalities to 2010 fatalities and find a 

9.6% reduction for 2020 compared to 2010. We are assuming that using the 2020 number will give us an average 

from MY 2017-2025. 
                                                      

 

 

1025 

by 0.904 to account for changes that the agency believes will take place in passenger car and 

light truck safety between the 2010 baseline on-road fleet used for this particular safety analysis 

and 2020, which we assume represents the average year between 2017 and 2025. 

In the CAFE model, a maximum amount of weight reduction was allowed for each subclass of 

vehicles to achieve a safety neutral result. No weight reduction was allowed for subcompact and 

compact passenger cars, up to 3.5% weight reduction was allowed for mid-size cars, up to 10% 

for large cars, and up to 20% for minivans, SUVs, and pickup trucks. This is one method the 

manufacturers could use to comply with the fuel economy standards and not increase societal 

fatalities. 

After applying these percentage increases to the estimated weight reductions per vehicle size by 

model year assumed in the Volpe model, Table IX-5 shows the results of NHTSA’s safety 

analysis separately for each model year572 based on the MY 2010 and MY 2008 baseline fleet. 

Presented are the undiscounted fatality impact, however, the dollar impacts are discounted by 

either the 3 percent or 7 percent discount rate. These are estimated increases or decreases in 

fatalities over the lifetime of the model year fleet. A positive number means that fatalities are 

projected to increase, a negative number ( ) means that fatalities are projected to decrease. The 

results are significantly affected by the assumptions put into the Volpe model to take more 

weight out of the heavy LTVs than out of other vehicles. Since the negative coefficients only 

appear for LTVs greater than 4,594 lbs., an improvement in safety can only occur if more weight 

is taken out of heavy light trucks than passenger cars or smaller light trucks. 

Combining passenger car and light truck estimates for the Preferred Alternative results in a 

decrease in fatalities over the cumulative lifetime of the nine model years of MY 2017-2025 of 8 

to 107 fatalities, broken up into an increase of 135 to 78 fatalities in passenger cars and a 

decrease of 143 to 185 fatalities in light trucks. The effects on fatalities range from a combined 

decrease of 300 fatalities for the 5% alternative to a combined effect of saving 58 fatalities for 

the 2% alternative. The difference in the results by alternative depends upon how much weight 

reduction is used in that alternative and the types and sizes of vehicles that the weight reduction 

applies to. 

Additionally, the societal impacts of increasing fatalities can be monetized using NHTSA’s 

estimated comprehensive cost per life of $6,348,253 in 2010 dollars. This consists of a value of 

a statistical life of $6.0 million in 2010 dollars plus external economic costs associated with 

fatalities such as medical care, insurance administration costs and legal costs and updated for 

572 NHTSA has changed the definitions of a passenger car and light truck for fuel economy purposes between the 

time of the Kahane 2003 analysis and this final rule. About 1.4 million 2 wheel drive SUVs have been redefined as 

passenger cars instead of light trucks. The Kahane 2012 analysis continues with the definitions used in the Kahane 

2003 analysis. Thus, there are different definitions between Tables IX-1, IX-2, and IX-3 (which use the old 

definitions) and Tables IX-4 and beyond (which use the new definitions). 
 

 

 

                                                      

 

 

 

1026 

inflation to 2010 dollars.573 Typically, NHTSA would also estimate the impact on injuries and 

add that to the societal costs of fatalities, but in this case NHTSA does not have a model 

estimating the impact of weight on injuries. However, based on past studies, fatalities account 

for roughly 44 percent of total comprehensive costs due to injury.574 If weight impacts non-fatal 

injuries roughly proportional to its impact on fatalities, then total costs would be roughly 2.27 

times the value of fatalities alone, or around $14.41 million per fatality. The potential societal 

costs for fatalities and injuries combined are also shown in Table IX-5 and Table IX-6, and are 

discounted by the appropriate discount rate for passenger cars separately from light trucks. We 

assume that any impact on fatalities will occur over the lifetime of the vehicle and the chance of 

it occurring in any particular year is directly related to the weighted vehicle miles traveled in that 

year. Since light trucks are driven longer and survive longer than passenger cars, they have a 

different discount rate applied to their lifetime monetized benefits to bring their monetized value 

back to a present value. The multipliers575 to bring monetized lifetime benefits back to present 

value are: 

Passenger Cars Light Trucks 

3% Discount rate 0.8024 0.7872 

7% Discount rate 0.6268 0.6083 

Decreases in societal costs over the lifetime of the nine model years are $64 to 1,203 million for 

the Preferred Alternative discounted at 3 percent and $36 to $922 million discounted at 7percent. 

The estimates by alternative range from a decrease of $3,399 million for the 5% alternative at a 3 

percent discount rate to an increase of $690 million for the 2% alternative at a 3 percent discount 

rate. 

573 Blincoe et al, The Economic Impact of Motor Vehicle Crashes 2000, May 2002. Data from this report were 

updated for inflation and combined with the current DOT guidance on value of a statistical life to estimate the 

comprehensive value of a statistical life. Available at http://www-nrd.nhtsa.dot.gov/Pubs/809446.PDF (last accessed 

August 1, 2012) or Docket No. NHTSA-2010-0131 

574 Based on data in Blincoe et al updated for inflation and reflecting the Department’s current VSL of $6.0 million 

in 2009 dollars. 

575 Thus, for example taking the undiscounted fatalities * $6,348,253 * 2.27 *0.8024 = the present discounted value 

of monetized safety impacts. If one wanted to discount the fatalities, multiply fatalities * the present discount 

multiplier. 
 

 

 

 

 

 

 

 

 

1027 

Table IX-5a

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Preferred Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

2 

7 -

5 

13 -

13 

12 -

12 

18 -

13 

19 -

10 

23 -

11 

22 -

9 

19 -

1 

135 -

78 

Light 

Trucks 

2010 

2008 

(5) ­

(5) 

(9) ­

(13) 

0 -

(17) 

(5) ­

(29) 

(18) ­

(27) 

(21) ­

(27) 

(24) ­

(27) 

(30) ­

(29) 

(31) ­

(11) 

(143) ­

(185) 

Total 

2010 

2008 

(2) ­

(3) 

(3) ­

(8) 

13 -

(3) 

7 -

(17) 

(1) ­

(14) 

(2) ­

(17) 

(2) ­

(16) 

(8) ­

(20) 

(12) ­

(10) 

(8) ­

(107) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$33 -

$26 

$79 -

$62 

$148 -

$155 

$140 -

$144 

$207 -

$149 

$222 -

$115 

$262 -

$128 

$251 -

$105 

$224 -

$14 

$1,566 

-

$899 

Light 

Trucks 

2010 

2008 

($53) ­

($58) 

($107) ­

($152) 

$3 -

($190) 

($53) ­

($330) 

($209) ­

($303) 

($236) ­

($310) 

($276) ­

($304) 

($341) ­

($332) 

($357) ­

($124) 

($1,630) 

-

($2,102) 

Total 

2010 

2008 

($20) ­

($31) 

($28) ­

($90) 

$151 -

($35) 

$87 -

($186) 

($3) ­

($154) 

($15) ­

($195) 

($14) ­

($176) 

($89) ­

($227) 

($133) ­

($109) 

($64) ­

($1,203) 
 

 

 

 

 

 

1028 

Table IX-5b

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

1% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

0 -

1 

5 -

3 

4 -

5 

4 -

4 

8 -

6 

7 -

4 

12 -

4 

11 -

4 

11 -

5 

61 -

35 

Light 

Trucks 

2010 

2008 

(3) ­

(5) 

(3) ­

(5) 

(6) ­

(7) 

(6) ­

(9) 

(4) ­

(10) 

(2) ­

(12) 

(3) ­

(12) 

(4) ­

(13) 

(5) ­

(12) 

(36) ­

(85) 

Total 

2010 

2008 

(3) ­

(3) 

2 -

(3) 

(2) ­

(2) 

(2) ­

(5) 

3 -

(4) 

4 -

(8) 

9 -

(9) 

7 -

(9) 

6 -

(7) 

25 -

(50) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$1 -

$16 

$54 -

$31 

$41 -

$61 

$50 -

$44 

$88 -

$67 

$77 -

$44 

$141 -

$45 

$129 -

$47 

$125 -

$53 

$705 -

$409 

Light 

Trucks 

2010 

2008 

($32) ­

($52) 

($33) ­

($60) 

($64) ­

($81) 

($67) ­

($103) 

($47) ­

($114) 

($27) ­

($131) 

($39) ­

($142) 

($46) ­

($153) 

($53) ­

($133) 

($409) ­

($969) 

Total 

2010 

2008 

($31) ­

($36) 

$20 -

($29) 

($22) ­

($20) 

($18) ­

($59) 

$41 -

($47) 

$50 -

($86) 

$102 -

($97) 

$83 -

($106) 

$71 -

($80) 

$297 -

($560) 
 

 

 

 

 

 

 

1029 

Table IX-5c

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

2% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

2 -

2 

5 -

3 

12 -

10 

10 -

10 

15 -

10 

16 -

10 

22 -

16 

20 -

17 

18 -

15 

119 -

94 

Light 

Trucks 

2010 

2008 

(5) ­

(6) 

(8) ­

(13) 

1 -

(20) 

(2) ­

(29) 

(4) ­

(31) 

(5) ­

(32) 

(8) ­

(34) 

(13) ­

(37) 

(16) ­

(38) 

(61) ­

(240) 

Total 

2010 

2008 

(3) ­

(3) 

(3) ­

(10) 

12 -

(10) 

9 -

(19) 

11 -

(21) 

11 -

(22) 

14 -

(18) 

7 -

(20) 

1 -

(23) 

58 -

(146) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$23 -

$25 

$63 -

$39 

$134 -

$118 

$117 -

$115 

$175 -

$120 

$182 -

$121 

$252 -

$182 

$228 -

$196 

$203 -

$178 

$1,377 

-

$1,094 

Light 

Trucks 

2010 

2008 

($52) ­

($63) 

($96) ­

($153) 

$9 -

($226) 

($18) ­

($327) 

($50) ­

($351) 

($58) ­

($369) 

($94) ­

($387) 

($146) ­

($423) 

($183) ­

($431) 

($688) ­

($2,729) 

Total 

2010 

2008 

($29) ­

($38) 

($33) ­

($114) 

$143 -

($107) 

$99 -

($212) 

$125 -

($231) 

$123 -

($249) 

$159 -

($205) 

$82 -

($227) 

$20 -

($253) 

$690 -

($1,636) 
 

 

 

 

 

 

1030 

Table IX-5d

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

3% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

8 -

6 

15 -

13 

14 -

12 

18 -

12 

19 -

10 

20 -

12 

19 -

13 

14 -

6 

130 -

87 

Light 

Trucks 

2010 

2008 

(5) ­

(5) 

(11) ­

(14) 

(15) ­

(16) 

(31) ­

(30) 

(37) ­

(30) 

(40) ­

(34) 

(43) ­

(36) 

(44) ­

(39) 

(52) ­

(45) 

(276) ­

(250) 

Total 

2010 

2008 

(2) ­

(3) 

(3) ­

(8) 

0 -

(4) 

(17) ­

(18) 

(19) ­

(18) 

(21) ­

(25) 

(23) ­

(23) 

(25) ­

(25) 

(38) ­

(39) 

(147) ­

(162) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$35 -

$31 

$91 -

$68 

$176 -

$147 

$162 -

$141 

$211 -

$144 

$216 -

$113 

$228 -

$144 

$218 -

$153 

$162 -

$71 

$1,500 

-

$1,012 

Light 

Trucks 

2010 

2008 

($53) ­

($61) 

($120) ­

($156) 

($169) ­

($186) 

($356) ­

($342) 

($418) ­

($343) 

($451) ­

($390) 

($485) ­

($407) 

($496) ­

($437) 

($589) ­

($513) 

($3,138) 

-

($2,836) 

Total 

2010 

2008 

($18) ­

($31) 

($29) ­

($88) 

$7 -

($39) 

($193) ­

($202) 

($207) ­

($198) 

($235) ­

($278) 

($257) ­

($263) 

($278) ­

($284) 

($427) ­

($441) 

($1,638) 

-

($1,824) 
 

 

 

 

 

 

1031 

Table IX-5e

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

4% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

7 -

6 

11 -

13 

7 -

11 

12 -

10 

13 -

8 

16 -

11 

15 -

4 

8 -

(2) 

93 -

64 

Light 

Trucks 

2010 

2008 

(6) ­

(2) 

(12) ­

(12) 

(15) ­

(21) 

(36) ­

(37) 

(44) ­

(31) 

(49) ­

(36) 

(43) ­

(37) 

(47) ­

(41) 

(55) ­

(50) 

(307) ­

(269) 

Total 

2010 

2008 

(3) ­

1 

(6) ­

(6) 

(4) ­

(8) 

(28) ­

(26) 

(31) ­

(21) 

(36) ­

(29) 

(26) ­

(26) 

(31) ­

(37) 

(47) ­

(52) 

(214) ­

(205) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$36 -

$37 

$75 -

$70 

$127 -

$152 

$85 -

$124 

$141 -

$120 

$146 -

$87 

$191 -

$126 

$177 -

$45 

$94 -

($23) 

$1,071 

-

$738 

Light 

Trucks 

2010 

2008 

($69) ­

($27) 

($140) ­

($139) 

($173) ­

($242) 

($406) ­

($421) 

($495) ­

($356) 

($556) ­

($411) 

($486) ­

($423) 

($529) ­

($466) 

($630) ­

($568) 

($3,483) 

-

($3,054) 

Total 

2010 

2008 

($33) ­

$9 

($64) ­

($70) 

($46) ­

($89) 

($321) ­

($297) 

($355) ­

($236) 

($410) ­

($323) 

($295) ­

($297) 

($352) ­

($421) 

($536) ­

($591) 

($2,412) 

-

($2,315) 
 

 

 

 

 

 

1032 

Table IX-5f

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

5% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

8 -

6 

15 -

9 

11 -

1 

18 -

1 

18 -

(0) 

21 -

3 

15 -

1 

9 -

1 

117 -

24 

Light 

Trucks 

2010 

2008 

(6) ­

(1) 

(14) ­

(11) 

(16) ­

(17) 

(42) ­

(43) 

(51) ­

(44) 

(53) ­

(49) 

(39) ­

(48) 

(46) ­

(54) 

(46) ­

(56) 

(312) ­

(323) 

Total 

2010 

2008 

(3) ­

2 

(6) ­

(5) 

(1) ­

(8) 

(31) ­

(42) 

(33) ­

(44) 

(34) ­

(49) 

(18) ­

(45) 

(31) ­

(54) 

(38) ­

(56) 

(195) ­

(300) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$33 -

$35 

$90 -

$66 

$174 -

$109 

$125 -

$10 

$203 -

$7 

$212 -

($0) 

$239 -

$36 

$176 -

$6 

$99 -

$6 

$1,352 

-

$274 

Light 

Trucks 

2010 

2008 

($71) ­

($7) 

($158) ­

($127) 

($182) ­

($193) 

($472) ­

($488) 

($574) ­

($504) 

($597) ­

($555) 

($438) ­

($546) 

($520) ­

($616) 

($528) ­

($638) 

($3,540) 

-

($3,673) 

Total 

2010 

2008 

($37) ­

$28 

($68) ­

($61) 

($8) ­

($84) 

($347) ­

($478) 

($371) ­

($497) 

($385) ­

($555) 

($199) ­

($510) 

($344) ­

($610) 

($429) ­

($632) 

($2,189) 

-

($3,399) 
 

 

 

 

 

 

1033 

Table IX-5g

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

6% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

4 -

3 

8 -

7 

14 -

11 

12 -

8 

18 -

9 

18 -

6 

21 -

9 

20 -

6 

11 -

6 

127 -

64 

Light 

Trucks 

2010 

2008 

(6) ­

(1) 

(14) ­

(12) 

(18) ­

(19) 

(42) ­

(45) 

(53) ­

(45) 

(56) ­

(54) 

(42) ­

(52) 

(52) ­

(57) 

(63) ­

(36) 

(347) ­

(323) 

Total 

2010 

2008 

(3) ­

2 

(5) ­

(6) 

(4) ­

(9) 

(30) ­

(37) 

(35) ­

(37) 

(37) ­

(48) 

(21) ­

(43) 

(31) ­

(52) 

(53) ­

(31) 

(220) ­

(259) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$44 -

$35 

$96 -

$77 

$158 -

$124 

$140 -

$98 

$214 -

$100 

$213 -

$69 

$246 -

$105 

$233 -

$65 

$125 -

$64 

$1,469 

-

$737 

Light 

Trucks 

2010 

2008 

($73) ­

($10) 

($155) ­

($138) 

($205) ­

($221) 

($479) ­

($511) 

($607) ­

($514) 

($633) ­

($617) 

($481) ­

($594) 

($586) ­

($651) 

($721) ­

($410) 

($3,940) 

-

($3,666) 

Total 

2010 

2008 

($29) ­

$26 

($60) ­

($61) 

($47) ­

($97) 

($339) ­

($413) 

($394) ­

($414) 

($420) ­

($548) 

($235) ­

($490) 

($353) ­

($586) 

($596) ­

($346) 

($2,471) 

-

($2,929) 
 

 

 

 

 

 

1034 

Table IX-5h

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

7% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

1 

7 -

6 

14 -

10 

13 -

9 

19 -

10 

19 -

8 

22 -

9 

18 -

8 

8 -

2 

123 -

63 

Light 

Trucks 

2010 

2008 

(9) ­

(1) 

(16) ­

(12) 

(19) ­

(19) 

(49) ­

(53) 

(64) ­

(49) 

(68) ­

(59) 

(55) ­

(48) 

(64) ­

(55) 

(70) ­

(30) 

(414) ­

(327) 

Total 

2010 

2008 

(6) ­

1 

(8) ­

(6) 

(5) ­

(9) 

(37) ­

(44) 

(45) ­

(40) 

(49) ­

(51) 

(33) ­

(39) 

(47) ­

(47) 

(62) ­

(29) 

(291) ­

(264) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$33 -

$15 

$86 -

$75 

$162 -

$118 

$146 -

$101 

$220 -

$111 

$217 -

$93 

$256 -

$105 

$205 -

$97 

$95 -

$19 

$1,420 

-

$735 

Light 

Trucks 

2010 

2008 

($98) ­

($8) 

($180) ­

($138) 

($219) ­

($221) 

($558) ­

($600) 

($729) ­

($561) 

($769) ­

($674) 

($620) ­

($546) 

($730) ­

($626) 

($796) ­

($344) 

($4,699) 

-

($3,717) 

Total 

2010 

2008 

($65) ­

$7 

($94) ­

($63) 

($56) ­

($103) 

($412) ­

($498) 

($509) ­

($450) 

($552) ­

($580) 

($364) ­

($441) 

($526) ­

($529) 

($701) ­

($325) 

($3,279) 

-

($2,983) 
 

 

 

 

 

 

1035 

Table IX-5i 

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Maximum Net Benefit Alternative
 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

5 -

1 

7 -

3 

12 -

6 

9 -

5 

16 -

6 

16 -

6 

22 -

10 

20 -

7 

19 -

7 

127 -

51 

Light 

Trucks 

2010 

2008 

(9) ­

(8) 

(15) ­

(15) 

(21) ­

(25) 

(42) ­

(44) 

(58) ­

(54) 

(62) ­

(56) 

(46) ­

(52) 

(47) ­

(53) 

(62) ­

(38) 

(363) ­

(344) 

Total 

2010 

2008 

(3) ­

(7) 

(8) ­

(12) 

(9) ­

(18) 

(33) ­

(39) 

(42) ­

(48) 

(46) ­

(50) 

(24) ­

(42) 

(27) ­

(46) 

(43) ­

(31) 

(237) ­

(294) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$61 -

$9 

$86 -

$31 

$136 -

$71 

$106 -

$55 

$184 -

$69 

$186 -

$74 

$259 -

$116 

$231 -

$84 

$219 -

$81 

$1,468 

-

$590 

Light 

Trucks 

2010 

2008 

($100) ­

($89) 

($171) ­

($173) 

($241) ­

($279) 

($481) ­

($495) 

($661) ­

($619) 

($703) ­

($641) 

($525) ­

($586) 

($538) ­

($602) 

($708) ­

($429) 

($4,129) 

-

($3,913) 

Total 

2010 

2008 

($38) ­

($79) 

($85) ­

($141) 

($105) ­

($208) 

($375) ­

($440) 

($476) ­

($550) 

($518) ­

($568) 

($266) ­

($470) 

($307) ­

($518) 

($490) ­

($348) 

($2,661) 

-

($3,323) 
 

 

 

 

 

 

1036 

Table IX-5j 

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Total Cost = Total Benefit Alternative 

Fatalities Undiscounted, Dollars Discounted at 3% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

5 -

1 

10 -

3 

15 -

10 

13 -

2 

20 -

3 

19 -

4 

22 -

7 

18 -

6 

13 -

5 

135 -

41 

Light 

Trucks 

2010 

2008 

(9) ­

(12) 

(16) ­

(19) 

(18) ­

(26) 

(46) ­

(46) 

(53) ­

(49) 

(59) ­

(50) 

(45) ­

(44) 

(48) ­

(47) 

(63) ­

(33) 

(358) ­

(325) 

Total 

2010 

2008 

(4) ­

(11) 

(6) ­

(16) 

(3) ­

(16) 

(34) ­

(44) 

(33) ­

(46) 

(40) ­

(46) 

(23) ­

(37) 

(30) ­

(42) 

(50) ­

(27) 

(223) ­

(283) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$61 -

$10 

$114 -

$37 

$175 -

$121 

$147 -

$23 

$226 -

$35 

$222 -

$43 

$254 -

$84 

$210 -

$64 

$156 -

$63 

$1,568 

-

$479 

Light 

Trucks 

2010 

2008 

($106) ­

($134) 

($177) ­

($214) 

($205) ­

($301) 

($527) ­

($518) 

($601) ­

($552) 

($670) ­

($562) 

($516) ­

($503) 

($545) ­

($535) 

($718) ­

($371) 

($4,066) 

-

($3,689) 

Total 

2010 

2008 

($44) ­

($125) 

($64) ­

($177) 

($30) ­

($180) 

($380) ­

($494) 

($375) ­

($517) 

($448) ­

($519) 

($261) ­

($418) 

($335) ­

($471) 

($562) ­

($308) 

($2,499) 

-

($3,210) 
 

 

 

 

 

 

 

 

 

1037 

Table IX-6a

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Preferred Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

2 

7 -

5 

13 -

13 

12 -

12 

18 -

13 

19 -

10 

23 -

11 

22 -

9 

19 -

1 

135 -

78 

Light 

Trucks 

2010 

2008 

(5) ­

(5) 

(9) ­

(13) 

0 -

(17) 

(5) ­

(29) 

(18) ­

(27) 

(21) ­

(27) 

(24) ­

(27) 

(30) ­

(29) 

(31) ­

(11) 

(143) ­

(185) 

Total 

2010 

2008 

(2) ­

(3) 

(3) ­

(8) 

13 -

(3) 

7 -

(17) 

(1) ­

(14) 

(2) ­

(17) 

(2) ­

(16) 

(8) ­

(20) 

(12) ­

(10) 

(8) ­

(107) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$26 -

$21 

$62 -

$49 

$116 -

$121 

$109 -

$112 

$161 -

$116 

$173 -

$90 

$205 -

$100 

$196 -

$82 

$175 -

$11 

$1,223 

-

$702 

Light 

Trucks 

2010 

2008 

($41) ­

($45) 

($83) ­

($117) 

$2 -

($147) 

($41) ­

($255) 

($162) ­

($234) 

($182) 

-

($240) 

($214) 

-

($235) 

($263) 

-

($257) 

($276) 

-

($95) 

($1,259) 

-

($1,624) 

Total 

2010 

2008 

($15) ­

($24) 

($21) ­

($69) 

$118 -

($26) 

$69 -

($142) 

($0) ­

($117) 

($9) ­

($150) 

($9) ­

($135) 

($67) ­

($175) 

($101) 

-

($84) 

($36) ­

($922) 
 

 

 

 

 

 

 

 

1038 

Table IX-6b

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

1% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

0 -

1 

5 -

3 

4 -

5 

4 -

4 

8 -

6 

7 -

4 

12 -

4 

11 -

4 

11 -

5 

61 -

35 

Light 

Trucks 

2010 

2008 

(3) ­

(5) 

(3) ­

(5) 

(6) ­

(7) 

(6) ­

(9) 

(4) ­

(10) 

(2) ­

(12) 

(3) ­

(12) 

(4) ­

(13) 

(5) ­

(12) 

(36) ­

(85) 

Total 

2010 

2008 

(3) ­

(3) 

2 -

(3) 

(2) ­

(2) 

(2) ­

(5) 

3 -

(4) 

4 -

(8) 

9 -

(9) 

7 -

(9) 

6 -

(7) 

25 -

(50) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$1 -

$12 

$42 -

$24 

$32 -

$48 

$39 -

$34 

$69 -

$52 

$60 -

$35 

$110 -

$35 

$101 -

$37 

$97 -

$42 

$551 -

$320 

Light 

Trucks 

2010 

2008 

($25) ­

($40) 

($26) ­

($46) 

($49) ­

($63) 

($52) ­

($80) 

($36) ­

($88) 

($21) ­

($101) 

($30) ­

($110) 

($36) ­

($118) 

($41) ­

($103) 

($316) 

-

($749) 

Total 

2010 

2008 

($24) ­

($28) 

$16 -

($22) 

($17) ­

($15) 

($13) ­

($45) 

$33 -

($36) 

$39 -

($66) 

$80 -

($74) 

$65 -

($81) 

$56 -

($61) 

$235 -

($429) 
 

 

 

 

 

 

 

 

1039 

Table IX-6c

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

2% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

2 -

2 

5 -

3 

12 -

10 

10 -

10 

15 -

10 

16 -

10 

22 -

16 

20 -

17 

18 -

15 

119 -

94 

Light 

Trucks 

2010 

2008 

(5) ­

(6) 

(8) ­

(13) 

1 -

(20) 

(2) ­

(29) 

(4) ­

(31) 

(5) ­

(32) 

(8) ­

(34) 

(13) ­

(37) 

(16) ­

(38) 

(61) ­

(240) 

Total 

2010 

2008 

(3) ­

(3) 

(3) ­

(10) 

12 -

(10) 

9 -

(19) 

11 -

(21) 

11 -

(22) 

14 -

(18) 

7 -

(20) 

1 -

(23) 

58 -

(146) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$18 -

$20 

$49 -

$31 

$105 -

$92 

$92 -

$90 

$137 -

$94 

$142 -

$94 

$197 -

$142 

$178 -

$153 

$159 -

$139 

$1,076 

-

$854 

Light 

Trucks 

2010 

2008 

($40) ­

($49) 

($74) ­

($118) 

$7 -

($174) 

($14) ­

($253) 

($39) ­

($271) 

($45) ­

($285) 

($72) ­

($299) 

($113) 

-

($327) 

($141) 

-

($333) 

($531) ­

($2,109) 

Total 

2010 

2008 

($22) ­

($29) 

($25) ­

($88) 

$112 -

($82) 

$78 -

($163) 

$98 -

($177) 

$97 -

($191) 

$125 -

($157) 

$65 -

($174) 

$17 -

($194) 

$544 -

($1,255) 
 

 

 

 

 

 

1040 

Table IX-6d

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

3% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

8 -

6 

15 -

13 

14 -

12 

18 -

12 

19 -

10 

20 -

12 

19 -

13 

14 -

6 

130 -

87 

Light 

Trucks 

2010 

2008 

(5) ­

(5) 

(11) ­

(14) 

(15) ­

(16) 

(31) ­

(30) 

(37) ­

(30) 

(40) ­

(34) 

(43) ­

(36) 

(44) ­

(39) 

(52) ­

(45) 

(276) ­

(250) 

Total 

2010 

2008 

(2) ­

(3) 

(3) ­

(8) 

0 -

(4) 

(17) ­

(18) 

(19) ­

(18) 

(21) ­

(25) 

(23) ­

(23) 

(25) ­

(25) 

(38) ­

(39) 

(147) ­

(162) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$28 -

$24 

$71 -

$53 

$138 -

$115 

$127 -

$110 

$165 -

$113 

$169 -

$88 

$178 -

$112 

$170 -

$120 

$126 -

$56 

$1,172 

-

$791 

Light 

Trucks 

2010 

2008 

($41) ­

($47) 

($93) ­

($121) 

($131) ­

($144) 

($275) ­

($265) 

($323) ­

($265) 

($349) ­

($302) 

($375) ­

($314) 

($383) ­

($338) 

($455) ­

($396) 

($2,425) 

-

($2,192) 

Total 

2010 

2008 

($13) ­

($23) 

($22) ­

($68) 

$7 -

($29) 

($148) ­

($155) 

($158) ­

($152) 

($180) ­

($214) 

($197) ­

($202) 

($213) ­

($218) 

($329) ­

($340) 

($1,253) 

-

($1,401) 
 

 

 

 

 

 

1041 

Table IX-6e

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

4% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

7 -

6 

11 -

13 

7 -

11 

12 -

10 

13 -

8 

16 -

11 

15 -

4 

8 -

(2) 

93 -

64 

Light 

Trucks 

2010 

2008 

(6) ­

(2) 

(12) ­

(12) 

(15) ­

(21) 

(36) ­

(37) 

(44) ­

(31) 

(49) ­

(36) 

(43) ­

(37) 

(47) ­

(41) 

(55) ­

(50) 

(307) ­

(269) 

Total 

2010 

2008 

(3) ­

1 

(6) ­

(6) 

(4) ­

(8) 

(28) ­

(26) 

(31) ­

(21) 

(36) ­

(29) 

(26) ­

(26) 

(31) ­

(37) 

(47) ­

(52) 

(214) ­

(205) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$28 -

$29 

$59 -

$54 

$99 -

$119 

$66 -

$97 

$110 -

$94 

$114 -

$68 

$149 -

$98 

$138 -

$35 

$74 -

($18) 

$837 -

$577 

Light 

Trucks 

2010 

2008 

($53) ­

($21) 

($108) ­

($108) 

($134) ­

($187) 

($313) ­

($325) 

($383) ­

($275) 

($430) ­

($317) 

($376) ­

($327) 

($409) ­

($360) 

($487) ­

($439) 

($2,691) 

-

($2,360) 

