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Chapter 5: Impacts on Emissions and Fuel Consumption

5.1 Executive Summary

Climate change is widely viewed as the most significant long-term threat to the global 

environment. According to the IPCC, it is extremely likely (>95 percent probability) that human 

influence was the dominant cause of the observed warming since the mid-20th century. The 

primary GHGs of concern are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), 

hydrofluorocarbons (HFCs), perfluorocarbons, and sulfur hexafluoride.1 Mobile sources emitted 

28 percent of all U.S. GHGs in 2012 when considering all upstream and downstream emissions,

and the transportation-related GHGs alone have grown 18 percent between 1990 and 2012.

2

Mobile sources addressed in the recent endangerment finding under CAA Section 202(a) –

highway vehicles including passenger cars, light-duty trucks, heavy-duty trucks, buses, and 

motorcycles – accounted for 24 percent of all U.S. GHGs in 2012.

3 Heavy-duty vehicles emit 

CO2, methane, nitrous oxide, and hydrofluorocarbons and are responsible for almost 22 percent 

of all mobile source GHGs (over 6 percent of all U.S. GHGs) and about 26 percent of CAA 

Section 202(a) mobile source GHGs. For heavy-duty vehicles in 2007, CO2 emissions 

represented nearly 97 percent of all GHG emissions (including HFCs).

4

This chapter provides the anticipated emissions impacts from the proposed standards. In 

addition, the emissions impacts of Alternative 4 are presented because the agencies are carefully 

considering it along with the preferred alternative. The reductions in emissions are expected for 

carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O) and hydrofluorocarbons (HFCs). In 

addition to reducing the emissions of greenhouse gases, this program would also affect the 

emissions of “criteria” air pollutants and their precursors, including carbon monoxide (CO), fine 

particulate matter (PM2.5), oxides of sulfur (SOX), volatile organic compounds (VOC) and oxides 

of nitrogen (NOX), and several air toxics, such as benzene, 1,3-butadiene, formaldehyde, 

acetaldehyde, and acrolein.

The proposed standards will affect both diesel- and gasoline-fueled heavy-duty vehicles, 

as well as those running on natural gases. The analyses account for both vehicle emissions 

(“downstream” emissions) and emissions from fuel production and distribution (“upstream” 

emissions). The agencies conducted coordinated and complementary analyses by employing 

both DOT’s CAFE model and EPA’s Motor Vehicle Emission Simulator (MOVES2014)5, 

relative to different reference cases (i.e., different baselines). 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. See Section 5.3 for additional details. The 

changes in upstream emissions result from decreased fuel consumption. The emission factors 

from GREET6 were used to estimate the changes in upstream emissions. In some cases, the 

GREET values were modified or updated by the agencies to be consistent with the EPA’s 

National Emission Inventory (NEI) and emission factors from MOVES. 
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Table 5-1 through Table 5-3 summarize the impact of the proposed program on GHG 

emissions from the heavy-duty sector in calendar years 2025, 2035 and 2050, using Method A 

and B, relative to two reference cases – more dynamic and less dynamic. Table 5-4 through 

Table 5-6 summarize the projected fuel savings from the proposed program in calendar years 

2025, 2035 and 2050, using Method A and B, relative to the two reference cases. The 

comparable analyses for Alternative 4 are summarized in Table 5-7 through Table 5-12.

Table 5-1 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Preferred Alternative vs. Alt 1b using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 27.2 86.9 123.0

Upstream 9.3 29.7 42.0

HFC 0.09 0.25 0.3

Total 36.6 116.9 165.3

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

Table 5-2 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Preferred Alternative vs. Alt 1a using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 28.1 94.6 134.9

Upstream 9.6 32.3 46.1

HFC 0.09 0.25 0.3

Total 37.8 127.2 181.3

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

Table 5-3 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Preferred Alternative vs. Alt 1a using Analysis Method B a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 27.4 94.7 136.5

Upstream 9.3 32.2 46.5

HFC 0.1 0.25 0.3

Total 36.8 127.2 183.3

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
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Table 5-4 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1b 

using Analysis Method A a

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 2.5 5.1% 7.6 14.3% 10.8 17.0%

Gasoline 0.2 2.4% 0.9 11.0% 1.2 13.2%

Total 2.7 4.7% 8.5 13.8% 12.0 16.5%

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

Table 5-5 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1a 

using Analysis Method A a

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 2.5 5.2% 8.3 15.4% 11.9 18.4%

Gasoline 0.2 2.6% 1.0 11.5% 1.3 13.7%

Total 2.7 4.8% 9.3 14.8% 13.2 17.8%

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 5-6 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1a 

using Analysis Method Ba

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 2.5 5.1% 8.5 15.6% 12.3 18.7%

