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11-1

Chapter 11: Results of the Preferred and Alternative

Standards

The heavy-duty truck segment is very complex. The sector consists of a diverse group of 

impacted parties, including engine manufacturers, chassis manufacturers, truck manufacturers, 

trailer manufacturers, truck fleet owners and the public. The proposed standards are largely

shaped to optimize the environmental and fuel savings benefits of the program, while balancing 

the relevant statutory factors and respecting the unique and varied nature of the sector. In 

developing this proposed rulemaking, we considered a number of alternatives that could result in 

fewer or potentially greater GHG and fuel consumption reductions than the preferred alternative. 

This section summarizes the alternatives we considered and presents assessments of technology

costs, CO2 reductions, and fuel savings associated with each alternative. See the preamble for a 

discussion of how the agencies balanced the relevant statutory factors to select the preferred 

alternative.

For this rule, the agencies conducted coordinated and complementary analyses by

employing both DOT’s CAFE model and EPA’s MOVES model. These models were used to 

project fuel consumption and GHG emissions impacts resulting from the proposed 

standards. The agencies used EPA’s MOVES model to estimate fuel consumption and emissions 

impacts for tractor-trailers (including the engines which power the vehicle), and vocational 

vehicles (including the engine which powers the vehicle). For heavy-duty pickups and vans, the 

agencies performed complementary analyses using the CAFE model (“Method A”) and the 

MOVES model (“Method B”) to estimate fuel consumption and emissions from these vehicles. 

For both methods, the agencies analyzed the impact of the proposed rules, relative to two 

different reference cases – less dynamic and more dynamic. The less dynamic baseline projects 

very little improvement in new vehicles in the absence of new Phase 2 standards. In contrast, the 

more dynamic baseline projects more improvements in vehicle fuel efficiency. See Chapter 5 for 

a discussion of the EPA’s MOVES model (which was used for both methods) and Chapter 10 for 

discussion of the DOT’s CAFE model (which was used for Method A).

11.1 What Are the Alternatives that the Agencies Considered?

The five alternatives below represent a broad range of potential stringency levels, and 

thus a broad range of associated technologies, costs and benefits for a HD vehicle fuel efficiency

and GHG emissions program.

In developing alternatives, NHTSA must consider EISA's requirement for the MD/HD 

fuel efficiency program noted above. 49 U.S.C. 32902(k)(2) and (3) contain the following three 

requirements specific to the MD/HD vehicle fuel efficiency improvement program: (1) The 

program must be “designed to achieve the maximum feasible improvement”; (2) the various 

required aspects of the program must be appropriate, cost-effective, and technologically feasible 

for MD/HD vehicles; and (3) the standards adopted under the program must provide not less than 

four model years of lead time and three model years of regulatory stability. In considering these 

various requirements, NHTSA will also account for relevant environmental and safety 

considerations.
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11-2

Each of the alternatives presented by NHTSA and EPA represents, in part, a different 

way the agencies could establish a HD program pursuant to EISA and the CAA. The agencies

are proposing Alternative 3. The alternatives below represent a broad range of approaches under 

consideration for finalizing the HD vehicle fuel efficiency and GHG emissions standards. 

Sections 11.1.1 through 11.2 summarize the alternatives that were analyzed and how they

were modeled. See Section 11.3 for details about the technology mix projected for each 

alternative and each regulatory category. 

11.1.1 Alternative 1: No Action (the Baseline for Phase 2)

OMB guidance regarding regulatory analysis indicates that proper evaluation of the 

benefits and costs of regulations and their alternatives requires agencies to identify a baseline:

“You need to measure the benefits and costs of a rule against a baseline. This 

baseline should be the best assessment of the way the world would look absent the 

proposed action. The choice of an appropriate baseline may require 

consideration of a wide range of potential factors, including:

• evolution of the market,

• changes in external factors affecting expected benefits and costs,

• changes in regulations promulgated by the agency or other government entities, 

and

• the degree of compliance by regulated entities with other regulations.

It may be reasonable to forecast that the world absent the regulation will 

resemble the present. If this is the case, however, your baseline should reflect the 

future effect of current government programs and policies. For review of an 

existing regulation, a baseline assuming no change in the regulatory program 

generally provides an appropriate basis for evaluating regulatory alternatives. 

When more than one baseline is reasonable and the choice of baseline will 

significantly affect estimated benefits and costs, you should consider measuring 

benefits and costs against alternative baselines. In doing so you can analyze the 

effects on benefits and costs of making different assumptions about other 

agencies’ regulations, or the degree of compliance with your own existing rules.

In all cases, you must evaluate benefits and costs against the same baseline. You 

should also discuss the reasonableness of the baselines used in the sensitivity 

analyses. For each baseline you use, you should identify the key uncertainties in 

your forecast.”1

A no-action alternative is also required as a baseline against which to measure 

environmental impacts of the proposed standards and alternatives. NHTSA, as required by the 

National Environmental Policy Act, is documenting these estimated impacts in the draft EIS 

published with this NPRM.2
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The No Action Alternative for today’s analysis, alternatively referred to as the “baseline” 

or “reference case,” assumes that the agencies would not issue new rules regarding MD/HD fuel 

efficiency and GHG emissions. That is, this alternative assumes that the Phase 1 MD/HD fuel 

efficiency and GHG emissions program’s model year 2018 standards would be extended 

indefinitely and without change.

The agencies recognize that there are a number of factors that create uncertainty in 

projecting a baseline against which to compare the future effects of the proposed action and the 

remaining alternatives. The composition of the future fleet—such as the relative position of 

individual manufacturers and the mix of products they each offer—cannot be predicted with 

certainty at this time. As reflected, in part, by the market forecast underlying the agencies’ 

analysis, we anticipate that the baseline market for medium- and heavy-duty vehicles will 

continue to evolve within a competitive market that responds to a range of factors. Additionally, 

the heavy-duty vehicle market is diverse, as is the range of vehicle purchasers. 

Heavy-duty vehicle manufacturers have reported that their customers’ purchasing 

decisions are influenced by their customers’ own determinations of minimum total cost of 

ownership, which can be unique to a particular customer’s circumstances. For example, some 

customers (e.g., less-than-truckload or package delivery operators) operate their vehicles within a 

limited geographic region and typically own their own vehicle maintenance and repair centers 

within that region. These operators tend to own their vehicles for long time periods, and 

sometimes for the entire service life of the vehicle. Their total cost of ownership is influenced by 

their ability to better control their own maintenance costs, and thus they can afford to consider 

fuel efficiency technologies that have longer payback periods, outside of the vehicle 

manufacturer’s warranty period. Other customers (e.g. truckload or long-haul operators) tend to 

operate cross-country, and thus must depend upon truck dealer service centers for repair and 

maintenance. Some of these customers tend to own their vehicles for about four to seven years, 

so that they typically do not have to pay for repair and maintenance costs outside of either the 

manufacturer’s warranty period or some other extended warranty period. Many of these 

customers tend to require seeing evidence of fuel efficiency technology payback periods on the 

order of 18 to 24 months before seriously considering evaluating a new technology for potential 

adoption within their fleet (NAS 2010, Roeth et al. 2013, Klemick et al. 2014). Purchasing 

decisions, however, are not based exclusively on payback period, but also include the 

considerations discussed in this section. For the baseline analysis, the agencies use payback 

period as a proxy for all of these considerations, and therefore the payback period for the 

baseline analysis is shorter than the payback period industry uses as a threshold for the further 

consideration of a technology. 

Purchasers of HD pickups and vans that want better fuel efficiency will demand that fuel 

consumption improvements pay back within approximately one to three years, but not all 

purchasers fall into this category. Some HD pickup and van owners accrue relatively few 

vehicle miles traveled per year, such that they may be less likely to adopt new fuel efficiency 

technologies, while other owners who use their vehicle(s) with greater intensity may be even 

more willing to pay for fuel efficiency improvements. Regardless of the type of customer, their 

determination of minimum total cost of ownership involves the customer balancing their own 

unique circumstances with a heavy-duty vehicle’s initial purchase price, availability of credit and 

lease options, expectations of vehicle reliability, resale value and fuel efficiency technology
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11-4

payback periods. The degree of the incentive to adopt additional fuel efficiency technologies also 

depends on customer expectations of future fuel prices, which directly impacts customer 

expectations of the payback period.

Another factor the agencies considered is that other federal and state-level policies and 

programs are specifically aimed at stimulating fuel efficiency technology development and 

deployment. Particularly relevant to this sector are DOE’s 21st Century Truck Partnership, 

EPA’s voluntary SmartWay Transport program, and California’s AB32 fleet requirements.3,4,5 

The future availability of more cost-effective technologies to reduce fuel consumption could 

provide manufacturers an incentive to produce more fuel-efficient medium- and heavy-duty 

vehicles, which in turn could provide customers an incentive to purchase these vehicles. The 

availability of more cost-effective technologies to reduce fuel consumption could also lead to a 

substitution of less cost-effective technologies, where overall fuel efficiency could remain fairly

flat if buyers are less interested in fuel consumption improvements than in reduced vehicle 

purchase prices and/or improved vehicle performance and/or utility.

Although we have estimated the cost and efficacy of fuel-saving technologies assuming 

performance and utility will be held constant, some uncertainty remains regarding whether these 

conditions will actually be observed. In particular, we have assumed payload will be preserved 

(and possibly improved via reduced vehicle curb weight); however, some fuel-saving 

technologies, such as natural gas fueled vehicles and hybrid electric vehicles, could reduce 

payload via increased curb weight due to the fuel tanks or added electrical machine, batteries and 

controls. It is also possible that under extended high power demand resulting from a vehicle 

towing up a road grade, certain types of hybrid powertrains could experience a temporary loss of 

towing capacity if the capacity of the hybrid’s energy storage device (e.g., batteries, hydraulic 

accumulator) is insufficient for the extended power demand. We have also assumed that fuelsaving technologies will be no more or less reliable than technologies already in production. 

However, if manufacturers pursue risky technologies or if the agencies provide insufficient leadtime to fully develop new technologies, they could prove to be less reliable, perhaps leading to 

increased repair costs and out-of-service time. This was observed as an unintended consequence 

of certain manufacturers’ initial introduction of certain emissions control technologies to meet 

EPA’s most stringent heavy-duty engine standards. If the fuel-saving technologies considered 

here ultimately involve similar reliability problems, overall costs will be greater than we have 

estimated. We have assumed drivers will be as accepting of new fuel-saving technologies as 

they are of technologies already in service. However, drivers could be less accepting of newer 

technologies -- particularly any which must be deployed manually. Except for increased costs to 

replace more efficient tires, we have assumed that routine maintenance costs will not increase or 

decrease. However, maintenance of new technologies could involve unique tools and parts. 

Therefore, maintenance costs could increase, and maintenance could involve increased vehicle 

out-of-service time. On the other hand new technologies can sometimes prove to be more 

reliable and require less maintenance than the technologies they replace. One example of this is 

the auxiliary power unit (APU) frequently installed on heavy-duty sleeper cab tractors. In the 

past these have been typically powered by small nonroad diesel engines that can require more 

frequent maintenance than the main engine of the tractor itself. However, more recently, as 

electric battery technology has advanced, some tractor manufacturers have introduced battery

APUs instead of engine-driven APUs. A comparison of recent sales of small engine driven 

APUs versus battery APUs suggests that customers may prefer battery APUs6, and some 
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operators and tractor dealerships have also told the agencies that the decrease in routine 

maintenance was an important factor in purchase decisions in favor of battery APUs. Again, 

insofar as these unaccounted-for costs or savings actually occur, overall costs could be larger or 

smaller than we have estimated. We have also applied the EIA’s AEO estimates of future fuel 

prices; however, heavy-duty vehicle customers could have different expectations about future

fuel prices, and could therefore be more inclined or less inclined to apply new technology to 

reduce fuel consumption than might be expected based on EIA’s forecast. We expect that 

vehicle customers will be uncertain about future fuel prices, and that this uncertainty will be 

reflected in the degree of enthusiasm to apply new technology to reduce fuel consumption.

Considering all of these factors, the agencies have approached the definition of the No 

Action Alternative separately for each vehicle and engine category covered by today’s proposal.

For trailers, the agencies considered two No Action alternatives to cover a nominal range 

of uncertainty. The trailer category is unique in the context of this rulemaking because it is the 

only heavy-duty category not regulated under Phase 1. In both No Action cases, the agencies 

projected that the combination of EPA’s voluntary SmartWay program, DOE’s 21st Century

Truck Partnership, California’s AB32 trailer requirements for fleets, and the potential for 

significantly reduced operating costs should result in continuing improvement to new trailers. 

Taking this into account, the agencies project that in 2018, 50 percent of new 53’ dry van and 

reefer trailers would have technologies qualifying for the SmartWay label (5 percent 

aerodynamic improvements and lower rolling resistance tires) and 50 percent would have 

automatic tire inflation systems to maintain optimal tire pressure. We also project that adoption 

of those same technologies would increase 1 percent per year until each technology is being used 

on 60 percent of new trailers. In the first case, Alternative 1a, this means that the agencies 

project that in the absence of new standards, the new trailer fleet technology would stabilize in 

2027 to a level of 60 percent adoption in 2027 for the No Action alternative. In the second case, 

Alternative 1b, the agencies projected that the fraction of the in-use fleet qualifying for 

SmartWay would continue to increase beyond 2027 as older trailers are replaced by newer 

trailers. We projected that these improvements would continue until 2040 when 75 percent of 

new trailers would be assumed to include skirts.

For vocational vehicles, the agencies considered one No Action alternative. For the 

vocational vehicle category the agencies recognized that these vehicles tend to operate over 

fewer vehicle miles travelled per year. Therefore, the projected payback periods for fuel 

efficiency technologies available for vocational vehicles are generally longer than the payback 

periods the agencies consider likely to lead to their adoption based solely on market forces. This 

is especially true for vehicles used in applications in which the vehicle operation is secondary to 

the primary business of the company using the vehicle. For example, since the fuel consumption 

of vehicles used by utility companies to repair power lines would generally be a smaller cost 

relative to the other costs of repairing lines, fuel saving technologies would generally not be as 

strongly demanded for such vehicles. Thus, the agencies project that fuel-saving technologies 

would either not be applied or only be applied as a substitute for more expensive fuel efficiency

technologies, except as necessitated by the Phase 1 fuel consumption and GHG standards. 

For tractors, the agencies considered two No Action alternatives to cover a nominal range 

of uncertainty. For Alternative 1a the agencies project that fuel-saving technologies would either 
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not be applied or only be applied as a substitute for more expensive fuel efficiency technologies 

to tractors (thereby enabling manufacturers to offer tractors that are less expensive to purchase), 

except as necessitated by the Phase 1 fuel consumption and GHG standards. In Alternative 1b 

the agencies estimated that some available technologies would save enough fuel to pay back 

fairly quickly – within the first six months of ownership. The agencies considered a range of 

information to formulate these two baselines for tractors.

Both public7and confidential historical information shows that tractor trailer fuel 

efficiency improved steadily through improvements in engine efficiency and vehicle 

aerodynamics over the past 40 years, except for engine efficiency which decreased or was flat 

between 2000 and approximately 2007 as a consequence of incorporating technologies to meet 

engine emission regulations. Today vehicle manufacturers, the Federal Government, academia 

and others continue to invest in research to develop fuel efficiency improving technologies for 

the future.

There is also evidence that manufacturers have, in the past, applied technologies to 

improve fuel efficiency absent a regulatory requirement to do so. Some manufacturers have 

even taken regulatory risk in order to increase fuel efficiency; in the 1990s, when fuel was 

comparatively inexpensive, some tractor manufacturers designed tractor engine controls to 

determine when the vehicle was not being emissions tested and, under such conditions, shift to 

more fuel-efficient operation even though doing so caused the vehicles to violate federal 

standards for NOX emissions. Also, some manufacturers have recently expressed concern that 

the Phase 1 tractor standards do not credit them for fuel-saving technologies they had already

implemented before the Phase 1 standards were adopted.

In public meetings and in meetings with the agencies, the trucking industry stated that 

fuel cost for tractors is the number one or number two expense for many operators, and therefore 

is a very important factor for their business. However, the pre-Phase 1 market suggests that, 

tractor manufacturers and operators could be slow to adopt some new technologies, even where 

the agencies have estimated that the technology would have paid for itself within a few months 

of operation. Tractor operators have told the agencies they generally require technologies to be 

demonstrated in their fleet before widespread adoption so they can assess the actual fuel savings 

for their fleet and any increase in cost associated with effects on vehicle operation, maintenance, 

reliability, mechanic training, maintenance and repair equipment, stocking unique parts and 

driver acceptance, as well as effects on vehicle resale value. Tractor operators have publicly 

stated they would consider conducting an assessment of technologies when provided with data 

that show the technologies may payback costs through fuel savings within 18 to 24 months, 

based on their assumptions about future fuel costs. In these cases, an operator may first conduct 

a detailed paper study of anticipated costs and benefits. If that study shows likely payback in 18 

to 24 months for their business, the fleet may acquire one or several tractors with the technology

to directly measure fuel savings, costs and driver acceptance for their fleet. Small fleets may not 

have resources to conduct assessments to this degree and may rely on information from larger 

fleets or observations of widespread acceptance of the technology within the industry before 

adopting a technology. This uncertainty over the actual fuel savings and costs and the lengthy 

process to assess technologies significantly slows the pace at which fuel efficiency technologies 

are adopted. 
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The agencies believe that using the two baselines addresses the uncertainties we have 

identified for tractors. The six-month payback period of Alternative 1b reflects the agencies’ 

consideration of factors, discussed above, that could limit—yet not eliminate—manufacturers’ 

tendencies to voluntarily improve fuel consumption. In contrast, Alternative 1a reflects a 

baseline for vehicles other than trailers wherein manufacturers either do not apply fuel efficiency

technologies or only apply them as a substitute for more expensive fuel efficiency technologies, 

except as necessitated by the Phase 1 fuel consumption and GHG standards.