Total 

2010 

2008 

($25) ­

$8 

($49) ­

($53) 

($35) ­

($68) 

($247) ­

($228) 

($273) ­

($181) 

($315) ­

($249) 

($227) ­

($229) 

($270) ­

($325) 

($413) ­

($457) 

($1,855) 

-

($1,783) 
 

 

 

 

 

 

1042 

Table IX-6f

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

5% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

3 

8 -

6 

15 -

9 

11 -

1 

18 -

1 

18 -

(0) 

21 -

3 

15 -

1 

9 -

1 

117 -

24 

Light 

Trucks 

2010 

2008 

(6) ­

(1) 

(14) ­

(11) 

(16) ­

(17) 

(42) ­

(43) 

(51) ­

(44) 

(53) ­

(49) 

(39) ­

(48) 

(46) ­

(54) 

(46) ­

(56) 

(312) ­

(323) 

Total 

2010 

2008 

(3) ­

2 

(6) ­

(5) 

(1) ­

(8) 

(31) ­

(42) 

(33) ­

(44) 

(34) ­

(49) 

(18) ­

(45) 

(31) ­

(54) 

(38) ­

(56) 

(195) ­

(300) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$26 -

$27 

$70 -

$52 

$136 -

$85 

$98 -

$8 

$158 -

$5 

$166 -

($0) 

$187 -

$28 

$138 -

$5 

$77 -

$5 

$1,056 

-

$214 

Light 

Trucks 

2010 

2008 

($55) ­

($6) 

($122) ­

($98) 

($140) ­

($149) 

($365) ­

($377) 

($444) ­

($389) 

($462) ­

($429) 

($339) ­

($422) 

($402) ­

($476) 

($408) ­

($493) 

($2,736) 

-

($2,838) 

Total 

2010 

2008 

($28) ­

$22 

($52) ­

($47) 

($4) ­

($64) 

($267) ­

($369) 

($285) ­

($384) 

($296) ­

($429) 

($152) ­

($394) 

($264) ­

($471) 

($330) ­

($488) 

($1,680) 

-

($2,624) 
 

 

 

 

 

 

1043 

Table IX-6g

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

6% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

4 -

3 

8 -

7 

14 -

11 

12 -

8 

18 -

9 

18 -

6 

21 -

9 

20 -

6 

11 -

6 

127 -

64 

Light 

Trucks 

2010 

2008 

(6) ­

(1) 

(14) ­

(12) 

(18) ­

(19) 

(42) ­

(45) 

(53) ­

(45) 

(56) ­

(54) 

(42) ­

(52) 

(52) ­

(57) 

(63) ­

(36) 

(347) ­

(323) 

Total 

2010 

2008 

(3) ­

2 

(5) ­

(6) 

(4) ­

(9) 

(30) ­

(37) 

(35) ­

(37) 

(37) ­

(48) 

(21) ­

(43) 

(31) ­

(52) 

(53) ­

(31) 

(220) ­

(259) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$35 -

$28 

$75 -

$60 

$124 -

$97 

$109 -

$76 

$167 -

$78 

$167 -

$54 

$192 -

$82 

$182 -

$51 

$98 -

$50 

$1,148 

-

$576 

Light 

Trucks 

2010 

2008 

($56) ­

($8) 

($120) ­

($107) 

($158) ­

($171) 

($370) ­

($394) 

($469) ­

($397) 

($489) ­

($477) 

($372) ­

($459) 

($453) ­

($503) 

($557) ­

($317) 

($3,045) 

-

($2,833) 

Total 

2010 

2008 

($22) ­

$20 

($45) ­

($47) 

($35) ­

($74) 

($261) ­

($318) 

($302) ­

($319) 

($323) ­

($423) 

($179) ­

($377) 

($271) ­

($453) 

($459) ­

($267) 

($1,897) 

-

($2,257) 
 

 

 

 

 

 

1044 

Table IX-6h

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

7% Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

3 -

1 

7 -

6 

14 -

10 

13 -

9 

19 -

10 

19 -

8 

22 -

9 

18 -

8 

8 -

2 

123 -

63 

Light 

Trucks 

2010 

2008 

(9) ­

(1) 

(16) ­

(12) 

(19) ­

(19) 

(49) ­

(53) 

(64) ­

(49) 

(68) ­

(59) 

(55) ­

(48) 

(64) ­

(55) 

(70) ­

(30) 

(414) ­

(327) 

Total 

2010 

2008 

(6) ­

1 

(8) ­

(6) 

(5) ­

(9) 

(37) ­

(44) 

(45) ­

(40) 

(49) ­

(51) 

(33) ­

(39) 

(47) ­

(47) 

(62) ­

(29) 

(291) ­

(264) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$26 -

$12 

$67 -

$58 

$127 -

$92 

$114 -

$79 

$172 -

$87 

$170 -

$73 

$200 -

$82 

$160 -

$76 

$74 -

$15 

$1,109 

-

$574 

Light 

Trucks 

2010 

2008 

($76) ­

($6) 

($139) ­

($106) 

($169) ­

($171) 

($431) ­

($463) 

($563) ­

($434) 

($594) ­

($520) 

($479) ­

($422) 

($564) ­

($484) 

($615) ­

($266) 

($3,631) 

-

($2,873) 

Total 

2010 

2008 

($50) ­

$6 

($72) ­

($48) 

($42) ­

($78) 

($317) ­

($384) 

($391) ­

($347) 

($425) ­

($447) 

($279) ­

($340) 

($405) ­

($408) 

($541) ­

($251) 

($2,522) 

-

($2,299) 
 

 

 

 

 

 

1045 

Table IX-6i 

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Maximum Net Benefit Alternative
 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

4 -

1 

5 -

4 

12 -

6 

8 -

4 

14 -

5 

14 -

6 

20 -

7 

16 -

8 

14 -

9 

105 -

50 

Light 

Trucks 

2010 

2008 

(8) ­

(6) 

(14) ­

(13) 

(20) ­

(22) 

(41) ­

(41) 

(50) ­

(33) 

(51) ­

(36) 

(39) ­

(37) 

(45) ­

(39) 

(65) ­

(25) 

(333) ­

(254) 

Total 

2010 

2008 

(5) ­

(5) 

(10) ­

(9) 

(8) ­

(17) 

(33) ­

(37) 

(36) ­

(28) 

(37) ­

(31) 

(19) ­

(30) 

(29) ­

(31) 

(51) ­

(17) 

(228) ­

(204) 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$32 -

$7 

$42 -

$37 

$105 -

$51 

$74 -

$36 

$124 -

$47 

$128 -

$51 

$178 -

$64 

$143 -

$76 

$125 -

$79 

$951 -

$449 

Light 

Trucks 

2010 

2008 

($71) ­

($52) 

($126) ­

($118) 

($176) ­

($197) 

($361) ­

($363) 

($440) ­

($291) 

($450) ­

($318) 

($342) ­

($325) 

($391) ­

($342) 

($570) ­

($222) 

($2,926) 

-

($2,227) 

Total 

2010 

2008 

($39) ­

($45) 

($83) ­

($81) 

($71) ­

($146) 

($288) ­

($327) 

($316) ­

($243) 

($322) ­

($267) 

($163) ­

($260) 

($248) ­

($266) 

($445) ­

($143) 

($1,975) 

-

($1,778) 
 

 

 

 

 

 

1046 

Table IX-6j 

 Comparison of the Calculated Weight Safety-Related Fatality Impacts 

 over the Lifetime of the Vehicles Produced in each Model Year 

Total Cost = Total Benefit Alternative 

Fatalities Undiscounted, Dollars Discounted at 7% 

Fatalities 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

2024 

MY 

2025 Total 

Passenger 

Cars 

2010 

2008 

5 -

1 

10 -

3 

15 -

10 

13 -

2 

20 -

3 

19 -

4 

22 -

7 

18 -

6 

13 -

5 

0 -

0 

Light 

Trucks 

2010 

2008 

(9) ­

(12) 

(16) ­

(19) 

(18) ­

(26) 

(46) ­

(46) 

(53) ­

(49) 

(59) ­

(50) 

(45) ­

(44) 

(48) ­

(47) 

(63) ­

(33) 

0 -

0 

Total 

2010 

2008 

(4) ­

(11) 

(6) ­

(16) 

(3) ­

(16) 

(34) ­

(44) 

(33) ­

(46) 

(40) ­

(46) 

(23) ­

(37) 

(30) ­

(42) 

(50) ­

(27) 

0 -

0 

Millions 

of 

Dollars 

Passenger 

Cars 

2010 

2008 

$48 -

$8 

$89 -

$29 

$137 -

$94 

$115 -

$18 

$177 -

$27 

$174 -

$34 

$199 -

$66 

$164 -

$50 

$122 -

$49 

$1,225 

-

$375 

Light 

Trucks 

2010 

2008 

($82) ­

($104) 

($137) ­

($165) 

($159) ­

($232) 

($407) ­

($400) 

($465) ­

($427) 

($518) ­

($435) 

($399) ­

($388) 

($421) ­

($414) 

($555) ­

($286) 

($3,142) 

-

($2,851) 

Total 

2010 

2008 

($34) ­

($96) 

($48) ­

($137) 

($22) ­

($138) 

($292) ­

($382) 

($288) ­

($399) 

($344) ­

($401) 

($200) ­

($322) 

($257) ­

($364) 

($433) ­

($238) 

($1,918) 

-

($2,476) 
                                                      

1047 

Sensitivity tests 

Table IX-2, the table of principal findings, includes sampling-error confidence bounds for the 

five parameters used in the Volpe model: the statistical uncertainty that is a consequence of 

having less than a census of data. NHTSA’s 2011 preliminary report acknowledged another 

source of uncertainty, namely that the baseline statistical model can be varied by choosing 

different control variables or redefining the vehicle classes or crash types, for example. 

Alternative models produce different point estimates. NHTSA believed it was premature to 

address that in the preliminary report. “The potential for variation will perhaps be better 

understood after the public and other agencies have had an opportunity to work with the new 

database.”576 NHTSA has now garnered 11 more or less plausible alternative techniques that 

could be construed as sensitivity tests of the baseline model, which were tested or proposed by 

Charles Farmer (IIHS) or Paul Green (UMTRI) in their peer reviews, Mike Van Auken (DRI) in 

his public comments, or Tom Wenzel in his parallel research for DOE. See Kahane 2012 for a 

further discussion of the models and the rationales behind them. The models use NHTSA’s 

databases and regression-analysis approach, but differ from the baseline model in one or more 

terms or assumptions. NHTSA applied the 11 techniques to the latest databases to generate 

alternative Volpe-model coefficients. The range of estimates produced by the sensitivity tests 

gives an idea of the uncertainty inherent in the formulation of the models, subject to the caveat 

that these 11 tests are, of course, not an exhaustive list of conceivable alternatives. Here are the 

baseline and alternative results, ordered from the lowest to the highest estimated increase in 

societal risk per 100-pound reduction for cars weighing less than 3,106 pounds: 

576 Kahane (2011), p. 81. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

 

1048 

Table IX-7
 

Fatality Increase (%) Per 100-Pound Mass Reduction While Holding Footprint* Constant 

Cars Cars CUVs & LTVs† LTVs† 

 < 3,106 ≥ 3,106 Minivans < 4,594 ≥ 4,594 

Baseline estimate 1.56 .51 - .37 .52 - .34 

95% confidence bounds Lower: .39 - .59 - 1.55 - .45 - .97 

(sampling error) Upper: 2.73 1.60 .81 1.48 .30 

11 Alternative Models 

1. Track width/wheelbase w. stopped veh data .25 - .89 - .13 - .09 - .97 

2. With stopped-vehicle State data .97 - .62 - .33 .35 - .80 

3. By track width & wheelbase .97 .24 - .24 - .07 - .58 

4. W/O CY control variables 1.53 .43 .04 1.20 .30 

5. CUVs/minivans weighted by 2010 sales 1.56 .51 .53 .52 - .35 

6. W/O non-significant control variables 1.64 .68 - .46 .35 - .54 

7. Incl. muscle/police/AWD cars/big vans 1.81 .49 - .37 .49 - .76 

8. Control for vehicle manufacturer 1.91 .75 1.64 .68 - .13 

9. Control for veh manufacturer/nameplate 2.07 1.82 1.31 .66 - .13 

10. Limited to drivers with BAC=0 2.32 1.06 - .19 .86 - .58 

11. Limited to good drivers‡ 3.00 1.62 .00 1.09 - .30 

*While holding track width and wheelbase constant in alternative model nos. 1 and 3.

†

Excluding CUVs and minivans. 

‡BAC=0, no drugs, valid license, at most 1 crash and 1 violation during the past 3 years. 

For example, in cars weighing less than 3,106 pounds, the baseline estimate associates 100­

pound mass reduction, while holding footprint constant, with a 1.56 percent increase in societal 

fatality risk. The corresponding estimates for the 11 sensitivity tests range from a 0.25 to a 3.00 

percent increase. The sensitivity tests illustrate both the fragility and the robustness of the 

baseline estimates. On the one hand, the variation among the Volpe coefficients is quite large 

relative to the baseline estimate: in the preceding example of cars < 3,106 pounds, from almost 

zero to almost double baseline. That is so because the societal effect of mass reduction is small 

and, as Wenzel has said, it “is overwhelmed by other known vehicle, driver, and crash 

factors.”577 In other words, a variation in how to model some of those other vehicle, driver, and 

crash factors – which is exactly what the sensitivity tests do – can appreciably change the 

estimate of the societal effect of mass reduction. 

On the other hand, the variations are not all that large in absolute terms. The ranges of the 

alternative estimates, at least these alternatives, are about as wide as the sampling-error 

confidence bounds for the baseline estimates. As a general rule, in the alternative models, as in 

the baseline models, mass reduction tends to be relatively more harmful in the lighter vehicles, 

more beneficial in the heavier vehicles. Thus, in all models, the point estimate of the Volpe 

coefficient is positive for cars < 3,106 pounds, and in all models except one, it is negative for 

577 Wenzel, T. (2011). Assessment of NHTSA’s Report “Relationships Between Fatality Risk, Mass, and Footprint 

in Model Year 2000-2007 Passenger Cars and LTVs.” (Docket No. NHTSA-2010-0152-0026). Berkeley, CA: 

Lawrence Berkeley National Laboratory, p. iv. 
 

1049 

LTVs ≥ 4,594 pounds. None of these models suggest mass reduction in small cars would be 

beneficial. All suggest mass reduction in heavy LTVs would be beneficial or, at worst, close to 

neutral. In general, any judicious combination of mass reductions that maintain footprint and are 

proportionately higher in the heavier vehicles is unlikely to have a societal effect large enough to 

be detected by statistical analyses of crash data. 

Table IX-8 provides the estimated fatality impacts of the alternative models as a sensitivity 

analysis. In this table we combine the total fatalities for each model year over the MY 2017-25 

model years, and show them for the MY 2010 baseline. All of the sensitivity analyses performed 

for this analysis are based on the MY 2010 baseline. There was no need to perform sensitivity 

analyses around two different baselines. 

The variations in results from the sensitivity analyses are more or less within the confidence 

bounds of the 2012 Report (as shown in Table IX-2) ranging from a decrease of 843 fatalities to 

an increase of 1,905 fatalities. All of the fatality estimates in this table are of undiscounted 

fatalities. 
 

 

1050 

Table IX-8
 

Estimated Undiscounted Fatality Increase or Decrease in ( ) 

over the Lifetime of the Combined 9 Model Years 2017-2025 

Passenger Cars and Light Trucks Combined 

Preferred Alternative
 

Model Year 2010 Baseline 

Main Analysis Results (8) 

Sensitivity 

#1 (843) 

#2 (686) 

#3 (279) 

#4 665 

#5 657 

#6 (114) 

#7 (167) 

#8 1,687 

#9 1,905 

#10 385 

#11 940 
1051 

X. NET BENEFITS AND SENSITIVITY ANALYSIS 

This chapter compares the costs of technologies needed to make improvements in fuel economy 

with the potential benefits, expressed in total costs (millions of dollars) from a societal 

perspective for each model year. The costs do not include CAFE civil penalties estimated to be 

paid by manufacturers to NHTSA, since these are transfer payments. Thus, the total costs shown 

in this section do not match the total costs shown in Chapter VII. These are incremental costs 

and benefits compared to the adjusted baseline of MY 2016. A payback period is calculated, 

from the consumer’s perspective. Finally, sensitivity analyses are also performed on some of the 

assumptions made in this analysis. 

Table X-1 provides the total incremental costs (in millions of dollars) from a societal perspective 

at a 3 percent discount rate. Table X-2 presents the same set of total incremental costs at a 7 

percent discount rate. Table X-3 provides the total benefits at a 3 percent discount rate from a 

societal perspective for all vehicles produced. Table X-4 presents total benefits at a 7 percent 

discount rate from a societal perspective for all vehicles produced. 

Table X-5 shows the total net benefits (in millions of dollars) from a societal perspective at a 3 

percent discount rate for the projected fleet of sales for MY 2017 – MY 2025. Table X-6 is 

analogous to Table X-5, with use of a 7 percent discount rate. 

Total costs follow a predictable pattern with costs rising to reflect the more expensive 

technologies that manufacturers must apply in order to achieve the CAFE levels that are required 

under the more aggressive alternatives. With a 3 percent discount rate, total compliance costs for 

the passenger car fleet under the Total Cost = Total Benefit alternative are 1.5 times greater than 

those of the Preferred Alternative. In the case a 7 percent discount rate, this ratio increases 

slightly to 1.6. For the light truck fleet, in the case of a 3 percent discount rate, total compliance 

costs are 2.5 times higher under the Total Cost = Total Benefit alternative than under the 

Preferred Alternative; in the case of a 7 percent discount rate, this ratio increases to 2.9. 

In Tables X-3 and X-4, lifetime societal benefits follow a similar predictable pattern, with higher 

benefits associated with the more expensive technologies that are enabled under the more 

aggressive alternatives. For the combined fleet, the TC=TB alternative produces gross benefits 

roughly 1.47 times those of the Preferred Alternative under a 3% discount rate and 1.45 times 

those of the Preferred Alternative under a 7% discount rate. 
1052 

Tables X-5 and X-6 present the net benefits to society produced by each alternative. Each 

alternative, including the Preferred Alternative, results in a net benefit to society. In Table X-5, 

the combined net benefit for passenger cars and light trucks under all nine model years ranges 

from $247 billion under the 2% Annual Increase alternative to $424 billion under the 7% Annual 

Increase alternative. Net benefits for the Preferred Alternative (the total under both vehicle types 

and all model years) are $344 billion at the 3% discount rate. 
1053 

Table X-1a 

Incremental Total Cost – Societal Perspective578

Passenger Cars, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $3,491 ­ $2,607 $5,168 ­ $4,683 $7,638 ­ $7,291 $9,601 ­ $10,810 $12,106 ­ $13,242 $13,430 ­ $15,277 $15,119 ­ $16,605 $18,0

$19,3

2% Annual Increase 2010 2008 $1,605 ­ $1,607 $2,803 ­ $2,859 $4,270 ­ $4,244 $5,803 ­ $6,007 $7,217 ­ $7,131 $8,036 ­ $8,071 $9,060 ­ $9,116 $10,8

$10,7

3% Annual Increase 2010 2008 $2,606 ­ $2,180 $3,894 ­ $4,167 $6,079 ­ $5,916 $7,922 ­ $8,674 $8,907 ­ $10,121 $10,167 ­ $11,685 $11,645 ­ $12,362 $14,0

$13,7

4% Annual Increase 2010 2008 $4,164 ­ $3,145 $5,761 ­ $5,595 $8,574 ­ $7,791 $11,189 ­ $11,269 $13,569 ­ $13,639 $14,852 ­ $15,612 $16,440 ­ $17,455 $18,5

$20,0

5% Annual Increase 2010 2008 $5,012 ­ $3,842 $7,065 ­ $6,644 $11,417 ­ $9,169 $14,716 ­ $14,620 $17,395 ­ $18,733 $19,669 ­ $21,332 $22,848 ­ $24,232 $26,7

$29,3

6% Annual Increase 2010 2008 $5,531 ­ $5,361 $8,018 ­ $8,602 $13,240 ­ $11,105 $16,863 ­ $16,597 $22,173 ­ $22,413 $24,372 ­ $29,313 $31,536 ­ $34,180 $42,3

$43,7

7% Annual Increase 2010 2008 $7,847 ­ $6,806 $10,987 ­ $11,131 $16,890 ­ $14,395 $19,740 ­ $20,165 $24,429 ­ $28,395 $34,527 ­ $39,071 $42,017 ­ $43,210 $50,3

$56,0

Max Net Benefits 2010 2008 $8,895 ­ $9,396 $10,319 ­ $11,118 $15,851 ­ $14,538 $17,866 ­ $17,970 $19,681 ­ $20,307 $21,194 ­ $21,259 $23,039 ­ $22,387 $26,6

$25,4

Total Cost = Total Benefit 2010 2008 $9,126 ­ $14,897 $10,572 ­ $15,664 $17,021 ­ $17,382 $19,073 ­ $20,695 $21,891 ­ $23,075 $23,719 ­ $25,237 $28,568 ­ $27,487 $32,7

$30,8

578 “Societal perspective” includes technology costs and societal costs, but does not include payment of civil penalties by manufacturers 

with the CAFE standards. 
1054 

Table X-1b 

Incremental Total Cost – Societal Perspective 

Light Trucks, 3% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $1,056 ­ $644 $1,255 ­ $1,385 $2,889 ­ $2,543 $3,977 ­ $3,608 $5,781 ­ $4,925 $6,227 ­ $5,717 $6,895 ­ $6,130 $7,64

$6,7

2% Annual Increase 2010 2008 $2,477 ­ $1,055 $2,495 ­ $1,624 $3,122 ­ $2,204 $3,430 ­ $2,992 $3,769 ­ $3,563 $4,112 ­ $4,051 $4,463 ­ $4,146 $4,90

$4,4

3% Annual Increase 2010 2008 $2,885 ­ $1,374 $2,957 ­ $2,050 $3,856 ­ $3,160 $4,975 ­ $4,432 $5,921 ­ $5,342 $6,347 ­ $5,941 $7,041 ­ $6,280 $7,46

$6,8

4% Annual Increase 2010 2008 $3,083 ­ $2,104 $3,465 ­ $3,008 $4,535 ­ $4,648 $6,070 ­ $6,273 $7,182 ­ $7,697 $7,751 ­ $8,330 $8,531 ­ $8,945 $9,45

$9,6

5% Annual Increase 2010 2008 $3,241 ­ $2,641 $3,736 ­ $3,869 $5,658 ­ $6,019 $8,474 ­ $8,965 $10,564 ­ $10,708 $11,527 ­ $12,190 $12,974 ­ $12,887 $14,6

$14,5

6% Annual Increase 2010 2008 $3,601 ­ $3,552 $4,187 ­ $4,906 $6,414 ­ $7,208 $9,364 ­ $11,731 $12,128 ­ $13,622 $13,139 ­ $15,423 $14,617 ­ $16,199 $17,5

$18,8

7% Annual Increase 2010 2008 $4,340 ­ $3,765 $5,092 ­ $5,544 $7,419 ­ $8,306 $11,036 ­ $12,508 $13,212 ­ $15,351 $14,138 ­ $17,401 $15,486 ­ $19,411 $17,9

$20,9

Max Net Benefits 2010 2008 $4,747 ­ $6,982 $5,094 ­ $7,671 $7,052 ­ $8,903 $9,232 ­ $12,788 $10,967 ­ $14,149 $11,609 ­ $14,686 $12,811 ­ $15,253 $13,6

$16,4

Total Cost = Total Benefit 2010 2008 $4,930 ­ $7,383 $5,269 ­ $7,996 $6,807 ­ $9,232 $9,707 ­ $13,367 $11,357 ­ $14,762 $11,809 ­ $15,378 $12,980 ­ $16,105 $13,8

$17,0
1055 

Table X-1c 

Incremental Total Cost – Societal Perspective 

Passenger Cars and Light Trucks Combined, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $4,547 ­ $3,251 $6,423 ­ $6,067 $10,528 ­ $9,834 $13,578 ­ $14,417 $17,887 ­ $18,167 $19,657 ­ $20,994 $22,013 ­ $22,735 $25,6

$26,1

2% Annual Increase 2010 2008 $4,082 ­ $2,662 $5,298 ­ $4,484 $7,392 ­ $6,449 $9,232 ­ $8,999 $10,987 ­ $10,694 $12,148 ­ $12,122 $13,523 ­ $13,262 $15,7

$15,1

3% Annual Increase 2010 2008 $5,490 ­ $3,554 $6,851 ­ $6,218 $9,935 ­ $9,076 $12,897 ­ $13,106 $14,828 ­ $15,463 $16,514 ­ $17,626 $18,686 ­ $18,642 $21,5

$20,5

4% Annual Increase 2010 2008 $7,247 ­ $5,249 $9,227 ­ $8,603 $13,109 ­ $12,439 $17,259 ­ $17,541 $20,751 ­ $21,336 $22,603 ­ $23,942 $24,971 ­ $26,400 $27,9

$29,7

5% Annual Increase 2010 2008 $8,253 ­ $6,483 $10,801 ­ $10,513 $17,075 ­ $15,188 $23,190 ­ $23,586 $27,959 ­ $29,440 $31,196 ­ $33,521 $35,822 ­ $37,119 $41,4

$43,9

6% Annual Increase 2010 2008 $9,132 ­ $8,913 $12,205 ­ $13,509 $19,654 ­ $18,313 $26,228 ­ $28,328 $34,301 ­ $36,035 $37,511 ­ $44,736 $46,152 ­ $50,379 $59,8

$62,5

7% Annual Increase 2010 2008 $12,187 ­ $10,571 $16,079 ­ $16,674 $24,309 ­ $22,701 $30,777 ­ $32,672 $37,641 ­ $43,746 $48,665 ­ $56,472 $57,503 ­ $62,621 $68,3

$76,9

Max Net Benefits 2010 2008 $13,641 ­ $16,379 $15,412 ­ $18,788 $22,904 ­ $23,441 $27,098 ­ $30,758 $30,647 ­ $34,455 $32,803 ­ $35,945 $35,850 ­ $37,640 $40,2

$41,8

Total Cost = Total Benefit 2010 2008 $14,056 ­ $22,281 $15,841 ­ $23,660 $23,828 ­ $26,614 $28,780 ­ $34,062 $33,248 ­ $37,837 $35,528 ­ $40,615 $41,548 ­ $43,592 $46,6

$47,8
1056 

Table X-2a 

Incremental Total Cost – Societal Perspective579

Passenger Cars, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $3,355 ­ $2,477 $4,965 ­ $4,447 $7,281 ­ $6,906 $9,168 ­ $10,289 $11,514 ­ $12,655 $12,753 ­ $14,595 $14,324 ­ $15,851 $17,1

$18,5

2% Annual Increase 2010 2008 $1,540 ­ $1,516 $2,696 ­ $2,702 $4,062 ­ $3,994 $5,502 ­ $5,682 $6,856 ­ $6,761 $7,602 ­ $7,630 $8,526 ­ $8,604 $10,1

$10,1

3% Annual Increase 2010 2008 $2,499 ­ $2,063 $3,733 ­ $3,944 $5,783 ­ $5,578 $7,514 ­ $8,222 $8,441 ­ $9,621 $9,617 ­ $11,102 $10,957 ­ $11,714 $13,2

$12,9

4% Annual Increase 2010 2008 $4,016 ­ $2,995 $5,551 ­ $5,323 $8,197 ­ $7,395 $10,686 ­ $10,734 $12,930 ­ $13,029 $14,136 ­ $14,912 $15,614 ­ $16,674 $17,5

$19,1

5% Annual Increase 2010 2008 $4,827 ­ $3,664 $6,803 ­ $6,339 $10,946 ­ $8,722 $14,099 ­ $14,004 $16,667 ­ $18,020 $18,814 ­ $20,498 $21,872 ­ $23,271 $25,6

$28,2

6% Annual Increase 2010 2008 $5,316 ­ $5,147 $7,721 ­ $8,251 $12,717 ­ $10,624 $16,184 ­ $15,934 $21,335 ­ $21,596 $23,434 ­ $28,209 $30,356 ­ $32,833 $40,7

$42,0

7% Annual Increase 2010 2008 $7,591 ­ $6,557 $10,642 ­ $10,734 $16,313 ­ $13,847 $19,019 ­ $19,415 $23,575 ­ $27,366 $33,324 ­ $37,574 $40,488 ­ $41,534 $48,4

$53,7

Max Net Benefits 2010 2008 $7,784 ­ $8,700 $9,029 ­ $9,797 $11,891 ­ $11,923 $14,665 ­ $14,443 $16,635 ­ $16,294 $17,461 ­ $17,112 $18,539 ­ $18,246 $21,3

$20,4

Total Cost = Total Benefit 2010 2008 $8,822 ­ $14,398 $10,222 ­ $15,128 $16,421 ­ $16,764 $18,352 ­ $19,928 $21,059 ­ $22,191 $22,786 ­ $24,248 $27,436 ­ $26,401 $31,3

$29,5

579 “Societal perspective” includes technology costs and societal costs, but does not include civil penalties. 
1057 

Table X-2b 

Incremental Total Cost – Societal Perspective 

Light Trucks, 7% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $1,019 ­ $612 $1,207 ­ $1,298 $2,759 ­ $2,381 $3,817 ­ $3,380 $5,534 ­ $4,640 $5,940 ­ $5,386 $6,559 ­ $5,774 $7,23

$6,3

2% Annual Increase 2010 2008 $2,394 ­ $992 $2,407 ­ $1,517 $2,990 ­ $2,055 $3,283 ­ $2,784 $3,600 ­ $3,330 $3,908 ­ $3,791 $4,218 ­ $3,878 $4,60

$4,1

3% Annual Increase 2010 2008 $2,783 ­ $1,289 $2,846 ­ $1,915 $3,687 ­ $2,957 $4,761 ­ $4,161 $5,649 ­ $5,037 $6,036 ­ $5,592 $6,665 ­ $5,906 $7,04

$6,4

4% Annual Increase 2010 2008 $2,979 ­ $1,995 $3,340 ­ $2,832 $4,343 ­ $4,389 $5,824 ­ $5,937 $6,860 ­ $7,340 $7,392 ­ $7,936 $8,118 ­ $8,510 $8,98