For HD pickups and vans, the agencies considered two No Action alternatives to cover a 

nominal range of uncertainty: a less-dynamic baseline (designated Alternative 1a) where no 

improvements are modeled beyond those needed to meet Phase 1 standards and a dynamic 

baseline (designated Alternative 1b) where certain cost-effective technologies (i.e., those that 

payback within a 6 month period) are assumed to be applied by manufacturers to improve fuel 

efficiency beyond the Phase 1 requirements in the absence of new Phase 2 standards. In 

Alternative 1b the agencies considered additional technology application, which involved the 

explicit estimation of the potential to add specific fuel-saving technologies to each specific 

vehicle model included in the agencies’ HD pickup and van fleet analysis, as discussed in 

Section VI of the Preamble. Estimated technology application and corresponding impacts 

depend on the modeled inputs. Also, under this approach a manufacturer that has improved fuel 

consumption and GHG emissions enough to achieve compliance with the standards is assumed 

to apply further improvements, provided those improvements reduce fuel outlays by enough 

(within a specified amount of time, the payback period) to offset the additional costs to purchase 

the new vehicle. These calculations explicitly account for and respond to fuel prices, vehicle 

survival and mileage accumulation, and the cost and efficacy of available fuel-saving 

technologies. Therefore, all else being equal, more technology is applied when fuel prices are 

higher and/or technology is more cost-effective. Manufacturers of HD pickups and vans have 

reported to the agencies that buyers of these vehicles consider the total cost of vehicle ownership, 

not just new vehicle price, and that manufacturers plan as if buyers will expect fuel consumption 

improvements to “pay back” within periods ranging from approximately one to three years. For 

example, some manufacturers made decisions to introduce more efficient HD vans and HD 

pickup transmissions before such vehicles were subject to fuel consumption and/or GHG 

standards. However, considering factors discussed above that could limit manufacturers’ 

tendency to voluntarily improve HD pickup and van fuel consumption, Alternative 1b applies a 

6-month payback period. In contrast for Alternative 1a the agencies project that fuel-saving 

technologies would either not be applied or only be applied as a substitute for more expensive 

fuel efficiency technologies, except as necessitated by the Phase 1 fuel consumption and GHG 

standards. The Method A sensitivity analysis presented Chapter 10 of this draft RIA also 

examines other payback periods. In terms of impacts under reference case fuel prices, the 

payback period input plays a more significant role under the No-Action Alternatives (defined by 

a continuation of model year 2018 standards) than under the more stringent regulatory

alternatives described next.

11.1.1.1 Alternative 1a

For an explanation of analytical Methods A and B identified in some of the following 

tables, please see Preamble Section I.D; for an explanation of the less dynamic baseline, 1a, and 

more dynamic baseline, 1b, please see Preamble Section X.A.1. The estimated reductions in 
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11-8

CO2 emission rates8used in MOVES for Alternative 1a are presented inChapter 10 discusses the 

agencies’ use of the CAFE model in greater detail.

Table 11-1 The projected use of auxiliary power units (APU) during extended idling for 

Alternative 1a is presented in Table 11-2. The reductions in aerodynamic and tire rolling 

resistance coefficients, and the absolute changes in average vehicle weight are presented in Table 

11-3. Chapter 10 discusses the agencies’ use of the CAFE model in greater detail.

Table 11-1 Estimated Reductions in CO2 Emission Rates for Method B Alternative 1a Modeling in MOVES

VEHICLE TYPE FUEL MODEL 

YEARS

FUEL/CO2

REDUCTION

Long-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018-2024 0.5%

2025+ 0.6%

Short-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018+ 0.2%

Single-Frame 

Vocational9

Diesel and CNG 2021-2023 0%

2024+ 0%

Gasoline 2021-2023 0%

2024+ 0%

HD Pickup Trucks 

and Vansa

Diesel and 

Gasoline

2021 0%

2022 0%

2023 0%

2024 0%

2025+ 0%

Note:

a Chapter 10 presents CAFE model inputs for the Method A analysis.

Table 11-2 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers for 

Alternative 1a Modeling in MOVES

VEHICLE TYPE MODEL YEARS APU PENETRATION

Combination LongHaul

Tractors

2010+ 30%
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Table 11-3 Estimated Reductions in Road Load Factors for Alternative 1a Modeling in MOVES

VEHICLE TYPE MODEL 

YEARS

REDUCTION IN 

TIRE ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG 

COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)a

Combination Long-haul 

Tractor-Trailers

2018 2.1% 3.0% -129

2019-2020 2.2% 3.1% -129

2021 2.2% 3.2% -129

2022-2023 2.3% 3.3% -129

2024 2.4% 3.4% -129

2025 2.4% 3.5% -129

2026 2.5% 3.5% -129

2027+ 2.5% 3.6% -129

Combination Shorthaul Tractor-Trailers102018 0.8% 1.1% -49

2019-2020 0.8% 1.2% -49

2021-2022 0.9% 1.2% -49

2023-2026 0.9% 1.3% -49

2027+ 1.0% 1.4% -49

Intercity Buses 2021-2023 0% 0% 0

2024+ 0% 0% 0

Transit and School 

Buses

2021-2023 0% 0% 0

2024+ 0% 0% 0

Refuse Trucks 2021-2023 0% 0% 0

2024+ 0% 0% 0

Single Unit Short-haul 

Trucks

2021-2023 0% 0% 0

2024+ 0% 0% 0

Single Unit Long-haul 

Trucks

2021-2023 0% 0% 0

2024+ 0% 0% 0

Motor Homes 2021-2023 0% 0% 0

2024+ 0% 0% 0

Note:

a Negative weight reductions reflect an expected weight increase as a byproduct of the other vehicle and engine 

improvements.

11.1.1.2 Alternative 1b

The estimated reductions in CO2 emission rates used in MOVES and the projected use of 

auxiliary power units (APU) during extended idling for Alternative 1b are presented in Table 

11-4 and Table 11-5, respectively. The reductions in aerodynamic and tire rolling resistance 

coefficients, and the absolute changes in average vehicle weight are presented in Table 11-6.
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Table 11-4 Estimated Reductions in CO2 Emission Rates for Method B Alternative 1b Modeling in MOVES

VEHICLE TYPE FUEL MODEL 

YEARS

FUEL/CO2

REDUCTION

Long- and ShortHaul TractorTrailer and HHD 

Vocational

Diesel 2018+ 0%

Single-Frame 

Vocational11

Diesel and CNG 2021-2023 0%

2024+ 0%

Gasoline 2021-2023 0%

2024+ 0%

HD pickup trucks 

and vansa

Diesel and 

Gasoline

2021-2022 2.18%

2023 2.71%

2024+ 2.86%

Note:

a Chapter 10 presents CAFE model inputs for the Method A analysis.

Table 11-5 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers for 

Alternative 1b Modeling in MOVES

VEHICLE TYPE MODEL 

YEARS

APU 

PENETRATION

Combination Long-Haul 

Tractors

2010+ 30%
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Table 11-6 Estimated Reductions in Road Load Factors for Alternative 1b Modeling in MOVES

TRUCK TYPE MODEL 

YEARS

REDUCTION IN TIRE 

ROLLING RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)a

Combination 

Long-haul 

Tractor-Trailers

2019 0.2% 0.5% 0

2020 0.2% 0.7% 0

2021 0.4% 1.2% 0

2022 0.6% 1.7% 0

2023 0.8% 2.5% 0

2024 1.1% 3.4% 0

2025 1.4% 4.4% 0

2026 1.7% 5.3% 0

2027 2.0% 6.1% 0

2028 2.1% 6.6% 0

Combination 

Short-haul 

Tractor-Trailers12

2019 0.3% 0.4% 0

2020 0.4% 0.7% 0

2021 0.7% 1.0% 0

2022 1.0% 1.6% 0

2023 1.5% 2.2% 0

2024 2.0% 3.1% 0

2025 2.6% 3.9% 0

2026 3.1% 4.8% 0

2027 3.6% 5.4% 0

2028 3.9% 6.0% 0

Intercity Buses 2021-

2023

0% 0% 0

2024+ 0% 0% 0

Transit and 

School Buses

2021-

2023

0% 0% 0

2024+ 0% 0% 0

Refuse Trucks 2021-

2023

0% 0% 0

2024+ 0% 0% 0

Single Unit 

Short-haul 

Trucks

2021-

2023

0% 0% 0

2024+ 0% 0% 0

Single Unit 

Long-haul Trucks

2021-

2023

0% 0% 0

2024+ 0% 0% 0

Motor Homes 2021-

2023

0% 0% 0

2024+ 0% 0% 0

Note:

a Negative weight reductions reflect an expected weight increase as a byproduct of the other vehicle and engine 

improvements.
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11.1.2 Alternative 2: Less Stringent than the Preferred Alternative

For vocational vehicles and combination tractor-trailers, Alternative 2 represents a 

stringency level which is approximately half as stringent overall as the preferred alternative. The 

agencies developed Alternative 2 to reflect a continuation of the Phase 1 approach of– applying 

off-the-shelf technologies rather than requiring the development of new technologies or 

fundamental improvements to existing technologies. For tractors and vocational vehicles, this 

also involved less integrated optimization of the vehicles and engines. Alternative 2 would not 

set standards for MY 2027.

The agencies’ decisions regarding which technologies could be applied to comply with 

Alternative 2 considered not only assuming the use of off-the shelf technologies, but also 

considered other factors, as well, such as how broadly certain technologies fit in-use applications 

and regulatory structure. The resulting Alternative 2 could be met with most of the same 

technologies the agencies project could be used to meet the proposed standards, although at 

lower application rates. Alternative 2 is estimated to be achievable without the application of 

some technologies, at any level. These and other differences are described below by category.

The agencies project that Alternative 2 combination tractor standards could be met by

applying lower adoption rates of the projected technologies for Alternative 3. This includes a 

projection of slightly lower per-technology effectiveness for Alternative 2 versus 3. Alternative 

2 also assumes that there would be little optimization of combination tractor powertrains. 

The agencies project that the Alternative 2 vocational vehicle standard could be met 

without any use of strong hybrids. Rather, it could be met with lower adoption rates of the other 

technologies that could be used to meet Alternative 3, our proposed standards. This includes a 

projection of slightly lower per-technology effectiveness for Alternative 2 versus 3 and little 

optimization of vocational vehicle powertrains. 

The Alternative 2 trailer standards would apply to only 53-foot dry and refrigerated box 

trailers and could be met through the use of less effective aerodynamic technologies and higher 

rolling resistance tires versus what the agencies projected could be used to meet Alternative 3.

As discussed above in Chapter 5, the HD pickup truck and van alternatives are 

characterized by an annual required percentage change (decrease) in the functions defining 

attribute-based targets for per-mile fuel consumption and GHG emissions. Under the HD pickup 

and van standards in Alternative 2 and each other alternative, a manufacturer’s fleet would, 

setting aside any changes in production mix, be required to achieve average fuel 

consumption/GHG levels that increase in stringency every year relative to the standard defined 

for MY2018 (and held constant through 2020) that establishes fuel consumption/GHG targets for 

individual vehicles. A manufacturer’s specific fuel consumption/GHG requirement is the salesweighted average of the targets defined by the work-factor curve in each year. Therefore, 

although the alternatives involve steady increases in the functions defining the targets, stringency

increases faced by any individual manufacturer may not be steady if changes in the 

manufacturer’s product mix cause fluctuations in the average fuel consumption and GHG levels 

required of the manufacturer. See Section VI.D. of the Preamble for additional discussion of this 

topic. Alternative 2 represents a 2.0 percent annual improvement in the target curve through 
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11-13

2025 in fuel consumption/GHG emissions relative to the work-factor curve in 2020.This would 

be 0.5 percent less stringent per year compared to the proposed standards of Alternative 3 and 

would not increase in stringency for MYs 2026 or 2027. For HD pickups and vans the agencies 

project that most manufacturers could comply with the standards defining Alternative 2 by

applying technologies similar to those that could be applied in order to comply with the proposed 

standards, but at lower application rates than could be necessitated by the proposed standards. 

The biggest technology difference the agencies project between Alternative 2 and the proposed 

standards of Alternative 3 would be that we project that most manufacturers could meet the 

Alternative 2 standards without any use of stop-start or other mild or strong hybrid technologies.

The analytical inputs for Alternative 2 are shown in the following tables. The estimated reductions in CO2

emission rates used in MOVES and the projected use of auxiliary power units (APU) during extended idling 

are presented in Table 11-7 and Table 11-8, respectively. The reductions in aerodynamic and tire rolling 

resistance coefficients, and the absolute changes in average vehicle weight are presented in 

Table 11-9.

Table 11-7 Estimated Reductions in CO2 Emission Rates for Method B Alternative 2 Modeling in MOVES

VEHICLE TYPE FUEL MODEL 

YEARS

FUEL/CO2

REDUCTION

Long-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018-2020 0.9%

2021-2023 3.9%

2024+ 6.9%

Short-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018-2020 0.3%

2021-2023 3.2%

2024+ 6.4%

Single-Frame 

Vocational13

Diesel and CNG 2021-2023 2.1%

2024+ 5.1%

Gasoline 2021-2023 1.1%

2024+ 2.1%

HD pickup trucks 

and vansa

Diesel and 

Gasoline

2021 2.00%

2022 3.96%

2023 5.88%

2024 7.76%

2025+ 9.61%

Note:

a Chapter 10 presents CAFE model inputs for the Method A analysis.
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Table 11-8 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers for 

Alternative 2 Modeling in MOVES

VEHICLE TYPE MODEL 

YEARS

APU 

PENETRATION

Combination Long-Haul

Tractors

2010-2020 30%

2021-2023 60%

2024+ 80%

Table 11-9 Estimated Reductions in Road Load Factors for Alternative 2 Modeling in MOVES

VEHICLE 

TYPE

MODEL 

YEARS

REDUCTION IN TIRE 

ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)a

Combination 

Long-haul 

Tractor-Trailers

2018-

2020

4.0% 5.1% -131

2021-

2023

5.8% 11.0% -135

2024+ 9.0% 12.4% -140

Combination 

Short-haul 

Tractor-Trailers14

2018-

2020

1.2% 1.6% -41

2021-

2023

5.3% 6.4% -42

2024+ 6.6% 7.4% -43

Intercity Buses 2021-

2023

6.5% 0% 0

2024+ 7.6% 0% 0

Transit and 

School Buses

2021-

2023

0% 0% 0

2024+ 2.7% 0% 0

Refuse Trucks 2021-

2023

0% 0% 0

2024+ 2.7% 0% 0

Single Unit 

Short-haul 

Trucks

2021-

2023

4.8% 0% 0

2024+ 5.6% 0% 0

Single Unit 

Long-haul Trucks

2021-

2023

6.5% 0% 0

2024+ 7.6% 0% 0

Motor Homes 2021-

2023

3.0% 0% 0

2024+ 5.9% 0% 0

Note:

a Negative weight reductions reflect an expected weight increase as a byproduct of the other vehicle and engine 

improvements.
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11-15

11.1.3 Alternative 3: Preferred Alternative and Proposed Standards

Alternative 3 represents the agencies’ preferred approach. This alternative consists of the 

preferred fuel efficiency and GHG standards for HD engines, HD pickup trucks and vans, Class 

2b through Class 8 vocational vehicles, and Class 7 and 8 combination tractors. 

Details regarding modeling of this preferred alternative are included in Chapter 5 of this 

draft RIA as the control case (Section 5.3.2.3.1). Note that the impacts of this alternative are 

summarized in RIA Chapter 0, along with the impacts of the other alternatives. 

11.1.4 Alternative 4: Achieving Proposed Standards with Less Lead-Time

Alternative 4 represents standards that are effective on a more accelerated timeline in 

comparison to the timeline of the proposed standards in Alternative 3. Alternatives 3 and 4 were 

both designed to achieve similar fuel efficiency and GHG emission levels in the long term but 

with Alternative 4 being accelerated in its implementation timeline. Specifically, Alternative 4 

reflects the same or similar standard stringency levels as Alternative 3, but 3 years sooner (2 

years for heavy-duty pickups and vans), so that the final phase of the standards would occur in 

MY 2024, or (for heavy duty pickups and vans) 2025.

The estimated reductions in CO2 emission rates used in MOVES and the projected use of 

auxiliary power units (APU) during extended idling for Alternative 4 are presented in Table 

11-10 and Table 11-11, respectively. The reductions in aerodynamic and tire rolling resistance 

coefficients, and the absolute changes in average vehicle weight are presented in Table 11-12.
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11-16

Table 11-10 Estimated Reductions in CO2 Emission Rates for Method B Alternative 4 Modeling in MOVES

VEHICLE TYPE FUEL MODEL 

YEARS

FUEL/CO2

REDUCTION

Long-haul Tractor-Trailer

and HHD Vocational

Diesel 2018-2020 1.3%

2021-2023 6.6%

2024+ 10.4%

Short-haul Tractor-Trailer

and HHD Vocational

Diesel 2018-2020 0.9%

2021-2023 6.9%

2024+ 10.4%

Single-Frame Vocational15 Diesel and CNG 2021-2023 7.7%

2024+ 13.3%

Gasoline 2021-2023 5.2%

2024+ 10.3%

HD pickup trucks and vansa Diesel and 

Gasoline

2021 3.50%

2022 6.88%

2023 10.14%

2024 13.28%

2025+ 16.32%

Note:

a Chapter 10 presents CAFE model inputs for the Method A analysis.

Table 11-11 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers for 

Alternative 4 Modeling in MOVES

VEHICLE TYPE MODEL 

YEARS

APU PENETRATION

Combination 

Long-Haul

Tractors

2010-2020 30%

2021-2023 80%

2024+ 90%
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Table 11-12 Estimated Reductions in Road Load Factors for Alternative 4 Modeling in MOVES

VEHICLE 

TYPE

MODEL 

YEARS

REDUCTION IN TIRE 

ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)a

Combination 

Long-haul 

Tractor-Trailers

2018-

2020

5.5% 5.1% -131

2021-

2023

12.6% 19.3% -246

2024+ 17.9% 26.9% -304

Combination 

Short-haul 

TractorTrailers16

2018-

2020

4.0% 1.6% -41

2021-

2023

13.0% 11.6% -100

2024+ 17.6% 15.9% -127

Intercity Buses 2021-

2023

6.5% 0% 0

2024+ 16.5% 0% 0

Transit Buses 2021-

2023

0% 0% 0

2024+ 3.0% 0% 0

School Buses 2021-

2023

0% 0% 0

2024+ 4.0% 0% 0

Refuse Trucks 2021-

2023

0% 0% 20

2024+ 3.0% 0% 25

Single Unit 

Short-haul 

Trucks

2021-

2023

4.8% 0% 5.8

2024+ 13.0% 0% 7

Single Unit 

Long-haul 

Trucks

2021-

2023

6.5% 0% 20

2024+ 16.5% 0% 25

Motor Homes 2021-

2023

3.0% 0% 0

2024+ 7.4% 0% 0

Note:

a Negative weight reductions reflect an expected weight increase as a byproduct of the other vehicle and 

engine improvements.

11.1.5 Alternative 5: More Stringent Standards 

Alternative 5 represents even more stringent standards compared to Alternatives 3 and 4, 

as well as the same implementation timeline as Alternative 4. As discussed in the feasibility

discussions in the preamble, we are not proposing Alternative 5 because we cannot project that 

manufacturers can develop and introduce in sufficient quantities the technologies that could be 

used to meet Alternative 5 standards. We believe that for some or all of the categories, the 

Alternative 5 standards are technically infeasible within the lead time allowed. We have not 
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11-18

fully estimated costs for this alternative for tractors and vocational vehicles because we believe 

that there would be such substantial additional costs related to pulling ahead the development of 

so many additional technologies that we cannot accurately predict these costs. We also believe 

this alternative could result in a decrease in the in-use reliability and durability of new heavyduty vehicles and that we do not have the ability to accurately quantify the costs that would be 

associated with such problems. Instead we merely note that costs would be significantly greater 

than the estimated costs for Alternatives 3 and 4.

The tractor and vocational vehicle standards would be based on higher adoption rates of 

the projected technologies and higher effectiveness. In addition, it assumes some adoption of allelectric vocational vehicles. 

The trailer standards in Alternative 5 are more stringent than Alternatives 3 and 4, but 

rely on the same technologies. The greater reductions would be projected to be achieved through 

a combination of slightly higher effectiveness and higher adoption rates. 

The Alternative 5 HD pickup truck and van standards would be based on more extensive 

use of mild and strong hybrid technology and its use by more manufacturers. The result would 

be that over half of the HD gasoline pickup fleet would need to incorporate some form of strong 

hybrid technology. If achievable, Alternative 5 would require the average pickup truck or van 

fuel consumption and GHG emissions to decrease by approximately 4.0 percent per year relative 

to Phase 1 for model years 2021, 2022, 2023, 2024 and 2025. This is more aggressive than 

Alternative 3 by 1.50 percent per year over the same model years. The estimated reductions in 

CO2 emission rates used in MOVES and the projected use of auxiliary power units (APU) during 

extended idling for Alternative 5 are presented in Table 11-13 and Table 11-14, respectively. 

The reductions in aerodynamic and tire rolling resistance coefficients, and the absolute changes 

in average vehicle weight are presented in Table 11-15. 
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11-19

Table 11-13 Estimated Reductions in CO2 Emission Rates for Method B Alternative 5 Modeling in MOVES

VEHICLE TYPE FUEL MODEL 

YEARS

FUEL/CO2

REDUCTION

Long-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018-2020 1.3%

2021-2023 10.3%

2024+ 13.5%

Short-haul 

Tractor-Trailer

and HHD 

Vocational

Diesel 2018-2020 0.9%

2021-2023 11.3%

2024+ 14.9%

Single-Frame 

Vocational17

Diesel and CNG 2021-2023 14.0%

2024+ 18.5%

Gasoline 2021-2023 11.0%

2024+ 15.0%

HD pickup trucks 

and vansa

Diesel and 

Gasoline

2021 4.00%

2022 7.84%

2023 11.53%

2024 15.07%

2025+ 18.46%

Note:

a Chapter 10 presents CAFE model inputs for the Method A analysis.

Table 11-14 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers for 

Alternative 5 Modeling in MOVES

VEHICLE TYPE MODEL YEARS APU PENETRATION

Combination LongHaul Tractors2010-2020 30%

2021+ 100%
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11-20

Table 11-15 Estimated Reductions in Road Load Factors for Alternative 5 Modeling in MOVES

VEHICLE TYPE MODEL 

YEARS

REDUCTION IN 

TIRE ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG 

COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)a

Combination Long-haul 

Tractor-Trailers

2018-2020 5.4% 7.3% -170

2021-2023 14.3% 24.6% 936

2024+ 19.2% 31.4% 850

Combination Short-haul 

Tractor-Trailers18

2018-2020 3.9% 2.3% -53

2021-2023 14.5% 15.0% 997

2024+ 18.8% 19.0% 943

Intercity Buses 2021-2023 6.5% 0% 0

2024+ 16.5% 0% 0

Transit Buses 2021-2023 0% 0% 0

2024+ 8.0% 0% 0

School Buses 2021-2023 0% 0% 0

2024+ 9.1% 0% 0

Refuse Trucks 2021-2023 0% 0% 255

2024+ 8.0% 0% 255

Single Unit Short-haul 

Trucks

2021-2023 4.8% 0% 58

2024+ 15.2% 0% 95

Single Unit Long-haul 

Trucks

2021-2023 6.5% 0% 185

2024+ 16.5% 0% 185

Motor Homes 2021-2023 3.0% 0% 0

2024+ 12.4% 0% 0

Note:

a Negative weight reductions reflect an expected weight increase as a byproduct of the other vehicle and engine 

improvements.

11.2 How Do These Alternatives Compare in Overall GHG Emissions 

Reductions and Fuel Efficiency and Cost?

As noted earlier, the agencies analyzed the impact of each alternative on both 

downstream and upstream emissions using two complementary methods. The results of Method 

A are shown in section 11.2.1. The results of Method B are shown in section 11.2.2.

11.2.1 Comparison of Alternatives Using Method A

The following tables compare the overall fuel consumption and GHG emissions 

reductions and benefits and costs of each of the regulatory alternatives the agencies considered.

Note that for tractors, trailers, pickups and vans the agencies compared overall fuel 

consumption and GHG emissions reductions and benefits and costs relative to two different 

baselines, described above in the section on the No Action alternative. Therefore, for tractors, 

trailers, pickups and vans two results are listed; one relative to each baseline, namely Alternative 

1a and Alternative 1b.
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11-21

Also note that the agencies analyzed pickup and van overall fuel consumption and 

emissions reductions and benefits and costs using the NHTSA CAFE model (Method A). In

addition, the agencies used EPA’s MOVES model to estimate pickup and van fuel consumption 

and emissions and a cost methodology that applied vehicle costs in different model years 

(Method B). In both cases, the agencies used the CAFE model to estimate average per vehicle 

cost, and this analysis extended through model year 2030.A The agencies concluded that in these 

instances the choice of baseline and the choice of modeling approach (Method A versus Method 

B) did not impact the agencies’ decision to propose Alternative 3 as the preferred alternative and 

hence the proposed standards for HD pickups and vans.

Table 11-16 compares the fuel savings, technology costs, avoided GHG emissions, costs, 

and benefits (at three percent) for the above regulatory alternatives, as estimated under Method

A. Table 11-17 provides the same comparisons for the alternative relative to baseline 1b. Table 

11-18 and Table 11-19 show the same summary, discounted at seven percent. Subsequent tables

(Table 11-20 and Table 11-21) summarize segment-specific impacts on fuel consumption and 

GHG emissions.

 

A Although the agencies have considered regulatory alternatives involving standards increasing in stringency 

through, at the latest, 2027, the agencies extended the CAFE modeling analysis through model year 2030 rather than 

model year 2027 in order to obtain more fully stabilized results given projected product cadence, multiyear 

planning, and application of earned credits.
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11-22

Table 11-16 Summary of Costs and Benefits through MY 2029 by Alternative, Discounted at 3% (Relative to 

Baseline 1a), Method Aa

VEHICLE SEGMENT ALT 2 ALT 3 ALT 4 ALT 5

Discounted pre-tax fuel savings ($billion)

HD pickups and Vans 11.7 18.3 22.3 24.8

Vocational Vehicles 5.6 18.4 24.3 38.5

Tractors/Trailers 88.1 138.4 151.7 196.8

Total 105.4 175.1 198.3 260.2

Discounted Total technology costs ($billion)

HD pickups and Vans 3.0 5.0 8.2 9.9

Vocational Vehicles 1.2 7.6 10.8 26.0

Tractors/Trailers 9.2 12.8 15.3 34.8

Total 13.4 25.4 34.3 70.6

Discounted value of emissions reductions ($billon)

HD pickups and Vans 3.1 5.0 6.1 6.8

Vocational Vehicles 0.6 2.6 3.5 5.7

Tractors/Trailers 21.5 32.7 35.1 45.1

Total 25.2 40.3 44.7 57.7

Total costs($billion)

HD pickups and Vans 3.5 5.7 9.1 15.2

Vocational Vehicles 3.0 9.5 12.8 28.1

Tractors/Trailers 11.5 15.5 18.1 37.5

Total 18.0 30.8 40.0 80.8

Total benefits($billion)

HD pickups and Vans 17.2 27.0 33.0 36.7

Vocational Vehicles 12.7 31.2 39.7 60.2

Tractors/Trailers 142.5 217.5 236.7 304.2

Total 172.4 275.8 309.4 401.1

Net benefits($billion)

HD pickups and Vans 13.7 21.3 23.9 21.5

Vocational Vehicles 9.6 21.7 26.9 32.1

Tractors/Trailers 131.0 202.0 218.7 266.7

Total 154.3 245.0 269.4 320.3

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-23

Table 11-17 Summary of Program Benefits and Costs through MY 2029, Discounted at 3% (Relative to 

Baseline 1b) Method A a

VEHICLE SEGMENT ALT 2 ALT 3 ALT 4 ALT 5

Discounted pre-tax fuel savings ($billion)

HD pickups and Vans 9.6 15.9 19.1 22.2

Vocational Vehicles 5.6 18.4 24.3 38.5

Tractors/Trailers 80.5 130.8 144.0 189.2

Total 95.6 165.1 187.4 250.0

Discounted Total technology costs ($billion)

HD pickups and Vans 2.5 5.0 7.2 9.7

Vocational Vehicles 1.2 7.6 10.8 25.9

Tractors/Trailers 8.9 12.5 15.0 34.4

Total 12.5 25.0 32.9 70.0

Discounted value of emissions reductions ($billon)

HD pickups and Vans 2.8 4.5 5.4 6.3

Vocational Vehicles 1.7 6.1 8.1 13.1

Tractors/Trailers 37.5 59.4 64.6 84.4

Total 41.9 70.1 78.2 103.8

Total costs($billion)

HD pickups and Vans 2.8 5.5 7.8 10.4

Vocational Vehicles 3.0 9.5 12.8 28.0

Tractors/Trailers 11.2 15.2 17.7 37.2

Total 17.0 30.3 38.4 75.7

Total benefits($billion)

HD pickups and Vans 14.1 23.5 28.3 32.9

Vocational Vehicles 12.7 31.2 39.7 60.2

Tractors/Trailers 131.1 206.2 225.4 292.8

Total 157.9 260.9 293.3 385.9

Net benefits($billion)

HD pickups and Vans 11.3 18.0 20.4 22.5

Vocational Vehicles 9.6 21.7 26.9 32.1

Tractors/Trailers 119.9 191.0 207.6 255.6

Total 140.9 230.7 254.9 310.3

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.

The following two tables summarize results for each of the segments covered by today’s 

proposal, discounted at 7 percent.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-24

Table 11-18 Summary of Program Benefits and Costs through MY 2029, discounted at 7% (Relative to 

Baseline 1a) Method A a

VEHICLE SEGMENT ALT 2 ALT 3 ALT 4 ALT 5

Discounted pre-tax fuel savings ($billion)

HD pickups and Vans 6.4 9.9 12.2 13.6

Vocational Vehicles 2.9 9.7 13.0 20.9

Tractors/Trailers 47.7 74.6 82.3 107.3

Total 57.0 94.2 107.5 141.8

Discounted Total technology costs ($billion)

HD pickups and Vans 2.1 3.4 5.7 6.9

Vocational Vehicles 0.8 5.0 7.3 17.8

Tractors/Trailers 6.3 8.7 10.5 23.9

Total 9.1 17.1 23.5 48.6

Discounted value of emissions reductions ($billon)

HD pickups and Vans 2.7 4.3 5.3 5.9

Vocational Vehicles 1.4 5.0 6.6 10.6

Tractors/Trailers 29.9 46.3 50.4 65.4

Total 34.0 55.6 62.3 81.8

Total costs($billion)

HD pickups and Vans 2.4 3.8 6.2 10.1

Vocational Vehicles 1.8 6.1 8.4 19.0

Tractors/Trailers 7.6 10.3 12.1 25.5

Total 11.8 20.2 26.7 54.6

Total benefits($billion)

HD pickups and Vans 10.4 16.3 20.1 22.3

Vocational Vehicles 7.3 18.3 23.6 36.2

Tractors/Trailers 85.1 130.0 142.2 183.5

Total 102.9 164.6 185.8 242.1

Net benefits($billion)

HD pickups and Vans 8.1 12.4 13.9 12.2

Vocational Vehicles 5.5 12.2 15.2 17.2

Tractors/Trailers 77.5 119.7 130.1 158.0

Total 91.1 144.4 159.1 187.5

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-25

Table 11-19 Summary of Program Benefits and Costs through MY 2029, discounted at 7% (Relative to 

Baseline 1b) Method A a

VEHICLE SEGMENT ALT 2 ALT 3 ALT 4 ALT 5

Discounted pre-tax fuel savings ($billion)

HD pickups and Vans 5.2 8.5 10.4 12.2

Vocational Vehicles 2.9 9.7 13.0 20.9

Tractors/Trailers 44.0 71.0 78.6 103.7

Total 52.2 89.2 102.0 136.8

Discounted Total technology costs ($billion)

HD pickups and Vans 1.7 3.4 4.9 6.7

Vocational Vehicles 0.8 5.0 7.3 17.8

Tractors/Trailers 6.0 8.4 10.3 23.7

Total 8.5 16.8 22.5 48.2

Discounted value of emissions reductions ($billon)

HD pickups and Vans 2.5 4.0 4.8 5.5

Vocational Vehicles 1.4 5.0 6.6 10.6

Tractors/Trailers 27.5 43.9 48.0 63.0

Total 31.4 52.9 59.4 79.1

Total costs($billion)

HD pickups and Vans 1.9 3.7 5.3 7.1

Vocational Vehicles 1.8 6.1 8.4 19.0

Tractors/Trailers 7.3 10.0 11.9 25.3

Total 11.1 19.8 25.6 51.4

Total benefits($billion)

HD pickups and Vans 8.6 14.1 17.1 20.0

Vocational Vehicles 7.3 18.3 23.6 36.2

Tractors/Trailers 78.9 123.7 135.9 177.3

Total 94.8 156.2 176.6 233.5

Net benefits($billion)

HD pickups and Vans 6.7 10.5 11.9 12.9

Vocational Vehicles 5.5 12.2 15.2 17.2

Tractors/Trailers 71.5 113.7 124.0 152.0

Total 83.7 136.4 151.1 182.2

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.