$9,2

5% Annual Increase 2010 2008 $3,127 ­ $2,519 $3,601 ­ $3,670 $5,437 ­ $5,720 $8,165 ­ $8,563 $10,169 ­ $10,280 $11,082 ­ $11,705 $12,447 ­ $12,370 $14,1

$14,0

6% Annual Increase 2010 2008 $3,472 ­ $3,410 $4,036 ­ $4,686 $6,183 ­ $6,899 $9,046 ­ $11,261 $11,710 ­ $13,105 $12,667 ­ $14,835 $14,069 ­ $15,587 $16,9

$18,1

7% Annual Increase 2010 2008 $4,201 ­ $3,613 $4,925 ­ $5,300 $7,165 ­ $7,973 $10,665 ­ $12,041 $12,753 ­ $14,821 $13,628 ­ $16,797 $14,898 ­ $18,758 $17,2

$20,2

Max Net Benefits 2010 2008 $4,610 ­ $6,512 $4,885 ­ $7,129 $6,688 ­ $8,250 $8,670 ­ $10,622 $10,343 ­ $11,891 $10,919 ­ $12,296 $11,989 ­ $12,433 $12,8

$13,1

Total Cost = Total Benefit 2010 2008 $4,785 ­ $7,150 $5,107 ­ $7,718 $6,570 ­ $8,884 $9,369 ­ $12,872 $10,951 ­ $14,218 $11,378 ­ $14,797 $12,481 ­ $15,499 $13,3

$16,4
1058 

Table X-2c 

Incremental Total Cost – Societal Perspective 

Combined, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $4,373 ­ $3,089 $6,172 ­ $5,745 $10,040 ­ $9,286 $12,985 ­ $13,669 $17,047 ­ $17,295 $18,693 ­ $19,981 $20,883 ­ $21,625 $24,3

$24,8

2% Annual Increase 2010 2008 $3,934 ­ $2,508 $5,103 ­ $4,219 $7,053 ­ $6,049 $8,786 ­ $8,466 $10,456 ­ $10,092 $11,510 ­ $11,420 $12,745 ­ $12,482 $14,7

$14,2

3% Annual Increase 2010 2008 $5,283 ­ $3,351 $6,578 ­ $5,859 $9,470 ­ $8,535 $12,275 ­ $12,383 $14,090 ­ $14,657 $15,653 ­ $16,694 $17,622 ­ $17,620 $20,3

$19,4

4% Annual Increase 2010 2008 $6,994 ­ $4,990 $8,891 ­ $8,155 $12,540 ­ $11,784 $16,510 ­ $16,670 $19,790 ­ $20,369 $21,528 ­ $22,847 $23,732 ­ $25,184 $26,5

$28,3

5% Annual Increase 2010 2008 $7,955 ­ $6,183 $10,403 ­ $10,009 $16,383 ­ $14,442 $22,264 ­ $22,568 $26,835 ­ $28,300 $29,896 ­ $32,203 $34,319 ­ $35,640 $39,7

$42,2

6% Annual Increase 2010 2008 $8,788 ­ $8,557 $11,757 ­ $12,937 $18,899 ­ $17,523 $25,230 ­ $27,196 $33,045 ­ $34,701 $36,101 ­ $43,044 $44,425 ­ $48,420 $57,6

$60,1

7% Annual Increase 2010 2008 $11,792 ­ $10,170 $15,567 ­ $16,034 $23,478 ­ $21,820 $29,683 ­ $31,456 $36,328 ­ $42,187 $46,952 ­ $54,371 $55,385 ­ $60,291 $65,7

$74,0

Max Net Benefits 2010 2008 $12,394 ­ $15,212 $13,914 ­ $16,926 $18,578 ­ $20,173 $23,334 ­ $25,066 $26,978 ­ $28,186 $28,379 ­ $29,408 $30,528 ­ $30,679 $34,2

$33,6

Total Cost = Total Benefit 2010 2008 $13,607 ­ $21,548 $15,329 ­ $22,847 $22,991 ­ $25,648 $27,721 ­ $32,800 $32,011 ­ $36,409 $34,163 ­ $39,045 $39,917 ­ $41,901 $44,7

$46,0
1059 

Table X-3a 

Present Value of Lifetime Societal Benefits580 by Alternative

Passenger Cars, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $12,907 - $10,806 $18,736 - $18,668 $28,873 - $27,786 $35,979 - $38,398 $44,882 - $45,214 $49,850 - $51,915 $56,963 - $56,756 $65,45

$64,3

2% Annual Increase 2010 2008 $5,837 - $6,938 $9,334 - $11,448 $14,408 - $15,901 $20,483 - $21,837 $25,159 - $25,879 $28,024 - $29,368 $32,250 - $33,833 $37,92

$39,5

3% Annual Increase 2010 2008 $9,919 - $9,455 $14,567 - $16,773 $22,637 - $23,710 $30,754 - $33,073 $35,437 - $37,947 $39,941 - $43,515 $46,372 - $47,564 $55,23

$52,1

4% Annual Increase 2010 2008 $13,906 - $13,355 $19,540 - $22,085 $29,969 - $29,907 $39,996 - $40,478 $48,846 - $47,604 $53,826 - $53,705 $60,116 - $59,242 $66,68

$67,0

5% Annual Increase 2010 2008 $17,365 - $16,047 $24,279 - $25,387 $36,863 - $34,222 $47,250 - $46,910 $55,294 - $55,843 $60,933 - $61,541 $67,990 - $67,320 $77,14

$76,6

6% Annual Increase 2010 2008 $20,141 - $19,577 $27,546 - $29,371 $41,832 - $37,952 $50,211 - $50,491 $59,960 - $59,418 $65,225 - $68,535 $73,709 - $75,196 $85,38

$85,6

7% Annual Increase 2010 2008 $24,124 - $23,157 $32,035 - $33,353 $45,415 - $42,565 $53,534 - $54,400 $61,517 - $63,139 $70,425 - $73,626 $77,671 - $79,531 $88,05

$90,3

Max Net Benefits 2010 2008 $27,812 - $28,457 $32,030 - $33,766 $44,228 - $40,246 $51,352 - $49,366 $57,354 - $56,328 $61,814 - $60,264 $67,230 - $64,227 $74,69

$71,1

Total Cost = Total Benefit 2010 2008 $28,621 - $34,195 $32,625 - $38,340 $45,037 - $43,337 $52,566 - $52,880 $58,957 - $59,629 $64,273 - $65,194 $71,657 - $70,606 $80,19

$77,8

580 These benefits are considered from a “societal perspective” because they include externalities. They are distinguished from a consu

consumers generally would not think about the value of carbon dioxide, energy security, etc. This table includes only social benefits; th

costs are included in Table X-1. 
1060 

Table X-3b 

Present Value of Lifetime Societal Benefits by Alternative

Light Trucks, 3% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $4,388 - $3,430 $5,868 - $7,976 $14,954 - $14,829 $19,870 - $21,498 $27,579 - $29,219 $30,592 - $33,374 $34,742 - $36,035 $38,69

$40,3

2% Annual Increase 2010 2008 $9,939 - $7,528 $10,723 - $10,510 $15,393 - $14,918 $17,403 - $19,141 $19,356 - $22,746 $21,270 - $25,347 $23,726 - $26,818 $26,16

$28,7

3% Annual Increase 2010 2008 $11,983 - $10,205 $13,299 - $14,101 $19,689 - $21,375 $24,595 - $27,770 $29,699 - $33,034 $32,616 - $36,078 $36,653 - $38,540 $39,09

$41,3

4% Annual Increase 2010 2008 $12,424 - $13,062 $15,080 - $18,041 $22,708 - $27,140 $28,976 - $34,540 $35,597 - $40,576 $38,631 - $43,886 $42,757 - $47,289 $46,95

$50,2

5% Annual Increase 2010 2008 $13,587 - $14,886 $16,288 - $21,130 $25,710 - $31,711 $32,799 - $41,217 $40,027 - $47,024 $43,494 - $50,923 $49,223 - $54,129 $53,76

$57,9

6% Annual Increase 2010 2008 $15,518 - $17,355 $18,317 - $23,627 $27,050 - $34,101 $34,537 - $44,752 $42,482 - $50,979 $46,264 - $55,322 $51,805 - $57,468 $57,40

$61,9

7% Annual Increase 2010 2008 $16,678 - $18,772 $19,817 - $26,200 $29,088 - $36,181 $37,251 - $45,423 $44,825 - $52,959 $48,012 - $57,010 $53,251 - $60,351 $57,78

$63,4

Max Net Benefits 2010 2008 $16,794 - $26,116 $19,135 - $29,996 $27,735 - $36,862 $34,273 - $45,119 $41,705 - $51,142 $44,660 - $53,847 $49,478 - $56,135 $52,65

$58,9

Total Cost = Total Benefit 2010 2008 $17,491 - $26,847 $19,733 - $30,611 $27,100 - $37,631 $34,841 - $45,375 $42,388 - $51,005 $44,579 - $53,652 $49,320 - $56,245 $52,98

$58,9
1061 

Table X-3c 

Present Value of Lifetime Societal Benefits by Alternative

Passenger Cars and Light Trucks Combined, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $17,295 - $14,236 $24,604 - $26,644 $43,827 - $42,615 $55,849 - $59,896 $72,461 - $74,433 $80,442 - $85,289 $91,704 - $92,791 $104,1

$104,

2% Annual Increase 2010 2008 $15,776 - $14,466 $20,057 - $21,959 $29,801 - $30,818 $37,885 - $40,978 $44,515 - $48,625 $49,295 - $54,715 $55,976 - $60,651 $64,08

$68,3

3% Annual Increase 2010 2008 $21,903 - $19,660 $27,865 - $30,874 $42,325 - $45,085 $55,349 - $60,842 $65,136 - $70,981 $72,558 - $79,593 $83,025 - $86,103 $94,32

$93,4

4% Annual Increase 2010 2008 $26,329 - $26,416 $34,620 - $40,126 $52,677 - $57,046 $68,972 - $75,018 $84,442 - $88,180 $92,457 - $97,592 $102,873 - $106,531 $113,6

$117,

5% Annual Increase 2010 2008 $30,952 - $30,933 $40,567 - $46,517 $62,573 - $65,934 $80,049 - $88,128 $95,321 - $102,867 $104,428 - $112,464 $117,213 - $121,449 $130,9

$134,

6% Annual Increase 2010 2008 $35,659 - $36,932 $45,863 - $52,998 $68,882 - $72,053 $84,748 - $95,243 $102,443 - $110,396 $111,490 - $123,857 $125,514 - $132,664 $142,7

$147,

7% Annual Increase 2010 2008 $40,802 - $41,930 $51,851 - $59,554 $74,502 - $78,747 $90,785 - $99,823 $106,342 - $116,098 $118,436 - $130,637 $130,922 - $139,882 $145,8

$153,

Max Net Benefits 2010 2008 $44,606 - $54,573 $51,165 - $63,762 $71,963 - $77,108 $85,625 - $94,485 $99,059 - $107,470 $106,475 - $114,111 $116,708 - $120,362 $127,3

$130,

Total Cost = Total Benefit 2010 2008 $46,113 - $61,043 $52,359 - $68,950 $72,137 - $80,968 $87,407 - $98,254 $101,345 - $110,633 $108,852 - $118,846 $120,977 - $126,851 $133,1

$136,
1062 

Table X-4a 

Present Value of Lifetime Societal Benefits581 by Alternative

Passenger Cars, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $10,334 - $8,655 $15,012 - $14,957 $23,133 - $22,270 $28,828 - $30,770 $35,972 - $36,237 $39,953 - $41,603 $45,658 - $45,486 $52,45

$51,5

2% Annual Increase 2010 2008 $4,677 - $5,557 $7,483 - $9,171 $11,549 - $12,740 $16,408 - $17,496 $20,157 - $20,737 $22,452 - $23,530 $25,841 - $27,112 $30,38

$31,7

3% Annual Increase 2010 2008 $7,942 - $7,573 $11,670 - $13,438 $18,135 - $19,002 $24,641 - $26,500 $28,397 - $30,408 $32,005 - $34,866 $37,166 - $38,115 $44,26

$41,7

4% Annual Increase 2010 2008 $11,136 - $10,695 $15,657 - $17,693 $24,012 - $23,968 $32,048 - $32,435 $39,147 - $38,150 $43,137 - $43,036 $48,184 - $47,472 $53,44

$53,6

5% Annual Increase 2010 2008 $13,908 - $12,850 $19,458 - $20,338 $29,536 - $27,425 $37,857 - $37,576 $44,307 - $44,735 $48,820 - $49,299 $54,476 - $53,930 $61,80

$61,3

6% Annual Increase 2010 2008 $16,132 - $15,675 $22,076 - $23,527 $33,519 - $30,413 $40,234 - $40,453 $48,036 - $47,588 $52,251 - $54,856 $59,027 - $60,173 $68,3

$68,4

7% Annual Increase 2010 2008 $19,324 - $18,543 $25,675 - $26,712 $36,384 - $34,102 $42,890 - $43,579 $49,291 - $50,549 $56,369 - $58,878 $62,145 - $63,596 $70,43

$72,1

Max Net Benefits 2010 2008 $21,104 - $22,376 $24,397 - $25,644 $33,058 - $30,088 $39,268 - $36,256 $44,064 - $41,354 $46,782 - $44,370 $50,172 - $47,796 $56,35

$52,9

Total Cost = Total Benefit 2010 2008 $22,925 - $27,356 $26,145 - $30,685 $36,061 - $34,701 $42,096 - $42,336 $47,221 - $47,746 $51,475 - $52,197 $57,373 - $56,534 $64,2

$62,3

581 These benefits are considered from a “societal perspective” because they include externalities. They are distinguished from a consu

consumers generally would not think about the value of carbon dioxide, energy security, etc. This table includes only social benefits; th

costs are included in Table X-2. 
1063 

Table X-4b 

Present Value of Lifetime Societal Benefits by Alternative

Light Trucks, 7% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $3,483 - $2,717 $4,659 - $6,323 $11,863 - $11,755 $15,773 - $17,051 $21,876 - $23,171 $24,263 - $26,462 $27,545 - $28,570 $30,67

$31,9

2% Annual Increase 2010 2008 $7,876 - $5,967 $8,501 - $8,333 $12,207 - $11,826 $13,804 - $15,180 $15,354 - $18,036 $16,871 - $20,097 $18,816 - $21,262 $20,74

$22,8

3% Annual Increase 2010 2008 $9,501 - $8,089 $10,548 - $11,181 $15,614 - $16,944 $19,514 - $22,022 $23,555 - $26,195 $25,865 - $28,604 $29,058 - $30,552 $30,98

$32,7

4% Annual Increase 2010 2008 $9,850 - $10,355 $11,957 - $14,306 $18,008 - $21,512 $22,990 - $27,389 $28,231 - $32,172 $30,635 - $34,792 $33,899 - $37,484 $37,22

$39,8

5% Annual Increase 2010 2008 $10,773 - $11,800 $12,916 - $16,752 $20,389 - $25,134 $26,022 - $32,680 $31,743 - $37,282 $34,487 - $40,369 $39,018 - $42,905 $42,6

$45,9

6% Annual Increase 2010 2008 $12,305 - $13,754 $14,527 - $18,729 $21,451 - $27,027 $27,401 - $35,466 $33,690 - $40,400 $36,683 - $43,836 $41,065 - $45,533 $45,48

$49,0

7% Annual Increase 2010 2008 $13,224 - $14,883 $15,715 - $20,771 $23,066 - $28,680 $29,545 - $36,017 $35,540 - $41,993 $38,063 - $45,194 $42,203 - $47,828 $45,78

$50,3

Max Net Benefits 2010 2008 $13,506 - $20,101 $15,190 - $23,201 $21,984 - $28,917 $27,071 - $34,022 $32,702 - $38,482 $34,834 - $40,591 $38,712 - $41,985 $41,48

$43,9

Total Cost = Total Benefit 2010 2008 $13,867 - $21,281 $15,647 - $24,269 $21,490 - $29,835 $27,642 - $35,953 $33,617 - $40,412 $35,347 - $42,504 $39,097 - $44,555 $41,99

$46,6
1064 

Table X-4c 

Present Value of Lifetime Societal Benefits by Alternative

Passenger Cars and Light Trucks Combined, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $13,817 - $11,373 $19,671 - $21,280 $34,996 - $34,025 $44,601 - $47,821 $57,847 - $59,408 $64,216 - $68,065 $73,203 - $74,056 $83,12

$83,5

2% Annual Increase 2010 2008 $12,553 - $11,524 $15,984 - $17,504 $23,755 - $24,567 $30,212 - $32,676 $35,511 - $38,773 $39,322 - $43,626 $44,657 - $48,374 $51,13

$54,5

3% Annual Increase 2010 2008 $17,443 - $15,662 $22,218 - $24,619 $33,750 - $35,946 $44,155 - $48,523 $51,951 - $56,603 $57,870 - $63,470 $66,224 - $68,667 $75,25

$74,5

4% Annual Increase 2010 2008 $20,986 - $21,050 $27,614 - $31,998 $42,020 - $45,481 $55,037 - $59,824 $67,378 - $70,322 $73,771 - $77,828 $82,083 - $84,956 $90,67

$93,5

5% Annual Increase 2010 2008 $24,681 - $24,651 $32,374 - $37,090 $49,924 - $52,559 $63,879 - $70,256 $76,051 - $82,017 $83,307 - $89,667 $93,494 - $96,836 $104,4

$107,

6% Annual Increase 2010 2008 $28,436 - $29,429 $36,602 - $42,256 $54,970 - $57,440 $67,635 - $75,919 $81,725 - $87,988 $88,934 - $98,691 $100,092 - $105,706 $113,7

$117,

7% Annual Increase 2010 2008 $32,549 - $33,426 $41,389 - $47,483 $59,450 - $62,782 $72,435 - $79,596 $84,831 - $92,542 $94,433 - $104,072 $104,348 - $111,424 $116,2

$122,

Max Net Benefits 2010 2008 $34,610 - $42,476 $39,587 - $48,846 $55,042 - $59,005 $66,339 - $70,278 $76,766 - $79,836 $81,616 - $84,960 $88,883 - $89,780 $97,83

$96,9

Total Cost = Total Benefit 2010 2008 $36,793 - $48,637 $41,792 - $54,954 $57,552 - $64,537 $69,738 - $78,290 $80,838 - $88,158 $86,822 - $94,701 $96,469 - $101,089 $106,2

$108,
1065 

Table X-5a 

Net Total Benefits582

Over the Vehicle’s Lifetime – Present Value 

Passenger Cars, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $9,416 - $8,199 $13,568 - $13,985 $21,234 - $20,495 $26,378 - $27,589 $32,776 - $31,972 $36,420 - $36,638 $41,844 - $40,151 $47,40

$44,9

2% Annual Increase 2010 2008 $4,232 - $5,331 $6,531 - $8,589 $10,138 - $11,656 $14,680 - $15,830 $17,942 - $18,749 $19,989 - $21,298 $23,190 - $24,718 $27,10

$28,8

3% Annual Increase 2010 2008 $7,314 - $7,275 $10,673 - $12,606 $16,558 - $17,794 $22,832 - $24,399 $26,530 - $27,826 $29,774 - $31,830 $34,727 - $35,202 $41,15

$38,4

4% Annual Increase 2010 2008 $9,742 - $10,209 $13,778 - $16,490 $21,395 - $22,116 $28,807 - $29,209 $35,276 - $33,965 $38,974 - $38,093 $43,676 - $41,787 $48,16

$46,9

5% Annual Increase 2010 2008 $12,354 - $12,205 $17,214 - $18,744 $25,446 - $25,053 $32,535 - $32,290 $37,898 - $37,110 $41,265 - $40,209 $45,142 - $43,088 $50,35

$47,2

6% Annual Increase 2010 2008 $14,610 - $14,216 $19,528 - $20,769 $28,592 - $26,847 $33,347 - $33,894 $37,787 - $37,005 $40,853 - $39,222 $42,173 - $41,017 $43,04

$41,8

7% Annual Increase 2010 2008 $16,277 - $16,351 $21,048 - $22,223 $28,525 - $28,170 $33,794 - $34,235 $37,088 - $34,744 $35,898 - $34,555 $35,654 - $36,321 $37,68

$34,2

Max Net Benefits 2010 2008 $18,917 - $19,061 $21,712 - $22,648 $28,376 - $25,708 $33,486 - $31,396 $37,674 - $36,022 $40,620 - $39,004 $44,191 - $41,840 $48,0

$45,7

Total Cost = Total Benefit 2010 2008 $19,495 - $19,298 $22,054 - $22,676 $28,016 - $25,954 $33,493 - $32,184 $37,066 - $36,553 $40,554 - $39,957 $43,089 - $43,119 $47,48

$47,0

582 This table is from a societal perspective, thus, civil penalties are deleted from the costs because they are a transfer payment (from m

Treasury). 
1066 

Table X-5b 

Net Total Benefits

Over the Vehicle’s Lifetime – Present Value 

Light Trucks, 3% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $3,332 - $2,786 $4,613 - $6,591 $12,064 - $12,286 $15,893 - $17,890 $21,798 - $24,294 $24,365 - $27,657 $27,847 - $29,905 $31,05

$33,5

2% Annual Increase 2010 2008 $7,462 - $6,473 $8,228 - $8,886 $12,270 - $12,713 $13,973 - $16,150 $15,587 - $19,183 $17,158 - $21,296 $19,264 - $22,671 $21,26

$24,3

3% Annual Increase 2010 2008 $9,099 - $8,830 $10,342 - $12,051 $15,833 - $18,215 $19,619 - $23,337 $23,778 - $27,692 $26,270 - $30,138 $29,612 - $32,260 $31,62

$34,4

4% Annual Increase 2010 2008 $9,340 - $10,957 $11,614 - $15,033 $18,173 - $22,492 $22,906 - $28,268 $28,415 - $32,879 $30,879 - $35,556 $34,226 - $38,344 $37,50

$40,5

5% Annual Increase 2010 2008 $10,346 - $12,245 $12,552 - $17,261 $20,052 - $25,692 $24,325 - $32,252 $29,464 - $36,316 $31,968 - $38,733 $36,249 - $41,242 $39,07

$43,3

6% Annual Increase 2010 2008 $11,917 - $13,803 $14,130 - $18,720 $20,636 - $26,893 $25,173 - $33,021 $30,354 - $37,356 $33,126 - $39,899 $37,188 - $41,269 $39,83

$43,1

7% Annual Increase 2010 2008 $12,338 - $15,007 $14,724 - $20,657 $21,669 - $27,875 $26,214 - $32,915 $31,613 - $37,608 $33,874 - $39,609 $37,765 - $40,940 $39,83

$42,5

Max Net Benefits 2010 2008 $12,048 - $19,134 $14,041 - $22,325 $20,683 - $27,959 $25,041 - $32,331 $30,738 - $36,993 $33,051 - $39,161 $36,667 - $40,882 $39,05

$42,5

Total Cost = Total Benefit 2010 2008 $12,561 - $19,464 $14,464 - $22,615 $20,294 - $28,399 $25,134 - $32,008 $31,031 - $36,242 $32,770 - $38,274 $36,340 - $40,140 $39,09

$41,8
1067 

Table X-5c 

Net Total Benefits

Over the Vehicle’s Lifetime – Present Value 

Passenger Cars and Light Trucks Combined, 3% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $12,748 - $10,986 $18,181 - $20,576 $33,299 - $32,781 $42,271 - $45,479 $54,574 - $56,266 $60,785 - $64,295 $69,691 - $70,056 $78,45

$78,5

2% Annual Increase 2010 2008 $11,693 - $11,804 $14,759 - $17,475 $22,408 - $24,370 $28,653 - $31,980 $33,528 - $37,931 $37,147 - $42,594 $42,453 - $47,389 $48,36

$53,1

3% Annual Increase 2010 2008 $16,413 - $16,106 $21,015 - $24,656 $32,391 - $36,009 $42,452 - $47,736 $50,308 - $55,519 $56,044 - $61,967 $64,339 - $67,462 $72,77

$72,9

4% Annual Increase 2010 2008 $19,082 - $21,167 $25,393 - $31,523 $39,568 - $44,607 $51,713 - $57,477 $63,691 - $66,844 $69,853 - $73,649 $77,902 - $80,131 $85,66

$87,5

5% Annual Increase 2010 2008 $22,700 - $24,450 $29,766 - $36,004 $45,498 - $50,746 $56,859 - $64,542 $67,362 - $73,426 $73,232 - $78,942 $81,391 - $84,330 $89,4

$90,6

6% Annual Increase 2010 2008 $26,527 - $28,019 $33,658 - $39,489 $49,227 - $53,740 $58,520 - $66,915 $68,141 - $74,362 $73,979 - $79,121 $79,361 - $82,285 $82,88

$84,9

7% Annual Increase 2010 2008 $28,616 - $31,358 $35,773 - $42,879 $50,194 - $56,046 $60,008 - $67,150 $68,701 - $72,352 $69,772 - $74,164 $73,418 - $77,262 $77,52

$76,8

Max Net Benefits 2010 2008 $30,965 - $38,194 $35,753 - $44,974 $49,059 - $53,667 $58,527 - $63,727 $68,412 - $73,015 $73,671 - $78,165 $80,858 - $82,722 $87,06

$88,2

Total Cost = Total Benefit 2010 2008 $32,057 - $38,762 $36,517 - $45,290 $48,309 - $54,354 $58,627 - $64,192 $68,098 - $72,796 $73,324 - $78,231 $79,429 - $83,259 $86,57

$88,8
1068 

Table X-6a 

Net Total Benefits583

Over the Vehicle’s Lifetime – Present Value 

Passenger Cars, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $6,980 - $6,178 $10,047 - $10,510 $15,852 - $15,365 $19,660 - $20,481 $24,458 - $23,581 $27,200 - $27,008 $31,335 - $29,635 $35,33

$33,0

2% Annual Increase 2010 2008 $3,137 - $4,041 $4,786 - $6,468 $7,486 - $8,746 $10,905 - $11,814 $13,301 - $13,976 $14,849 - $15,900 $17,314 - $18,507 $20,20

$21,5

3% Annual Increase 2010 2008 $5,442 - $5,511 $7,938 - $9,494 $12,353 - $13,423 $17,127 - $18,279 $19,956 - $20,787 $22,388 - $23,764 $26,209 - $26,401 $31,00

$28,8

4% Annual Increase 2010 2008 $7,120 - $7,700 $10,106 - $12,370 $15,815 - $16,573 $21,362 - $21,701 $26,217 - $25,121 $29,001 - $28,125 $32,570 - $30,798 $35,85

$34,5

5% Annual Increase 2010 2008 $9,081 - $9,186 $12,656 - $13,999 $18,589 - $18,703 $23,758 - $23,571 $27,641 - $26,715 $30,006 - $28,800 $32,603 - $30,659 $36,15

$33,1

6% Annual Increase 2010 2008 $10,816 - $10,528 $14,354 - $15,276 $20,802 - $19,789 $24,050 - $24,518 $26,700 - $25,992 $28,817 - $26,647 $28,671 - $27,340 $27,54

$26,4

7% Annual Increase 2010 2008 $11,733 - $11,986 $15,033 - $15,978 $20,071 - $20,255 $23,871 - $24,164 $25,717 - $23,182 $23,045 - $21,304 $21,657 - $22,062 $21,94

$18,3

Max Net Benefits 2010 2008 $13,320 - $13,675 $15,368 - $15,848 $21,168 - $18,165 $24,603 - $21,813 $27,428 - $25,060 $29,321 - $27,258 $31,633 - $29,550 $34,96

$32,4

Total Cost = Total Benefit 2010 2008 $14,103 - $12,958 $15,923 - $15,556 $19,641 - $17,938 $23,744 - $22,408 $26,161 - $25,555 $28,689 - $27,949 $29,937 - $30,132 $32,8

$32,7

583 This table is from a societal perspective, thus, civil penalties are deleted from the costs because they are a transfer payment (from m

Treasury). 
1069 

Table X-6b 

Net Total Benefits

Over the Vehicle’s Lifetime – Present Value 

Light Trucks, 7% Discount Rate 

(Millions of 2010 Dollars) 

Light Trucks Baseline Fleet MY 2017 MY 2018 MY 2019 MY 2020 MY 2021 MY 2022 MY 2023 MY 202

Preferred Alternative 2010 2008 $2,464 - $2,105 $3,453 - $5,025 $9,105 - $9,374 $11,956 - $13,671 $16,342 - $18,531 $18,323 - $21,076 $20,986 - $22,796 $23,43

$25,6

2% Annual Increase 2010 2008 $5,482 - $4,975 $6,095 - $6,816 $9,217 - $9,771 $10,521 - $12,396 $11,753 - $14,705 $12,963 - $16,306 $14,598 - $17,384 $16,14

$18,6

3% Annual Increase 2010 2008 $6,718 - $6,800 $7,702 - $9,267 $11,927 - $13,987 $14,753 - $17,861 $17,906 - $21,158 $19,829 - $23,011 $22,393 - $24,647 $23,93

$26,3

4% Annual Increase 2010 2008 $6,872 - $8,360 $8,617 - $11,474 $13,664 - $17,123 $17,166 - $21,453 $21,371 - $24,832 $23,243 - $26,856 $25,781 - $28,974 $28,24

$30,6

5% Annual Increase 2010 2008 $7,646 - $9,281 $9,315 - $13,083 $14,952 - $19,414 $17,857 - $24,117 $21,574 - $27,002 $23,405 - $28,664 $26,572 - $30,536 $28,50

$31,9

6% Annual Increase 2010 2008 $8,833 - $10,344 $10,490 - $14,043 $15,268 - $20,129 $18,355 - $24,205 $21,980 - $27,294 $24,016 - $29,000 $26,996 - $29,946 $28,57

$30,9

7% Annual Increase 2010 2008 $9,023 - $11,270 $10,790 - $15,471 $15,901 - $20,707 $18,880 - $23,977 $22,787 - $27,172 $24,435 - $28,397 $27,306 - $29,071 $28,52

$30,0

Max Net Benefits 2010 2008 $8,896 - $13,589 $10,305 - $16,072 $15,296 - $20,667 $18,402 - $23,400 $22,360 - $26,590 $23,916 - $28,294 $26,723 - $29,552 $28,65

$30,8

Total Cost = Total Benefit 2010 2008 $9,082 - $14,130 $10,540 - $16,551 $14,920 - $20,951 $18,273 - $23,081 $22,666 - $26,195 $23,970 - $27,707 $26,616 - $29,056 $28,66

$30,2
1070 

Table X-6c 

Net Total Benefits

Over the Vehicle’s Lifetime – Present Value 

Passenger Cars and Light Trucks Combined, 7% Discount Rate 

(Millions of 2010 Dollars) 

Passenger Cars and Light 

Trucks 

Baseline 

Fleet 

MY 

2017 

MY 

2018 

MY 

2019 

MY 

2020 

MY 

2021 

MY 

2022 

MY 

2023 

MY 

202

Preferred Alternative 2010 2008 $9,444 - $8,284 $13,500 - $15,535 $24,957 - $24,739 $31,616 - $34,152 $40,800 - $42,112 $45,523 - $48,085 $52,320 - $52,431 $58,77

$58,6

2% Annual Increase 2010 2008 $8,620 - $9,016 $10,881 - $13,285 $16,703 - $18,517 $21,426 - $24,211 $25,054 - $28,681 $27,812 - $32,206 $31,912 - $35,892 $36,34

$40,2

3% Annual Increase 2010 2008 $12,160 - $12,311 $15,640 - $18,761 $24,279 - $27,411 $31,880 - $36,140 $37,862 - $41,945 $42,217 - $46,776 $48,602 - $51,047 $54,94

$55,1

4% Annual Increase 2010 2008 $13,992 - $16,060 $18,723 - $23,844 $29,479 - $33,696 $38,528 - $43,154 $47,588 - $49,952 $52,244 - $54,981 $58,351 - $59,772 $64,09

$65,1

5% Annual Increase 2010 2008 $16,727 - $18,467 $21,971 - $27,081 $33,541 - $38,117 $41,615 - $47,688 $49,215 - $53,718 $53,411 - $57,464 $59,175 - $61,195 $64,66

$65,0

6% Annual Increase 2010 2008 $19,649 - $20,872 $24,845 - $29,319 $36,071 - $39,917 $42,405 - $48,723 $48,680 - $53,287 $52,833 - $55,647 $55,667 - $57,286 $56,12

$57,3

7% Annual Increase 2010 2008 $20,756 - $23,256 $25,823 - $31,449 $35,973 - $40,962 $42,752 - $48,141 $48,504 - $50,355 $47,480 - $49,701 $48,963 - $51,133 $50,47

$48,4

Max Net Benefits 2010 2008 $22,216 - $27,264 $25,673 - $31,920 $36,464 - $38,832 $43,005 - $45,212 $49,788 - $51,650 $53,237 - $55,552 $58,356 - $59,101 $63,6

$63,2

Total Cost = Total Benefit 2010 2008 $23,185 - $27,089 $26,463 - $32,107 $34,561 - $38,889 $42,017 - $45,489 $48,827 - $51,749 $52,659 - $55,657 $56,553 - $59,188 $61,48

$62,9
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                                      

 

1071 

Breakdown of costs and benefits for the preferred alternative 

Table X-7 provides a breakdown of the costs (parenthesized) and benefits for the preferred 

alternative using a 3 percent and 7 percent discount rate, respectively. 

Table X-7584
 

Preferred Alternative
 

Cost and Benefit Estimates 

Passenger Cars and Light Trucks Combined 

MY 2017-2025 Combined 

(Millions of 2010 Dollars) 

Societal Effect Baseline 

Fleet 

Undiscounted 

Value 

Sum of 

Present 

Discounted 

Values @ 3% 

Sum of Present 

Discounted 

Values @ 7% 

Lifetime Fuel Expenditures 

(Pretax) 

2010 

2008 

$577,260 -

$592,122 

$459,059 -

$470,819 

$358,200 -

$367,315 

Consumer Surplus from 

Additional Driving 

2010 

2008 

$53,178 -

$53,817 

$42,264 -

$42,782 

$32,988 -

$33,398 

Refueling Time Value 2010 

2008 

$17,088 -

$19,794 

$13,769 -

$15,937 

$10,869 -

$12,575 

Petroleum Market 

Externalities 

2010 

2008 

$29,626 -

$30,960 

$23,816 -

$24,888 

$18,776 -

$19,622 

Maintenance Costs 2010 

2008 

($5,204) - 

($4,938) 

($5,204) - 

($4,938) 

($3,877) - 

($3,677) 

Congestion Costs 2010 

2008 

($22,347) - 

($22,821) 

($17,964) - 

($18,346) 

($14,166) - 

($14,468) 

Accident Costs 2010 

2008 

($10,492) - 

($10,725) 

($8,425) - 

($8,612) 

($6,639) - 

($6,787) 

Noise Costs 2010 

2008 

($416) - 

($425) 

($334) - 

($341) 

($263) - 

($269) 

Value of Reduced 

Fatalities 

2010 

2008 

$52 -

$680 

$20 -

$527 

$5 -

$406 

Relative Value Loss (EVs) 2010 

2008 

($91) - 

($570) 

($91) - 

($570) 

($40) - 

($247) 

CO2 2010 

2008 

$59,625 -

$60,718 

$46,881 -

$47,745 

$46,881 -

$47,745 

584 The CAFE model estimates maintenance costs and relative value losses in discounted terms only. In the 

“undiscounted value” column of Tables X-7, the 3% discounted values for these categories are substituted. CO2 

benefits are presented in undiscounted and 3% discounted levels only, in keeping with the application of intergenerational discounting. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1072 

CO 2010 

2008 

$0 -

$0 

$0 -

$0 

$0 -

$0 

VOC 2010 

2008 

$674 -

$701 

$550 -

$571 

$440 -

$457 

NOX 2010 

2008 

$1,280 -

$1,338 

$1,072 -

$1,108 

$880 -

$900 

PM 2010 

2008 

$8,387 -

$8,434 

$6,839 -

$6,886 

$5,467 -

$5,509 

SOX 2010 

2008 

$7,070 -

$6,079 

$5,682 -

$4,878 

$4,478 -

$3,841 

Total 2010 

2008 

$715,690 -

$735,164 

$567,933 -

$583,333 

$454,001 -

$466,321 

Payback Period 

The “payback period” represents the length of time required for a vehicle buyer to recoup, 

through savings in fuel use, the higher cost of purchasing a more fuel-efficient vehicle. Thus, 

only these two factors are considered (purchase price and fuel savings). When a higher CAFE 

standard requires a manufacturer to improve the fuel economy of some of its vehicle models, the 

manufacturer’s added costs for doing so are generally reflected in higher prices for these models. 

While buyers of these models pay higher prices to purchase these vehicles, their improved fuel 

economy lowers the consumer’s costs for purchasing fuel to operate them. Over time, buyers 

may recoup the higher purchase prices they pay for these vehicles in the form of savings in 

outlays for fuel. The length of time required to repay the higher cost of buying a more fuelefficient vehicle is referred to as the buyer’s payback period. 

The length of this payback period depends on the initial increase in a vehicle’s purchase price, 

the improvement in its fuel economy, the number of miles it is driven each year, and the retail 

price of fuel. We calculated payback periods using the fuel economy improvement and average 

price increase estimated to result from the standard, the future retail gasoline prices, and 

estimates of the number of miles vehicles are driven each year as they age. These calculations 

are taken from a consumer’s perspective, not a societal perspective. Thus, only gasoline savings 

are included on the benefits side of the equation. The price of gasoline includes fuel taxes, since 

consumers generally only consider and respond to what they pay at the pump, and future savings 

are discounted to present value using a 3% discount rate or a 7% discount rate. The payback 

periods are estimated as an average for all manufacturers for the different alternatives. The 

payback periods for MY 2025 are shown in Table X-8. Discounted at 7%, the payback periods 

are slightly longer, since the benefits are discounted more. 
 

1073 

Table X-8 

Payback Period for MY 2025 Average Vehicles 

(in years) 

Alternative Discount 

Rate Baseline Passenger Cars Light Trucks Combined 

Preferred 

3% 2010 3.0 1.8 2.6 

3% 2008 3.5 1.7 2.9 

1% 

3% 2010 2.6 1.4 2.2 

3% 2008 2.2 1.0 1.8 

2% 

3% 2010 2.8 1.7 2.4 

3% 2008 2.6 1.4 2.2 

3% 

3% 2010 2.6 1.8 2.3 

3% 2008 2.8 1.6 2.4 

4% 

3% 2010 3.1 2.0 2.8 

3% 2008 3.0 2.1 2.7 

5% 

3% 2010 4.1 2.8 3.7 

3% 2008 4.4 2.7 3.8 

6% 

3% 2010 5.5 3.5 4.8 

3% 2008 5.8 3.4 4.9 

7% 

3% 2010 6.9 3.9 5.8 

3% 2008 6.5 4.2 5.7 

Max Net 

3% 2010 3.8 2.7 3.4 

3% 2008 3.8 2.8 3.5 

TC=TB 

3% 2010 4.2 2.7 3.7 

3% 2008 4.3 2.9 3.8 
 

1074 

Alternative Discount 

Rate Baseline Passenger Cars Light Trucks Combined 

Preferred 

7% 2010 3.1 1.9 2.7 

7% 2008 3.8 1.8 3.1 

1% 

7% 2010 2.8 1.4 2.3 

7% 2008 2.3 1.0 1.9 

2% 

7% 2010 2.9 1.7 2.5 

7% 2008 2.7 1.4 2.3 

3% 

7% 2010 2.7 1.9 2.4 

7% 2008 3.0 1.6 2.5 

4% 

7% 2010 3.4 2.1 2.9 

7% 2008 3.2 2.2 2.9 

5% 

7% 2010 4.6 3.0 4.0 

7% 2008 4.9 2.8 4.2 

6% 

7% 2010 6.1 3.8 5.3 

7% 2008 6.5 3.7 5.5 

7% 

7% 2010 7.4 4.2 6.3 

7% 2008 7.4 4.7 6.4 

Max Net 

7% 2010 3.6 2.8 3.3 

7% 2008 3.8 2.7 3.4 

TC=TB 

7% 2010 4.6 2.9 4.0 

7% 2008 4.7 3.1 4.1 
                                                      

 

1075 

CUMULATIVE IMPACTS 

Section 1(b) of Executive Order 13563 Improving Regulatory Planning and Review requires the 

agencies to take into account to the extent practicable "the costs of cumulative regulations." To 

adhere to this requirement, we examined the costs of all NHTSA light vehicle final rules with an 

effective date from MY 2010 or later. In addition, proposed rules which have been published in 

the Federal Register for light vehicles are also identified and preliminary cost estimates provided. 

The baseline for the fuel economy cost estimates for this final rule is the 2010 baseline. This 

analysis does not include potential rulemakings that are identified in the NHTSA priority plan585, 

since final decisions have not been made whether those programs or projects will become 

rulemakings, what alternative will be proposed and the cost estimate for the proposal. 

Costs include manufacturing cost per vehicle and fuel costs for safety standards that increase 

weight and also possible other operational costs. For fuel economy the costs are the per vehicle 

technology costs plus the costs of fines. These cost estimates are the same whether we use a 3 

percent or 7 percent discount rate to discount future benefits or costs because they occur at the 

time the vehicle is purchased and no discounting is necessary. Instead of using the estimates 

from previous fuel economy regulatory impact analyses for MY 2011 through MY 2016, the 

costs provided in this analysis are those from the current Volpe model of costs manufacturers 

would incur to achieve the MY 2016 CAFE standards. Thus, they are the most up-to-date fuel 

economy estimates for previous years. The costs are not the same as shown throughout the rest 

of the analysis, since the baseline assumes that the 2010 standards would have been extended to 

apply to MYs 2011-25 if the agency had not adopted these higher standards, whereas the rest of 

the analysis starts with the MY 2016 standards. For safety standards, the cost per affected 

vehicle includes the most likely cost, in our opinion, from of the range of costs and 

countermeasures that any vehicle might incur. The cost per average vehicle takes into account 

voluntary compliance with the rule, and does not consider those vehicles that complied with the 

rule voluntarily as needing incremental costs, and the average cost for all vehicles that need to 

meet the rule. For fuel economy, the cost is based on the agency’s most up-to-date estimates of 

the costs of technologies. All costs from previous years are adjusted to 2010 dollars using the 

implicit price deflator for gross domestic product (GDP). 

The results of this analysis show that compared to a MY 2009 baseline, standards that are 

already final rules and have been proposed (including this rule) are estimated to add costs to the 

average passenger car and light truck as shown in Table X-9. Based on the final rules and 

augural rules, the average passenger car will increase in price by $2,236 and the average light 

585 “NHTSA Vehicle Safety and Fuel Economy Rulemaking and Research Priority Plan 2011-2013”, March 2011 

http://www.nhtsa.gov/Laws+&+Regulations/Vehicles/Vehicle+Safety+Rulemaking+and+Research+Priority+Plan+2 

009-2011 (last accessed August 1, 2012) 
 

1076 

truck will increase in price by $2,186. Tables X-10, X-11, and X-12 provide a breakdown of 

those costs by model year, by vehicle type, and safety versus fuel economy rules. 

Table X-9 

Estimated Average Vehicle Increases in Consumer Cost 

For Final and Augural Rules 

For MY 2025 vehicles compared to MY 2009 vehicles 

(in 2010 Economics) 

Safety Standards Fuel Economy 

Standards Total 

Passenger Cars $351 $1,885 $2,236 

Light Trucks $283 $1,903 $2,186 
 

                                                      

 

 

 

 

 

 

 

 

1077 

Table X-10 

Costs of Passenger Car and Light Truck Safety Rulemakings 

That Take Effect in MY 2010 or Later 

 (With a GVWR of 10,000 lbs. or less, in 2010 economics) 

Final 

Effective 

Model 

Year 

Cost Per 

Affected Vehicle 

Average Cost Per 

Vehicle 

Total Industry Cost 

FMVSS No. 214; Side 

Impact Protection586

2013 $277587 $38 Passenger cars: $355M 

Light trucks: $263, 

a total of $618M 

FMVSS No. 226 

Ejection Mitigation588

2017 $54589 $31 Passenger cars: $291M 

Light trucks: $216M, 

a total of $507M 

FMVSS No. 216a Roof 

Crush Resistance, 

upgraded standard590

2015 $56 $54 Passenger cars: $192M 

Light trucks: $142M, 

a total of $334M591

FMVSS No. 202a Head 

Restraints592

2011 $7 $6 Passenger cars: $21M 

Light trucks: $16M, 

a total of $37M 

FMVSS No. 208 

Designated seating 

position 

2010 $2.21 for 

passenger cars 

and $3.41 for 

light trucks593

$0.036 for 

passenger cars and 

$0.018 for light 

trucks594

Passenger cars: $0.349M 

Light trucks: $0.124M, 

a total of $0.473M595

586 Docket No. 2007-29134-0004, 72 FR 51907. http://www.regulations.gov/#!documentDetail;D=NHTSA-2007­

29134-0004 

587 The average incremental cost per vehicle was estimated to be $33 and the cost per affected vehicle was estimated 

to be $242 in 2004 economics. When adjusted with Gross Domestic Product (GDP), it resulted in $38 and $276 for 

the average cost and the affected vehicle cost, respectively, in 2010 economics. 

588 Docket No. 2011-0004-0003, 76 FR 3212. http://www.regulations.gov/#!documentDetail;D=NHTSA-2011­

0004-0003 

589 The cost per affected vehicle was estimated to be $53 and the average incremental cost per vehicle was estimated 

to be $31 in 2009 economics. In 2010 economics, the affected vehicle and the average costs were estimated to be 

$54 and $31. 

590 Docket No. 2009-0093-0004, 74 FR 22347. http://www.regulations.gov/#!documentDetail;D=NHTSA-2009­

0093-0004 

591 With the estimated $54 average vehicle cost, the total cost would be $334M, 192M for passenger cars and $142M 

for light trucks in 2010 economics. 

592 Docket No. 2004-19807-0001, 69 FR 74848. http://www.regulations.gov/#!documentDetail;D=NHTSA-2004­

19807-0001. 593 The cost per affected vehicles was estimated to be $2 for passenger cars and $3.07 for light trucks in 2005 

economics. In 2010 economics, the costs were $2.21 and $3.41 for passenger cars and light trucks, respectively. 

594 When adjusted to the 2010 economics, it resulted in $0.036 for passenger cars and $0.018 for light trucks 
 $166601

 

                                                                                                                                                                              

 

 

 

 

 

 

1078 

FMVSS No. 126 

Electronic Stability 

Control Systems596

2011 $532 $100 for passenger 

cars and $32 for 

light trucks597

Passenger cars: $801M 

Light trucks: $292M, 

a total of $1,093M 

FMVSS No. 208 5th 

percentile female 

FMVSS 208 rule598

2013 $0 - $21.40 $0.31 for passenger 

cars and $0.32 for 

light trucks 

Passenger cars: $2.9M 

Light trucks: $2.3M, 

a total cost of $5.2M 

Proposed Estimated 

Effective 

Model 

Year 

Cost Per 

Affected Vehicle 

Average Cost Per 

Vehicle 

Total Cost 

FMVSS No. 111 Rear 

Visibility599

2015600 $121 Passenger cars: $1,150M 

Light trucks: $855M, 

a total of $2,005M 

595 The total costs were estimated to be $0.314M for passenger cars and $0.112M for light trucks in 2005 economics. 

In 2010 economics, the total costs were $0.349M for passenger cars and $0.124M for light trucks

596 Docket No. 2007-27662-2, 72 FR 17236. http://www.regulations.gov/#!documentDetail;D=NHTSA-2007­

27662-0002 

597 The average vehicle costs were estimate to be $90 for average passenger car and $29 for average light trucks in 

2005 economics. When adjusted to the 2010 economics, it resulted in $100 for passenger cars and $32 for light 

trucks. 

598 Docket No. 2005-22323-0002, 71 FR 51768. http://www.regulations.gov/#!documentDetail;D=NHTSA-2005­

22323-0002 

599 Docket No. 2010-0162-0034, 75 FR 76186. 600 Estimated effective date. 601 The rear visibility cost numbers reflect the likely final rule of 130 degree cameras mounted in the dash. The cost 

per affected vehicle would be $159 in 2007 economics. The average vehicle cost would be $116 and the 

incremental total cost would be $1,919 million in 2007 economics based on 16.6 million sales in 2007. When 

adjusted with the 2010 economics, the cost per affected vehicle was estimated to be $166 and the average cost was 

estimated to be $121. The total cost was estimated to be $2,005M in 2010 economics. 
1079 

Table X-11 

Fuel Economy Costs of Passenger Cars 

Incremental by Model Year 

(in 2010 economics) 

CAFE Effective Model 

Year 

Incremental Cost 

Per Average 

Vehicle $ 

Projected Sales 

in Analysis 

(millions of 

vehicles) 

Total Industry 

Cost 

($ millions) 

Final Rules 2010 No change $0 

2011 $33 9.3 $306 

2012 $91 9.1 $826 

2013 $129 9.8 $1,260 

2014 $146 10.2 $1,485 

2015 $148 10.6 $1,567 

2016 $202 10.8 $2,180 

Final Rule 2017 $85 10.0 $847 

2018 $170 9.9 $1,684 

2019 $151 10.0 $1,507 

2020 $170 10.3 $1,746 

2021 $169 10.5 $1,777 

Augural Rule 2022 $84 10.7 $903 

2023 $99 11.0 $1,093 

2024 $192 11.3 $2,168 

2025 $17 11.5 $201 
 

1080 

Table X-12 

Fuel Economy Costs of Light Trucks 

Incremental by Model Year 

 (in 2010 economics) 

CAFE Effective Model 

Year 

Incremental Cost 

Per Average 

Vehicle $ 

Projected Sales 

in Analysis 

(millions of 

vehicles) 

Total Industry 

Cost 

($ millions) 

Final Rules 2010 $0 9.0 $0 

2011 $105 6.9 $726 

2012 $123 5.8 $714 

2013 $88 6.0 $526 

2014 $247 5.9 $1,458 

2015 $215 5.8 $1,245 

2016 $162 5.7 $926 

Final Rule 2017 $78 5.8 $450 

2018 $69 5.7 $391 

2019 $197 5.6 $1,105 

2020 $209 5.6 $1,171 

2021 $286 5.7 $1,627 

Augural Rule 2022 $35 5.7 $200 

2023 $78 5.7 $447 

2024 $69 5.7 $393 

2025 $-58 5.7 $-329 
 

1081 

The light truck costs for MY 2025 are negative in Table X-12 ($-58). This appears to be the 

result of a combination of the achieved level of light truck fuel economy with the 2010 baseline 

increasing only from 37.4 to 37.6 mpg, the learning curve on costs being applied to the specific 

technologies used, and multi-year planning. This analysis reports incremental impacts accruing 

over the useful life of vehicles sold in a given model year, relative to impacts accruing over the 

useful life of vehicles sold in the preceding model year. Incremental impacts in each model year 

are attributed to standards applicable in that model year. However, because of multiyear 

planning effects, an increase in stringency in one model year, if assumed to carry forward 

indefinitely for purposes of defining a baseline for analysis of standards in the ensuing model 

year, would have impacts both in earlier model years and in later model years. Therefore, in any 

given model year, the impacts of CAFE standards could be more precisely attributed to a range 

of model years around that model year. For example, impacts attributable to the MY 2020 fleet 

can be attributed to standards applicable through MY 2019, in MY 2020, and (because of 

multiyear planning effects) after MY 2020. By the same token, the MY 2020 standards produce 

impacts before MY 2020, in MY 2020, and after MY 2020. However, such accounting would 

require incremental analysis with a dynamic baseline—analysis NHTSA has not conducted for 

today’s rulemaking. For future rulemakings, NHTSA will give further consideration to the 

attribution of impacts to CAFE standards applicable in each of a series of model years, and to the 

practicality of analysis to support alternative approaches to attribution. 

Tables X-13 and X-14 show the cumulative safety and fuel economy costs on a per vehicle basis 

and also total costs for the industry (multiplying average costs per vehicle by projected sales). 

These cumulative costs are compared to MY 2009 vehicles. The baseline for the fuel economy 

cost estimates for this final rule is the 2010 baseline. 
 

 

 

 

 

1082 

Table X-13 

Cumulative Cost Effects of Recent Passenger Cars Rules and Proposals 

(in 2010 economics) 

MY Average Cost per Vehicle, Cumulative Safety 

and Fuel Economy Costs 

Total Cost 

(in $M's) 

2010 $0 $0 

2011 $139 $1,040 

2012 $229 $1,966 

2013 $397 $4,525 

2014 $542 $8,291 

2015 $865 $14,991 

2016 $1,067 $22,511 

2017 $1,183 $31,112 

2018 $1,353 $41,094 

2019 $1,504 $52,613 

2020 $1,673 $65,895 

2021 $1,843 $81,020 

2022 $1,927 $97,121 

2023 $2,026 $114,400 

2024 $2,218 $134,120 

2025 $2,236 $154,237 
 

 

 

1083 

Table X-14 

Cumulative Cost Effects of Recent Light Truck Rules and Proposals

 (in 2010 economics) 

MY Average Cost per Vehicle, Cumulative Safety 

and Fuel Economy Costs 

Total Cost 

(in $M's) 

2010 $0 $0 

2011 $143 $752 

2012 $266 $1,808 

2013 $393 $3,741 

2014 $640 $6,810 

2015 $1,030 $12,049 

2016 $1,192 $17,315 

2017 $1,301 $23,212 

2018 $1,369 $29,190 

2019 $1,567 $36,266 

2020 $1,776 $44,364 

2021 $2,061 $53,982 

2022 $2,096 $63,818 

2023 $2,175 $74,038 

2024 $2,244 $84,659 

2025 $2,186 $94,994 
                                                      

 

 

 

 

 

 

1084 

Sensitivity Analyses 

The agency performed a number of sensitivity analyses to examine important assumptions. All 

sensitivity analyses were based on the standard setting output of the Volpe model, and – in a 

departure from the central analysis presented elsewhere in this FRIA – sensitivity analyses are 

based solely upon the 2010 baseline fleet. We examine sensitivity with respect to the following 

economic parameters: 

1) The price of gasoline: The main analysis uses the Reference Case AEO 2012 Early Release 

estimate for the price of gasoline. As the AEO 2012 Early Release does not contain Low and 

High Price Cases, ranges derived from the Low and High Price Cases from the AEO 2011 

were utilized in conjunction with the Reference Case AEO 2012 Early Release to study the 

effect of the Low and High Price Cases on the model results. 

2)	 The rebound effect: The main analysis uses a rebound effect of 10 percent to project 

increased miles traveled as the cost per mile driven decreases. In the sensitivity analysis, we 

examine the effect of using a 5, 15, or 20 percent rebound effect instead. 

3)	 The value of CO2 benefits: The main analysis uses $22 per ton discounted at a 3 percent 

discount rate to quantify the benefits of reducing CO2 emissions and $0.199 per gallon to 

quantify the benefits of reducing fuel consumption. In the sensitivity analysis, we examine 

the following values and discount rates applied only to the social cost of carbon to value 

carbon benefits, considering low, high, and very high valuations of approximately $5, $36, 

and $68 per ton, respectively with regard to the benefits of reducing CO2 emissions.602 These 

are the 2010 values, which increase over time. These values can be translated into cents per 

gallon by multiplying by 0.0089,603 giving the following values: 

($4.91 per ton CO2) x 0.0089 = $0.044 per gallon discounted at 5% 

($22.22 per ton CO2) x 0.0089 = $0.198 per gallon discounted at 3% (used in the main 

analysis) 

($36.49 per ton CO2) x 0.0089 = $0.325 per gallon discounted at 2.5% 

602 The low, high, and very high valuations of $5, $36, and $67 are rounded for brevity; the exact values are $4.86,
 

$36.13, and $66.88, respectively. While the model uses the unrounded values, the use of unrounded values is not
 

intended to imply that the chosen values are precisely accurate to the nearest cent; rather, they are average levels
 

resulting from the many published studies on the topic. 

603 The molecular weight of Carbon (C) is 12, the molecular weight of Oxygen (O) is 16, thus the molecular weight
 

of CO2 is 44. 1 gallon of gas weighs 2,819 grams, of that 2,433 grams are carbon. One ton of CO2/One ton of C 

(44/12)* 2433grams C/gallon *1 ton/1000kg * 1 kg/1000g = (44 * 2433*1*1) / (12*1*1000 * 1000) = 

0.0089. Thus, one ton of CO2*0.0089 = 1 gallon of gasoline. 
                                                      

 

 

1085 

And a 95th percentile estimate of 

($67.55 per ton CO2) x 0.0089 = $0.601 per gallon discounted at 3% 

4)	 Global Warming Potential (non-CO2 GHG benefits): The main analysis does not monetize 

benefits associated with the reduction of non-CO2 GHGs (methane, nitrous oxide, HFC134a). This sensitivity analysis uses a GWP approach to convert non-CO2 GHGs to CO2­

equivalence to monetize these benefits using the same methods with which the benefits of 

CO2 reductions are valued. 

One limitation relevant to the primary benefits analysis is that it does not include the 

valuation of non-CO2 GHG impacts (i.e., CH4, N2O, and HFCs). The SCC estimates used in 

this analysis were developed through an interagency process that included EPA, 

DOT/NHTSA, and other executive branch entities, and concluded in February 2010.604 The 

interagency group did not directly estimate the social costs of non-CO2 GHG emissions when 

it developed the current social cost of CO2 values. Moreover, the group determined that it 

would not transform the CO2 estimates into estimates for non-CO2 GHGs using global 

warming potentials (GWPs), which measure the ability of different gases to trap heat in the 

atmosphere (i.e., radiative forcing per unit of mass) over a particular timeframe relative to 

CO2. Recognizing that non-CO2 GHG impacts associated with this rulemaking (net 

reductions in CH4, N2O, and HFCs) would provide economic benefits to society, however, 

the agencies requested comment on a methodology to value such impacts. Several 

commenters strongly recommended that the agencies value non-CO2 GHG impacts 

associated with this final rule. See the preamble IV.C.3 for a summary of the public 

comments and NHTSA’s response. 

One way to approximate the value of marginal non-CO2 GHG emission reductions in the 

absence of direct model estimates is to convert the reductions to CO2-equivalents which may 

then be valued using the SCC. Conversion to CO2-e is typically done using the global 

warming potential (GWP) for the non-CO2 gas; we refer to this method as the “GWP 

approach.” The GWP is an aggregate measure that approximates the additional energy 

trapped in the atmosphere over a given timeframe from a perturbation of a non-CO2 gas 

relative to CO2. The time horizon most commonly used is 100 years. One potential problem 

with utilizing temporally aggregated statistics, such as the GWPs, is that the additional 

604 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 Council, 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://www.epa.gov/oms/climate/regulations/scc-tsd.pdf 
                                                      

 

1086 

radiative forcing from the GHG perturbation is not constant over time and any differences in 

temporal dynamics between gases will be lost. 

While the GWP approach provides an approximation of the monetized value of the non-CO2 

GHG reductions anticipated from this rule, it produces estimates that are less accurate than 

those obtained from direct model computations for a variety of reasons, including the 

differences in atmospheric lifetime of non-CO2 gases relative to CO2. This is a potentially 

confounding issue given that the social cost of GHGs is based on a discounted stream of 

damages—i.e., they are not constant over time—and that are non-linear in temperature. 

A limited number of studies in the published literature explore the differences in the social 

benefit estimates from the GWP approach and direct modeling. One recent working paper 

(Marten and Newbold, 2011) found that the GWP-weighted benefit estimates for CH4 and 

N2O are likely to be lower than those that would be derived using a directly modeled social 

cost of these gases for a variety of reasons.605 This conclusion is reached using the 100 year 

GWP coefficients as put forth in the IPCC Fourth Assessment Report (CH4 is 25, N2O is 

298). The GWP reflects only the integrated radiative forcing of a gas over 100 years. In 

contrast, the directly modeled social cost differs from the GWP because the differences in 

timing of the warming between gases are explicitly modeled, the non-linear effects of 

temperature change on economic damages are included, and rather than treating all impacts 

over a hundred years equally, the modeled social cost applies a discount rate but calculates 

impacts through the year 2300. 