While the agencies’ explicit analysis of manufacturers’ potential responses to today’s 

standards extends through model year 2030, the resulting fuel savings and avoided emissions 

summarized in the following two tables occur as those vehicles.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-26

Table 11-20 Fuel Savings and GHG Emissions Reductions by Vehicle Segment, Relative to Baseline 1a, 

Method Aa

MY 2018 - 2029 TOTAL

FUEL 

REDUCTIONS

UPSTREAM & 

DOWNSTREAM 

GHG 

REDUCTIONS

(billion gallons) (MMT)

Alternative 2

HD Pickup Trucks/Vans 5.5 67.5

Vocational Vehicles 2.5 33.632.2

Tractors and Trailers 37.8 518.8493.0

Total 45.8 619.9592.7

Alt. 3 - Preferred Alternative

HD Pickup Trucks/Vans 8.8 107.6

Vocational Vehicles 8.3 110.3107.0

Tractors and Trailers 59.5 816.4775.7

Total 76.7 1,034.3990.4

Alt. 4

HD Pickup Trucks/Vans 10.7 130.5

Vocational Vehicles 10.9 143139.8

Tractors and Trailers 65.0 892.1847.7

Total 86.7 1,166.4118.0

Alt. 5

HD Pickup Trucks/Vans 12.0 145.4

Vocational Vehicles 17.3 226.9221.0

Tractors and Trailers 84.2 1,155.1097.6

Total 113.4 1,527.4464.1

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-27

Table 11-21 Fuel Savings and GHG Emissions Reductions by Vehicle Segment, Relative to Baseline 1b

Method Aa

MY 2018 - 2029 

TOTAL

FUEL 

REDUCTIONS

UPSTREAM & 

DOWNSTREAM 

GHG 

REDUCTIONS

(billion gallons) (MMT)

Alternative 2

HD Pickup Trucks/Vans 4.5 55.5

Vocational Vehicles 2.5 33.6

Tractors and Trailers 34.4 471.9

Total 41.4 561.0

Alt. 3 - Preferred Alternative

HD Pickup Trucks/Vans 7.8 94.1

Vocational Vehicles 8.3 110.3

Tractors and Trailers 56.1 769.4

Total 72.2 973.8

Alt. 4

HD Pickup Trucks/Vans 9.3 112.8

Vocational Vehicles 10.9 143.8

Tractors and Trailers 61.6 845.2

Total 81.8 1,101.8

Alt. 5

HD Pickup Trucks/Vans 10.8 130.5

Vocational Vehicles 17.3 226.9

Tractors and Trailers 80.7 1,108.2

Total 108.8 1,465.6

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-28

11.2.2 Comparison of Alternatives Using Method B

Method B analyzed the impact of each alternative on both downstream and upstream

emissions, as shown in Table 11-22. The table contains the annual GHG and fuel consumption 

impacts and technology costs in 2035 and 2050 for each alternative (relative to the reference 

scenario of Alternative 1a), presenting both the total impacts across all regulatory categories and 

for each individual regulatory category. Note that by 2050 when all the alternative would be 

almost completely phased in, Alternatives 3 and 4 would provide essentially the same annual 

benefits.

Table 11-22 Annual GHG & Fuel Reductions and Technology Costs vs. the Less Dynamic Baseline and using 

Method B: Calendar Years 2035 and 2050 a

UPSTREAM

+DOWNSTREAM 

GHG REDUCTIONS 

(MMT)

FUEL REDUCTIONS 

(BILLION GALLONS)

TECHNOLOGY 

COST (MILLIONS OF 

2012$)

2035 2050 2035 2050 2035 2050

Alternative 1a (relative 

to itself)

0 0 0 0 $0 $0

Alt. 2 Less StringentTotal

72 101 5.2 7.3 $2,559 $3,090

Tractors 59 84 4.2 6.0 $1,855 $2,279

HD Pickups & Vans 8 11 0.7 0.9 $471 $541

Vocational Vehicles 5 7 0.3 0.5 $233 $271

Alt. 3 Preferred – Total 127 183 9.3 13.4 $5,856 $6,987

Tractors 97 141 7.0 10.1 $2,888 $3,548

HD Pickups & Vans 14 19 1.1 1.6 $892 $1,024

Vocational Vehicles 16 23 1.2 1.7 $2,076 $2,414

Alt. 4 More Stringent–

Total

132 184 9.7 13.5 $6,180 $7,358

Tractors 100 141 7.2 10.1 $2,888 $3,548

HD Pickups & Vans 15 19 1.2 1.6 $1,215 $1,395

Vocational Vehicles 17 23 1.3 1.7 $2,077 $2,415

Alt. 5 More Stringent–

Total

168 232 12.4 17.0 N/A N/A

Tractors 126 176 9.0 12.6 N/A N/A

HD Pickups & Vans 17 22 1.4 1.8 N/A N/A

Vocational Vehicles 26 34 1.9 2.5 N/A N/A

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an explanation of the less 

dynamic baseline, 1a, and more dynamic baseline, 1b, please see Preamble Section X.A.1

Table 11-23 presents a summary of all costs and benefits for each program alternative 

relative to the Alternative 1a baseline case. Table 11-24 shows cost per ton of GHG reduced.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-29

Table 11-23 Monetized Net Benefits Associated with Each Alternative Relative to the Less Dynamic Baseline

and using Method B

(Billions of 2012$, Except GHG Reductions)

a, b

Alt.1

Baseline

Alt.2 Less 

Stringent

Alt.3

Preferred

Alt.4 More 

Stringent

Alt.5 More 

Stringent

203

5

Vehicle Program

Costsc

$0 -$2.6 -$5.9 -$6.2 N/A

Maintenance costs $0 -$0.06 -$0.13 -$0.14 N/A

Fuel Expenditures

(pre-tax)

$0 $20.9 $37.2 $38.7 $49.4

Benefits $0 $12.8 $20.5 $21.1 $26.3

Net Benefits $0 $31.1 $51.7 $53.5 N/A

GHG reductions 

(MMT)

0 71.9 127.1 132.0 168.3

205

0

Vehicle Program

Costsc

$0 -$3.1 -$7.0 -$7.4 N/A

Maintenance costs $0 -$0.06 -$0.13 -$0.14 N/A

Fuel Expenditures

(pre-tax)

$0 $31.5 $57.5 $57.6 $72.7

Benefits $0 $19.9 $32.9 $32.9 $40.6

Net Benefits $0 $48.3 $83.2 $83.0 N/A

GHG Reductions 

(MMT)

0 101.2 183.4 183.8 231.8

NP

V, 

3%

Vehicle Program

Costsc

$0 -$39.8 -$86.8 -$98.6 N/A

Maintenance costs $0 -$0.88 -$1.80 -$1.91 N/A

Fuel Expenditures

(pre-tax)

$0 $280.0 $495.6 $517.6 $664.3

Benefits $0 $175.2 $279.7 $289.7 $361.5

Net Benefits $0 $414.5 $686.8 $706.8 N/A

NP

V, 

7%

Vehicle Program

Costsc

$0 -$19.3 -$41.1 -$48.4 N/A

Maintenance costs $0 -$0.42 -$0.86 -$0.92 N/A

Fuel Expenditures

(pre-tax)

$0 $118.1 $206.7 $219.0 $283.0

Benefits $0 $105.5 $173.5 $180.7 $228.0

Net Benefits $0 $203.8 $338.1 $350.5 N/A

Notes: 

a Benefits and net benefits calculated using the 3% average Social Cost of CO2 value. The net present value of 

reduced CO2 emissions is calculated differently than other benefits. The same discount rate used to discount the 

value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net present value of 

SCC for internal consistency. Refer to the SCC TSD for more detail. 

b

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an explanation of the 

less dynamic baseline, 1a, and more dynamic baseline, 1b, please see Preamble Section X.A.1

c Vehicle program costs include compliance costs and R&D.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-30

Table 11-24 Annual Cost per Metric Ton of CO2eq Emissions Reduced in Each Control Case Alternative

Vs. the Less Dynamic Baseline and using Method B

(Dollar Values are 2012$) a

YEAR ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4

MORE 

STRINGENT

ALT.5 

MORE 

STRINGENT

2035 $/metric ton 

w/o fuel

$36 $47 $48 N/A

$/metric ton 

w/ fuel

-$250 -$250 -$250 N/A

2050 $/metric ton 

w/o fuel

$31 $39 $41 N/A

$/metric ton 

w/ fuel

-$280 -$270 -$270 N/A

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an 

explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see 

Preamble Section X.A.1

11.2.2.1 Tractors and Trailers

Table 11-25 presents a summary of all costs and benefits for each tractor/trailer program 

Alternative relative to the alternative 1a baseline case. Table 11-26 shows cost per ton of GHG 

reduced.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-31

Table 11-25 Monetized Net Benefits Associated with Each Alternative Relative to the Less Dynamic Baseline

and using Method B

Tractor/Trailers 

(Billions of 2012$, Except GHG Reductions)

b

ALT.1

BASELI

NE

ALT.2

LESS 

STRING

ENT

ALT.3

PREFER

RED

ALT.4

MORE 

STRINGE

NT

ALT.5

MORE 

STRINGE

NT

2035 Vehicle Program

Costsc

$0 -$1.9 -$2.9 -$2.9 N/A

Maintenance costs $0 -$0.03 -$0.08 -$0.08 N/A

Fuel Expenditures

(pre-tax)

$0 $17.2 $28.4 $29.2 $36.8

Benefits $0 $10.3 $15.7 $16.0 $19.7

Net Benefits $0 $25.6 $41.0 $42.2 N/A

GHG Reductions 

(MMT)

0 59.1 97.2 100.0 125.9

2050 Vehicle Program

Costsc

$0 -$2.3 -$3.6 -$3.6 N/A

Maintenance costs $0 -$0.03 -$0.08 -$0.08 N/A

Fuel Expenditures

(pre-tax)

$0 $26.1 $44.0 $44.0 $54.8

Benefits $0 $16.1 $25.2 $25.2 $30.7

Net Benefits $0 $39.9 $65.5 $65.6 N/A

GHG Reductions 

(MMT)

0 83.8 140.9 141.1 175.7

NPV, 

3%

Vehicle Program

Costsc

$0 -$28.8 -$43.7 -$46.2 N/A

Maintenance costs $0 -$0.47 -$1.19 -$1.22 N/A

Fuel Expenditures

(pre-tax)

$0 $231.7 $381.5 $394.5 $499.5

Benefits $0 $141.7 $215.7 $221.6 $274.2

Net Benefits $0 $344.1 $552.3 $568.8 N/A

NPV, 

7%

Vehicle Program

Costsc

$0 -$13.9 -$20.9 -$22.7 N/A

Maintenance costs $0 -$0.23 -$0.59 -$0.60 N/A

Fuel Expenditures

(pre-tax)

$0 $98.1 $160.1 $167.5 $213.4

Benefits $0 $85.8 $133.8 $138.1 $172.4

Net Benefits $0 $169.8 $272.4 $282.3 N/A

Notes: 

a Benefits and net benefits calculated using the 3% average Social Cost of CO2 value applied only to CO2

reductions. The net present value of reduced CO2 emissions is calculated differently than other benefits. 

The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, and 2.5 

percent) is used to calculate net present value of SCC for internal consistency. Refer to the SCC TSD for 

more detail. 

b

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an explanation of 

the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see Preamble Section X.A.1

c Vehicle program costs include compliance costs and R&D.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-32

Table 11-26 Annual Cost per Metric Ton of CO2eq Emissions Reduced in Each Control Case Alternative

Vs. the Less Dynamic Baseline and using Method B

Tractor/Trailers

(Dollar Values are 2012$) a

YEAR ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4

MORE 

STRINGENT

ALT.5 

MORE 

STRINGENT

2035 $/metric ton 

w/o fuel

$32 $31 $30 N/A

$/metric ton 

w/ fuel

-$260 -$260 -$260 N/A

2050 $/metric ton 

w/o fuel

$28 $26 $26 N/A

$/metric ton 

w/ fuel

-$280 -$290 -$290 N/A

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an 

explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see 

Preamble Section X.A.1

11.2.2.2 Vocational Vehicles

Table 11-27 presents a summary of all costs and benefits for each vocational program 

alternative relative to the Alternative 1a baseline case. Table 11-28 shows cost per ton of GHG 

reduced.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-33

Table 11-27 Monetized Net Benefits Associated with Each Alternative Relative to the Less Dynamic Baseline

and using Method B

Vocational Vehicles

(Billions of 2012$, Except GHG Reductions)

a, b

ALT.1

BASELI

NE

ALT.2

LESS 

STRING

ENT

ALT.3

PREFER

RED

ALT.4 ALT.5

MORE 

STRINGE

NT

2035 Vehicle Program

Costsc

$0 -$0.2 -$2.1 -$2.1 N/A

Maintenance costs $0 -$0.02 -$0.03 -$0.04 N/A

Fuel Expenditures

(pretax)

$0 $1.3 $4.7 $5.1 $7.6

Benefits $0 $1.1 $2.6 $2.8 $3.9

Net Benefits $0 $2.2 $5.2 $5.8

GHG Reductions 

(MMT)

0 4.7 16.1 17.4 25.8

2050 Vehicle Program

Costsc

$0 -$0.3 -$2.4 -$2.4 N/A

Maintenance costs $0 -$0.02 -$0.03 -$0.04 N/A

Fuel Expenditures

(pretax)

$0 $2.0 $7.3 $7.3 $10.7

Benefits $0 $1.7 $4.2 $4.2 $5.9

Net Benefits $0 $3.4 $9.0 $9.1 N/A

GHG Reductions 

(MMT)

0 6.5 23.2 23.3 33.9

NPV, 

3%

Vehicle Program

Costsc

$0 -$3.6 -$29.6 -$32.8 N/A

Maintenance costs $0 -$0.22 -$0.42 -$0.52 N/A

Fuel Expenditures

(pretax)

$0 $16.9 $60.6 $66.3 $99.9

Benefits $0 $14.8 $34.8 $37.4 $52.7

Net Benefits $0 $27.9 $65.4 $70.3 N/A

NPV, 

7%

Vehicle Program

Costsc

$0 -$1.7 -$13.8 -$16.0 N/A

Maintenance costs $0 -$0.10 -$0.19 -$0.24 N/A

Fuel Expenditures

(pretax)

$0 $6.9 $24.7 $27.9 $42.5

Benefits $0 $8.3 $21.5 $23.4 $33.8

Net Benefits $0 $13.4 $32.2 $35.0 N/A

Notes: 

a Benefits and net impacts calculated using the 3% average Social Cost of CO2 value. The net present value 

of reduced CO2 emissions is calculated differently than other benefits. The same discount rate used to 

discount the value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net 

present value of SCC for internal consistency. Refer to the SCC TSD for more detail. 

b

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an explanation of 

the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see Preamble Section X.A.1

c Vehicle program costs include compliance costs and R&D.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-34

Table 11-28 Annual Cost per Metric Ton of CO2eq Emissions Reduced in Each Control Case Alternative

Vs. the Less Dynamic Baseline and using Method B

Vocational Vehicles

(Dollar Values are 2012$) a

YEAR ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 ALT.5 

MORE 

STRINGENT

2035 $/metric ton 

w/o fuel

$53 $130 $120 N/A

$/metric ton 

w/ fuel

-$230 -$160 -$170 N/A

2050 $/metric ton 

w/o fuel

$44 $110 $110 N/A

$/metric ton 

w/ fuel

-$260 -$210 -$210 N/A

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for 

an explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please 

see Preamble Section X.A.1

11.2.2.3 HD Pickups and Vans

Table 11-29 presents a summary of all costs and benefits for each HD pickup and van 

program alternative relative to the Alternative 1a baseline case. Table 11-30 shows cost per ton 

of GHG reduced.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-35

Table 11-29 Monetized Net Benefits Associated with Each Alternative Relative to the Less Dynamic Baseline

and using Method B

HD Pickups and Vans

(Billions of 2012$, Except GHG Reductions)

a, b

ALT.1

BASELI

NE

ALT.2

LESS 

STRING

ENT

ALT.3

PREFER

RED

ALT.4

MORE 

STRINGE

NT

ALT.5

MORE 

STRINGE

NT

2035 Vehicle Program

Costsc

$0 -$0.5 -$0.9 -$1.2 N/A

Maintenance costs $0 -$0.01 -$0.01 -$0.01 N/A

Fuel Expenditures

(pretax)

$0 $2.5 $4.2 $4.4 $5.0

Benefits $0 $1.4 $2.2 $2.3 $2.6

Net Benefits $0 $3.4 $5.5 $5.5 N/A

GHG Reductions 

(MMT)

0 8.1 13.9 14.6 16.6

2050 Vehicle Program

Costsc

$0 -$0.5 -$1.0 -$1.4 N/A

Maintenance costs $0 -$0.01 -$0.01 -$0.01 N/A

Fuel Expenditures

(pretax)

$0 $3.5 $6.3 $6.3 $7.2

Benefits $0 $2.1 $3.5 $3.5 $4.0

Net Benefits $0 $5.1 $8.7 $8.4 N/A

GHG Reductions 

(MMT)

0 10.8 19.3 19.4 22.1

NPV, 

3%

Vehicle Program

Costsc

$0 -$7.5 -$13.5 -$19.6 N/A

Maintenance costs $0 -$0.18 -$0.18 -$0.18 N/A

Fuel Expenditures

(pretax)

$0 $31.4 $53.5 $56.8 $64.9

Benefits $0 $18.7 $29.2 $30.7 $34.6

Net Benefits $0 $42.4 $69.1 $67.7 N/A

NPV, 

7%

Vehicle Program

Costsc

$0 -$3.7 -$6.5 -$9.7 N/A

Maintenance costs $0 -$0.08 -$0.08 -$0.08 N/A

Fuel Expenditures

(pretax)