The agencies also undertook a literature search for estimates of the marginal social cost of 

non-CO2 GHGs. A range of these estimates are available in published literature (Fankhauser 

(1994), Kandlikar (1995), Hammitt et al. (1996), Tol et al. (2003), Tol, et al. (2006), Hope 

(2005) and Hope and Newberry (2006). Most of these estimates are based upon modeling 

assumptions that are dated and inconsistent. Some of these studies focused on, for example, 

marginal methane reductions in the 1990s and early 2000s and report estimates for only the 

single year of interest specific to the study. The assumptions underlying the social cost of 

non-CO2 GHG estimates available in the literature differ from those agreed upon by the SCC 

interagency group and in many cases use older versions of the integrated assessment models. 

Without additional analysis, the non-CO2 GHG benefit estimates available in the current 

literature are not acceptable to use to value the methane reductions finalized in this 

rulemaking. 

605 Marten, A. and S. Newbold. 2011. “Estimating the Social Cost of Non-CO2 GHG Emissions: Methane and 

Nitrous Oxide.” NCEE Working Paper Series #11-01. http://yosemite.epa.gov/ee/epa/eed.nsf/WPNumber/2011­

01?opendocument. Accessed May 24, 2012. Docket ID EPA-HQ-OAR-2010-0799. 
 

                                                      

 

1087 

In the absence of direct model estimates from the interagency analysis, and in the interest of 

being responsive to comments encouraging us to examine this, NHTSA has conducted a 

sensitivity analysis using the GWP approach to estimate the benefits associated with 

reductions of three non-CO2 GHGs in each calendar year. Estimates for this rulemaking are 

given below for illustrative purposes and represent the CO2-e estimate of CH4, N2O, and 

HFC reductions multiplied by the SCC estimates. CO2-e is calculated using the AR4 100­

year GWP of each gas: CH4 (25), N2O (298), and HFC-134a (1,430).606 

5)	 Military security: The main analysis does not assign a value to the military security benefits 

of reducing fuel consumption. In the sensitivity analysis, we examine the impact of using a 

value of 12 cents per gallon instead. 

6)	 Consumer Benefit: The main analysis assumes there is no loss in value to consumers 

resulting from vehicles that have an increase in price and higher fuel economy. This 

sensitivity analysis assumes that there is a 25, or 50 percent loss in value to consumers – 

equivalent to the assumption that consumers will only value the calculated benefits they will 

achieve at 75, or 50 percent, respectively, of the main analysis estimates. 

7) Post-warranty repair costs: The main analysis includes repair costs during the warranty 

period; post-warranty repair costs are addressed in a sensitivity analysis. The warranty 

period is assumed to be 5 years for the powertrain and 3 years for the rest of the vehicle. 

This sensitivity analysis scales the frequency of repair by vehicle survival rates, assumes that 

per-vehicle repair costs during the post-warranty period are the same as in the in-warranty 

period, and that repair costs are proportional to incremental direct costs (therefore vehicles 

with additional components will have increased repair costs). 

8) Battery cost: The agency conducted a sensitivity analysis of battery costs for HEV, PHEV 

and EV technologies. The ranges for battery costs are based on the recommendations from 

the technical experts in the field of battery energy storage technologies at Department of 

Energy (DOE) and Argonne National Laboratory (ANL). These ranges of battery costs are 

developed using the Battery Performance and Cost (BatPaC) model developed by ANL and 

funded by DOE607. The values for these ranges are shown in Table X-15 and are calculated 

with 95% confidence interval after analyzing the confidence bound using the BatPaC model. 

606 As in the MY 2012-2016 LD rules and in the MY 2014-2018 MD and HD rule, the global warming potentials 

(GWP) used in this rulemaking are consistent with the 100-year time frame values in the 2007 Intergovernmental 

Panel on Climate Change (IPCC) Fourth Assessment Report (AR4). At this time, the 100-year GWP values from 

the 1995 IPCC Second Assessment Report (SAR) are used in the official U.S. GHG inventory submission to the 

United Nations Framework Convention on Climate Change (UNFCCC) (per the reporting requirements under that 

international convention) . The UNFCCC recently agreed on revisions to the national GHG inventory reporting 

requirements, and will begin using the 100-year GWP values from AR4 for inventory submissions in the future. 

According to the AR4, CH4 has a 100-year GWP of 25, N2O has a 100-year GWP of 298, and HFC-134a has a 100­

year GWP of 1430. 

607 Section 3.4.3.9 in TSD Chapter 3 has detailed descriptions of the history of the BatPac model and how the 

agencies used the BatPac model in this analysis. 
 

1088 

Table X-15 

Suggested Confidence Bounds as Percentages of the Calculated Point Estimate for a 

Graphite-based Li-ion Battery Using the Default Inputs in BatPaC 

Confidence Interval 

Battery Type Cathodes Lower upper 

HEV LMO, LFP, NCA, NMC -10% 10% 

PHEV, EV NMC, NCA -10% 20% 

PHEV, EV LMO, LFP -20% 35% 

ANL also stated that if a simpler approach to defining bounds is desired, +/- 20 percent 

bounds could be placed on the cost of PHEV and EV batteries. The NHTSA sensitivity 

analysis uses the bounds that were determined in the in-depth ANL analysis that are shown in 

the table instead of the simpler and more approximate +/- 20 percent bounds. 

In the NPRM central analysis, EPA developed direct manufacturing costs (DMC) for battery 

systems using ANL’s BatPaC model. For this sensitivity analysis, NHTSA scaled these 

central battery system costs by the percentages shown in Table X-15, per guidance from 

DOE and ANL experts on reasonable ranges for these costs. Figures X-1 to X-5 shows these 

battery system DMCs in terms of $/kW for HEV and $/kWh for 20-mile range PHEV 

(PHEV20), 40-mile range PHEV (PHEV40), 75-mile range EV (EV75), 100-mile range EV 

(EV100) and 150-mile range EV (EV150). We note that battery system cost varies with 

vehicle subclasses and driving range. Smaller batteries tend to be relatively more expensive 

per kWh because the cost for the battery management system, disconnect units and baseline 

thermal management system is the same from vehicle to vehicle for each type of 

electrification system, such as HEV, PHEV and EV (but varies between different 

electrification systems) and this cost is spread over fewer kWh for smaller vehicle. For 

example, the battery system cost for EVs ranges from $221/kWh for subcompact cars for 

EV75, to $160/kWh for large trucks for EV150 in MY 2021. Note: the agencies do not apply 

PHEV or EV technology to large MPVs/minivans or large trucks; however, the estimated 

costs of such a system are shown here for completeness. 
1089 

Figure X-1 

Battery System Direct Manufacture Cost (DMC) for P2 HEV 

Figure X-2 

Battery System Direct Manufacture Cost (DMC) for PHEV20 

Figure X-3 
 

1090 

Battery System Direct Manufacture Cost (DMC) for PHEV40 

Figure X-4 

Battery System Direct Manufacture Cost (DMC) for EV75 

Figure X-5 

Battery System Direct Manufacture Cost (DMC) for EV150 
 

1091 

For the reader’s reference, this sensitivity was conducted using what the agency refers to as 

“standard setting” analytical runs, in which the agency restricts the operation of the model 

consistent with statutory requirements related to how the agency may determine maximum 

feasible CAFE standards (for example, the standard setting runs do not include EVs, because 

NHTSA may not consider the fuel economy of EVs when setting maximum feasible CAFE 

standards, nor do they consider PHEVs prior to MY 2020, for the same reason), as compared to 

the “real-world” analysis, in which the agency attempts to model how manufacturers might 

respond to the standards (and regulatory alternatives) taking account of all available technologies 

and compliance flexibilities. NHTSA used the “standard setting” runs for this sensitivity 

analysis to show the regulatory impact of the battery cost. In the “standard setting” runs, NHTSA 

included 30-mile range PHEV (PHEV30) only after MY2019 to represent all PHEVs, the cost of 

which is the average cost of PHEV20 and PHEV40. NHTSA did not apply any EVs in this 

analysis. 

9) Mass reduction cost: Due to the wide range of mass reduction cost as stated in TSD Chapter 

3, a sensitivity analysis was performed examining the impact of the cost of vehicle mass 

reduction to the total technology cost. The direct manufacturing cost (DMC) for mass 

reduction is represented as a linear function between the unit DMC versus percent of mass 

reduction as shown in Figure X-6. The slope of this line used for the central analysis is $4.36 

(2010$) per pound per percent of mass reduction. The slope of the line is varied ± 40% as the 

upper and lower bound for this sensitivity study. The values for the range of mass reduction 

cost are shown in Table X-16. 
 

 

 

1092 

Table X-16 

Bounds for Mass Reduction Direct Manufacturing Cost (2010$) 

Sensitivity Bound 

Slope of Mass 

Reduction Line 

[$/(lb-%MR) 

Example 

Unit Direct 

Manufacture Cost1 

[$/lb] 

Example 

Total Direct 

Manufacture Cost2 

[$/lb] 

Lower Bound $2.61 $0.39 $235 

NPRM Central Analysis $4.36 $0.65 $392 

Upper Bound $6.10 $0.92 $549 

Notes 

1. Example is based on 15% mass reduction. 

 Unit direct manufacturing cost [$/lb]= Slope x Percent of Mass Reduction 

2. Example is based on 15% mass reduction for a 4000-lb vehicle. 

 Total direct manufacturing cost [$] = Unit Direct Manufacturing Cost x Amount of Mass Reduction 
   

   

   

     

         

   

Mass Reduction Cost Sensitivity Bounds
 

(2010$)
 

Unit Cost [$/lb]

1

0.9

0.8

0.7

0.6

0.5

0.4

0.3

0.2

0.1

0 0

0% 2% 4% 6% 8% 10% 12% 14% 16%

Slope = 6.10

Slope = 4.36

Slope = 2.61

Percent of Mass Reduction

Lower Bound FR Central Analysis Upper Bound

1093 

Figure X-6 

Direct Manufacturing Cost for Mass Reduction (2010$) 

10) Market-driven response: The baseline for the central analysis is based on the MY 2016 

CAFE standards and assumes that manufacturers will make no changes in the fuel economy 

from that level through MY 2025. A sensitivity analysis was performed to simulate potential 

increases in fuel economy over the compliance level required if MY 2016 standards were to 

remain in place. The assumption is that the market would drive manufacturers to put 

technologies into their vehicles that they believe consumers would value and be willing to 

pay for. Using parameter values consistent with the central analysis, the agency simulated a 

market-driven response baseline by applying a payback period of one year for purposes of 

calculating the value of future fuel savings when simulating whether manufacturers would 

apply additional technology to an already CAFE-compliant fleet. In other words we assumed 

that manufacturers that were above their MY 2016 CAFE level would compare the cost to 

consumers to the fuel savings in the first year of operation and decide to voluntarily apply 

those technologies to their vehicles when benefits for the first year exceeded costs for the 

consumer. For a manufacturer’s fleet that that has not yet achieved compliance with CAFE 

standards, the agency continued to apply a five-year payback period. In other words, for this 

sensitivity analysis the agency assumed that manufacturers that have not yet met CAFE 

standards for future model years will apply technology as if buyers were willing to pay for 

the technologies as long as the fuel savings throughout the first five years of vehicle 
 

 

                                                      

1094 

ownership exceeded their costs. Once having complied with those standards, however, 

manufacturers are assumed to consider making further improvements in fuel economy as if 

buyers were only willing to pay for fuel savings to be realized during the first year of vehicle 

ownership. The ‘market-drive response’ analysis assumes manufacturers will overcomply if 

additional technology is sufficiently cost effective. Because this assumption has a greater impact 

under the baseline standards, its application reduces the incremental costs, effects, and benefits 

attributable to the new standards. This does not mean costs, effects, and benefits would actually 

be smaller with a market-driven response; rather it means costs, effects, and benefits would be at 

least as great, but would be partially attributable not to the new standards, but instead to the 

market. 

11) Transmission shift optimization technology disabled: As part of the simulation work for the final 

rule, ANL attempted to replicate the shift optimizer technology but produced different results 

than those of Ricardo, particularly in the application of shift optimization to naturally aspirated 

engines. Because of this uncertainty in effectiveness values, NHTSA conducted a sensitivity 

case analysis with transmission shift optimizer technology disabled. 

Above we discuss how we mathematically determined market demand, but a potential rationale for 

more market demand follows: For years, consumers have been learning about the benefits that 

accrue to them from owning and operating vehicles with greater fuel efficiency. Consumer 

demand has thus shifted towards such vehicles, not only because of higher fuel prices but also 

because many consumers are learning about the value of purchases based not only on initial costs 

but also on the total cost of owning and operating a vehicle over its lifetime. This type of 

learning is expected to continue before and during the model years affected by this rule, 

particularly given the new fuel economy labels that clarify potential economic effects and should 

therefore reinforce that learning.608 Therefore, some increase in the demand for, and production 

of, more fuel efficient vehicles is incorporated as a market driven response in this sensitivity 

analysis. 

Varying each of the above 11 parameters in isolation results in a variety of economic scenarios. 

These are listed in Table X-17 below along with the preferred alternative. 

12) The agency performed two additional sensitivity analyses presented in Tables X-20 and X21. First, the agency analyzed the impact that having a retail price equivalent (RPE) factor of 

1.5 for all technologies would have on the various alternatives instead of using the indirect 

608 A recent Consumer Reports study supports the noted increase in consumer learning and consequent desire for 

more fuel-efficient vehicles. See “High Gas Prices Motivate Drivers to Change Direction,” Consumer Reports, May 

2012, available at: http://www.consumerreports.org/content/cro/en/cars/fuel-economy-survey-high-gas-pricesimpact-drivers.html (last accessed August 1, 2012) 
 

1095 

cost markup (ICM) methodology. The ICM methodology results in an overall markup factor 

of 1.2 to 1.25 compared to the RPE markup factor from variable cost of 1.5. Next, the 

agency conducted a separate sensitivity analysis using values that were derived from the 

2011 NAS report.2

 This analysis used an RPE markup factor of 1.5 for non-electrification 

technologies, which is consistent with the NAS estimation for technologies manufactured by 

suppliers, and a RPE markup factor of 1.33 for electrification technologies (HEV, PHEV and 

EV); three types of learning which include no learning for mature technologies, 1.25 percent 

annual learning for evolutionary technologies, and 2.5 percent annual learning for 

revolutionary technologies; technology cost estimates for 52 percent (33 out of 63) 

technologies; and technology effectiveness estimates for 56 percent (35 out of 63) of 

technologies. Cost learning was applied to technology costs in a manner similar to how cost 

learning is applied in the central analysis for many technologies which have base costs which 

are applicable to recent or near-term future model years. As noted above, the cost learning 

factors used for the sensitivity case are different than the values used in the central 

analysis. For the other inputs in the sensitivity case, where the NAS study has inconsistent 

information or lacks projections, NHTSA used the same input values that were used in the 

central analysis. 

13) Table X-22 separately examines the sensitivity of the benefits of reducing criteria pollutants 

and vehicle safety to alternate values of statistical life. 
 

 

 

 

 

1096 

Table X-17 

Sensitivity Analyses
 

Name Fuel Price Discount 

Rate 

Rebound 

Effect SCC Military Security 

Reference Reference 3% 10% $22 0¢/gal 

High Fuel Price High 3% 10% $22 0¢/gal 

Low Fuel Price Low 3% 10% $22 0¢/gal 

5% Rebound Effect Reference 3% 5% $22 0¢/gal 

15% Rebound Effect Reference 3% 15% $22 0¢/gal 

20% Rebound Effect Reference 3% 20% $22 0¢/gal 

12¢/gal Military Security 

Value Reference 3% 10% $22 12¢/gal 

$5/ton CO2 Value Reference 3% 10% $5 0¢/gal 

$36/ton CO2 Value Reference 3% 10% $36 0¢/gal 

$68/ton CO2 Value Reference 3% 10% $68 0¢/gal 

Global Warming Potential Reference 3% 10% $22 0¢/gal 

50% Consumer Benefit Reference 3% 10% $22 0¢/gal 

75% Consumer Benefit Reference 3% 10% $22 0¢/gal 

Post-Warranty Repair Costs Reference 3% 10% $22 0¢/gal 

Low Battery Cost Reference 3% 10% $22 0¢/gal 

High Battery Cost Reference 3% 10% $22 0¢/gal 

Low Cost Mass Reduction Reference 3% 10% $22 0¢/gal 

High Cost Mass Reduction Reference 3% 10% $22 0¢/gal 

Market-Driven Response Reference 3% 10% $22 0¢/gal 

No Shift Optimization Reference 3% 10% $22 0¢/gal 
                                                      

1097 

Table X-18 presents the achieved fuel economy, per-vehicle price increase, total benefits, total 

cost, lifetime fuel savings, and the lifetime reductions in CO2 emissions that would result under 

the standards from the economic scenarios. For the achieved fuel economy and per-vehicle price 

increase, the table presents only the model year 2025 results, since this model year showed the 

greatest impacts. For net benefits, fuel savings, and CO2 emissions reductions, the table presents 

totals over the nine model years, rather than their values for MY 2025, to reflect the total impact 

of the standards that would result from the various economic assumptions. To derive a valid 

comparison between the baseline and the sensitivity analyses, all runs were based on a 3% 

discount rate using the central standard setting data runs. Thus, the preferred mpg levels and 

baseline are slightly different than the main analysis. Costs include both technology costs and 

fine payments. 

Table X-19 presents the percentage changes from the Preferred Alternative economic 

assumptions for the items in Table X-18. From these tables, we conclude the following 

regarding the impact of varying the economic parameters among the considered values: 

1) Varying the economic assumptions has almost no impact on achieved mpg. The mass 

reduction cost sensitivities, battery cost reduction sensitivities609, market-based baseline 

sensitivity, and no shift optimization sensitivity cases are the only instances in which 

achieved mpg differs from the reference case of the Preferred Alternative. None of these 

alter the outcome by more than 0.3 mpg for either fleet. 

2) Varying the economic assumptions has, at most, a small impact on per-vehicle costs, with 

only the no shift optimization variation affecting the per-vehicle cost by more than 10 

percent from the central analysis level. Similarly, fuel saved and CO2 emissions 

reductions vary only slightly across the sensitivity cases, where the only substantial 

impact results from the market-driven baseline sensitivity in which voluntary 

overcompliance reduces the number of gallons of fuel saved as well as the quantity of 

CO2 emissions by just under 28 percent. 

3) The category most affected by variations in the economic parameters considered in these 

sensitivity analyses is net benefits. The sensitivity analyses examining the AEO low and 

high fuel price scenarios demonstrate the potential to negatively impact net benefits by up 

to 38 percent or to increase them by about 32 percent relative to those of the Preferred 

Alternative. Other large impacts on net benefits occurred with the $68/ton CO2 

valuation, in which net benefits increased by nearly 22 percent, the market-driven 

baseline, which reduces net benefits by close to 32 percent, and (as expected) the 50 and 

75 percent consumer fuel savings valuation cases, which decrease net benefits by 

approximately 52 and 26 percent, respectively. 

609 The difference resulting from changes in battery cost are less that 0.05 mpg, therefore are imperceptible in Table 

X-12 and round to 0% in Table X-13. 
 

1098 

4)	 Even if consumers value the benefits achieved at 50% of the main analysis assumptions, 

total benefits still exceed costs, with net benefits greater than $135 billion. 

Regarding the lower fuel savings and CO2 emissions reductions predicted by the sensitivity 

analysis as fuel price increases, which initially may seem counterintuitive, we note that there are 

some counterbalancing factors occurring. As fuel price increases, people will drive less and so 

fuel savings and CO2 emissions reductions may decrease. 
1099 

Table X-18a 

Sensitivity Analyses

 (mpg, Per-Vehicle Cost, Total Benefits, Total Cost, Fuel Saved, & CO2 Emissions Reduced) 

Passenger Cars 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Passenger Cars 

Preferred 54.1 $1,578 $293,062 109,852 2,384 

High Fuel Price 54.2 $1,623 $385,879 102,888 2,234 

Low Fuel Price 53.8 $1,498 $180,822 112,798 2,449 

5% Rebound Effect 54.1 $1,578 $306,879 113,226 2,458 

15% Rebound Effect 54.1 $1,578 $290,962 106,478 2,310 

20% Rebound Effect 54.1 $1,578 $283,004 103,105 2,237 

12¢/gal Military Security 

Value 54.1 $1,578 $308,923 109,852 2,384 

$5/ton CO2 Value 54.1 $1,578 $274,982 109,852 2,384 

$36/ton CO2 Value 54.1 $1,578 $317,760 109,852 2,384 

$68/ton CO2 Value 54.1 $1,578 $364,833 109,852 2,384 

Global Warming Potential 54.1 $1,578 $299,023 109,852 2,384 

50% Consumer Benefit 54.1 $1,578 $141,150 109,852 2,384 

75% Consumer Benefit 54.1 $1,578 $220,035 109,852 2,384 

Post-Warranty Repair Costs 54.1 $1,578 $286,038 109,852 2,384 

Low Battery Cost 54.1 $1,570 $299,128 109,869 2,384 

High Battery Cost 54.1 $1,591 $298,490 109,831 2,384 

Low Cost Mass Reduction 54.1 $1,551 $300,244 109,931 2,386 
 

1100 

High Cost Mass Reduction 54.1 $1,600 $297,339 109,826 2,384 

Market-Driven Baseline 54.4 $1,618 $216,774 86,564 1,878 

No Shift Optimization 53.9 $1,626 $283,476 107,957 2,340 
1101 

Table X-18b 

Sensitivity Analyses

 (mpg, Per-Vehicle Cost, Total Benefits, Total Cost, Fuel Saved, & CO2 Emissions Reduced) 

Light Trucks 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Light Trucks 

Preferred 39.3 $1,226 $175,793 61,984 1,333 

High Fuel Price 39.3 $1,331 $242,737 60,886 1,312 

Low Fuel Price 39.1 $1,132 $118,820 68,407 1,479 

5% Rebound Effect 39.3 $1,226 $182,716 64,149 1,380 

15% Rebound Effect 39.3 $1,226 $175,216 59,818 1,286 

20% Rebound Effect 39.3 $1,226 $171,466 57,653 1,239 

12¢/gal Military Security 

Value 39.3 $1,226 $184,284 61,984 1,333 

$5/ton CO2 Value 39.3 $1,226 $165,604 61,984 1,333 

$36/ton CO2 Value 39.3 $1,226 $189,482 61,984 1,333 

$68/ton CO2 Value 39.3 $1,226 $215,721 61,984 1,333 

Global Warming Potential 39.3 $1,226 $179,017 61,984 1,333 

50% Consumer Benefit 39.3 $1,226 $91,951 61,984 1,333 

75% Consumer Benefit 39.3 $1,226 $135,458 61,984 1,333 

Post-Warranty Repair Costs 39.3 $1,226 $173,514 61,984 1,333 

Low Battery Cost 39.3 $1,225 $178,979 61,984 1,333 

High Battery Cost 39.3 $1,226 $178,953 61,984 1,333 

Low Cost Mass Reduction 39.4 $1,194 $183,675 63,111 1,355 
 

1102 

High Cost Mass Reduction 39.1 $1,165 $176,659 60,497 1,299 

Market-Driven Baseline 39.3 $985 $103,943 37,887 818 

No Shift Optimization 39.2 $1,392 $171,545 60,623 1,300 
1103 

Table X-18c 

Sensitivity Analyses

 (mpg, Per-Vehicle Cost, Total Benefits, Total Cost, Fuel Saved, & CO2 Emissions Reduced) 

Passenger Cars and Light Trucks Combined 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Passenger Cars and Light 

Trucks 

Preferred 48.1 $1,461 $468,855 171,836 3,717 

High Fuel Price 48.2 $1,526 $628,616 163,775 3,545 

Low Fuel Price 47.8 $1,376 $299,642 181,205 3,928 

5% Rebound Effect 48.1 $1,461 $489,595 177,374 3,838 

15% Rebound Effect 48.1 $1,461 $466,178 166,297 3,597 

20% Rebound Effect 48.1 $1,461 $454,469 160,758 3,476 

12¢/gal Military Security Value 48.1 $1,461 $493,208 171,836 3,717 

$5/ton CO2 Value 48.1 $1,461 $440,586 171,836 3,717 

$36/ton CO2 Value 48.1 $1,461 $507,241 171,836 3,717 

$68/ton CO2 Value 48.1 $1,461 $580,554 171,836 3,717 

Global Warming Potential 48.1 $1,461 $478,040 171,836 3,717 

50% Consumer Benefit 48.1 $1,461 $233,100 171,836 3,717 

75% Consumer Benefit 48.1 $1,461 $355,494 171,836 3,717 

Post-Warranty Repair Costs 48.1 $1,461 $459,553 171,836 3,717 

Low Battery Cost 48.1 $1,456 $478,107 171,853 3,718 

High Battery Cost 48.1 $1,470 $477,443 171,815 3,717 

Low Cost Mass Reduction 48.1 $1,432 $483,919 173,042 3,741 
1104 

High Cost Mass Reduction 48.0 $1,455 $473,998 170,323 3,683 

Market-Driven Baseline 48.2 $1,408 $320,717 124,451 2,696 

No Shift Optimization 47.9 $1,635 $455,021 168,580 3,640 
 

1105 

Table X-19a 

Sensitivity Analyses – Percentage Change from the Reference Case
 

Passenger Cars
 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Passenger Cars 

Preferred Base Base Base Base Base 

High Fuel Price 0.3% 2.9% 31.7% -6.3% -6.3% 

Low Fuel Price -0.6% -5.1% -38.3% 2.7% 2.7% 

5% Rebound Effect 0.0% 0.0% 4.7% 3.1% 3.1% 

15% Rebound Effect 0.0% 0.0% -0.7% -3.1% -3.1% 

20% Rebound Effect 0.0% 0.0% -3.4% -6.1% -6.2% 

12¢/gal Military Security Value 0.0% 0.0% 5.4% 0.0% 0.0% 

$5/ton CO2 Value 0.0% 0.0% -6.2% 0.0% 0.0% 

$36/ton CO2 Value 0.0% 0.0% 8.4% 0.0% 0.0% 

$68/ton CO2 Value 0.0% 0.0% 24.5% 0.0% 0.0% 

Global Warming Potential 0.0% 0.0% 2.0% 0.0% 0.0% 

50% Consumer Benefit 0.0% 0.0% -51.8% 0.0% 0.0% 

75% Consumer Benefit 0.0% 0.0% -24.9% 0.0% 0.0% 

Post-Warranty Repair Costs 0.0% 0.0% -2.4% 0.0% 0.0% 

Low Battery Cost 0.0% -0.5% 2.1% 0.0% 0.0% 

High Battery Cost 0.0% 0.8% 1.9% 0.0% 0.0% 

Low Cost Mass Reduction 0.0% -1.7% 2.5% 0.1% 0.1% 

High Cost Mass Reduction 0.1% 1.4% 1.5% 0.0% 0.0% 
 

1106 

Market-Driven Baseline 0.6% 2.6% -26.0% -21.2% -21.2% 

No Shift Optimization -0.3% 3.1% -3.3% -1.7% -1.8% 
 

1107 

Table X-19b 

Sensitivity Analyses – Percentage Change from the Reference Case
 

Light Trucks 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Light Trucks 

Preferred Base Base Base Base Base 

High Fuel Price 0.1% 8.6% 38.1% -1.8% -1.6% 

Low Fuel Price -0.6% -7.7% -32.4% 10.4% 10.9% 

5% Rebound Effect 0.0% 0.0% 3.9% 3.5% 3.5% 

15% Rebound Effect 0.0% 0.0% -0.3% -3.5% -3.5% 

20% Rebound Effect 0.0% 0.0% -2.5% -7.0% -7.0% 

12¢/gal Military Security Value 0.0% 0.0% 4.8% 0.0% 0.0% 

$5/ton CO2 Value 0.0% 0.0% -5.8% 0.0% 0.0% 

$36/ton CO2 Value 0.0% 0.0% 7.8% 0.0% 0.0% 

$68/ton CO2 Value 0.0% 0.0% 22.7% 0.0% 0.0% 

Global Warming Potential 0.0% 0.0% 1.8% 0.0% 0.0% 

50% Consumer Benefit 0.0% 0.0% -47.7% 0.0% 0.0% 

75% Consumer Benefit 0.0% 0.0% -22.9% 0.0% 0.0% 

Post-Warranty Repair Costs 0.0% 0.0% -1.3% 0.0% 0.0% 

Low Battery Cost 0.0% 0.0% 1.8% 0.0% 0.0% 

High Battery Cost 0.0% 0.0% 1.8% 0.0% 0.0% 

Low Cost Mass Reduction 0.2% -2.6% 4.5% 1.8% 1.7% 

High Cost Mass Reduction -0.5% -5.0% 0.5% -2.4% -2.5% 
 

1108 

Market-Driven Baseline 0.1% -19.6% -40.9% -38.9% -38.7% 

No Shift Optimization -0.2% 13.6% -2.4% -2.2% -2.5% 
1109 

Table X-19c 

Sensitivity Analyses – Percentage Change from the Reference Case
 

Passenger Cars and Light Trucks Combined 

Economic Assumptions 

MY 2025 

Achieved 

mpg 

MY 2025 

PerVehicle 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Passenger Cars and Light 

Trucks 

Preferred Base Base Base Base Base 

High Fuel Price 0.2% 4.5% 34.1% -4.7% -4.6% 

Low Fuel Price -0.6% -5.8% -36.1% 5.5% 5.7% 

5% Rebound Effect 0.0% 0.0% 4.4% 3.2% 3.2% 

15% Rebound Effect 0.0% 0.0% -0.6% -3.2% -3.2% 

20% Rebound Effect 0.0% 0.0% -3.1% -6.4% -6.5% 

12¢/gal Military Security Value 0.0% 0.0% 5.2% 0.0% 0.0% 

$5/ton CO2 Value 0.0% 0.0% -6.0% 0.0% 0.0% 

$36/ton CO2 Value 0.0% 0.0% 8.2% 0.0% 0.0% 

$68/ton CO2 Value 0.0% 0.0% 23.8% 0.0% 0.0% 

Global Warming Potential 0.0% 0.0% 2.0% 0.0% 0.0% 

50% Consumer Benefit 0.0% 0.0% -50.3% 0.0% 0.0% 

75% Consumer Benefit 0.0% 0.0% -24.2% 0.0% 0.0% 

Post-Warranty Repair Costs 0.0% 0.0% -2.0% 0.0% 0.0% 

Low Battery Cost 0.0% -0.4% 2.0% 0.0% 0.0% 

High Battery Cost 0.0% 0.6% 1.8% 0.0% 0.0% 

Low Cost Mass Reduction 0.1% -1.9% 3.2% 0.7% 0.7% 

High Cost Mass Reduction -0.1% -0.4% 1.1% -0.9% -0.9% 
 

1110 

Market-Driven Baseline 0.4% -3.6% -31.6% -27.6% -27.5% 

No Shift Optimization -0.3% 12.0% -3.0% -1.9% -2.1% 
 

 

1111 

Table X-20a 

Achieved mpg level, MY 2025 

Comparing Different Cost Mark-up Methodologies 

(3% Discount Rate) 

ICM Method 

(Main 

Analysis 

Costs) 

RPE Method 

(Main 

Analysis 

Costs) 

Difference 

(mpg) 

Passenger Cars 

Preferred Alternative 54.07 53.92 0.16 

Max Net Benefits 56.52 56.42 0.10 

Light trucks 

Preferred Alternative 39.29 39.14 0.15 

Max Net Benefits 43.66 43.56 0.10 

Table X-20b 

Achieved mpg level, MY 2025 

Comparing ICM Method with Main Analysis Costs vs. NAS Costs 

(3% Discount Rate) 

ICM Method 

(Main 

Analysis 

Costs) 

ICM Method 

(NAS Cost 

Estimates) 

Difference 

(mpg) 

Passenger Cars 

Preferred Alternative 54.07 52.78 1.29 

Max Net Benefits 56.52 55.32 1.20 

Light trucks 

Preferred Alternative 39.29 37.71 1.58 

Max Net Benefits 43.66 43.27 0.39 
 

 

 

 

 

 

 

1112 

Table X-21 

Sensitivity Analyses
 

(Achieved mpg, Per-Vehicle Cost, Net Benefits, Fuel Saved, & CO2 Emissions Reduced) 

Cost Method and Set of Cost 

Estimates 

MY 2025 

Achieved 

mpg 

Average MY 

2025 PerVehicle 

Technology 

Cost 

MY 2017-2025 

Net Benefits, 

Discounted 3%, 

in Millions of $ 

MY 2017-

2025 Fuel 

Saved, in 

Millions of 

Gallons 

MY 2017-

2025 CO2 

Emissions 

Reduced, in 

mmT 

Passenger Cars 

ICM w/Main Analysis Costs 54.07 $1,578 $293,062 109,852 2,384 

RPE w/Main Analysis Costs 53.92 $1,943 $273,307 107,200 2,325 

ICM w/NAS Costs 52.78 $2,103 $242,912 100,496 2,155 

Light trucks 

ICM w/Main Analysis Costs 39.29 $1,226 $175,793 61,984 1,333 

RPE w/Main Analysis Costs 39.14 $1,491 $181,243 65,083 1,397 

ICM w/NAS Costs 37.71 $1,375 $154,597 56,337 1,217 

Sensitivity Analysis, Value of Statistical Life 

The value associated with preventing a fatality is measured by the Value of a Statistical Life 

(VSL), defined as the value of preventing one random fatality among a population at risk. The 

Office of Management and Budget (OMB) reviews and approves regulations issued from 

numerous agencies including DOT, EPA, OSHA, CPSC, etc., and issues guidance for agencies 

to use in analyzing the impacts of their regulations. Although OMB guidance generally seeks to 

ensure a level of consistency in the issues addressed by various regulatory agencies, OMB has 

not established a common VSL for use across all government agencies. Instead, OMB 

recommends that each agency develop and justify its own VSL. As a result, different agencies 

assign different values to saving a life in their regulations. 
 

                                                      

 

1113 

The Department of Transportation (DOT) has issued a series of guidance memos for the various 

modes within the department. In February 2008, DOT established a VSL of $5.8 million with 

supplementary calculations at $3.2 million and $8.4 million in recognition of uncertainty found 

over a range of studies (these figures are measured in 2007 dollars). NHTSA typically adds the 

economic cost of crashes to the VSL of about $300,000 to determine the comprehensive cost of 

fatal crashes. These economic costs include medical costs, legal costs, insurance administration 

costs, property damage, travel delay costs, etc. In March 2009 DOT issued updated guidance 

establishing a VSL of $6.0 million for 2009. Adjusting the economic cost portion to 2009 

economics as well produced a comprehensive costs of $6.32 million for the central analysis, and 

supplemental comprehensive costs of $3.72 and $8.92 million. These values were used in the 

NPRM, which was based on 2009 economics. The Final Rule is based on 2010 economics. 

Adjusting these comprehensive values for 2010 economics produces estimates of $6.34 million 

for the central value, with alternative values of $3.74 million and $8.94 million.610 

Within the CAFE FRIA, VSL is used for two different purposes, once to value benefits-per-ton 

from reducing emissions of criteria pollutants in Chapter VIII, and once to value potential safety 

impacts in Chapter IX. The potential safety impacts calculation is discussed outside the Volpe 

model, in order to emphasize the uncertainty surrounding this issue. It is examined separately 

and put in context of the overall net benefits derived from the Volpe model. 

The benefits-per-ton values for reducing emissions of criteria pollutants were derived by EPA for 

use by both EPA and NHTSA in this rulemaking activity. These estimates were based on an 

estimate of VSL derived previously by EPA and reported in its Guidelines for Preparing 

Economic Analyses (see Technical Support Document, Section 4.B.11.b.).611 This estimate is 

$6.3 million in 2000 dollars, which corresponds to $7.79 million when expressed in 2009 dollars, 

which was used in the sensitivity analysis for the NPRM. EPA has adjusted this value to $7.98 

million to reflect 2010 economics. NHTSA agreed to use the estimates of per-ton benefits from 

reducing air pollutant emissions derived by EPA in this rulemaking, despite their reliance on a 

VSL estimate higher than that endorsed by DOT. 

610 Note that these represent a simple average of comprehensive values calculated for crashworthiness and crash 

avoidance countermeasures. Fatality impacts result from both mass reduction and the rebound effect. The 

interaction of these two sources affects both crashworthiness and crash avoidance, although the portions of each 

impact are uncertain. Therefore, a simple average of the two estimates is used. Since the two values differ by less 

than 1%, the impact is not significant in any case. 

611 U.S. Environmental Protection Agency (U.S. EPA). 2000. Guidelines for Preparing Economic Analyses. EPA 

240-R-00-003. National Center for Environmental Economics, Office of Policy Economics and Innovation. 

Washington, DC. 
 

1114 

As noted in the DOT guidance, however, the uncertainty surrounding the VSL is notable, and 

should be recognized in regulatory analyses. Accordingly, NHTSA has prepared this sensitivity 

analysis, which examines the values of both safety mortality impact and mortality benefits from 

reducing criteria pollutant emissions under the complete range of DOT VSL values, as well as 

the EPA value. Table X-22 summarizes these estimates. The fatality impacts examined were 

derived from the scenario representing the real world scenario (credits allowed), with voluntary 

over-compliance and a 2010 baseline. As noted in the safety section, mass reduction within all 

scenarios was specifically targeted towards certain vehicle types in order to attempt to remain 

safety neutral over the 2017-2025 model year lifetimes. In this particular scenario, this produced 

a combined total of 17 fatalities prevented over the 2017-2025 period. 
                                                      

 

1115 

Table X-22 

Sensitivity Analysis of Alternate VSLs 

Preferred Alternative
 

Assumed VSL 

(2010 Dollars) Source 

Value of Fatality 

Impacts, 2017-2025, 

3% Discount Rate 

($millions) 

Value of Mortality 

Benefits from Reduced 

Emissions of Criteria 

Air Pollutants 

($millions)612 

$3.74 million DOT Lower Estimate $51 savings $960 

$6.34 million DOT Central Estimate $86 savings $1630 

$7.98 million EPA VSL Estimate $109 savings $2100 

$8.94 million DOT Upper Estimate $122 savings $2300 

As mentioned above, the safety impacts are highly uncertain and are not used in the Volpe 

model. Although the criteria pollutants benefits are used in the Volpe model, their impact is 

small. 

Sensitivity Analysis for Maximum Net Benefit and Total Costs = Total Benefits Alternatives 

In the tables above, the preferred alternative is the baseline and sensitivity analyses are compared 

to the preferred alternative. For the maximum net benefits and total cost = total benefit 

alternatives, it is more likely that the mpg level will be more affected by different assumptions 

that affect costs and benefits, due to the methodology used to determine the mpg level of those 

alternatives. Thus, this analysis compares MY 2025 passenger car, light truck and combined 

mpg levels for different sensitivity analyses (see Tables X-23a and X-23b) at a 3% discount rate. 

612 All numbers derived from 2025 impacts from EIS Table 4.2.1-8-B2, which reflects the real world scenario 

(credits allowed), with voluntary over-compliance and a 2010 baseline under a 3% discount rate. Laden et al (2006) 

values were used for this sensitivity examination. 
 

1116 

Table X-23a 

Sensitivity Analysis for Maximum Net Benefits Alternative
 

Maximum Net Benefit Passenger 

Car mpg 

Light 

Truck mpg 

Combined 

mpg 

Reference 56.5 43.7 51.5 

7% Discount Rate 54.2 43.9 50.3 

High Fuel Price 56.7 43.5 51.5 

Low Fuel Price 56.0 43.5 51.1 

5% Rebound Effect 56.5 43.7 51.5 

15% Rebound Effect 56.5 43.7 51.5 

20% Rebound Effect 56.5 43.7 51.5 

12¢/gal Military Security 

Value 56.5 43.7 51.5 

$5/ton CO2 Value 56.5 43.7 51.5 

$36/ton CO2 Value 56.5 43.7 51.5 

$68/ton CO2 Value 56.5 43.7 51.5 

Global Warming Potential 56.5 43.7 51.5 

50% Consumer Benefit 56.5 43.7 51.5 

75% Consumer Benefit 56.5 43.7 51.5 

Post-Warranty Repair Costs 56.5 43.7 51.5 

Low Battery Cost 56.5 43.7 51.5 

High Battery Cost 56.5 43.7 51.5 

Low Cost Mass Reduction 56.5 43.7 51.5 

High Cost Mass Reduction 56.6 43.6 51.5 

RPE w/Main Analysis Costs 56.4 43.6 51.4 

ICM w/NAS Costs 55.3 43.3 50.6 
 

1117 

Market-Driven Baseline 56.4 43.5 51.3 

No Shift Optimization 56.2 43.3 51.1 
 

1118 

Table X-23b 

Sensitivity Analysis for Total Cost = Total Benefit Alternative
 

Maximum Net Benefit Passenger 

Car mpg 

Light 

Truck mpg 

Combined 

mpg 

Reference 58.1 43.8 52.4 

7% Discount Rate 58.1 43.8 52.4 

High Fuel Price 58.6 43.7 52.7 

Low Fuel Price 57.7 43.7 52.1 

5% Rebound Effect 58.1 43.8 52.4 

15% Rebound Effect 58.1 43.8 52.4 

20% Rebound Effect 58.1 43.8 52.4 

12¢/gal Military Security 

Value 58.1 43.8 52.4 

$5/ton CO2 Value 58.1 43.8 52.4 

$36/ton CO2 Value 58.1 43.8 52.4 

$68/ton CO2 Value 58.1 43.8 52.4 

Global Warming Potential 58.1 43.8 52.4 

50% Consumer Benefit 58.1 43.8 52.4 

75% Consumer Benefit 58.1 43.8 52.4 

Post-Warranty Repair Costs 58.1 43.8 52.4 

Low Battery Cost 58.1 43.8 52.4 

High Battery Cost 58.1 43.8 52.4 

Low Cost Mass Reduction 58.1 43.8 52.4 

High Cost Mass Reduction 58.1 43.7 52.4 

RPE w/Main Analysis Costs 58.1 43.6 52.3 

ICM w/NAS Costs 57.2 43.6 51.8 
1119 

Market-Driven Baseline 58.1 43.7 52.4 

No Shift Optimization 57.7 43.4 52.0 
                                                       

 

 

1120 

XI. FLEXIBILITIES IN MEETING THE STANDARD 

A. The CO2 Credits and Fuel Consumption Improvement Values for Air Conditioning 

Efficiency, Off-cycle Reductions, and Full-size Pickup Trucks 

In addition to the existing statutory provisions that add various flexibilities to the CAFE 

program, today’s final rule establishes several changes to the procedures for purposes of 

calculating CAFE levels used to determine manufacturers’ compliance with CAFE standards. 

These changes provide incentives to apply specific technologies based on their potential to 

achieve fuel economy improvements not observed under current fuel economy test procedures, 

as well as “game changing” technologies for light trucks. These changes, discussed briefly here, 

are presented in detail in Section IV.I of the preamble to today’s final rule and in Chapter 5 of 

the Joint TSD. 

For the MYs 2012-2016 rule, EPA provided an option for manufacturers to generate credits for 

complying with GHG standards by incorporating efficiency-improving vehicle technologies that 

would reduce CO2 and fuel consumption from air conditioning (A/C) operation. EPA also 

provided another credit generating option for vehicle operation that is not captured by the 

Federal Test Procedure (FTP) and Highway Fuel Economy Test (HFET), collectively known as 

the “two-cycle” test procedure. EPA referred to these credits as “off-cycle credits.” See 76 FR 

74937, 74998, 75020. 

For the MYs 2017-2025 rule, EPA proposed to modify fuel economy calculation procedures 

such that if a vehicle employs technologies designated as improving A/C efficiency or otherwise 

reducing off-cycle fuel consumption, the vehicle will, for purposes of CAFE, receive a higher 

fuel economy rating than would otherwise be the case. See id. and 76 FR 74995-998. For this 

final rule, under its EPCA authority, EPA is allowing manufacturers to generate fuel 

consumption improvement values for purposes of CAFE compliance based on the use of A/C 

efficiency and the other off-cycle technologies. These fuel consumption improvement values 

will not apply to compliance with the CAFE program for MYs 2012-2016. Also, any reductions 

in leakage of HFCs from air conditioning systems, which are generally unrelated to fuel 

consumption reductions, will not apply to compliance with the CAFE program, and will continue 

to apply only to the EPA GHG program. 

NHTSA expects that, because of the increases to calculated fuel economy values available for 

improvements to the efficiency of A/C systems (up to 0.000563 gal/mi for cars and 0.000810 

gal/mi for trucks),613 manufacturers will take technological steps to maximize these benefits. 

613 Note that these are gallons per mile and not miles per gallon. The actual miles per gallon improvement depends 

upon the baseline mpg of the vehicle. 
1121 

Since we project that all manufacturers will adopt these A/C improvements to their maximum 

extent, we have also accounted for expected A/C efficiency improvements in determining the 

maximum feasible CAFE standards. Other (non-A/C) off-cycle improvements in fuel 

consumption may also be eligible to apply towards compliance with the CAFE standards, as 

discussed above; however, with two exceptions (for the two-cycle benefits of stop-start and 

active aerodynamic improvements – technologies which we expect manufacturers to adopt 

widely and whose benefits can be reliably quantified), these off-cycle improvements are not 

incorporated in the stringency of the standards. 

EPA, in coordination with NHTSA, is also introducing for MYs 2017-2025 a new incentive for 

certain advanced technologies used in full-sized pickup trucks. Under its EPCA authority for 

CAFE, EPA is establishing fuel economy improvement values for manufacturers that hybridize a 

significant quantity of their full-size pickup trucks, or that use other technologies that 

significantly improve the fuel economy of these full-sized pickup trucks. We discuss each of 

these types of incentives in detail in the Preamble and in Chapter 5 of the Joint TSD. 
 

                                                       

1122 

XII.	 PROBABILISTIC UNCERTAINTY ANALYSIS 

OMB Circular A-4 directs agencies to conduct formal probabilistic uncertainty analysis of 

complex rules where there are large, multiple uncertainties whose analysis raises technical 

challenges or where effects cascade and where the impacts of the rule exceed $1 billion. CAFE 

meets all of these criteria. This chapter identifies and quantifies the major uncertainties in the 

final regulatory impact analysis and estimates the probability distribution of the benefits, costs, 

and net benefits of the compliance options selected for the final MYs 2017-2021 passenger car 

and light truck CAFE standards and augural MYs 2022-2025 standards. Throughout the course 

of the main analysis, input values were selected from a variety of often conflicting sources. Best 

estimates were selected based on the preponderance of data and analyses available, but there is 

inevitably a level of uncertainty in these selections, particularly given the time frame of the 

rulemaking. Some of these inputs contributed less to the overall variations of the outcomes, and, 

thus, are less significant. Some inputs depend on others or are closely related (e.g., oil import 

externalities), and thus can be combined. With the vast number of uncertainties embedded in 

this regulatory analysis, this uncertainty analysis identifies only the major independent 

uncertainty factors having appreciable variability and impact on the end results and quantifies 

them by probability distributions. The values of these uncertainties are then randomly selected 

and fed back into the CAFE Compliance and Effects model (CAFE model) to determine the net 

benefits using the Monte Carlo statistical simulation technique.614 The simulation technique 

induces the probabilistic outcomes accompanied with degrees of probability or plausibility. This 

facilitates a more informed decision-making process, because it provides additional information 

about the degree to which a particular outcome is likely. Using single point estimates for a large 

number of variables in an analysis provides a very limited view of the potential results, and 

provides no measure of confidence in the estimated outcome beyond the assertion that it is the 

“most likely.” The likelihood of correctly estimating the exact total costs and benefits of a 

program as complex as CAFE, over such a long time frame, is small. But by using Monte Carlo 

simulations to explicitly consider the uncertainty around the important inputs to the analysis, 

decision-makers are able to see the probabilities associated with a large range of outcomes and 

develop confidence in achieving acceptable levels of net benefit from the existing program 

specification, even without perfect information about future conditions. 

The analysis is based on the actual processes used to derive net benefits as described in the 

previous chapters. As with the sensitivity analyses discussed in Chapter X, NHTSA utilized the 

2010 baseline fleet for the entirety of the uncertainty analysis. Each variable (e.g., cost of a 

particular technology) in the simulation model represents an uncertainty factor that would 

614 See, for example, Morgan, MG, Henrion, M, and Small M, “Uncertainty: A Guide to Dealing with Uncertainty in 

Quantitative Risk and Policy Analysis,” Cambridge University Press, 1990. 
 

                                                      

1123 

potentially alter the modeling outcomes if its value was changed. We assume that most of these 

variables are independent of each other, although similar technology costs are sampled in such a 

way that they are simultaneously at similar points in their respective cost distributions, even if 

the distributions themselves are different. For example, a single technology cost might be 

sampled as three variables based on the platform to which it is applied (e.g., midsize passenger 

car, or small light truck). The distributions of cost would be different because larger vehicles 

often have higher incremental technology costs. However, it is more likely that a single 

technology’s cost would be simultaneously higher than expected (in the central analysis) for each 

of the vehicle classes to which it is applied than be higher than expected for some classes and 

lower than expected for others. The sample design of technology costs for the final rule’s Monte 

Carlo analysis attempts to account for such similarities. The confidence intervals around the 

costs and benefits of technologies reflect independent levels of uncertainty regarding costs and 

benefits, rather than linked probabilities dependent on higher or lower quality versions of a 

specific technology. 

The uncertainties of these variables are described by appropriate probability distribution 

functions based on available data. If data are not sufficient or not available, agency staff used 

professional judgment to estimate the probability distributions of these uncertainty factors. A 

complete description of the formulas and methods used in the CAFE model is available on 

NHTSA’s website.615 

After defining and quantifying the major uncertainty factors, the next step is to run the 

simulation model many times to obtain a distribution of results rather than single-value 

estimates. In each run of the model, the 2012–2016 CAFE standards are held constant after 2016 

in the baseline run, and then the final (and augural) standards of this rule are implemented in 

2017 under the policy alternative runs. This policy environment is identical for each run in the 

simulation to ensure that variation in outcomes is a product of the relationship between the 

standards and the values of the underlying uncertainties in each case, rather than simultaneous 

changes in both uncertainties and the policy environment. The simulation process was run 

repeatedly for approximately 30,000 trials under each discount rate scenario (three and seven 

percent). Each complete run is a trial, and each trial represents a randomly generated instance of 

each included variable based on its probability distribution. The relevant variables in the 

615 2017–2025 CAFE Compliance and Effects Modeling System Documentation, Volpe Center, U.S. Dept. of 

Transportation, August 2012,. Available at http://www.nhtsa.gov/fuel-economy (last accessed Jul. 13, 2012). 
1124 

simulation model then take on the selected values from the trial, and the model simulates CAFE 

compliance, costs, and benefits. 

Simulation Models and Uncertainty Factors 

A Monte Carlo simulation was conducted using the CAFE modeling system that was developed 

to estimate the impacts of higher CAFE requirements described in previous chapters. The 

purpose of the Monte Carlo simulation was to consider simultaneous variation in the values of 

chosen uncertainty parameters and its resulting impact on key output metrics—fuel savings and 

net benefits, for example. Net benefits are the difference between (1) the total dollar value that 

would be saved in fuel costs and other benefits and (2) the total costs of the rule. 

The agency reviewed the inputs and relationships that drive the CAFE model to determine the 

factors that are the major sources of uncertainty. Several factors were identified as potentially 

contributing to uncertainty to the estimated impacts of higher CAFE standards, although not all 

were ultimately selected to be run in the simulation. In particular, the social cost of damages 

caused by criteria pollutant and greenhouse gas emissions have been omitted from the analysis, 

the latter based on guidance from the interagency working group that developed the cost 

estimates used in the central analysis. The list of included uncertainties is: 

(1) Technology costs; 

(2) Technology effectiveness; 

(3) Fuel prices; 

(4) Manufacturers’ decision to produce vehicles with fuel economies higher than the levels 

mandated by CAFE standards; 

(5) Average vehicle miles traveled per vehicle; 

(6) The passenger car share of the new vehicle market; 

(7) The value of oil consumption externalities and; 

(8) The rebound effect. 

Technology Costs 
                                                      

 

1125 

The costs incurred by manufacturers to modify their vehicles to meet new CAFE levels are 

assumed to be passed on to consumers in the form of higher new car prices. These technology 

costs are the primary determinant of the overall cost of improving fuel economy. 

Sixty-five different technologies were examined as possible methods to comply with higher 

CAFE standards. These technologies were described in Chapter V earlier in this analysis. The 

agency used what were deemed the most likely cost values in the main analysis. For the 

uncertainty analysis, the agency modeled the plausible range of costs individually for each 

technology using beta distributions with mode values equal to the corresponding technology 

costs used in the central analysis. The beta distribution was chosen to represent the higher 

probability implicit in the central values, but also recognizing that alternative values 

recommended by the National Academy of Sciences (NAS) would have some probability of 

occurring. For a variety of reasons discussed elsewhere in this analysis, the agency selected 

central values that differ from the NAS recommendations. However, one purpose of an 

uncertainty analysis is to identify plausible alternate assumptions and reflect the possibility that 

these alternative values could occur. The agency calculated the ratio of total MY 2025 costs 

under the central values used in this analysis and compared them to the alternate values based on 

NAS recommendations, and found that NAS recommended values were 1.45 times the central 

values.616 The agency created a beta model based on a mode equal to the central value, with the 

tails defined based on the average confidence intervals found in the NAS study. This 

confidence interval (18.6%) was added to the NAS relative cost. There were no confidence 

intervals provided in the FEV reports,617 which defines the mode value, so the lower tail was 

defined as the absolute value of the difference between the NAS value and its upper confidence 

interval subtracted from the central values. 

This effectively assigned a confidence interval to the central values of 27%. Within these 

parameters, the agency chose alpha and beta values of 1.8 and 3.14, respectively, to assign a 5% 

probability that values chosen would be equal to or greater than the NAS costs. The use of beta 

distributions with the above parameters allow for a range of technology costs less than those 

used in the central analysis, in-between those of the central analysis and those of the NAS study, 

and above those of the NAS study, with the greatest weight assigned around the central NPRM 

values. It should be noted that while, on average, the NAS recommended values for technology 

616 This factor reflects differences in direct technology cost estimates, indirect cost markups, and rates of learning. It 

thus represents the full range of assumptions that influence cost estimates. 617 It should be noted that, although the FEV cost study did not determine formal uncertainty ranges or confidence 

intervals, FEV did conduct sensitivity analysis for some of the technologies for which they estimated costs, focusing 

on potential changes in labor and burden rates, material costs, and mark-ups such as engineering, profit, and enditem scrappage. This analysis found, for example, that a 20 percent decrease in labor rates would yield a 3 percent 

decrease in the cost of HEV technology. 
 

1126 

costs are greater than the central NPRM values, there are cases on individual technologies where 

the NAS values are less than the central NPRM values. In these cases, the beta curve is reversed 

(beta values of 3.14 and 1.8 are used) to keep the mode at the central NPRM value and assign 

5% probability that the value chosen would be equal to or less than the NAS cost. 

Technology Effectiveness 

The modifications adopted by manufacturers to enable their vehicles to meet new CAFE levels 

will improve fuel efficiency and reduce the cost of operating the more efficient vehicles. The 

effectiveness of each technology determines how large an impact it will have towards enabling 

manufacturers to meet the higher CAFE standards, and will thus determine how much additional 

improvement is needed and which additional technologies will be required to achieve full 

compliance. In selecting the likely path that manufacturers will choose to meet CAFE, the 

CAFE model tests the interaction of technology costs and effectiveness to achieve an optimal 

(cost-minimizing) technological solution. Technology effectiveness is thus a primary 

determinant of the overall cost and benefit of improving fuel economy. 

As noted above, sixty-five different technologies were examined as possible methods to comply 

with higher CAFE standards. These technologies were described in Chapter V earlier in this 

analysis. Chapter V also summarizes the estimated range of effectiveness for these technologies. 

The agency used what were deemed the most likely effectiveness values in the main analysis. 

For the uncertainty analysis, the central NPRM value and the NAS-recommended value for 

effectiveness were used in establishing a range for variation. In many cases, the values were the 

same. In this case, a normal distribution was used and, as had been done in previous uncertainty 

analysis for CAFE rule-making, technology complexity was used to determine the standard 

deviation for the distribution. The determination of complexity was by agency expert 

professional judgment, and divided into low-complexity, medium-complexity and highcomplexity. The technologies in each category and the standard deviation for each are shown in 

the table below. 

Low Complexity Medium Complexity High Complexity 

Standard Deviation = 14.5% Standard Deviation = 29% Standard Deviation = 43.5% 

Variable Valve Timing 

(VVT) - Coupled Cam 

Phasing (CCP) on SOHC Discrete Variable Valve Lift (DVVL) on SOHC Plug-in Hybrid - 30 mi range 
 

 

 

 

1127 

Variable Valve Timing 

(VVT) - Intake Cam Phasing 

(ICP) Cylinder Deactivation on SOHC Plug-in Hybrid 

6-Speed Manual/Improved 

Internals 

Variable Valve Timing (VVT) - Dual Cam 

Phasing (DCP) 

Electric Vehicle (Early 

Adopter) - 75 mile range 

High Efficiency Gearbox 

(Manual) Discrete Variable Valve Lift (DVVL) on DOHC 

Electric Vehicle (Early 

Adopter) - 100 mile range 

Improved Auto. Trans. 

Controls/Externals Continuously Variable Valve Lift (CVVL) 

Electric Vehicle (Early 

Adopter) - 150 mile range 

6-Speed Trans with Improved 

Internals (Auto) Cylinder Deactivation on DOHC 

Electric Vehicle (Broad 

Market) - 150 mile range 

High Efficiency Gearbox 

(Auto or DCT) Stoichiometric Gasoline Direct Injection (GDI) Fuel Cell Vehicle 

Shift Optimizer Cylinder Deactivation on OHV 

Mass Reduction - Level 1 

Variable Valve Actuation - CCP and DVVL on 

OHV 

Mass Reduction - Level 2 

Stoichiometric Gasoline Direct Injection (GDI) 

on OHV 

Mass Reduction - Level 3 

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Small Displacement 

Low Rolling Resistance Tires 

- Level 3 

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Medium Displacement 

Secondary Axle Disconnect 

Turbocharging and Downsizing - Level 1 (18 

bar BMEP) - Large Displacement 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Small Displacement 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Medium Displacement 

Turbocharging and Downsizing - Level 2 (24 

bar BMEP) - Large Displacement 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Small Displacement 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Medium Displacement 
 

1128 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 1 (24 bar BMEP) - Large Displacement 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Small Displacement 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Medium Displacement 

Cooled Exhaust Gas Recirculation (EGR) - 

Level 2 (27 bar BMEP) - Large Displacement 

6-speed DCT 

8-Speed Trans (Auto or DCT) 

Mass Reduction - Level 4 

Mass Reduction - Level 5 

In cases where the NAS value did not equal the central NPRM value, a beta distribution was 

used to give a distribution which had 20% probability of being outside of the range between the 

NAS value and the central NPRM value. The beta parameters used were 1.2 and 1.055 for cases 

where the NAS value was less than the central NPRM value, and 1.1 and 1.411 for cases where 

the central NPRM value was less than the NAS value. 

Fuel Prices 

Higher CAFE standards will result in reduced gasoline consumption, which will translate into 

lower vehicle operating costs for consumers. The value of fuel saved is a direct function of fuel 

prices. Fuel prices are thus a primary determinant of the overall social benefit that will result 

from improving fuel economy. 

Forecasting gasoline prices over a long period of time is a deeply uncertain process, and this 

analysis attempts to measure impacts that occur over the approximately the next 50 years, 

because vehicles sold in MY 2025 that reach their full useful life will not be retired until after 

2060.;. In the main analysis, the agency utilized fuel price projections from the Energy 

Information Administration’s (EIA) Annual Energy Outlook 2012 (AEO) Early Release. The 

main analysis is based on the AEO 2012 Early Release Reference Case scenario, which 
 

 

 

 

 

                                                      

1129 

represents EIA’s current best estimate of future fuel prices. For the uncertainty analysis, the 

Agency examined two other scenarios based on the AEO 2012 Early Release, the Low Oil Price 

scenario (LOP) and the High Oil Price scenario (HOP).618 The LOP scenario was chosen to 

allow for the possibility that the EIA’s Reference Case predictions could overestimate the price 

of gasoline in the future. However, previous escalation in the price of gasoline resulted in prices 

that exceeded those estimated by EIA for their reference case. To reflect the possibility of 

significantly higher prices, the agency selected the HOP case, which gives the highest gasoline 

price forecasts among all AEO scenarios. 