$0 $13.1 $21.9 $23.7 $27.1

Benefits $0 $11.4 $18.2 $19.3 $21.8

Net Benefits $0 $20.7 $33.5 $33.2 N/A

Notes: 

a Benefits and net impacts calculated using the 3% average Social Cost of CO2 value. The net present value 

of reduced CO2 emissions is calculated differently than other benefits. The same discount rate used to 

discount the value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net 

present value of SCC for internal consistency. Refer to the SCC TSD for more detail. 

b

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an explanation of 

the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see Preamble Section X.A.1

c Vehicle program costs include compliance costs and R&D.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-36

Table 11-30 Annual Cost per Metric Ton of CO2eq Emissions Reduced in Each Control Case Alternative

Vs. the Less Dynamic Baseline and using Method B

HD Pickups and Vans

(Dollar Values are 2012$) a

YEAR ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4

MORE 

STRINGENT

ALT.5 

MORE 

STRINGENT

2035 $/metric ton 

w/o fuel

$59 $65 $84 N/A

$/metric ton 

w/ fuel

-$240 -$240 -$220 N/A

2050 $/metric ton 

w/o fuel

$51 $53 $73 N/A

$/metric ton 

w/ fuel

-$270 -$270 -$250 N/A

Note:

a

For an explanation of analytical Methods A and B, please see Preamble Section I.D; for an 

explanation of the less dynamic baseline, 1a, and more dynamic baseline, 1b, please see 

Preamble Section X.A.1

11.3 Detailed Technology Projections for Each Category

The alternatives were developed to reflect different levels of technology (in terms of 

effectiveness, adoption rate, and timing) that would be required to meet increasing levels of 

stringency. For each of these alternatives, the agencies projected a fleet mix of technologies that 

would be capable of meeting the standards. These projections are summarized below for each 

category. Note that for trailers, the alternatives differ in terms of which trailers would be subject 

to the standards, in addition to the level of technology necessary to the meet the standards. Note 

also that the same technology projections applied for both Method A and Method B. Details 

regarding the preferred alternative are included in Chapter 2 of this draft RIA (Sections 2.5-

2.10). 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-37

11.3.1 Tractor Technology

Table 11-31 Alternative 2 2021MY Technology Adoption Rates for Tractors

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 2 Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Aerodynamics 

Bin I 10% 10% 0% 10% 10% 0% 10% 10% 0%

Bin II 80% 80% 0% 80% 80% 0% 80% 80% 0%

Bin III 10% 10% 45% 10% 10% 45% 10% 10% 45%

Bin IV 0% 0% 35% 0% 0% 35% 0% 0% 35%

Bin V 20% 20% 20%

Bin VI 0% 0% 0%

Bin VII 0% 0% 0%

Steer Tires 

Base 15% 15% 5% 15% 15% 5% 15% 15% 15%

Level 1 60% 60% 65% 60% 60% 65% 60% 60% 65%

Level 2 25% 25% 30% 25% 25% 30% 25% 25% 20%

Level 3 0% 0% 0% 0% 0% 0% 0% 0% 0%

Drive Tires 

Base 15% 15% 5% 15% 15% 5% 15% 15% 5%

Level 1 60% 60% 65% 60% 60% 65% 60% 60% 60%

Level 2 25% 25% 30% 25% 25% 30% 25% 25% 35%

Level 3 0% 0% 0% 0% 0% 0% 0% 0% 0%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 30% 30% 30%

Other N/A N/A N/A N/A N/A N/A 0% 0% 0%

Transmission Type 

Manual 45% 45% 45% 45% 45% 45% 45% 45% 45%

AMT 40% 40% 40% 40% 40% 40% 40% 40% 40%

Auto 10% 10% 10% 10% 10% 10% 10% 10% 10%

Dual Clutch 5% 5% 5% 5% 5% 5% 5% 5% 5%

Driveline

Axle 

Lubricant

20% 20% 20% 20% 20% 20% 20% 20% 20%

6x2 or 4x2 

Axle

10% 10% 20% 10% 10% 10%

Downspeed 20% 20% 0% 0% 0% 0% 0% 0% 0%

Accessory Improvements 

A/C 10% 10% 10% 10% 10% 10% 10% 10% 10%

Electric 

Access.

10% 10% 10% 10% 10% 10% 10% 10% 10%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-38

Other Technologies 

Predictive 

Cruise 

Control

20% 20% 20% 20% 20% 20% 20% 20% 20%

Automated 

Tire 

Inflation 

System

10% 10% 10% 10% 10% 10% 10% 10% 10%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-39

Table 11-32 Alternative 2 2024MY Technology Adoption Rates for Tractors

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 2 Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Aerodynamics 

Bin I 10% 10% 0% 10% 10% 0% 10% 10% 0%

Bin II 70% 70% 0% 70% 70% 0% 70% 70% 0%

Bin III 20% 20% 35% 20% 20% 35% 20% 20% 35%

Bin IV 0% 0% 45% 0% 0% 45% 0% 0% 45%

Bin V 20% 20% 20%

Bin VI 0% 0% 0%

Bin VII 0% 0% 0%

Steer Tires 

Base 10% 10% 5% 10% 10% 5% 10% 10% 10%

Level 1 60% 60% 60% 60% 60% 60% 60% 60% 60%

Level 2 30% 30% 35% 30% 30% 35% 30% 30% 30%

Level 3 0% 0% 0% 0% 0% 0% 0% 0% 0%

Drive Tires 

Base 10% 10% 5% 10% 10% 5% 10% 10% 5%

Level 1 60% 60% 60% 60% 60% 60% 60% 60% 50%

Level 2 30% 30% 35% 30% 30% 35% 30% 30% 45%

Level 3 0% 0% 0% 0% 0% 0% 0% 0% 0%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 40% 40% 40%

Other N/A N/A N/A N/A N/A N/A 10% 10% 10%

Transmission Type 

Manual 20% 20% 20% 20% 20% 20% 20% 20% 20%

AMT 50% 50% 50% 50% 50% 50% 50% 50% 50%

Auto 20% 20% 20% 20% 20% 20% 20% 20% 20%

Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10%

Driveline

Axle 

Lubricant

40% 40% 40% 40% 40% 40% 40% 40% 40%

6x2 or 4x2 

Axle

20% 20% 20% 20% 20% 20%

Downspeed 0% 0% 0% 0% 0% 0% 0% 0% 0%

Accessory Improvements 

A/C 20% 20% 20% 20% 20% 20% 20% 20% 20%

Electric 

Access.

20% 20% 20% 20% 20% 20% 20% 20% 20%

Other Technologies 

Predictive 

Cruise 

Control

40% 40% 40% 40% 40% 40% 40% 40% 40%

Automated 20% 20% 20% 20% 20% 20% 20% 20% 20%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-40

Tire 

Inflation 

System
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-41

Table 11-33 Alternative 4Adoption Rates for 2021 MY

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 4 2021MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Aerodynamics 

Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0%

Bin II 65% 65% 0% 65% 65% 0% 65% 65% 0%

Bin III 30% 30% 35% 30% 30% 35% 30% 30% 35%

Bin IV 5% 5% 30% 5% 5% 30% 5% 5% 30%

Bin V 25% 25% 25%

Bin VI 10% 10% 10%

Bin VII 0% 0% 0%

Steer Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 35% 35% 35% 35% 35% 35% 35% 35% 35%

Level 2 45% 45% 45% 45% 45% 45% 45% 45% 45%

Level 3 15% 15% 15% 15% 15% 15% 15% 15% 15%

Drive Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 35% 35% 35% 35% 35% 35% 35% 35% 35%

Level 2 45% 45% 45% 45% 45% 45% 45% 45% 45%

Level 3 15% 15% 15% 15% 15% 15% 15% 15% 15%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 80% 80% 80%

Transmission Type 

Manual 25% 25% 25% 25% 25% 25% 25% 25% 25%

AMT 40% 40% 40% 40% 40% 40% 40% 40% 40%

Auto 30% 30% 30% 30% 30% 30% 30% 30% 30%

Dual Clutch 5% 5% 5% 5% 5% 5% 5% 5% 5%

Driveline 

Axle 

Lubricant

20% 20% 20% 20% 20% 20% 20% 20% 20%

6x2 Axle 10% 10% 20% 10% 10% 30%

Downspeed 30% 30% 30% 30% 30% 30% 30% 30% 30%

Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50%

Accessory Improvements 

A/C 20% 20% 20% 20% 20% 20% 20% 20% 20%

Electric 

Access.

20% 20% 20% 20% 20% 20% 20% 20% 20%

Other Technologies 

Predictive 

Cruise 

Control

30% 30% 30% 30% 30% 30% 30% 30% 30%

Automated 

Tire 

30% 30% 30% 30% 30% 30% 30% 30% 30%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-42

Inflation 

System
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-43

Table 11-34 Alternative 4 Adoption Rates for 2024 MY

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 4 2024 MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Aerodynamics 

Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0%

Bin II 50% 50% 0% 50% 50% 0% 50% 50% 0%

Bin III 40% 40% 20% 40% 40% 20% 40% 40% 20%

Bin IV 10% 10% 20% 10% 10% 20% 10% 10% 20%

Bin V 35% 35% 35%

Bin VI 20% 20% 20%

Bin VII 5% 5% 5%

Steer Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20%

Level 2 50% 50% 50% 50% 50% 50% 50% 50% 50%

Level 3 25% 25% 25% 25% 25% 25% 25% 25% 25%

Drive Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20%

Level 2 50% 50% 50% 50% 50% 50% 50% 50% 50%

Level 3 25% 25% 25% 25% 25% 25% 25% 25% 25%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 100% 100% 100%

Transmission Type 

Manual 0% 0% 0% 0% 0% 0% 0% 0% 0%

AMT 50% 50% 50% 50% 50% 50% 50% 50% 50%

Auto 30% 30% 30% 30% 30% 30% 30% 30% 30%

Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10%

Driveline

Axle Lubricant 40% 40% 40% 40% 40% 40% 40% 40% 40%

6x2 Axle 20% 20% 60% 20% 20% 60%

Downspeed 60% 60% 60% 60% 60% 60% 60% 60% 60%

Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50%

Accessory Improvements 

A/C 30% 30% 30% 30% 30% 30% 30% 30% 30%

Electric Access. 30% 30% 30% 30% 30% 30% 30% 30% 30%

Other Technologies 

Predictive 

Cruise Control

40% 40% 40% 40% 40% 40% 40% 40% 40%

Automated Tire 

Inflation 

System

40% 40% 40% 40% 40% 40% 40% 40% 40%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-44

Table 11-35 Alternative 5 Adoption Rates for 2021 MY

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 5 2021 MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Additional 

Waste Heat 

Recovery

10% 10% 10%

Aerodynamics 

Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0%

Bin II 50% 50% 0% 50% 50% 0% 50% 50% 0%

Bin III 40% 40% 20% 40% 40% 20% 40% 40% 20%

Bin IV 10% 10% 20% 10% 10% 20% 10% 10% 20%

Bin V 35% 35% 35%

Bin VI 20% 20% 20%

Bin VII 5% 5% 5%

Steer Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 30% 30% 30% 30% 30% 30% 30% 30% 20%

Level 2 40% 40% 40% 40% 40% 40% 40% 40% 40%

Level 3 25% 25% 25% 25% 25% 25% 25% 25% 35%

Drive Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 30% 30% 30% 30% 30% 30% 30% 30% 20%

Level 2 40% 40% 40% 40% 40% 40% 40% 40% 40%

Level 3 25% 25% 25% 25% 25% 25% 25% 25% 35%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 100% 100% 100%

Transmission Type 

Manual 0% 0% 0% 0% 0% 0% 0% 0% 0%

AMT 50% 50% 50% 50% 50% 50% 50% 50% 50%

Auto 40% 40% 40% 40% 40% 40% 40% 40% 40%

Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10%

Driveline

Axle 

Lubricant

40% 40% 40% 40% 40% 40% 40% 40% 40%

6x2 Axle 20% 20% 20% 20% 20% 30%

Downspeed 60% 60% 60% 60% 60% 60% 60% 60% 60%

Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50%

Accessory Improvements 

A/C 30% 30% 30% 30% 30% 30% 30% 30% 30%

Electric 

Access.

30% 30% 30% 30% 30% 30% 30% 30% 30%

Other Technologies 

Predictive 

Cruise 

40% 40% 40% 40% 40% 40% 40% 40% 40%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-45

Control

Automated 

Tire Inflation 

System

40% 40% 40% 40% 40% 40% 40% 40% 40%

Hybrid 

Powertrain 

with 

Electrified 

Accessories

20% 20% 20% 20% 20% 20% 20% 20% 20%

Weight 

Reduction 

(lbs)

1,200 1,200 1,200 1,200 1,200 1,200 1,200 1,200 1,200

Table 11-36 Alternative 5 Adoption Rates for 2024 MY

CLASS 7 CLASS 8

Day Cab Day Cab Sleeper Cab

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Low 

Roof

Mid 

Roof

High 

Roof

Alternative 5 2024 MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100%

Additional 

Waste Heat 

Recovery

10% 10% 10%

Aerodynamics 

Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0%

Bin II 40% 40% 0% 40% 40% 0% 40% 40% 0%

Bin III 50% 50% 15% 50% 50% 15% 50% 50% 15%

Bin IV 10% 10% 15% 10% 10% 15% 10% 10% 15%

Bin V 35% 35% 35%

Bin VI 25% 25% 25%

Bin VII 10% 10% 10%

Steer Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20%

Level 2 40% 40% 40% 40% 40% 40% 40% 40% 40%

Level 3 35% 35% 35% 35% 35% 35% 35% 35% 35%

Drive Tires 

Base 5% 5% 5% 5% 5% 5% 5% 5% 5%

Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20%

Level 2 40% 40% 40% 40% 40% 40% 40% 40% 40%

Level 3 35% 35% 35% 35% 35% 35% 35% 35% 35%

Extended Idle Reduction 

APU N/A N/A N/A N/A N/A N/A 100% 100% 100%

Transmission Type 

Manual 0% 0% 0% 0% 0% 0% 0% 0% 0%

AMT 50% 50% 50% 50% 50% 50% 50% 50% 50%

Auto 40% 40% 40% 40% 40% 40% 40% 40% 40%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-46

Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10%

Driveline

Axle 

Lubricant

40% 40% 40% 40% 40% 40% 40% 40% 40%

6x2 Axle 20% 20% 60% 20% 20% 60%

Downspeed 60% 60% 60% 60% 60% 60% 60% 60% 60%

Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50%

Accessory Improvements 

A/C 30% 30% 30% 30% 30% 30% 30% 30% 30%

Electric 

Access.

30% 30% 30% 30% 30% 30% 30% 30% 30%

Other Technologies 

Predictive 

Cruise 

Control

40% 40% 40% 40% 40% 40% 40% 40% 40%

Automated 

Tire 

Inflation 

System

40% 40% 40% 40% 40% 40% 40% 40% 40%

Hybrid 

Powertrain 

with 

Electrified 

Accessories

40% 40% 40% 40% 40% 40% 40% 40% 40%

Weight 

Reduction 

(lbs)

1,200 1,200 1,200 1,200 1,200 1,200 1,200 1,200 1,200
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-47

11.3.2 Trailer Technology

Table 11-37 Alternative 1 Trailer Adoption Rates

TECHNOLOGY LONG BOX

DRY & REFRIGERATED VANS

SHORT BOX, 

NON-AERO BOX, 

& NON-BOX TRAILERS

Model Year 2018 2021 2024 2027 2040a2018+

Aerodynamics

Bin I 45% 41% 38% 35% 20% 100%

Bin II - - - - -

Bin III 20% 20% 20% 20% 20% -

Bin IV 30% 34% 37% 40% 55% -

Bin V 5% 5% 5% 5% 5% -

Bin VI - - - - - -

Bin VII - - - - -

Bin VIII - - - - - -

Avg Delta CdA (m2) 0.2 0.3 0.3 0.3 0.4 0.0

Tire Rolling Resistance

Level 1 tires 50% 47% 43% 40% 25% 100%

Level 2 tires 50% 53% 57% 60% 75% -

Level 3 tires - - - - - -

Avg CRR (kg/ton) 5.6 5.5 5.5 5.5 5.3 6.0

Tire Inflation

ATI 50% 53% 57% 60% 75% 0%

Avg % Reduction 0.8% 0.8% 0.9% 0.9% 1.1% 0.0%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0

Note:

a Considered in Alternative 1b only
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-48

Table 11-38 Alternative 2 Trailer Adoption Rates

TECHNOLOGY LONG BOX

DRY & REFRIGERATED VANS

SHORT BOX, 

NON-AERO BOX, 

& NON-BOX TRAILERS

Model Year 2018 2021 2024 2018+

Aerodynamics

Bin I 5% 5% 5% 100%

Bin II -

Bin III 30% 20% 10% -

Bin IV 60% 70% 75% -

Bin V 5% 5% 10% -

Bin VI - - - -

Bin VII - - - -

Bin VIII - - - -

Avg Delta CdA (m2) 0.4 0.4 0.5 0.0

Tire Rolling Resistance

Level 1 tires 15% 10% 5% 100%

Level 2 tires 85% 90% -

Level 3 tires 95% -

Avg CRR (kg/ton) 5.2 5.2 4.8 6.0

Tire Inflation

ATI 85% 90% 95% 0%

Avg % Reduction 1.3% 1.4% 1.4% 0.0%

Weight Reduction (pounds)