From these forecast fuel prices, a set of distributions were made for each year (up to 2100) for 

each fuel type (gasoline, diesel, ethanol-85, electricity). The Reference case, LOP and HOP 

were, for each fuel, fit to a curve to supply a less jagged target (this reduced the annual variation 

in the projections, but preserved the long-term trend which was most relevant to this analysis), 

and a beta distribution was fit to each year for each fuel. This distribution used the curve-fitted 

Reference case as the mode and was calibrated to give approximately 12.5% probability that the 

chosen fuel price would be lower than LOP or higher than HOP. From here, a single random 

value is chosen to represent the percentile of each (annual) beta distribution, tracing out a full 

time series of fuel prices for each random draw. 

618 The AEO 2012 Early Release does not include low and high fuel price scenarios; ranges for the low and high 

scenarios were derived using an estimate of the relationship between World Oil Price and the average price of 

gasoline (and diesel). 
1130 

Figure XII-1 

Bounding Fuel Price Cases in Monte Carlo Sampling 

$1.00

$2.00

$3.00

$4.00

$5.00

$6.00

$7.00

$8.00

$9.00

$10.00

$11.00

Gasoline Price ($2010 per gallon)

Lower Bound Reference Case Upper bound

Addressing Uncertainty about the Supply of Fuel Economy Beyond the Levels Mandated 

by the Standards 

The CAFE model implicitly includes the capability to apply appropriate amounts of technology 

under varying fuel price cases by including a variable that represents manufacturers’ assumption 

about consumer willingness-to-pay for fuel economy technology. This willingness-to-pay is 

characterized as the payback period for fuel economy technology investments, meaning the 

number of years’ worth of fuel savings necessary to balance the cost of the new technology. In 

the central analysis, the model alters that variable to be zero once a manufacturer reaches 

compliance (or decides to pay fines, if they have historically done so). This means that no 

additional technology is added beyond the standards in the baseline, or in any of the other 
1131 

regulatory scenarios. For the central analysis, which uses a single fuel price projection and 

economic and technological parameter values consistent with it, the zero-year payback 

assumption is generally consistent with the collection of other assumptions. For example, 

assuming a one-year payback period (instead of zero) after compliance with 2016 standards in 

the central analysis only adds about 1 MPG to MY 2025 fuel economy in the baseline. However, 

under more extreme fuel prices, the zero-year payback assumption begins to create internally 

inconsistent results. 

To address this limitation, NHTSA has included the length of the payback period (that 

manufacturers assume consumers desire) in the uncertainty analysis. Assuming some non-zero 

payback period ensures that when fuel prices are very high, manufacturers will continue to add 

cost-effective fuel economy technologies even when the standards are not sufficient to force 

these additions. As one might expect, higher fuel prices and longer payback periods result in 

more fuel economy technology being added beyond the level mandated by the standards, while 

lower fuel prices and shorter payback periods result in less. 

 The cases that most challenge internal consistency are naturally found at the extremes, lowprice-long-payback, for example. In the low-price-long-payback case, the fuel savings would still 

be very low, technology would still not be very attractive, and only a small amount of additional 

fuel economy technology (if any at all) would be added to vehicles already in compliance. So 

one could credibly argue that there is uncertainty about the degree to which manufacturers 

understand consumers’ willingness-to-pay for fuel economy and add slightly more than would be 

demanded. 

Similarly, under the high-price-short-payback draws, fuel prices are high enough to make some 

technology additions occur in the baseline, but maybe not the ideal amount under those 

conditions because manufacturers assumed a shorter payback period than consumers have with 

high fuel prices. Since there is uncertainty about manufacturers’ ability to perfectly respond to 

consumer preferences, these draws produce results that are still plausible (if less probable than 

others). 

The payback period itself is drawn from a Poisson distribution with lambda = .85. This places 

slightly higher probability on the central analysis value of zero, with steeply decreasing 

probabilities afterward. 
 

1132 

Average Vehicle Miles Travelled Per Vehicle 

One of the most influential inputs to the CAFE model is the annual VMT schedule, which 

defines the baseline vehicle mile travelled by the average vehicle at each age of its life. Although 

the mileage accumulation schedule is based on the 2009 NHTS, a very large sample of 

households, it is still only one sample. NHTSA included uncertainty about this mileage 

accumulation schedule in the uncertainty analysis by sampling first-year VMT from a probability 

distribution and then applied the annual percentage reductions from the central analysis in each 

subsequent year of the vehicle’s life. 

NHTSA fit a distribution to the observed first-year VMT in the 2009 NHTS, then empirically 

estimated the sampling distribution of mean first-year VMT. Each instance of average first-year 

VMT in the Monte Carlo simulation is drawn from a probability distribution that was fit to the 

estimated sampling distribution of the mean (using separate distributions for passenger cars and 

light trucks). The probability distribution for the average first year passenger car VMT is 

normal, with a mean of 13,216 miles and a standard deviation of 108.3 miles. The distribution of 

average first year light truck VMT is also normal, with a mean of 14,757 miles and a standard 

deviation of 129 miles. Although these distributions produce small deviations from the mean, the 

increases (or decreases) in first-year VMT ultimately impact VMT at every age of the vehicle’s 

life. As in the central analysis, NHTSA incorporates the impact of fleet vehicle operations on 

average VMT by averaging their estimated usage into the value obtained by the random draw. 

The Passenger Car Share of the New Vehicle Market 

The agencies rely on outputs from the Energy Information Administration’s NEMS model to 

derive estimates of total annual light-duty vehicle sales and sales by regulatory class for all 

future model years. Continuing to use the static market forecast based on the NEMS run that 

underlies the central analysis could lead to implausible results under varying combinations of 

input parameters, because changing the values of any of the factors that influence that forecast 

would be likely to change the forecast as well. To address this limitation, NHTSA investigated 

the transportation module in NEMS to better understand the underlying equation that takes total 

new vehicle sales and distributes them to vehicle classes. The annual share of passenger cars in 

NEMS is determined by a difference equation that considers the historic car share, per capita 
                                                      

 

1133 

income, fuel price, average car horsepower, average car weight, vehicle fuel economy, and an 

autocorrelation coefficient to account for time series influences. 

Since all of those variables are either implicitly included in the CAFE model, or simulated as 

part of the Monte Carlo analysis, NHTSA was able to address uncertainty about the passenger 

car share of the new vehicle market by adding a new relationship to the model rather than adding 

a new uncertainty parameter to the sample. NHTSA used the NEMS run that informs the central 

analysis to develop a approximation of the relationship between passenger car share and the 

variables described above. Incorporating this relationship into the CAFE model ensures that the 

passenger car share in any trial is consistent with the other values drawn for that trial, and that 

the resulting passenger car share is consistent with the logic used to develop the passenger car 

share in the central analysis. This endogenous relationship only appears in the version of the 

CAFE model that was used for the Monte Carlo analysis — the central analysis still relies upon a 

static forecast for both the main analysis and all sensitivity runs. 

Oil Consumption Externalities 

Reduced fuel consumption can benefit society by lowering the world market price for oil, 

reducing the threat of petroleum supply disruptions, reducing the cost of military operations 

related to the security of international oil production, distribution, and maintenance and operation 

of the strategic petroleum reserve. These benefits are called “externalities” because they are not 

reflected directly in the market price of fuel. A full description of these externalities is included 

in Chapter VIII under “Other Economic Benefits from Reducing Petroleum Use.” These factors 

increase the net social benefits from reduced fuel consumption. Although they represent a 

relatively small portion of overall social benefits, there is a significant level of uncertainty as to 

their values.619 

Monopsony costs represent the reduced value of payments from U.S. oil purchasers to foreign oil 

suppliers that results when lower U.S. oil demand reduces the world price of petroleum, beyond 

619 For reasons noted in Chapter VIII, the agency opted not to conduct uncertainty analysis surrounding the military 

security externality. While there is uncertainty regarding the value of the military security externality, the agency 

believes that U.S. military expenditures are unlikely to be directly influenced by this rule. 
                                                      

1134 

the savings from reduced purchases of petroleum itself.620 However, consistency with NHTSA’s 

use of estimates of the global benefits from reducing emissions of CO2 and other greenhouse 

gases in this analysis requires the use of a global perspective for assessing their net value. From 

this perspective, reducing these payments simply results in a transfer of resources from foreign 

oil suppliers to U.S. purchasers (or more properly, in a savings in the value of resources 

previously transferred from U.S. purchasers to foreign producers), and provides no real savings 

in resources to the global economy. Thus NHTSA’s analysis of the benefits from adopting 

higher CAFE standards for MY 2017-2025 cars and light trucks excludes the reduced value of 

monopsony payments by U.S. oil consumers that might result from lower fuel consumption by 

these vehicles, and they are likewise not included in the uncertainty analysis. 

The second component of external economic costs imposed by U.S. petroleum imports arises 

because an increase in oil prices triggered by a disruption in the supply of imported oil reduces 

the level of output that the U.S. economy can produce. The reduction in potential U.S. economic 

output depends on the extent and duration of the increases in petroleum product prices that result 

from a disruption in the supply of imported oil, as well as on whether and how rapidly these 

prices return to pre-disruption levels. Even if prices for imported oil return completely to their 

original levels, however, economic output will be at least temporarily reduced from the level that 

would have been possible without a disruption in oil supplies. It is estimated that each gallon of 

fuel saved that results in a reduction in U.S. petroleum imports (either crude petroleum or refined 

fuel) will reduce the expected costs of oil supply disruptions to the U.S. economy by $0.097 to 

$0.297, with the actual value most likely to be $0.197 per gallon. The uncertainty analysis draws 

samples from a normal distribution with a mean of $0.197 and a standard deviation of $0.05, 

developed so that the upper and lower bounds of the estimated range occur two standard 

deviations from the mean. 

The Rebound Effect 

By reducing the amount of gasoline used and, thus, the cost of operating a vehicle, higher CAFE 

standards are expected to result in a slight increase in annual miles driven per vehicle. This 

“rebound effect” impacts net societal benefits because the increase in miles driven offsets a 

620 The reduction in payments from U.S. oil purchasers to domestic petroleum producers is not included as a benefit, 

since it represents a transfer that occurs entirely within the U.S. economy. 
 

 

 

 

 

 

1135 

portion of the gasoline savings that results from more fuel-efficient vehicles. Although 

consumers derive value from this extra driving, it also leads to increases in crashes, congestion, 

noise, and pollution costs associated with driving. As Table XII-1 illustrates, most recent 

estimates of the magnitude of the rebound effect for light duty vehicles fall in the range of 15-20 

percent (i.e., increasing vehicle use will offset 15-20 percent of the fuel savings resulting from an 

improvement in fuel economy), but studies also show that the rebound effect has been gradually 

decreasing over time. On this basis, the agency employed a rebound effect of 10 percent in the 

main analysis. A more complete discussion of the rebound effect is included in Chapter VIII. 

For the uncertainty analysis, a range of 5 to 30 percent was used and employed in a slightly 

skewed beta distribution which produced a mean of approximately 14.2 percent. The skewed 

distribution reflects the agency’s belief that the more credible studies that differ from the 10 

percent value chosen for the main analysis fall below this value (i.e., are more negative) and 

differ by more substantial margins than the upper range of credible values. Table XII-2 

summarizes the economic parameters used in the uncertainty analysis. 

Table XII-1 

Summary Statistics for Estimates of the Rebound Effect 

Category of Estimates Number of 

Studies 

Number of 

Estimates 

Range Distribution 

Low High Median Mean Std. Dev. 

All Estimates 22 66 7% 75% 22% 23% 14% 

Published Estimates 17 50 7% 75% 22% 24% 14% 

U.S. Time-Series Data 7 34 7% 45% 14% 18% 9% 

Household Survey Data 13 23 9% 75% 31% 31% 16% 

Pooled U.S. State Data 2 9 8% 58% 22% 25% 14% 

Constant Rebound Effect (1) 15 37 7% 75% 20% 23% 16% 

Variable Rebound Effect: (1) 10 29 10% 45% 23% 23% 10% 
 

 

1136 

Table XII-2 

Economic Parameters in the Monte Carlo Analysis 

Discount Rates (%) 0.03, 0.07 

Fuel Path Randomization Parameter 

Uniform distribution range (0,1) 

Rebound Effect Randomization Parameters 

Beta Distribution, Alpha Shape 1.50 

Beta Distribution, Beta Shape 3.00 

Scale -0.25 

Base -0.05 

Price Shock Randomization Parameters 

Normal Distribution, Mean $0. 197 

Normal Distribution, Standard Deviation $0.05 

Payback Period Uncertainty 

Poisson Distribution, lambda shape 0.85 
 

 

 

1137 

Modeling Results – Trial Draws 

Because of the complexity of the CAFE model, the computer time required to perform the 

uncertainty analysis was significant. The uncertainty analysis conducted a total of 60,000 trials 

(30,000 for each discount rate). Figures XII-2 through XII-11 graphically illustrate the draw 

results for a selected sample of the 137 variables (65 technology effectiveness rates, 65 

technology costs, fuel price series, oil import externalities, length of payback period for 

additional fuel savings, first-year VMT (by regulatory class), and the rebound effect) that were 

examined. 

Although the full uncertainty ranges for all technologies are presented in Table XII-3 and XII-4, 

the agency chose to graphically highlight a subset of these technologies in Figure XII-2 through 

XII-7. These technologies were selected for illustrative purposes due to their high penetration 

rates and due to their importance as enablers of the preferred alternative. 
 

1138 

Figure XII-2 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

$255 $257 $258 $260 $261 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) - Medium Displacement 

Frequency Cumulative % 

Monte Carlo Draw Profile, Combined Fleet, Costs
 

Figure XII-3 

Monte Carlo Draw Profile, Combined Fleet, Effectiveness
 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

500 

1000 

1500 

2000 

2500 

-0.008 0.008 0.025 0.041 0.058 

Turbocharging and Downsizing - Level 2 (24 bar 

BMEP) - Medium Displacement 

Frequency Cumulative % 
1139 

Figure XII-4
 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

$1.58 $1.59 $1.61 $1.62 $1.64 

Shift Optimizer 

Frequency Cumulative % 

Monte Carlo Draw Profile, Combined Fleet, Costs
 

Figure XII-5
 

Monte Carlo Draw Profile, Combined Fleet, Effectiveness
 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

500 

1000 

1500 

2000 

2500 

0.02 0.03 0.03 0.04 0.05 

Shift Optimizer 

Frequency Cumulative % 
 

1140 

Figure XII-6
 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

-$2,002 -$772 $458 $1,688 $2,918 

Strong Hybrid - Level 1 

Frequency Cumulative % 

Monte Carlo Draw Profile, Combined Fleet, Costs
 

Figure XII-7
 

Monte Carlo Draw Profile, Combined Fleet, Effectiveness
 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

100 

200 

300 

400 

500 

600 

700 

800 

-0.023 -0.005 0.013 0.031 0.049 

Strong Hybrid - Level 1 

Frequency Cumulative % 
 

1141 

Figure XII-8 

Monte Carlo Draw Profile 

Pretax Fuel Price Path 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

140% 

0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

$2.47 $2.71 $2.95 $3.19 $3.42 $3.66 $3.90 $4.13 $4.37 $4.61 

Gasoline Price Estimates 2017 

Frequency Cumulative % 

Figure XII-9 

Monte Carlo Draw Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

140% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

-0.29 -0.27 -0.24 -0.22 -0.19 -0.17 -0.14 -0.12 -0.09 -0.07 

Rebound Effect 

Frequency Cumulative % 
1142 

Figure XII-10 

Monte Carlo Draw Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

140% 

0 

500 

1000 

1500 

2000 

2500 

-$0.04 $0.01 $0.05 $0.10 $0.15 $0.20 $0.24 $0.29 $0.34 $0.39 

Price Shock Cost 

Frequency Cumulative % 
1143 

Table XII-3 

Monte Carlo Draw Results, Combined Fleet, Technology Costs 

Technology Distribution α Shape 

Parameter 

β Shape 

Parameter 

Low Value 

Low Friction Lubricants - Level 1 Beta 1.8 3.14 2.7386283 Engine Friction Reduction - Level 1 Beta 1.8 3.14 14.547884 

Low Friction Lubricants and Engine Friction Reduction - Level 2 Beta 1.8 3.14 13.708552 

Variable Valve Timing (VVT) - Coupled Cam Phasing (CCP) on SOHC Beta 1.8 3.14 41.923728 

Discrete Variable Valve Lift (DVVL) on SOHC Beta 1.8 3.14 33.064626 

Cylinder Deactivation on SOHC Beta 1.8 3.14 -74.25367 

Variable Valve Timing (VVT) - Intake Cam Phasing (ICP) Beta 1.8 3.14 41.923728 

Variable Valve Timing (VVT) - Dual Cam Phasing (DCP) Beta 1.8 3.14 38.563648 Discrete Variable Valve Lift (DVVL) on DOHC Beta 1.8 3.14 33.064626 Continuously Variable Valve Lift (CVVL) Beta 1.8 3.14 61.546277 

Cylinder Deactivation on DOHC Beta 1.8 3.14 -74.25367 

Stoichiometric Gasoline Direct Injection (GDI) Beta 1.8 3.14 58.8416 Cylinder Deactivation on OHV Beta 1.8 3.14 105.31028 

Variable Valve Actuation - CCP and DVVL on OHV Beta 1.8 3.14 50.936136 

Stoichiometric Gasoline Direct Injection (GDI) on OHV Beta 3.14 1.8 53.222227 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement Beta 3.14 1.8 376.70283 

621 Note, for the Low, High and Mode values: These values are only given as estimates. They were generated from averages over all tec

data. Rather than the values shown here, the model receives as inputs an index where 1.0 = the mode value. 
1144 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement Beta 3.14 1.8 -209.89942 

Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement Beta 3.14 1.8 524.71386 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement Beta 1.8 3.14 13.964956 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement Beta 1.8 3.14 230.03571 

Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement Beta 1.8 3.14 387.75822 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement Beta 1.8 3.14 264.93308 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement Beta 1.8 3.14 264.93308 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement Beta 1.8 3.14 264.93308 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement Beta 1.8 3.14 467.50209 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement Beta 1.8 3.14 467.50209 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement Beta 3.14 1.8 -344.95423 

Advanced Diesel - Small Displacement Beta 1.8 3.14 835.62872 

Advanced Diesel - Medium Displacement Beta 3.14 1.8 846.37148 Advanced Diesel - Large Displacement Beta 1.8 3.14 1651.4607 6-Speed Manual/Improved Internals Beta 1.8 3.14 234.95286 

High Efficiency Gearbox (Manual) Beta 1.8 3.14 218.90336 Improved Auto. Trans. Controls/Externals Beta 1.8 3.14 52.382421 

6-Speed Trans with Improved Internals (Auto) Beta 1.8 3.14 -180.87206 6-speed DCT Beta 3.14 1.8 -61.336479 

8-Speed Trans (Auto or DCT) Beta 1.8 3.14 184.89548 High Efficiency Gearbox (Auto or DCT) Beta 1.8 3.14 218.90336 

Shift Optimizer Beta 1.8 3.14 1.4557074 
1145 

Electric Power Steering Improved Accessories - Level 1 Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) 12V Micro-Hybrid (Stop-Start) Integrated Starter Generator Strong Hybrid - Level 1 Conversion from SHEV1 to SHEV2 Strong Hybrid - Level 2 Plug-in Hybrid - 30 mi range Mass Reduction - Level 1 Mass Reduction - Level 2 Mass Reduction - Level 3 Mass Reduction - Level 4 Mass Reduction - Level 5 Low Rolling Resistance Tires - Level 1 Low Rolling Resistance Tires - Level 2 Low Rolling Resistance Tires - Level 3 Low Drag Brakes Secondary Axle Disconnect Aero Drag Reduction, Level 1 Aero Drag Reduction, Level 2 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta 

Beta Beta Beta Beta 

Beta 

Beta 

Beta 

Beta 

Beta Beta 

1.8 

1.8 

3.14 

1.8 

1.8 

3.14 

1.8 

3.14 

3.14 

1.8 

1.8 1.8 1.8 1.8 

1.8 

3.14 

1.8 

1.8 

1.8 1.8 

3.14

3.14

1.8 

3.14

3.14

1.8 

3.14 

1.8 

1.8 

3.14 

3.14 3.14 3.14 3.14 

3.14 

1.8 

3.14

3.14 

3.143.14

 87.391493

 68.504232

53.15804

 119.24381

 711.89927

-1959.6721

1123.7961 

-1849.0735 

5335.4639 

-0.8142845

-0.3709052 

0.0095596 0.2816568 0.5213845 

-3.0180253

52.703973

 64.370593

82.193257 

 36.696475 131.17966

 

 

 

 

 

 

 

 

 

 

  
Std Dev Indexed α Shape β Shape 

Technology Distribution (in 0:1 Low Value Mode Mean Parameter Parameter 

range) 

Low Friction Lubricants - Level 1 Beta 1.2 1.0549956 0.004375 0.0066054 

Beta 1.2 1.0549956 0.0113021 0.0231732 

Engine Friction Reduction - Level 1 Low Friction Lubricants and Engine Beta 1.1 1.4108074 0.0101395 0.0133455 Friction Reduction - Level 2 Variable Valve Timing (VVT) - Coupled Normal 1 0.145 Cam Phasing (CCP) on SOHC 

Discrete Variable Valve Lift (DVVL) on Normal 1 0.29 SOHC Cylinder Deactivation on SOHC Normal 1 0.29 

Variable Valve Timing (VVT) - Intake Normal 1 0.145 Cam Phasing (ICP) Variable Valve Timing (VVT) - Dual Cam Normal 1 0.29 Phasing (DCP) Discrete Variable Valve Lift (DVVL) on Normal 1 0.29 DOHC Continuously Variable Valve Lift (CVVL) Normal 1 0.29 

Cylinder Deactivation on DOHC Normal 1 0.29 Stoichiometric Gasoline Direct Injection Normal 1 0.29 (GDI) Cylinder Deactivation on OHV Normal 1 0.29 

1146 

Table XII-4 

Monte Carlo Draw Results, Combined Fleet, Fuel Economy Improvement Rates 
1147 

Variable Valve Actuation - CCP and DVVL on OHV Normal 1 0.29 Stoichiometric Gasoline Direct Injection (GDI) on OHV Normal 1 0.29 Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Small Displacement Normal 1 0.29 Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Medium Displacement Normal 1 0.29 Turbocharging and Downsizing - Level 1 (18 bar BMEP) - Large Displacement Normal 1 0.29 Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Small Displacement Normal 1 0.29 Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Medium Displacement Normal 1 0.29 Turbocharging and Downsizing - Level 2 (24 bar BMEP) - Large Displacement Normal 1 0.29 Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Small Displacement 

Normal 1 0.29 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Medium Displacement 

Normal 1 0.29 

Cooled Exhaust Gas Recirculation (EGR) - Level 1 (24 bar BMEP) - Large Displacement 

Normal 1 0.29 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Small Displacement 

Normal 1 0.29 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Medium Displacement 

Normal 1 0.29 
1148 

Cooled Exhaust Gas Recirculation (EGR) - Level 2 (27 bar BMEP) - Large Displacement 

Normal 1 0.29 

Advanced Diesel - Small Displacement Beta 1.1 1.4108074 0.0357976 0.0479829 

Advanced Diesel - Medium Displacement Beta 1.1 1.4108074 0.0357976 0.0479829 

Advanced Diesel - Large Displacement Beta 1.1 1.4108074 0.0357976 0.0405367 

6-Speed Manual/Improved Internals Normal 1 0.145 

High Efficiency Gearbox (Manual) Normal 1 0.145 

Improved Auto. Trans. Controls/Externals Normal 1 0.145 

6-Speed Trans with Improved Internals (Auto) Normal 1 0.145 6-speed DCT Normal 1 0.29 

8-Speed Trans (Auto or DCT) Normal 1 0.29 High Efficiency Gearbox (Auto or DCT) Normal 1 0.145 

Shift Optimizer Normal 1 0.145 

Electric Power Steering Beta 1.1 1.4108074 0.0107917 0.0130838 

Improved Accessories - Level 1 Beta 1.2 1.0549956 0.00875 0.0120124 

Improved Accessories - Level 2 (w/ Alternator Regen and 70% efficient alternator) 

Beta 1.2 1.0549956 0.002625 0.01954 

12V Micro-Hybrid (Stop-Start) Beta 1.1 1.4108074 0.0170219 0.0202968 
1149 

Integrated Starter Generator Beta 1.1 1.4108074 0.0555699 0.060814 

Strong Hybrid - Level 1 Beta 1.2 1.0549956 -0.0216179 0.0415055 

Conversion from SHEV1 to SHEV2 Beta 1.1 1.4108074 0.1118695 0.1233505 

Strong Hybrid - Level 2 Beta 1.2 1.0549956 -0.0245667 0.0084411 

Plug-in Hybrid - 30 mi range Normal 1 0.435 Mass Reduction - Level 1 Normal 1 0.145 Mass Reduction - Level 2 Normal 1 0.145 Mass Reduction - Level 3 Normal 1 0.145 Mass Reduction - Level 4 Normal 1 0.29 

Mass Reduction - Level 5 Normal 1 0.29 

Low Rolling Resistance Tires - Level 1 Beta 1.1 1.4108074 0.016625 0.0177751 

Low Rolling Resistance Tires - Level 2 Beta 1.2 1.0549956 0.0169643 0.0216479 

Low Rolling Resistance Tires - Level 3 Normal 1 0.145 

Low Drag Brakes Beta 1.1 1.4108074 0.007 0.007832 

Secondary Axle Disconnect Normal 1 0.145 Aero Drag Reduction, Level 1 Beta 1.2 1.0549956 0.013125 0.0231252 

Aero Drag Reduction, Level 2 Beta 1.1 1.4108074 0.0214944 0.0244414 
 

                                                      

 

 

1150 

Modeling Results – Output 

Tables XII-5, XII-6, and XII-7 summarize the modeling results for fuel saved, total costs, 

societal benefits, and net benefits for passenger cars and trucks, respectively, under a 7% 

discount rate. They also indicate the probability that net benefits exceed zero. Tables XII-8, 

XII-9, and XII-10 summarize these same results under a 3 percent discount rate. These results 

are also illustrated in Figures XII-11 through XII-14 for the combined fleet under the Preferred 

Alternative at the 7 percent discount rate for MY 2025. Although not shown here, the general 

shapes of the resulting output distributions are similar for the light trucks, for the 3 percent 

discount rate, and for other model years as well. The following discussions summarize the range 

of results presented in these tables for the combined passenger car and light truck fleets across 

both the 7 percent (typically the lower range) and 3 percent (typically upper range) discount 

rates.622 

Fuel Savings:

623 The analysis indicates that MY 2017 vehicles (both passenger cars and light 

trucks) will experience between -166 million and 20,142 million gallons of fuel savings over 

their useful lifespan. Negative fuel savings imply greater fuel consumption under the standards 

than in the baseline (for the same trial). MY 2018 vehicles will experience between 494 million 

and 34,380 million gallons of fuel savings over their useful lifespan. MY 2019 vehicles will 

experience between 743 million and 56,991 million gallons of fuel savings over their useful 

lifespan. MY 2020 vehicles will experience between 559 million and 77,193 million gallons of 

fuel savings over their useful lifespan. MY 2021 vehicles will experience between 732 million 

and 99,094 million gallons of fuel savings over their useful lifespan. MY 2022 vehicles will 

experience between 911 million and 108,747 million gallons of fuel savings over their useful 

lifespan. MY 2023 vehicles will experience between 972 million and 120,468 million gallons of 

fuel savings over their useful lifespan. MY 2024 vehicles will experience between 964 million 

and 134,279 million gallons of fuel savings over their useful lifespan. MY 2025 vehicles will 

experience between 1032 million and 144,463 million gallons of fuel savings over their useful 

lifespan. 

Over the combined lifespan of the nine model years, between -627 and 805,278 million gallons 

of fuel will be saved. 

622 In a few cases the upper range results were obtained from the 7% rate and the lower range results were obtained 

from the 3% rate. While this may seem counterintuitive, it results from the random selection process that is inherent 

in the Monte Carlo technique.

623 Note that Chapter XII of the PRIA erroneously listed fuel savings 1,000 times greater than expected. This error 

was fixed for the FRIA. 
1151 

Total Costs: The analysis indicates that owners of MY 2017 passenger cars and light trucks will 

pay between -$47 million and $6,800 million in higher vehicle prices to purchase vehicles with 

improved fuel efficiency. MY 2018 owners will pay between -$43 million and $9,020 million 

more. MY 2019 owners will pay between -$66 million and $15,119 million more. MY 2020 

owners will pay between $99 million and $19,516 million more. MY 2021 owners will pay 

between $106 million and $26,253 million more. MY 2022 owners will pay between $25 

million and $29,752 million more. MY 2023 owners will pay between $26 million and $39,275 

million more. MY 2024 owners will pay between -$76 million and $48,809 million more. MY 

2025 owners will pay between -$40 million and $51,977 million more. 

Across all nine model years combined, owners will pay between $0.2 billion and $246.5 billion 

in higher vehicle prices to purchase vehicles with improved fuel efficiency. 

Net of Societal Costs and Benefits: The analysis indicates that changes to passenger cars and 

light trucks to meet the CAFE standards for each of the nine model years covered by this rule 

will produce overall net societal costs and benefits in the following ranges: 

 MY 2017: Between -$229 million and $22,544 million 

 MY 2018: Between $470 million and $37,580 million 

 MY 2019: Between $716 million and $62,293 million 

 MY 2020: Between $398 million and $86,184 million 

 MY 2021: Between $679 million and $109,215 million 

 MY 2022: Between $921 million and $120,015 million 

 MY 2023: Between $970 million and $134,972 million 

 MY 2024: Between $991 million and $149,797 million 

 MY 2025: Between $1,002 million and $162,174 million 

Over the combined lifespan of the nine model years, net social benefits valued between $5.9 

billion and $884.8 billion will be produced. 