Weight 0 0 0 0

Table 11-39 Alternative 3 Long Box Trailer Adoption Rates

TECHNOLOGY LONG BOX

DRY VANS

LONG BOX

REFRIGERATED VANS

Model Year 2018 2021 2024 2027 2018 2021 2024 2027

Aerodynamic Technologies

Bin I 5% - - - 5% - - -

Bin II - - - - - - - -

Bin III 30% 5% - - 30% 5% - -

Bin IV 60% 55% 25% - 60% 55% 25% -

Bin V 5% 10% 10% 10% 5% 10% 10% 20%

Bin VI - 30% 65% 50% - 30% 65% 60%

Bin VII - - - 40% - - - 20%

Bin VIII - - - - - - - -

Avg Delta CdA (m2) 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 5% 15% 5% 5% 5%

Level 2 tires 85% 95% - - 85% 95% - -

Level 3 tires - - 95% 95% - - 95% 95%

Avg CRR (kg/ton) 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8

Tire Inflation System

ATI 85% 95% 95% 95% 85% 95% 95% 95%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0 0 0
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-49

Table 11-40 Alternative 3 Short Box Trailer Adoption Rates

TECHNOLOGY SHORT BOX

DRY VANS

SHORT BOX

REFRIGERATED VANS

Model Year 2018 2021 2024 2027 2018 2021 2024 2027

Aerodynamic Technologies

Bin I 100% 5% - - 100% 5% - -

Bin II - 95% 70% 30% - 95% 70% 55%

Bin III - - 30% 60% - - 30% 40%

Bin IV - - - 10% - - - 5%

Bin V - - - - - - - -

Bin VI - - - - - - - -

Bin VII - - - - - - - -

Bin VIII - - - - - - - -

Avg Delta CdA (m2) 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 5% 15% 5% 5% 5%

Level 2 tires 85% 95% - - 85% 95% - -

Level 3 tires - - 95% 95% - - 95% 95%

Avg CRR (kg/ton) 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8

Tire Inflation System

ATI 85% 95% 95% 95% 85% 95% 95% 95%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0 0 0

Table 11-41 Alternative 3 Non-Aero Box and Non-Box Trailer Adoption Rates

TECHNOLOGY NON-AERO BOX

& NON-BOX TRAILERS

Model Year 2018 2021 2024 2027

Aerodynamic Technologies

Bin I 100% 100% 100% 100%

Bin II - - - -

Bin III - - - -

Bin IV - - - -

Bin V - - - -

Bin VI - - - -

Bin VII - - - -

Bin VIII - - - -

Avg Delta CdA (m2) 0.0 0.0 0.0 0.0

Trailer Tire Rolling Resistance

Level 1 tires - - - -

Level 2 tires 100% 100% - -

Level 3 tires - - 100% 100%

Avg CRR (kg/ton) 5.1 5.1 4.7 4.7

Tire Inflation System

ATI 100% 100% 100% 100%

Avg ATI Reduction (%) 1.5% 1.5% 1.5% 1.5%

Weight Reduction (pounds)

Weight 0 0 0 0
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-50

Table 11-42 Alternative 4 Long Box Trailer Adoption Rates

TECHNOLOGY LONG BOX

DRY VANS

LONG BOX

REFRIGERATED VANS

Model Year 2018 2021 2024 2018 2021 2024

Aerodynamic Technologies

Bin I 5% - - 5% - -

Bin II - - - - - -

Bin III 30% - - 30% - -

Bin IV 60% 25% - 60% 25% -

Bin V 5% 10% 10% 5% 10% 20%

Bin VI - 65% 50% - 65% 60%

Bin VII - - 40% - - 20%

Bin VIII - - - - - -

Avg Delta CdA (m2) 0.4 0.8 1.1 0.4 0.8 1.0

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 15% 5% 5%

Level 2 tires 85% 95% - 85% 95% -

Level 3 tires - - 95% - - 95%

Avg CRR (kg/ton) 5.2 5.1 4.8 5.2 5.1 4.8

Tire Inflation System

ATI 85% 95% 95% 85% 95% 95%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.3% 1.4% 1.4%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0

Table 11-43 Alternative 4 Short Box Trailer Adoption Rates

TECHNOLOGY SHORT BOX

DRY VANS

SHORT BOX

REFRIGERATED VANS

Model Year 2018 2021 2024 2018 2021 2024

Aerodynamic Technologies

Bin I 100% - - 100% - -

Bin II - 70% 30% - 70% 55%

Bin III - 30% 60% - 30% 40%

Bin IV - - 10% - - 5%

Bin V - - - - - -

Bin VI - - - - - -

Bin VII - - - - - -

Bin VIII - - - - - -

Avg Delta CdA (m2) 0.4 0.8 1.1 0.4 0.8 1.0

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 15% 5% 5%

Level 2 tires 85% 95% - 85% 95% -

Level 3 tires - - 95% - - 95%

Avg CRR (kg/ton) 5.2 5.1 4.8 5.2 5.1 4.8

Tire Inflation System

ATI 85% 95% 95% 85% 95% 95%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.3% 1.4% 1.4%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-51

Table 11-44 Alternative 4 Non-Aero Box and Non-Box Trailer Adoption Rates

TECHNOLOGY NON-AERO BOX

& NON-BOX TRAILERS

Model Year 2018 2021 2024

Aerodynamic Technologies

Bin I 100% 100% 100%

Bin II - - -

Bin III - - -

Bin IV - - -

Bin V - - -

Bin VI - - -

Bin VII - - -

Bin VIII - - -

Avg Delta CdA (m2) 0.0 0.0 0.0

Trailer Tire Rolling Resistance

Level 1 tires - - -

Level 2 tires 100% 100% -

Level 3 tires - - 100%

Avg CRR (kg/ton) 5.1 5.1 4.7

Tire Inflation System

ATI 100% 100% 100%

Avg ATI Reduction (%) 1.5% 1.5% 1.5%

Weight Reduction (pounds)

Weight 0 0 0

Table 11-45 Alternative 5 Box Trailer Adoption Rates

TECHNOLOGY LONG BOX

DRY VANS

LONG BOX

REFRIGERATED VANS

SHORT BOX DRY & 

REFRIGERATED VANS

Model Year 2018 2021 2024 2018 2021 2024 2018 2021 2024

Aerodynamic Technologies

Bin I 5% - - 5% 0% 0% 100% - -

Bin II - - - - - - - 65% 10%

Bin III 5% - - 5% - - - 25% 90%

Bin IV 55% 15% - 55% 15% - - - -

Bin V 10% - 10% - - - - -

Bin VI 25% 85% 10% 25% 85% 100% - - -

Bin VII - - 90% - - - - - -

Bin VIII - - - - - - - - -

Avg Delta CdA (m2) 0.6 0.9 1.4 0.6 0.9 1.0 0.0 0.1 0.3

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 15% 5% 5% 15% 5% 5%

Level 2 tires 85% 95% - 85% 95% - 85% 95% -

Level 3 tires - - 95% - - 95% - - 95%

Avg CRR (kg/ton) 5.2 5.1 4.8 5.2 5.1 4.8 5.2 5.1 4.8

Tire Inflation System

ATI 85% 95% 95% 85% 95% 95% 85% 95% 95%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.3% 1.4% 1.4% 1.3% 1.4% 1.4%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0 0 0 0
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-52

Table 11-46 Alternative 5 Non-Box Trailer Adoption Rates

TECHNOLOGY CONTAINER

CHASSIS

FLATBED TANKS NON-AERO BOX

& OTHER NONBOX

Model Year 2018 2021 2024 2018 2021 2024 2018 2021 2024 2018 2021 2024

Aerodynamic Technologies

Bin I 100% 80% 30% 100% 80% 30% 100% 67% 0% 100% 100% 100%

Bin II - - - - - - - - - - - -

Bin III - 20% 55% - 20% 55% - 33% - - - -

Bin IV - - 15% - - 15% - - 100% - - -

Bin V - - - - - - - - - - - -

Bin VI - - - - - - - - - - - -

Bin VII - - - - - - - - - - - -

Bin VIII - - - - - - - - - - - -

Avg Delta CdA (m2) 0.0 0.1 0.2 0.0 0.1 0.2 0.0 0.1 0.5 0.0 0.0 0.0

Trailer Tire Rolling Resistance

Level 1 tires 15% 5% 5% 15% 5% 5% 15% 5% 5% - - -

Level 2 tires 85% 95% - 85% 95% - 85% 95% - 100% 100% -

Level 3 tires - - 95% - - 95% - - 95% - - 100%

Avg CRR (kg/ton) 5.2 5.1 4.8 5.2 5.1 4.8 5.2 5.1 4.8 5.1 5.1 4.7

Tire Inflation System

ATI 85% 95% 95% 85% 95% 95% 85% 95% 95% 100% 100% 100%

Avg ATI Reduction (%) 1.3% 1.4% 1.4% 1.3% 1.4% 1.4% 1.3% 1.4% 1.4% 1.5% 1.5% 1.5%

Weight Reduction (pounds)

Weight 0 0 0 0 0 0 0 0 0 0 0 0

11.3.3 Vocational Vehicle Technology

Table 11-47 Alternative 2 Technology Adoption Rates for All Vocational Subcategories

TECHNOLOGY 2021 2024

HFC Leakage 100% 100%

Axle - Low Friction Lubes 40% 75%

Baseline Drive Tire CRR 50% 30%

Baseline Steer Tire CRR 20% 10%

5% better Drive Tire CRR 50% 70%

10% better Steer Tire CRR 80% 60%

15% better Steer Tire CRR 0% 30%

Neutral-idle 43% 80%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-53

Table 11-48 Alternative 3 Technology Adoption Rates for Vocational Subcategories: LHD, MHD, HHD 

Multipurpose & Urban

TECHNOLOGY 2021 2024 2027

Add Two Trans Gears 5% 5% 5%

HFC Leakage 100% 100% 100%

Axle - Low Friction Lubes 75% 75% 75%

Strong Hybrid 4% 7% 18%

Baseline Drive Tire CRR 50% 20% 10%

Baseline Steer Tire CRR 20% 10% 0%

5% better Drive Tire CRR 50% 50% 25%

10% better Drive Tire CRR 0% 30% 50%

10% better Steer Tire CRR 80% 30% 20%

15% better Drive Tire CRR 0% 0% 15%

15% better Steer Tire CRR 0% 60% 30%

20% better Steer Tire CRR 0% 0% 50%

Neutral-idle 70% 85% 30%

Stop-start 5% 15% 70%

Dual Clutch Transmission 5% 15% 5%

Trans_Improved 15% 30% 70%

200 Pounds Lightweighting 4% 4% 5%

Note: 

a

Idle reduction values in MY 2027 are for multipurpose vehicles. For Urban vehicles, Neutral Idle is 25% and StopStart is 75% in MY 2027.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-54

Table 11-49 Alternative 3 Technology Adoption Rates for Vocational Subcategories: LHD & MHD Regional

TECHNOLOGY 2021 2024 2027

Add Two Trans Gears 5% 5% 5%

HFC Leakage 100% 100% 100%

Axle - Low Friction Lubes 75% 75% 75%

Baseline Drive Tire CRR 50% 20% 10%

Baseline Steer Tire CRR 20% 10% 0%

5% better Drive Tire CRR 50% 50% 25%

10% better Drive Tire CRR 0% 30% 50%

10% better Steer Tire CRR 80% 30% 20%

15% better Drive Tire CRR 0% 0% 15%

15% better Steer Tire CRR 0% 60% 30%

20% better Steer Tire CRR 0% 0% 50%

Neutral-idle 70% 85% 30%

Stop-start 5% 15% 70%

Dual Clutch Transmission 5% 15% 5%

Trans_Improved 15% 30% 70%

200 Pounds Lightweighting 7% 7% 8%

Note: 

a Weight reduction values are given for LHD. For MHD, adoption rates are 6% in MYs 2021 & 2024, and 7% in 

MY 2027.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-55

Table 11-50 Alternative 3 Technology Adoption Rates for Vocational Subcategories: HHD Regional 

TECHNOLOGY 2021 2024 2027

HFC Leakage 100% 100% 100%

Axle 6x2 45% 60% 60%

Axle - Low Friction Lubes 75% 75% 75%

Baseline Drive Tire CRR 50% 20% 10%

Baseline Steer Tire CRR 20% 10% 0%

5% better Drive Tire CRR 50% 50% 25%

10% better Drive Tire CRR 0% 30% 50%

10% better Steer Tire CRR 80% 30% 20%

15% better Drive Tire CRR 0% 0% 15%

15% better Steer Tire CRR 0% 60% 30%

20% better Steer Tire CRR 0% 0% 50%

Automatic Transmission 22% 33% 25%

Stop-start 0% 15% 70%

Automated Manual Transmission 22% 33% 25%

Dual Clutch Transmission 22% 33% 25%

Trans_Improved 15% 30% 70%

200 Pounds Lightweighting 5% 5% 6%

Notes: 

a Adoption rates of Automatic, AMT, and DCT transmissions include those that would certify using GEM plus those 

that would certify using the powertrain test as improved/integrated.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-56

Table 11-51 Alternative 4 Technology Adoption Rates for Vocational Subcategories: LHD, MHD, HHD 

Multipurpose & Urban

Technology 2021 2024

Add Two Trans Gears 11% 10%

HFC Leakage 100% 100%

Axle - Low Friction Lubes 75% 75%

Strong Hybrid 9% 18%

Baseline Drive Tire CRR 50% 10%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 25%

10% better Drive Tire CRR 0% 50%

10% better Steer Tire CRR 80% 20%

15% better Drive Tire CRR 0% 15%

15% better Steer Tire CRR 0% 30%

20% better Steer Tire CRR 0% 50%

Neutral-idle 88% 30%

Stop-start 12% 70%

Dual Clutch Transmission 10% 10%

Trans_improved 25% 70%

200 Pounds Lightweighting 4% 5%

Note: 

1 Idle reduction values in MY 2024 are for multipurpose vehicles. For Urban vehicles, Neutral Idle is 25% and StopStart is 75% in MY 2024.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-57

Table 11-52 Alternative 4 Technology Adoption Rates for Vocational Subcategories: LHD & MHD Regional

TECHNOLOGY 2021 2024

Add Two Trans Gears 11% 10%

HFC Leakage 100% 100%

Axle - Low Friction Lubes 75% 75%

Baseline Drive Tire CRR 50% 10%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 25%

10% better Drive Tire CRR 0% 50%

10% better Steer Tire CRR 80% 20%

15% better Drive Tire CRR 0% 15%

15% better Steer Tire CRR 0% 30%

20% better Steer Tire CRR 0% 50%

Neutral-idle 88% 30%

Stop-start 12% 70%

Dual Clutch Transmission 10% 10%

Trans_improved 25% 70%

200 Pounds Lightweighting 7% 8%

Note: 

1 Weight reduction values are given for LHD. For MHD, adoption rates are 6% in MY 2021 & 7% in MY 2024.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-58

Table 11-53 Alternative 4 Technology Adoption Rates for Vocational Subcategories: HHD Regional

TECH 2021 2024

HFC Leakage 100% 100%

Axle 6x2 60% 60%

Axle - Low Friction Lubes 75% 75%

Baseline Drive Tire CRR 50% 10%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 25%

10% better Drive Tire CRR 0% 50%

10% better Steer Tire CRR 80% 20%

15% better Drive Tire CRR 0% 15%

15% better Steer Tire CRR 0% 30%

20% better Steer Tire CRR 0% 50%

Automatic Transmission 15% 25%

Stop-start 0% 70%

Automated Manual Transmission 15% 25%

Dual Clutch Transmission 15% 25%

Trans_improved 25% 70%

200 Pounds Lightweighting 5% 6%

Notes: 

1 Adoption rates of Automatic, AMT, and DCT transmissions include those that would certify using GEM plus 

those that would certify using the powertrain test as improved/integrated.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-59

Table 11-54 Alternative 5 Technology Adoption Rates for Vocational Subcategories: LHD Regional, LHD & 

HHD Multipurpose, LHD & HHD Urban

TECH 2021 2024

Add Two Trans Gears 16% 11%

HFC Leakage 100% 100%

Axle - Low Friction Lubes 100% 100%

Electric Vehicle 3% 3%

Strong Hybrid 27% 36%

Baseline Drive Tire CRR 50% 0%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 10%

10% better Drive Tire CRR 0% 45%

10% better Steer Tire CRR 80% 0%

15% better Drive Tire CRR 0% 45%

15% better Steer Tire CRR 0% 20%

20% better Steer Tire CRR 0% 80%

Neutral-idle 60% 40%

Stop-start 40% 60%

Dual Clutch Transmission 10% 5%

Trans_improved 35% 60%

Notes: 

1 Strong Hybrid is zero for the LHD Regional subcategory
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-60

Table 11-55 Alternative 5 Technology Adoption Rates for Vocational Subcategories: MHD Regional, MHD 

Multipurpose, & MHD Urban

TECHNOLOGY 2021 2024

Add Two Trans Gears 16% 11%

HFC Leakage 100% 100%

Axle - Low Friction Lubes 100% 100%

Electric Vehicle 3% 3%

Strong Hybrid 27% 36%

Baseline Drive Tire CRR 50% 0%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 10%

10% better Drive Tire CRR 0% 45%

10% better Steer Tire CRR 80% 0%

15% better Drive Tire CRR 0% 45%

15% better Steer Tire CRR 0% 20%

20% better Steer Tire CRR 0% 80%

Neutral-idle 60% 40%

Stop-start 40% 60%

Dual Clutch Transmission 10% 5%

Trans_improved 35% 60%

1,000 Pounds Lightweighting 28% 42%

Note: 

1 Strong Hybrid is zero for the MHD Regional subcategory
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-61

Table 11-56 Alternative 5 Technology Adoption Rates for Vocational Subcategories: HHD Regional

TECHNOLOGY 2021 2024

HFC Leakage 100% 100%

Axle_disconnect 61% 61%

Axle - Low Friction Lubes 100% 100%

Baseline Drive Tire CRR 50% 0%

Baseline Steer Tire CRR 20% 0%

5% better Drive Tire CRR 50% 10%

10% better Drive Tire CRR 0% 45%

10% better Steer Tire CRR 80% 0%

15% better Drive Tire CRR 0% 45%

15% better Steer Tire CRR 0% 20%

20% better Steer Tire CRR 0% 80%

Automatic Transmission 33% 33%

Stop-start 40% 60%

Automated Manual Transmission 33% 33%

Dual Clutch Transmission 33% 33%

Trans_improved 29% 34%

Note: 

1 Adoption rates of Automatic, AMT, and DCT transmissions include those that would certify using GEM plus 

those that would certify using the powertrain test as improved/integrated.

11.3.4 Pickup and Van Technology

11.3.4.1 Pickup and Van Technology for Method A

This section describes the penetration of selected technologies across the whole fleet, as 

well as across the fleet of the manufacturers as a percentage of the respective fleet. The model 

year represented for the Method A technology penetration is 2030.

Table 11-57 presents the fleet profile for the total industry as well as for each 

manufacturer showing total sales of HD vans and pickups, as well as share of different vehicle 

types within that total.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-62

Table 11-57 Fleet Profile for Model Year 2030 under Method A using the Dynamic Baseline

Overall 

Fleet Daimler Fiat Ford

General 

Motors Nissan

Total Vehicles Sales 755,787 24,188 110,622 335,385 272,441 13,152

Van Share 39.3% 100.0% 20.6% 41.4% 35.9% 100.0%

Pickup Share 60.7% 0.0% 79.4% 58.6% 64.1% 0.0%

Gasoline Share 56.4% 0.0% 40.1% 57.8% 64.3% 100.0%

Diesel Share 43.6% 100.0% 59.9% 42.2% 35.7% 0.0%

Gasoline Van Share 32.3% 0.0% 17.2% 34.0% 35.9% 100.0%

Diesel Van Share 6.9% 100.0% 3.3% 7.4% 0.0% 0.0%

Gasoline Pickup Share 24.1% 0.0% 22.8% 23.7% 28.4% 0.0%

Diesel Pickup Share 36.6% 0.0% 56.6% 34.9% 35.7% 0.0%

Table 11-58 presents the total penetration rates for select technologies in 2030 for the entire fleet. Table 11-59

through 
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11-63

Table 11-63 present the penetration rates for the same technologies for each

manufacturer.

Table 11-58 Technology Penetration Rates for the Overall Fleet in Model Year 2030 under Method A using 

the Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per 

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 25% 56% 56% 49% 49%

Engine friction 

reduction 29% 94% 94% 87% 87%

Cylinder 

deactivation 10% 29% 21% 21% 21%

Variable valve 

timing 19% 19% 19% 19% 19%

Gasoline direct 

injection 14% 17% 25% 31% 32%

Turbo Machinery 

Improvements 38% 38% 38% 38% 53%

8 speed 

transmission 33% 67% 96% 96% 97%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 23% 78% 78% 75%

Mass reduction 

and materials 0% 36% 38% 65% 65%

Electric power 

steering 24% 50% 92% 78% 76%

Improved 

accessories 22% 23% 63% 58% 73%

Stop/start engine 

systems 0% 0% 0% 3% 14%

Mild hybrid 0% 0% 0% 12% 34%

Strong hybrid 0% 0% 8% 13% 16%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-64

Table 11-59 Technology Penetration Rates for the Daimler in Model Year 2030 under Method A using the 

Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per 

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 0% 0% 0% 0% 0%

Engine friction 

reduction 44% 44% 44% 44% 44%

Cylinder 

deactivation 0% 0% 0% 0% 0%

Variable valve 

timing 0% 0% 0% 0% 0%

Gasoline direct 

injection 0% 0% 0% 0% 0%

Turbo Machinery 

Improvements 44% 44% 44% 44% 44%

8 speed 

transmission 0% 0% 44% 44% 100%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 0% 0% 0% 0%

Mass reduction 

and materials 0% 0% 0% 0% 0%

Electric power 

steering 0% 0% 0% 0% 0%

Improved 

accessories 0% 0% 0% 0% 0%

Stop/start engine 

systems 0% 0% 0% 0% 0%

Mild hybrid 0% 0% 0% 0% 0%

Strong hybrid 0% 0% 0% 0% 0%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-65

Table 11-60 Technology Penetration Rates for the Fiat in Model Year 2030 under Method A using the 

Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per 

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 0% 40% 40% 40% 40%

Engine friction 

reduction 18% 97% 97% 97% 97%

Cylinder 

deactivation 13% 23% 23% 23% 23%

Variable valve 

timing 17% 17% 17% 17% 17%

Gasoline direct 

injection 0% 17% 17% 17% 17%

Turbo Machinery 

Improvements 57% 57% 57% 57% 57%

8 speed 

transmission 48% 65% 88% 88% 88%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 0% 100% 100% 79%

Mass reduction 

and materials 0% 0% 100% 100% 100%

Electric power 

steering 0% 0% 100% 100% 83%

Improved 

accessories 0% 0% 63% 63% 72%

Stop/start engine 

systems 0% 0% 0% 0% 0%

Mild hybrid 0% 0% 0% 0% 0%

Strong hybrid 0% 0% 3% 3% 12%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-66

Table 11-61 Technology Penetration Rates for the Ford in Model Year 2030 under Method A using the 

Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per 

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 0% 58% 58% 41% 41%

Engine friction 

reduction 0% 93% 93% 76% 76%

Cylinder 

deactivation 0% 18% 0% 0% 0%

Variable valve 

timing 34% 34% 34% 34% 34%

Gasoline direct 

injection 16% 16% 34% 34% 34%

Turbo Machinery 

Improvements 35% 35% 35% 35% 69%

8 speed 

transmission 59% 100% 100% 100% 100%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 0% 59% 59% 59%

Mass reduction 

and materials 0% 0% 0% 59% 59%

Electric power 

steering 0% 30% 90% 59% 59%

Improved 

accessories 0% 0% 66% 59% 59%

Stop/start engine 

systems 0% 0% 0% 0% 32%

Mild hybrid 0% 0% 0% 0% 8%

Strong hybrid 0% 0% 2% 12% 18%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-67

Table 11-62 Technology Penetration Rates for the General Motors in Model Year 2030 under Method A 

using the Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 64% 64% 64% 64% 64%

Engine friction 

reduction 64% 100% 100% 100% 100%

Cylinder 

deactivation 18% 47% 47% 47% 47%

Variable valve 

timing 0% 0% 0% 0% 0%

Gasoline direct 

injection 18% 18% 18% 36% 36%

Turbo Machinery 

Improvements 36% 36% 36% 36% 36%

8 speed 

transmission 0% 36% 100% 100% 100%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 64% 100% 100% 100%

Mass reduction 

and materials 0% 100% 64% 64% 64%

Electric power 

steering 66% 100% 100% 100% 100%

Improved 

accessories 61% 63% 69% 63% 100%

Stop/start engine 

systems 0% 0% 0% 9% 0%

Mild hybrid 0% 0% 0% 34% 82%

Strong hybrid 0% 0% 19% 20% 18%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-68

Table 11-63 Technology Penetration Rates for the Nissan in Model Year 2030 under Method A using the 

Dynamic Baseline

Alternative 

1a

(0% per 

year)

Alternative 

2

2% per year

Alternative 

3 (2.5% per 

year)

Alternative 

4 

(3.5% per 

year)

Alternative 

5

(4% per 

year)

Low friction 

lubricants 100% 100% 100% 100% 100%

Engine friction 

reduction 100% 100% 100% 100% 100%

Cylinder 

deactivation 100% 49% 49% 49% 49%

Variable valve 

timing 100% 100% 100% 100% 100%

Gasoline direct 

injection 0% 51% 51% 51% 100%

Turbo Machinery

Improvements 0% 0% 0% 0% 0%

8 speed 

transmission 0% 0% 51% 51% 51%

Low rolling 

resistance tires 100% 100% 100% 100% 100%

Aerodynamic drag 

reduction 0% 0% 100% 100% 100%

Mass reduction 

and materials 0% 0% 0% 100% 100%

Electric power 

steering 0% 0% 100% 100% 100%

Improved 

accessories 0% 0% 0% 0% 28%

Stop/start engine 

systems 0% 0% 0% 0% 0%

Mild hybrid 0% 0% 0% 0% 27%

Strong hybrid 0% 0% 0% 0% 1%

11.3.4.2 Pickup and Van Technology for Method B

This section describes the penetration of selected technologies as separated by pickups 

and vans, as well as separated by fuel type (gasoline or diesel) using Method B. The model year 

represented for the technology penetration is 2030.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-69

The technology mix that is projected to be sufficient to meet the 2025/27 standards for 

each pickup and van alternative in the Method B analysis is shown in Table 11-65 through Table 

11-67.

Table 11-64 Technology Penetration Rates for Gasoline Pickups using Method B

ALTERNATIVE 

1A

(0% PER YEAR)

ALTERNATIVE 

2

2% PER YEAR

ALTERNATIVE 

3 (2.5% PER 

YEAR)

ALTERNATIVE 

4 

(3.5% PER 

YEAR)

ALTERNATIVE 

5

(4% PER YEAR)

Low friction 

lubricants

42% 100% 100% 100% 100%

Engine friction 

reduction

42% 100% 100% 100% 100%

Cylinder 

deactivation

8% 56% 56% 56% 56%

Variable valve 

timing

0% 56% 56% 56% 56%

Gasoline direct 

injection

0% 0% 0% 0% 0%

8 speed 

transmission

44% 86% 100% 100% 100%

Low rolling 

resistance tires

0% 100% 100% 100% 100%

Aerodynamic 

drag reduction

0% 42% 100% 100% 100%

Mass reduction 

and materials

0% 42% 56% 100% 100%

Electric power 

steering

42% 86% 100% 100% 100%

Improved 

accessories

41% 41% 86% 86% 92%

Stop/start 

engine systems

0% 0% 0% 20% 7%

Mild hybrid 0% 0% 0% 18% 20%

Strong hybrid 0% 1% 25% 48% 66%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-70

Table 11-65 Technology Penetration Rates for Gasoline Vans using Method B

ALTERNATIVE 

1A

(0% PER YEAR)

ALTERNATIVE 

2

2% PER YEAR

ALTERNATIVE 

3 (2.5% PER 

YEAR)

ALTERNATIVE 

4 

(3.5% PER 

YEAR)

ALTERNATIVE 

5

(4% PER YEAR)

Low friction 

lubricants

45% 100% 100% 100% 100%

Engine friction 

reduction

45% 100% 100% 100% 100%

Cylinder 

deactivation

23% 23% 23% 23% 23%

Variable valve 

timing

40% 40% 40% 40% 40%

Gasoline direct 

injection

42% 52% 77% 97% 100%

8 speed 

transmission

0% 95% 97% 97% 97%

Low rolling 

resistance tires

8% 60% 100% 60% 100%

Aerodynamic 

drag reduction

0% 40% 53% 53% 53%

Mass reduction 

and materials

0% 0% 8% 13% 13%

Electric power 

steering

3% 41% 55% 53% 53%

Improved 

accessories

0% 20% 7% 20% 42%

Stop/start 

engine systems

0% 0% 0% 2% 0%

Mild hybrid 0% 0% 0% 18% 38%

Strong hybrid 0% 0% 7% 0% 4%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-71

Table 11-66 Technology Penetration Rates for Diesel Pickups using Method B

ALTERNATIVE 

1A

(0% PER YEAR)

ALTERNATIVE 

2

2% PER YEAR

ALTERNATIVE 

3 (2.5% PER 

YEAR)

ALTERNATIVE 

4 

(3.5% PER 

YEAR)

ALTERNATIVE 

5

(4% PER YEAR)

Low friction 

lubricants

0% 0% 0% 0% 0%

Engine friction 

reduction

0% 0% 0% 0% 0%

Turbo 

machinery 

improvements

75% 100% 100% 100% 100%

8 speed 

transmission

61% 97% 97% 97% 97%

Low rolling 

resistance tires

0% 100% 100% 100% 100%

Aerodynamic 

drag reduction

0% 35% 100% 100% 100%

Mass reduction 

and materials

0% 35% 58% 100% 100%

Electric power 

steering

35% 53% 100% 100% 100%

Improved 

accessories

33% 35% 100% 100% 100%

Stop/start 

engine systems

0% 0% 0% 11% 31%

Mild hybrid 0% 0% 0% 36% 47%

Strong hybrid 0% 0% 0% 0% 0%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-72

Table 11-67 Technology Penetration Rates for Diesel Vans using Method B

ALTERNATIVE 

1A

(0% PER YEAR)

ALTERNATIVE 

2

2% PER YEAR

ALTERNATIVE 

3 (2.5% PER 

YEAR)

ALTERNATIVE 

4 

(3.5% PER 

YEAR)

ALTERNATIVE 

5

(4% PER YEAR)

Low friction 

lubricants

0% 0% 0% 0% 0%

Engine friction 

reduction

0% 0% 0% 0% 0%

Turbo 

machinery 

improvements

0% 20% 20% 20% 20%

8 speed 

transmission

0% 47% 67% 67% 93%

Low rolling 

resistance tires

7% 80% 54% 54% 100%

Aerodynamic 

drag reduction

0% 0% 7% 7% 7%

Mass reduction 

and materials

0% 0% 7% 7% 7%

Electric power 

steering

0% 11% 21% 12% 12%

Improved 

accessories

0% 0% 7% 7% 7%

Stop/start 

engine systems

0% 0% 0% 0% 0%

Mild hybrid 0% 0% 0% 0% 0%

Strong hybrid 0% 0% 0% 0% 0%
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-73

11.4 Numerical Standards Corresponding to Alternative Technology 

Scenarios

This section summarizes alternative EPA GHG and NHTSA fuel consumption standards 

corresponding to Alternatives 2, 4, and 5, including coefficients for the HD Pickup and Van 

alternative target curves. Note that the proposed standards correspond to Alternative 3.

11.4.1 Alternative 2 Vehicle Standards

Potential EPA GHG and NHTSA fuel consumption standards are shown for Alternative 2 in 

Table 11-68 to Table 11-71 and the coefficients for the HD Pickup and Van target curves for 

Alternative 2 are shown in Table 11-72.

Table 11-68 Alternative 2 Phase 2 Diesel (CI) Vocational Vehicle Standards

2021–2023 MODEL YEAR CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 305 194 205

MultiPurpose314 196 207

Regional 328 192 195

2021–2023 Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 29.9468 19.0615 20.0969

MultiPurpose30.8574 19.2642 20.2999

Regional 32.1726 18.8587 19.1834

2024 and Later Model Year CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 296 187 198

MultiPurpose304 189 200

Regional 317 185 190

2024 and Later Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 29.0602 18.3233 19.4746

MultiPurpose29.8789 18.5280 19.6796

Regional 31.1068 18.2209 18.6547
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-74

Table 11-69 Alternative 2 Phase 2 Gasoline (SI) Vocational Vehicle Standards

2021–2023 MODEL YEAR CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 330 210 221

Multi-Purpose 339 212 223

Regional 353 207 211

2021–2023 Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 37.0853 23.5770 24.8811

Multi-Purpose 38.1283 23.8092 25.1137

Regional 39.7508 23.3446 23.7185

2024–2026 Model Year CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 325 205 217

Multi-Purpose 334 207 219

Regional 348 204 208

2024–2026 Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 36.5703 23.0998 24.4215

Multi-Purpose 37.6252 23.3344 24.6563

Regional 39.1490 22.9826 23.3648
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-75

Table 11-70 Alternative 2 Tractor Standards

2021 MODEL YEAR CO2 GRAMS PER TON-MILE

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 102 82 73

Mid Roof 112 88 81

High Roof 114 90 80

2021 Model Year Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 10.0196 8.055 7.1709

Mid Roof 11.0020 8.6444 7.9568

High Roof 11.1984 8.8409 7.8585

2024 Model Year CO2 Grams per Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 97 77 68

Mid Roof 107 84 76

High Roof 109 85 74

2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 9.5285 7.5639 6.6798

Mid Roof 10.5108 8.2515 7.4656

High Roof 10.7073 8.3497 7.2692

Table 11-71 Alternative 2 Trailer Standards

MODEL 

YEAR

SUBCATEGORY DRY VAN REFRIGERATED VAN

LENGTH LONG SHORT LONG SHORT

2018 – 2020

EPA Standard 

(CO2 Grams per Ton-Mile) 83 147 84 151

Voluntary NHTSA Standard

(Gallons per 1,000 Ton-Mile) 8.1532 14.4401 8.2515 14.8330

2021 – 2023

EPA Standard

(CO2 Grams per Ton-Mile) 82 147 84 151

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 8.0550 14.4401 8.2515 14.8330

2024 – 2026

EPA Standard 

(CO2 Grams per Ton-Mile) 81 147 83 151

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 7.9568 14.4401 8.1532 14.8330
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-76

Table 11-72 Alternative 2 HD Pickup and Van Standard Target Curve Coefficients

Diesel Vehicles

Model Year a b c d

2018-2020 a

0.0416 320 0.0004086 3.143

2021 0.0408 313 0.0004008 3.075

2022 0.0400 307 0.0003929 3.016

2023 0.0392 301 0.0003851 2.957

2024 0.0384 295 0.0003772 2.898

2025 and later 0.0376 289 0.0003694 2.839

Gasoline Vehicles

Model Year a b c d

2018-2020 a0.0440 339 0.0004951 3.815

2021 0.0431 332 0.0004850 3.736

2022 0.0422 325 0.0004749 3.657

2023 0.0414 319 0.0004658 3.590

2024 0.0406 312 0.0004568 3.511

2025 and later 0.0398 306 0.0004478 3.443

Note:

a

Phase 1 primary phase-in coefficients. Alternative phase-in coefficients are different in MY2018 only.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-77

11.4.2 Alternative 4 Vehicle Standards

Potential EPA GHG and NHTSA fuel consumption standards are shown for Alternative 4 in 

Table 11-73 to Table 11-76 and the coefficients for the HD Pickup and Van target curves for 

Alternative 4 are shown in Table 11-77.