Net Benefits: The uncertainty analysis indicates that the net impact of the higher CAFE 

requirements for MY 2017 passenger cars and light trucks will be between a net cost of $1,021 

million and a net benefit of $18,396 million. Assuming a 7 percent discount rate, there is a 99.6 

percent certainty that changes made to the MY 2017 passenger car fleet to achieve the CAFE 
1152 

standards will produce a net benefit. For light trucks, this value is 97.2 percent. Assuming a 3 

percent discount rate, these values are 99.9 percent and 97.4 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2018 will be between a net cost of 

$717 million and a net benefit of $31,733 million. Assuming a 7 percent discount rate, there is a 

98.5 percent certainty that changes made to the MY 2018 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 99.7 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2019 will be between a net cost of 

$1,622 million and a net benefit of $53,503 million. Assuming a 7 percent discount rate, there is 

a 97.8 percent certainty that changes made to the MY 2019 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 99.3 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2020 will be between a net cost of 

$1,947 million and a net benefit of $86,184 million. Assuming a 7 percent discount rate, there is 

a 97.4 percent certainty that changes made to the MY 2020 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 99.0 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2021 will be between a net cost of 

$4,774 million and a net benefit of $95,398 million. Assuming a 7 percent discount rate, there is 

a 96.8 percent certainty that changes made to the MY 2021 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 99.0 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2022 will be between a net cost of 

$6,817 million and a net benefit of $104,740 million. Assuming a 7 percent discount rate, there 

is a 96.3 percent certainty that changes made to the MY 2022 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 98.8 percent and 100 percent, respectively. 
                           

                             

        

 

1153 

The net impact of the higher CAFE requirements for MY 2023 will be between a net cost of 

$12,900 million and a net benefit of $119,058 million. Assuming a 7 percent discount rate, there 

is a 93.9 percent certainty that changes made to the MY 2023 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 97.7 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2024 will be between a net cost of 

$18,421 million and a net benefit of $132,130 million. Assuming a 7 percent discount rate, there 

is a 89.6 percent certainty that changes made to the MY 2024 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 95.2 percent and 100 percent, respectively. 

The net impact of the higher CAFE requirements for MY 2025 will be between a net cost of 

$21,051 million and a net benefit of $143,774 million. Assuming a 7 percent discount rate, there 

is an 88.9 percent certainty that changes made to the MY 2025 passenger car fleet to achieve the 

CAFE standards will produce a net benefit. For light trucks, this value is 100 percent. Assuming 

a 3 percent discount rate, these values are 94.6 percent and 100 percent, respectively. 

Over all nine model years, the higher CAFE standards will produce a net impact ranging from a 

net cost of $69.3 billion to a net benefit of $774.7 billion. There is at least a 99.5 percent 

certainty that higher CAFE standards will produce a net societal benefit in each of the combined 

fleet model years covered by this rule. 

Keeping with our presentation conventions when both costs and benefits are presented on the

same table and combined, costs are displayed as parenthesized values to aid the reader in

following the summation logic.
1154 

Table XII-5 

UNCERTAINTY ANALYSIS RESULTS, PASSENGER CARS
 

(7% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 6,094 -35 12,822 

Total Cost ($mill.) ($2,879) (-$5) ($6,353) 

Social Benefits ($mill.) $7,051 -$49 $14,547 

Net Benefits ($mill.) $4,166 -$1,143 $11,330 

% Certainty Net Ben. > 0 99.6% 

MY 2018 

Fuel Saved (mill. gall) 8,718 -7 18,919 

Total Cost ($mill.) ($4,340) ($24) ($8,196) 

Social Benefits ($mill.) $9,548 -$118 $20,187 

Net Benefits ($mill.) $5,193 -$2,509 $15,316 

% Certainty Net Ben. > 0 98.5% 

MY 2019 

Fuel Saved (mill. gall) 13,317 56 27,286 

Total Cost ($mill.) ($6,335) ($18) ($12,296) 

Social Benefits ($mill.) $14,277 -$249 $28,780 

Net Benefits ($mill.) $7,767 -$4,117 $22,105 

% Certainty Net Ben. > 0 97.8% 

MY 2020 

Fuel Saved (mill. gall) 17,151 -199 34,855 

Total Cost ($mill.) ($8,298) ($68) ($14,617) 

Social Benefits ($mill.) $18,272 -$342 $37,350 

Net Benefits ($mill.) $9,709 -$5,192 $29,759 
1155 

% Certainty Net Ben. > 0 97.4% 

MY 2021 

Fuel Saved (mill. gall) 20,522 -283 41,831 

Total Cost ($mill.) ($10,310) ($107) ($20,891) 

Social Benefits ($mill.) $21,563 -$587 $44,153 

Net Benefits ($mill.) $10,903 -$7,790 $34,320 

% Certainty Net Ben. > 0 96.8% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 22,858 112 45,533 

Total Cost ($mill.) ($11,599) ($122) ($23,709) 

Social Benefits ($mill.) $23,998 -$316 $48,215 

Net Benefits ($mill.) $11,962 -$10,926 $37,758 

% Certainty Net Ben. > 0 96.3% 

MY 2023 

Fuel Saved (mill. gall) 25,251 66 50,648 

Total Cost ($mill.) ($13,168) ($146) ($29,662) 

Social Benefits ($mill.) $26,118 -$1,712 $53,547 

Net Benefits ($mill.) $12,417 -$19,390 $42,110 

% Certainty Net Ben. > 0 93.9% 

MY 2024 

Fuel Saved (mill. gall) 28,533 -54 55,300 

Total Cost ($mill.) ($15,993) ($74) ($36,930) 

Social Benefits ($mill.) $29,101 -$3,869 $57,986 

Net Benefits ($mill.) $12,514 -$32,331 $45,247 
 

1156 

% Certainty Net Ben. > 0 89.6% 

MY 2025 

Fuel Saved (mill. gall) 30,718 -446 59,285 

Total Cost ($mill.) ($16,918) (-$13) ($38,633) 

Social Benefits ($mill.) $30,767 -$8,651 $61,616 

Net Benefits ($mill.) $13,198 -$41,163 $48,328 

% Certainty Net Ben. > 0 88.9% 
1157 

Table XII-6 

UNCERTAINTY ANALYSIS RESULTS, LIGHT TRUCKS
 

(7% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 1,107 -1,509 4,680 

Total Cost ($mill.) ($430) (-$708) ($1,692) 

Social Benefits ($mill.) $1,301 -$1,867 $5,492 

Net Benefits ($mill.) $870 -$1,307 $4,198 

% Certainty Net Ben. > 0 97.2% 

MY 2018 

Fuel Saved (mill. gall) 3,507 -507 8,350 

Total Cost ($mill.) ($643) (-$615) ($1,964) 

Social Benefits ($mill.) $4,593 -$530 $10,471 

Net Benefits ($mill.) $3,949 -$184 $9,648 

% Certainty Net Ben. > 0 100.0% 

MY 2019 

Fuel Saved (mill. gall) 8,113 369 17,890 

Total Cost ($mill.) ($1,460) (-$535) ($3,734) 

Social Benefits ($mill.) $10,524 $571 $22,122 

Net Benefits ($mill.) $9,019 $393 $20,606 

% Certainty Net Ben. > 0 100.0% 

MY 2020 

Fuel Saved (mill. gall) 11,879 428 25,755 

Total Cost ($mill.) ($2,292) (-$379) ($6,368) 

Social Benefits ($mill.) $15,456 $640 $31,275 

Net Benefits ($mill.) $13,078 $441 $28,903 
1158 

% Certainty Net Ben. > 0 100.0% 

MY 2021 

Fuel Saved (mill. gall) 16,828 172 35,962 

Total Cost ($mill.) ($3,349) (-$310) ($8,790) 

Social Benefits ($mill.) $21,936 $439 $44,408 

Net Benefits ($mill.) $18,469 $269 $40,986 

% Certainty Net Ben. > 0 100.0% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 18,815 265 39,098 

Total Cost ($mill.) ($3,659) (-$312) ($9,689) 

Social Benefits ($mill.) $24,612 $2 $48,176 

Net Benefits ($mill.) $20,813 $139 $44,390 

% Certainty Net Ben. > 0 100.0% 

MY 2023 

Fuel Saved (mill. gall) 21,994 284 43,902 

Total Cost ($mill.) ($4,098) (-$251) ($10,824) 

Social Benefits ($mill.) $29,009 $76 $54,509 

Net Benefits ($mill.) $24,741 -$158 $50,443 

% Certainty Net Ben. > 0 100.0% 

MY 2024 

Fuel Saved (mill. gall) 24,935 518 49,093 

Total Cost ($mill.) ($4,506) (-$371) ($12,845) 

Social Benefits ($mill.) $33,148 $692 $61,436 

Net Benefits ($mill.) $28,445 $347 $56,938 
 

1159 

% Certainty Net Ben. > 0 100.0% 

MY 2025 

Fuel Saved (mill. gall) 28,102 777 53,978 

Total Cost ($mill.) ($4,815) (-$465) ($15,492) 

Social Benefits ($mill.) $37,660 $866 $66,344 

Net Benefits ($mill.) $32,627 $569 $61,515 

% Certainty Net Ben. > 0 100.0% 
1160 

Table XII-7 

UNCERTAINTY ANALYSIS RESULTS, PASSENGER CARS AND LIGHT TRUCKS
 

(7% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 7,201 -130 15,775 

Total Cost ($mill.) ($3,309) (-$47) ($6,800) 

Social Benefits ($mill.) $8,352 -$171 $17,945 

Net Benefits ($mill.) $5,036 -$1,021 $13,899 

% Certainty Net Ben. > 0 99.7% 

MY 2018 

Fuel Saved (mill. gall) 12,225 494 26,877 

Total Cost ($mill.) ($4,983) ($43) ($9,020) 

Social Benefits ($mill.) $14,140 $470 $29,848 

Net Benefits ($mill.) $9,142 -$717 $24,006 

% Certainty Net Ben. > 0 100.0% 

MY 2019 

Fuel Saved (mill. gall) 21,431 743 44,448 

Total Cost ($mill.) ($7,796) ($66) ($15,119) 

Social Benefits ($mill.) $24,800 $716 $49,374 

Net Benefits ($mill.) $16,787 -$1,622 $40,674 

% Certainty Net Ben. > 0 100.0% 

MY 2020 

Fuel Saved (mill. gall) 29,029 559 60,125 

Total Cost ($mill.) ($10,589) ($99) ($19,516) 

Social Benefits ($mill.) $33,728 $398 $68,247 

Net Benefits ($mill.) $22,787 -$1,947 $58,180 
1161 

% Certainty Net Ben. > 0 99.9% 

MY 2021 

Fuel Saved (mill. gall) 37,349 732 77,035 

Total Cost ($mill.) ($13,659) ($106) ($26,253) 

Social Benefits ($mill.) $43,499 $679 $86,347 

Net Benefits ($mill.) $29,372 -$4,774 $72,828 

% Certainty Net Ben. > 0 99.9% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 41,674 911 84,434 

Total Cost ($mill.) ($15,258) ($25) ($29,752) 

Social Benefits ($mill.) $48,610 $921 $94,784 

Net Benefits ($mill.) $32,775 -$6,817 $79,879 

% Certainty Net Ben. > 0 99.9% 

MY 2023 

Fuel Saved (mill. gall) 47,245 972 93,472 

Total Cost ($mill.) ($17,265) ($26) ($39,275) 

Social Benefits ($mill.) $55,127 $970 $106,531 

Net Benefits ($mill.) $37,158 -$12,900 $91,037 

% Certainty Net Ben. > 0 99.8% 

MY 2024 

Fuel Saved (mill. gall) 53,468 964 103,982 

Total Cost ($mill.) ($20,499) (-$76) ($48,809) 

Social Benefits ($mill.) $62,250 $991 $118,049 

Net Benefits ($mill.) $40,958 -$18,421 $100,862 
 

1162 

% Certainty Net Ben. > 0 99.5% 

MY 2025 

Fuel Saved (mill. gall) 58,820 1,032 111,686 

Total Cost ($mill.) ($21,733) (-$40) ($51,977) 

Social Benefits ($mill.) $68,427 $1,002 $127,583 

Net Benefits ($mill.) $45,825 -$21,051 $109,697 

% Certainty Net Ben. > 0 99.6% 

Combining MY 2017-2025 

Total Benefits at 7% discount rate: Societal benefits will total $6.0 billion to $698.7 billion, with a 

mean estimate of $358.9 billion. 

Total Costs at 7% discount rate: Costs will total between $0.2 billion and $246.5 billion, with a 

mean estimate of $115.1 billion. 
1163 

Table XII-8 

UNCERTAINTY ANALYSIS RESULTS, PASSENGER CARS
 

(3% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 7,753 -43 16,333 

Total Cost ($mill.) ($2,879) (-$5) ($6,353) 

Social Benefits ($mill.) $8,789 -$60 $18,231 

Net Benefits ($mill.) $5,901 -$648 $14,908 

% Certainty Net Ben. > 0 99.9% 

MY 2018 

Fuel Saved (mill. gall) 11,097 -8 24,090 

Total Cost ($mill.) ($4,340) ($24) ($8,196) 

Social Benefits ($mill.) $11,893 -$148 $25,285 

Net Benefits ($mill.) $7,534 -$1,604 $20,410 

% Certainty Net Ben. > 0 99.7% 

MY 2019 

Fuel Saved (mill. gall) 16,965 73 34,786 

Total Cost ($mill.) ($6,335) ($18) ($12,296) 

Social Benefits ($mill.) $17,789 -$308 $36,080 

Net Benefits ($mill.) $11,222 -$2,959 $29,296 

% Certainty Net Ben. > 0 99.3% 

MY 2020 

Fuel Saved (mill. gall) 21,865 -264 44,479 

Total Cost ($mill.) ($8,298) ($68) ($14,617) 

Social Benefits ($mill.) $22,775 -$441 $46,859 

Net Benefits ($mill.) $14,122 -$3,990 $39,143 
% Certainty Net Ben. > 0 99.0% 

MY 2021 

Fuel Saved (mill. gall) 26,166 -371 53,436 

Total Cost ($mill.) ($10,310) ($107) ($20,891) 

Social Benefits ($mill.) $26,868 -$748 $55,435 

Net Benefits ($mill.) $16,089 -$6,546 $45,395 

% Certainty Net Ben. > 0 99.0% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 29,156 144 58,226 

Total Cost ($mill.) ($11,599) ($122) ($23,709) 

Social Benefits ($mill.) $29,906 -$409 $60,560 

Net Benefits ($mill.) $17,722 -$9,215 $49,861 

% Certainty Net Ben. > 0 98.8% 

MY 2023 

Fuel Saved (mill. gall) 32,224 86 64,808 

Total Cost ($mill.) ($13,168) ($146) ($29,662) 

Social Benefits ($mill.) $32,555 -$2,030 $67,323 

Net Benefits ($mill.) $18,673 -$17,159 $55,594 

% Certainty Net Ben. > 0 97.7% 

MY 2024 

Fuel Saved (mill. gall) 36,440 -78 70,884 

Total Cost ($mill.) ($15,993) ($74) ($36,930) 

Social Benefits ($mill.) $36,304 -$4,495 $73,015 

Net Benefits ($mill.) $19,515 -$31,218 $59,948 

1164 
 

1165 

% Certainty Net Ben. > 0 95.2% 

MY 2025 

Fuel Saved (mill. gall) 39,267 -577 76,120 

Total Cost ($mill.) ($16,918) (-$13) ($38,633) 

Social Benefits ($mill.) $38,416 -$9,845 $77,724 

Net Benefits ($mill.) $20,631 -$41,679 $64,078 

% Certainty Net Ben. > 0 94.6% 
1166 

Table XII-9 

UNCERTAINTY ANALYSIS RESULTS, LIGHT TRUCKS
 

(3% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 1,425 -1,948 6,036 

Total Cost ($mill.) ($430) (-$708) ($1,692) 

Social Benefits ($mill.) $1,640 -$2,359 $6,940 

Net Benefits ($mill.) $1,209 -$1,800 $5,647 

% Certainty Net Ben. > 0 97.4% 

MY 2018 

Fuel Saved (mill. gall) 4,522 -655 10,794 

Total Cost ($mill.) ($643) (-$615) ($1,964) 

Social Benefits ($mill.) $5,805 -$667 $13,318 

Net Benefits ($mill.) $5,162 -$321 $12,495 

% Certainty Net Ben. > 0 100.0% 

MY 2019 

Fuel Saved (mill. gall) 10,464 472 23,137 

Total Cost ($mill.) ($1,460) (-$535) ($3,734) 

Social Benefits ($mill.) $13,296 $724 $28,135 

Net Benefits ($mill.) $11,776 $592 $26,587 

% Certainty Net Ben. > 0 100.0% 

MY 2020 

Fuel Saved (mill. gall) 15,329 554 33,365 

Total Cost ($mill.) ($2,292) (-$379) ($6,368) 

Social Benefits ($mill.) $19,533 $806 $39,800 

Net Benefits ($mill.) $17,125 $625 $37,373 
1167 

% Certainty Net Ben. > 0 100.0% 

MY 2021 

Fuel Saved (mill. gall) 21,730 221 46,611 

Total Cost ($mill.) ($3,349) (-$310) ($8,790) 

Social Benefits ($mill.) $27,729 $570 $56,562 

Net Benefits ($mill.) $24,222 $405 $53,057 

% Certainty Net Ben. > 0 100.0% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 24,313 344 50,735 

Total Cost ($mill.) ($3,659) (-$312) ($9,689) 

Social Benefits ($mill.) $31,124 -$3 $61,414 

Net Benefits ($mill.) $27,276 $138 $57,521 

% Certainty Net Ben. > 0 100.0% 

MY 2023 

Fuel Saved (mill. gall) 28,442 369 57,102 

Total Cost ($mill.) ($4,098) (-$251) ($10,824) 

Social Benefits ($mill.) $36,705 $92 $69,568 

Net Benefits ($mill.) $32,377 -$30 $65,370 

% Certainty Net Ben. > 0 100.0% 

MY 2024 

Fuel Saved (mill. gall) 32,272 671 63,891 

Total Cost ($mill.) ($4,506) (-$371) ($12,845) 

Social Benefits ($mill.) $41,969 $876 $78,509 

Net Benefits ($mill.) $37,197 $562 $73,854 
 

1168 

% Certainty Net Ben. > 0 100.0% 

MY 2025 

Fuel Saved (mill. gall) 36,405 1,011 70,444 

Total Cost ($mill.) ($4,815) (-$465) ($15,492) 

Social Benefits ($mill.) $47,715 $1,100 $84,998 

Net Benefits ($mill.) $42,605 $803 $80,003 

% Certainty Net Ben. > 0 100.0% 
1169 

Table XII-10 

UNCERTAINTY ANALYSIS RESULTS, PASSENGER CARS AND LIGHT TRUCKS
 

(3% Discount Rate) 

Item Mean Low High 

MY 2017 

Fuel Saved (mill. gall) 9,179 -166 20,142 

Total Cost ($mill.) ($3,309) (-$47) ($6,800) 

Social Benefits ($mill.) $10,429 -$229 $22,544 

Net Benefits ($mill.) $7,110 -$562 $18,396 

% Certainty Net Ben. > 0 99.9% 

MY 2018 

Fuel Saved (mill. gall) 15,619 637 34,380 

Total Cost ($mill.) ($4,983) ($43) ($9,020) 

Social Benefits ($mill.) $17,698 $592 $37,580 

Net Benefits ($mill.) $12,695 $65 $31,733 

% Certainty Net Ben. > 0 100.0% 

MY 2019 

Fuel Saved (mill. gall) 27,429 959 56,991 

Total Cost ($mill.) ($7,796) ($66) ($15,119) 

Social Benefits ($mill.) $31,084 $903 $62,293 

Net Benefits ($mill.) $22,997 -$455 $53,503 

% Certainty Net Ben. > 0 100.0% 

MY 2020 

Fuel Saved (mill. gall) 37,194 716 77,193 

Total Cost ($mill.) ($10,589) ($99) ($19,516) 

Social Benefits ($mill.) $42,307 $496 $86,184 

Net Benefits ($mill.) $31,247 -$399 $75,938 
1170 

% Certainty Net Ben. > 0 100.0% 

MY 2021 

Fuel Saved (mill. gall) 47,896 943 99,094 

Total Cost ($mill.) ($13,659) ($106) ($26,253) 

Social Benefits ($mill.) $54,597 $862 $109,215 

Net Benefits ($mill.) $40,310 -$2,155 $95,398 

% Certainty Net Ben. > 0 100.0% 

Item Mean Low High 

MY 2022 

Fuel Saved (mill. gall) 53,468 1,174 108,747 

Total Cost ($mill.) ($15,258) ($25) ($29,752) 

Social Benefits ($mill.) $61,030 $1,158 $120,015 

Net Benefits ($mill.) $44,998 -$3,345 $104,740 

% Certainty Net Ben. > 0 100.0% 

MY 2023 

Fuel Saved (mill. gall) 60,665 1,256 120,468 

Total Cost ($mill.) ($17,265) ($26) ($39,275) 

Social Benefits ($mill.) $69,260 $1,224 $134,972 

Net Benefits ($mill.) $51,050 -$11,945 $119,058 

% Certainty Net Ben. > 0 100.0% 

MY 2024 

Fuel Saved (mill. gall) 68,712 1,252 134,279 

Total Cost ($mill.) ($20,499) (-$76) ($48,809) 

Social Benefits ($mill.) $78,273 $1,260 $149,797 

Net Benefits ($mill.) $56,712 -$12,965 $132,130 
1171 

% Certainty Net Ben. > 0 99.8% 

MY 2025 

Fuel Saved (mill. gall) 75,673 1,326 144,463 

Total Cost ($mill.) ($21,733) (-$40) ($51,977) 

Social Benefits ($mill.) $86,131 $1,276 $162,174 

Net Benefits ($mill.) $63,237 -$16,623 $143,774 

% Certainty Net Ben. > 0 99.8% 

Combining MY 2017-2025 

Total Benefits at 3% discount rate: Societal benefits will total $7.5 billion to $884.8 billion, with a 

mean estimate of $330.4 billion. 

Total Costs at 3% discount rate: Costs will total between $0.2 billion and $246.5 billion, with a 

mean estimate of $115.1 billion. 
 

1172 

FIGURE XII-11 

Model Output Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

2000 

3,215 23,150 43,085 63,020 82,955 102,890 

Combined: Fuel Savings for "Preferred Alternative" 

(2025) at 7% Discount Rate 

Frequency Cumulative % 

FIGURE XII-12 

Model Output Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

2000 

3,535 26,350 49,165 71,980 94,795 117,610 

Combined: Social Benefits for "Preferred Alternative" 

(2025) at 7% Discount Rate 

Frequency Cumulative % 
 

1173 

FIGURE XII-13 

Model Output Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

500 

1000 

1500 

2000 

2500 

795 10,200 19,605 29,010 38,415 47,820 

Combined: Technology Cost for "Preferred 

Alternative" (2025) at 7% Discount Rate 

Frequency Cumulative % 

FIGURE XII-14 

Model Output Profile 

0% 

20% 

40% 

60% 

80% 

100% 

120% 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

2000 

-18,630 4,950 28,530 52,110 75,690 99,270 

Combined: Net Benefits for "Preferred Alternative" 

(2025) at 7% Discount Rate 

Frequency Cumulative % 
1174 

XIII.	 REGULATORY FLEXIBILITY ACT AND UNFUNDED MANDATES 

REFORM ACT ANALYSIS 

A. Regulatory Flexibility Act 

The Regulatory Flexibility Act of 1980 (5 U.S.C §601 et seq.) requires agencies to evaluate the 

potential effects of their proposed and final rules on small business, small organizations and 

small Government jurisdictions. 

5 U.S.C §603 requires agencies to prepare and make available for public comments initial and 

final regulatory flexibility analysis (RFA) describing the impact of proposed and final rules on 

small entities. Section 603(b) of the Act specifies the content of a RFA. Each RFA must 

contain: 

1.	 A description of the reasons why action by the agency is being considered; 

2.	 A succinct statement of the objectives of, and legal basis for a final rule; 

3.	 A description of and, where feasible, an estimate of the number of small entities to which 

the final rule will apply; 

4.	 A description of the projected reporting, recording keeping and other compliance 

requirements of a final rule including an estimate of the classes of small entities which 

will be subject to the requirement and the type of professional skills necessary for 

preparation of the report or record; 

5.	 An identification, to the extent practicable, of all relevant Federal rules which may 

duplicate, overlap or conflict with the final rule; 

6.	 Each final regulatory flexibility analysis shall also contain a description of any significant 

alternatives to the final rule which accomplish the stated objectives of applicable statutes 

and which minimize any significant economic impact of the final rule on small entities. 

1. Description of the reason why action by the agency is being considered 

NHTSA is issuing this final rule to improve vehicle fuel economy. 

2. Objectives of, and legal basis for, the final rule 
 

 

 

1175 

The Energy Independence and Security Act (EISA) mandates the setting of separate standards 

for passenger cars and for light trucks at levels sufficient to ensure that the average fuel economy 

of the combined fleet of all passenger cars and light trucks sold by all manufacturers in the U.S. 

in model year 2020 equals or exceeds 35 miles per gallon. 

3. Description and estimate of the number of small entities to which the final rule will apply 

The final rule will affect motor vehicle manufacturers. There is only one light truck 

manufacturer of electric vehicles that is a small business. However, there are nine domestically 

owned small passenger car manufacturers. 

Business entities are defined as small business using the North American Industry Classification 

System (NAICS) code, for the purpose of receiving Small Business Administration assistance. 

One of the criteria for determining size, as stated in 13 CFR 121.201, is the number of employees 

in the firm. For establishments primarily engaged in manufacturing or assembling automobiles, 

light and heavy duty trucks, buses, motor homes, or motor vehicle body manufacturing, the firm 

must have less than 1,000 employees to be classified as a small business. 

We believe that the rulemaking would not have a significant economic impact on the small 

vehicle manufacturers because under Part 525, passenger car manufacturers making less than 

10,000 vehicles per year can petition NHTSA to have alternative standards set for those 

manufacturers. Those manufacturers that currently don’t meet the required levels for their 

footprint can petition the agency for relief. If the standard is raised, it has no meaningful impact 

on these manufacturers; they still must go through the same process and petition for relief. Other 

small manufacturers (e.g. Tesla and Fisker) make electric vehicles or hybrid vehicles that will 

pass the final rule. 

Currently, there are ten small passenger car motor vehicle manufacturers in the United States. 

Table X1II-1 provides information about the 10 small domestic manufacturers in MY 2010. All 

are small manufacturers, having much less than 1,000 employees. 
 

 

 

 

 

 

1176 

Table XIII-1
 

Small Vehicle Domestic Manufacturers 

Manufacturer Employees Estimated Sales Sale Price Range Est. Revenues* 

Carbon Motor1 NA NA NA NA 

CODA2 150 NA $44,900** NA 

Fisker Automotive Inc.3 NA 15,000 $80,000 $1,200,000,000 

GGT Electric 

Mosler Automotive 25 20 $189,000 $3,780,000 

Panoz Auto 

Development Company 

50 150 $90,000 to $125,000 $16,125,000 

Saleen 170 1,000 

16*** 

$39,000 to $59,000 

$585,000 

$144,355,000 

Shelby American, Inc4 44 60 $42,000 to $135,000 $5,310,000 

Standard Taxi5 35 80 $25,000 $2,000,000 

Tesla Motors, Inc. 250 2,000 $50,000 to $100,000 $150,000,000 

1.	 Designs, manufactures, and sells law enforcement patrol vehicles 

2.	 Designs, manufactures, and sells electric vehicles. 

3.	 A joint venture of Quantum Fuel Systems Technologies Worldwide, Inc, and Fisker Coachbuild, 

LLC. The company is just starting. These are planned sales. 

4.	 A division of Carroll Shelby International, Inc. 

5.	 A subsidiary of Vehicle Production Group LLC (VPG). VPG has 35 employees. 

* Assuming an average sales price from the sales price range 

** Before the $8,000 federal tax credit and state incentives 

*** Ford Mustang Conversions 
 

 

1177 

The agency has not analyzed the impact of the final rule on these small manufacturers 

individually. However, assuming those that do not meet the final rule would petition the agency, 

rather than meet the final rule, the cost is not expected to be substantial. 

4. A description of the projected reporting, record keeping and other compliance requirements of 

a final rule including an estimate of the classes of small entities which will be subject to the 

requirement and the type of professional skills necessary for preparation of the report or record. 

This final rule includes no new requirements for reporting, record keeping of other compliance 

requirements. 

5. An identification, to the extent practicable, of all relevant Federal rules which may duplicate, 

overlap, or conflict with the final rule 

EPA and NHTSA are requiring joint final rules which complement each other. We know of no 

other Federal rules which duplicate, overlap, or conflict with the final rule. 

6. A description of any significant alternatives to the final rule which accomplish the stated 

objectives of applicable statutes and which minimize any significant economic impact of the 

final rule on small entities. 

The agencies have analyzed 10 different alternative levels of fuel economy and have provided a 

number of flexibilities. However, there are no other alternatives that can achieve the stated 

objectives without installing fuel economy technologies into the vehicle that could significantly 

minimize the impact on small entities. 

B. Unfunded Mandates Reform Act 

Section 202 of the Unfunded Mandates Reform Act of 1995 (UMRA) requires Federal agencies 

to prepare a written assessment of the costs, benefits, and other effects of a proposed or final rule 

that includes a Federal mandate likely to result in the expenditure by State, local, or tribal 

governments, in the aggregate, or by the private sector, of more than $100 million in any one 

year (adjusted for inflation with base year of 1995). Adjusting this amount by the gross domestic 

product price deflator for 2010 results in $136 million (111/81.606 = 1.36). Before promulgating 

a rule for which a written statement is needed, section 205 of UMRA generally requires NHTSA 
1178 

to identify and consider a reasonable number of regulatory alternatives and to 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 NHTSA to adopt an alternative other than the least costly, most 

cost-effective, or least burdensome alternative if the agency publishes with the final rule an 

explanation why that alternative was not adopted. 

This final rule will not result in the expenditure by State, local, or tribal governments, in the 

aggregate, of more than $136 million annually, but it will result in the expenditure of that 

magnitude by vehicle manufacturers and/or their suppliers. NHTSA considered a variety of 

alternative average fuel economy standards lower and higher than the final rule, as well as 

flexibilities for the manufacturers to comply with the final rule. NHTSA is statutorily required to 

set standards at the maximum feasible level achievable by manufacturers based on its 

consideration and balancing of relevant factors and has concluded that the fuel economy 

standards are the maximum feasible standards for the passenger car and light truck fleets for 

MYs 2017-2025 in light of the statutory considerations.