Table 11-73 Alternative 4 Phase 2 Diesel (CI) Vocational Vehicle Standards

2021–2023 MODEL YEAR CO2 Grams per 

Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 288 183 193

MultiPurpose297 185 196

Regional 309 181 185

2021–2023 Model Year Gallons of Fuel per 

1,000 Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 28.3890 17.9764 18.8605

MultiPurpose29.0766 18.0747 18.9587

Regional 30.1572 17.6817 17.9764

2024 and Later Model Year CO2 Grams per 

Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 272 172 182

MultiPurpose280 174 183

Regional 292 170 174

2024 and Later Model Year Gallons of Fuel per 

1,000 Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 26.7191 16.8959 17.8782

MultiPurpose27.5049 17.0923 17.9764

Regional 28.6837 16.6994 17.0923
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-78

Table 11-74 Alternative 4 Phase 2 Gasoline (SI) Vocational Vehicle Standards

2021–2023 MODEL YEAR CO2 Grams per 

Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 313 199 210

MultiPurpose323 201 212

Regional 336 197 201

2021–2023 Model Year Gallons of Fuel per 

1,000 Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 35.2200 22.3923 23.6300

MultiPurpose36.3452 22.6173 23.8551

Regional 37.8080 22.1672 22.6173

2024 and Later Model Year CO2 Grams per 

Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 299 189 196

MultiPurpose308 191 198

Regional 321 187 188

2024 and Later Model Year Gallons of Fuel per 

1,000 Ton-Mile

LHD 

(Class 2b5)

MHD 

(Class 6-

7)

HHD 

(Class 8)

Urban 33.6446 21.2670 22.0547

MultiPurpose34.6574 21.4921 22.2797

Regional 36.1202 21.0420 21.1545
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-79

Table 11-75 Alternative 4 Tractor Standards

DAY CAB SLEEPER CAB

Class 7 Class 8 Class 8

Low Roof 94 76 68

Mid Roof 104 82 76

High Roof 106 84 75

2021 Model Year Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 9.2338 7.4656 6.6798

Mid Roof 10.2161 8.055 7.4656

High Roof 10.4126 8.2515 7.3674

2024 Model Year CO2 Grams per Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 87 70 62

Mid Roof 96 76 69

High Roof 96 76 67

2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 8.5462 6.8762 6.0904

Mid Roof 9.4303 7.4656 6.7780

High Roof 9.4303 7.4656 6.5815

Table 11-76 Alternative 4 Trailer Standards

MODEL 

YEAR

SUBCATEGORY DRY VAN REFRIGERATED VAN

LENGTH LONG SHORT LONG SHORT

2018 - 2020

EPA Standard 

(CO2 Grams per Ton-Mile) 83 144 84 147

Voluntary NHTSA Standard

(Gallons per 1,000 Ton-Mile) 8.1532 14.1454 8.2515 14.4401

2021 - 2023

EPA Standard

(CO2 Grams per Ton-Mile) 80 142 81 145

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 7.8585 13.9489 7.9568 14.2436

2024 - 2026

EPA Standard 

(CO2 Grams per Ton-Mile) 77 140 80 144

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 7.5639 13.7525 7.8585 14.1454
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-80

Table 11-77 Alternative 4 HD Pickup and Van Standard Target Curve Coefficients

Diesel Vehicles

Model Year a b c d

2018-2020 a0.0416 320 0.0004086 3.143

2021 0.0402 308 0.0003949 3.026

2022 0.0388 298 0.0003811 2.927

2023 0.0374 287 0.0003674 2.819

2024 0.0361 277 0.0003546 2.721

2025 and later 0.0348 267 0.0003418 2.623

Gasoline Vehicles

Model Year a b c d

2018-2020 a0.0440 339 0.0004951 3.815

2021 0.0425 327 0.0004782 3.680

2022 0.0410 315 0.0004613 3.545

2023 0.0395 304 0.0004445 3.421

2024 0.0381 294 0.0004287 3.308

2025 and later 0.0368 283 0.0004141 3.184

Note:

a

Phase 1 primary phase-in coefficients. Alternative phase-in coefficients are different in MY2018 only.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-81

11.4.3 Alternative 5 Vehicle Standards

Potential EPA GHG and NHTSA fuel consumption standards are shown for Alternative 4 in 

Table 11-78 to Table 11-81 and the coefficients for the HD Pickup and Van target curves for 

Alternative 5 are shown in Table 11-82.

Table 11-78 Alternative 5 Phase 2 Diesel (CI) Vocational Vehicle Standards

2021–2023 MODEL YEAR CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 292 185 194

MultiPurpose300 186 196

Regional 313 183 185

2021–2023 Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 32.8863 20.7809 21.8523

MultiPurpose33.8112 20.9856 22.0566

Regional 35.2499 20.5761 20.8312

2024 and Later Model Year CO2 Grams per Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 278 175 185

MultiPurpose286 177 186

Regional 298 174 177

2024 and Later Model Year Gallons of Fuel per 1,000 Ton-Mile

LHD (Class 2b-5) MHD (Class 6-7) HHD (Class 8)

Urban 31.2817 19.7042 20.7621

MultiPurpose32.1840 19.9043 20.9617

Regional 33.4874 19.6042 19.8637
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-82

Table 11-79 Alternative 5 Phase 2 Gasoline (SI) Vocational Vehicle Standards

2021–2023 MODEL YEAR

CO2 Grams per Ton-Mile

LH

D 

(Cla

ss 

2b5)

MHD 

(Class 6-

7)

HH

D 

(Cla

ss 8)

Urba

n

292 185 194

Mult

iPurp

ose

300 186 196

Regi

onal

313 183 185

2021–2023 Model Year 

Gallons of Fuel per 1,000 

Ton-Mile

LH

D

(Cla

ss 

2b5)

MHD 

(Class 6-

7)

HH

D 

(Cla

ss 8)

Urba

n

32.8

863

20.7809 21.8

523

Mult

iPurp

ose

33.8

112

20.9856 22.0

566

Regi

onal

35.2

499

20.5761 20.8

312

2024 and Later Model Year 

CO2 Grams per Ton-Mile

LH

D 

(Cla

ss 

2b5)

MHD 

(Class 6-

7)

HH

D 

(Cla

ss 8)

Urba

n

278 175 185

Mult 286 177 186
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-83

iPurp

ose

Regi

onal

298 174 177

2024 and Later Model Year 

Gallons of Fuel per 1,000 

Ton-Mile

LH

D 

(Cla

ss 

2b5)

MHD 

(Class 6-

7)

HH

D 

(Cla

ss 8)

Urba

n

31.2

817

19.7042 20.7

621

Mult

iPurp

ose

32.1

840

19.9043 20.9

617

Regi

onal

33.4

874

19.6042 19.8

637
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-84

Table 11-80 Alternative 5 Tractor Standards 

DAY CAB SLEEPER CAB

Class 7 Class 8 Class 8

Low Roof 87 70 63

Mid Roof 96 75 71

High Roof 98 77 70

2021 Model Year Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 8.5462 6.8762 6.1886

Mid Roof 9.4303 7.3674 6.9745

High Roof 9.6267 7.5639 6.8762

2024 Model Year CO2 Grams per Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 82 65 58

Mid Roof 91 71 64

High Roof 92 72 63

2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile

Day Cab Sleeper Cab

Class 7 Class 8 Class 8

Low Roof 8.0550 6.3851 5.6974

Mid Roof 8.9391 6.9745 6.2868

High Roof 9.0373 7.0727 6.1886

Table 11-81 Alternative 5 Trailer Standards

MODEL 

YEAR

SUBCATEGORY DRY VAN REFRIGERATED VAN

LENGTH LONG SHORT LONG SHORT

2018 - 2020

EPA Standard 

(CO2 Grams per Ton-Mile) 82 144 83 147

Voluntary NHTSA Standard

(Gallons per 1,000 Ton-Mile) 8.0550 14.1454 8.1532 14.4401

2021 - 2023

EPA Standard

(CO2 Grams per Ton-Mile) 79 142 81 145

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 7.7603 13.9489 7.9568 14.2436

2024 - 2026

EPA Standard 

(CO2 Grams per Ton-Mile) 76 140 80 143

NHTSA Standard

(Gallons per 1,000 Ton-Mile) 7.4656 13.7525 7.8585 14.0472
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-85

Table 11-82 Alternative 5 HD Pickup and Van Standard Target Curve Coefficients

Diesel Vehicles

Model Year a b c d

2018-2020 a0.0416 320 0.0004086 3.143

2021 0.0400 307 0.0003929 3.016

2022 0.0384 295 0.0003772 2.898

2023 0.0368 283 0.0003615 2.780

2024 0.0354 271 0.0003477 2.662

2025 and later 0.0339 261 0.0003330 2.564

Gasoline Vehicles

Model Year a b c d

2018-2020 a0.0440 339 0.0004951 3.815

2021 0.0422 325 0.0004749 3.657

2022 0.0405 312 0.0004557 3.511

2023 0.0389 300 0.0004377 3.376

2024 0.0374 288 0.0004208 3.241

2025 and later 0.0359 276 0.0004040 3.106

Note:

a

Phase 1 primary phase-in coefficients. Alternative phase-in coefficients are different in MY2018 only.

11.4.4 Alternative Engine Standards

The alternative standards the agencies considered for heavy-duty tractor engines are 

provided in Table 11-83.

Table 11-83 Alternative Heavy-Duty Tractor Engine Standards over the SET Cycle

MODEL 

YEAR

STANDARDS ALTERNATIVE 2 ALTERNATIVE 4 ALTERNATIVE 5

MHD HHD MHD HHD MHD HHD

2021 –

2023

EPA Standard 481 455 477 451 474 448

(CO2 Grams 

per Ton-Mile)

NHTSA 

Standard

4.7250 4.4695 4.6857 4.4303 4.6562 4.4008

(Gallons per 

100 Ton-Mile)

2024 and 

Later

EPA Standard 471 445 466 441 464 438

(CO2 Grams 

per Ton-Mile)

NHTSA 

Standard

4.6267 4.3713 4.5776 4.3320 4.5580 4.3026

(Gallons per 

100 Ton-Mile)
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-86

Table 11-84 presents the alternative CO2 and fuel consumption standards the agencies 

considered for compression-ignition engines to be installed in vocational vehicles. As with the 

proposed standards, the first set of alternative standards would take effect with MY 2021, and the 

second set would take effect with MY 2024.

Table 11-84 Alternative Vocational Diesel Engine Standards over the Heavy-Duty FTP Cycle

MODEL 

YEAR

STANDARD LIGHT 

HEAVYDUTY 

DIESEL

MEDIUM 

HEAVYDUTY 

DIESEL

HEAVY 

HEAVYDUTY 

DIESEL

Alternative 2

2021-2023 CO2 Standard (g/bhp-hr) 571 571 550

Fuel Consumption Standard 

(gallon/100 bhp-hr)

5.6090 5.6090 5.4028

2024 and 

Later

CO2 Standard (g/bhp-hr) 559 559 539

Fuel Consumption (gallon/100 

bhp-hr)

5.4912 5.4912 5.2947

Alternative 4

2021-2023 CO2 Standard (g/bhp-hr) 562 562 541

Fuel Consumption Standard 

(gallon/100 bhp-hr)

5.5206 5.5206 5.3143

2024 and 

Later

CO2 Standard (g/bhp-hr) 553 553 533

Fuel Consumption (gallon/100 

bhp-hr)

5.4322 5.4322 5.2358

Alternative 5

2021-2023 CO2 STANDARD (G/BHP-HR) 559 559 538

Fuel Consumption Standard 

(gallon/100 bhp-hr)

5.4912 5.4912 5.2849

2024 and 

Later

CO2 Standard (g/bhp-hr) 550 550 530

Fuel Consumption (gallon/100 

bhp-hr)

5.4028 5.4028 5.2063
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-87

References

1 OMB Circular A-4, September 17, 2003. Available at http://www.whitehouse.gov/omb/circulars_a004_a-4.

2 NEPA requires agencies to consider a “no action” alternative in their NEPA analyses and to compare the effects of 

not taking action with the effects of the reasonable action alternatives to demonstrate the different environmental 

effects of the action alternatives. See 40 CFR 1502.2(e), 1502.14(d).CEQ has explained that “[T]he regulations 

require the analysis of the no action alternative even if the agency is under a court order or legislative command to 

act. This analysis provides a benchmark, enabling decision makers to compare the magnitude of environmental 

effects of the action alternatives. [See 40 CFR 1502.14(c).] * * * Inclusion of such an analysis in the EIS is 

necessary to inform Congress, the public, and the President as intended by NEPA. [See 40 CFR 1500.1(a).]'' Forty 

Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations, 46 FR 18026 (1981) 

(emphasis added).

3

http://energy.gov/eere/vehicles/vehicle-technologies-office-21st-century-truck

4

http://www.epa.gov/smartway/

5

State of California Global Warming Solutions Act of 2006 (Assembly Bill 32, or AB32)

6 Confidence Report: Idle-Reduction Solutions, North American Council for Freight Efficiency, Lee, Tessa, 2014, p. 

13.

7 Committee to Assess Fuel Economy Technologies for Medium- and Heavy-Duty Vehicles; National Research 

Council; Transportation Research Board (2010). “Technologies and Approaches to Reducing the Fuel Consumption 

of Medium- and Heavy-Duty Vehicles,” (hereafter, “NAS 2010”). Washington, D.C. The National Academies Press. 

Available electronically from the National Academies Press Website at 

http://www.nap.edu/catalog.php?record_id=12845 (last accessed September 10, 2010).

8 Note that the “CO2 emission 

rates” for tractors and vocational vehicles reflect changes in CO2 emissions not represented by tire rolling resistance,

aerodynamic drag, or vehicle weight. 

9 Vocational vehicles modeled in MOVES include heavy heavy-duty, medium heavy-duty, and light heavy-duty 

vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the 

inventories for the vocational sector. Instead, all vehicles with GVWR of less than 14,000 lbs were modeled using 

the energy rate reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these 

vehicles choose to average the lightest vocational vehicles into chassis-certified families (i.e., heavy-duty pickups 

and vans).

10 Vocational tractors are included in the short-haul tractor segment.

11 Vocational vehicles modeled in MOVES include heavy heavy-duty, medium heavy-duty, and light heavy-duty 

vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the 

inventories for the vocational sector. Instead, all vehicles under 14,000 lbs were modeled using the energy rate 

reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these vehicles 

choose to average the lightest vocational vehicles into chassis-certified families (i.e., heavy-duty pickups and vans).

12 Vocational tractors are included in the short-haul tractor segment.

13 Vocational vehicles modeled in MOVES include heavy heavy-duty, medium heavy-duty, and light heavy-duty 

vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the 

inventories for the vocational sector. Instead, all vehicles with GVWR of less than 14,000 lbs were modeled using 

the energy rate reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these 

vehicles choose to average the lightest vocational vehicles into chassis-certified families (i.e., heavy-duty pickups 

and vans).

14 Vocational tractors are included in the short-haul tractor segment.

15 Vocational vehicles modeled in MOVES include heavy heavy-duty, medium heavy-duty, and light heavy-duty 

vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the 

inventories for the vocational sector. Instead, all vehicles with GVWR less than 14,000 lbs were modeled using the 

energy rate reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these 

vehicles choose to average the lightest vocational vehicles into chassis-certified families (i.e., heavy-duty pickups 

and vans).

16 Vocational tractors are included in the short-haul tractor segment.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

11-88

17 Vocational vehicles modeled in MOVES include heavy heavy-duty, medium heavy-duty, and light heavy-duty 

vehicles. However, for light heavy-duty vocational vehicles, class 2b and 3 vehicles are not included in the 

inventories for the vocational sector. Instead, all vehicles under 14,000 lbs were modeled using the energy rate 

reductions described below for HD pickup trucks and vans. In practice, many manufacturers of these vehicles 

choose to average the lightest vocational vehicles into chassis-certified families (i.e., heavy-duty pickups and vans).

18 Vocational tractors are included in the short-haul tractor segment.