Gasoline 0.2 2.1% 0.8 10.4% 1.1 12.8%

Total 2.7 4.7% 9.3 14.9% 13.4 18.0%

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 5-7 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Alternative 4 vs. Alt 1b using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 33.5 90.9 124.0

Upstream 11.5 31.0 42.3

HFC 0.09 0.25 0.3

Total 45.1 122.2 166.6

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
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Table 5-8 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Alternative 4 vs. Alt 1a using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 34.6 98.7 136.0

Upstream 11.8 33.7 46.5

HFC 0.09 0.25 0.3

Total 46.5 132.7 182.8

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 5-9 Annual Total Reductions of Heavy-Duty GHG Emissions in Calendar Years 2025, 2035 and 2050 –

Alternative 4 vs. Alt 1a using Analysis Method B a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream 33.7 98.3 136.9

Upstream 11.5 33.4 46.6

HFC 0.1 0.25 0.3

Total 45.3 132.0 183.8

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 5-10 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1b using 

Analysis Method A a

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 3.0 6.1% 7.9 14.8% 10.8 17.0%

Gasoline 0.3 3.9% 1.0 12.1% 1.3 13.8%

Total 3.3 5.8% 8.9 14.4% 12.1 16.6%

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

Table 5-11 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1a using 

Analysis Method A a

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 3.1 6.3% 8.6 16.0% 12.0 18.5%

Gasoline 0.3 4.3% 1.1 12.5% 1.3 14.3%

Total 3.4 6.0% 9.7 15.5% 13.3 18.0%

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
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Table 5-12 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1a using 

Analysis Method B a

CY2025 CY2035 CY2050

Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction Billion 

Gallons

% Reduction

Diesel 3.1 6.2% 8.8 16.1% 12.3 18.7%

Gasoline 0.3 3.4% 0.9 11.1% 1.1 12.9%

Total 3.4 5.9% 9.7 15.5% 13.4 18.0%

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 non-GHG impacts of the proposed rulemaking are largely driven by three factors. 

The largest contributor is from the projected increased use of auxiliary power units (APUs), 

which provide power, heat and cooling for trucks during extended engine idling. Reduced 

emissions from upstream fuel production and distribution also contribute significantly to the 

emissions benefits. Emissions of certain pollutants, such as NOX and PM2.5 are further reduced 

through improved engine efficiency, aerodynamics and tire rolling resistance and absolute 

changes in average total running weight of the vehicles. To a smaller extent, a rebound of 

vehicle miles traveled (VMT) would increase the emissions of all pollutants proportional to the 

VMT rebound amount. The emissions impacts of non-GHGs on both downstream and upstream

from the heavy-duty sector in calendar years 2025, 2035 and 2050 are summarized in Table 5-13

through Table 5-15, using Method A and B, relative to the two reference cases. The comparable 

analyses for Alternative 4 are summarized in Table 5-16 through Table 5-18.

Table 5-13 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Preferred Alternative vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 3% 25 13% 34 16% 

Acetaldehyde 672 10% 1,893 30% 2,682 36% 

Acrolein 97 10% 273 31% 387 37% 

Benzene 145 5% 421 18% 595 22% 

CO 30,282 3% 87,286 8% 123,876 10% 

Formaldehyde 2,119 11% 5,969 32% 8,460 37% 

NOX 101,916 7% 291,282 26% 413,501 31% 

PM2.5 376 1% 1,535 3% 2,199 4% 

SOX 6,213 5% 19,905 14% 28,101 17% 

VOC 16,227 6% 49,080 18% 69,525 22% 

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
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Table 5-14 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Preferred Alternative vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 3% 25 13% 35 16%

Acetaldehyde 672 10% 1,891 30% 2,680 36%

Acrolein 97 10% 273 31% 386 37%

Benzene 145 5% 425 18% 603 22%

CO 30,487 3% 88,724 8% 126,081 10%

Formaldehyde 2,119 11% 5,969 32% 8,461 37%

NOX 102,983 7% 299,911 26% 427,332 32%

PM2.5 419 1% 1,910 4% 2,791 5%

SOX 6,421 5% 21,672 15% 30,850 18%

VOC 16,403 6% 50,812 19% 72,253 23%

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 5-15 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Preferred Alternative vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 2.7% 25 15.1% 36 19.4%

Acetaldehyde 674 10.1% 1,902 30.5% 2,697 36.0%

Acrolein 97 9.8% 274 31.3% 388 36.9%

Benzene 149 5.4% 445 18.8% 633 22.9%

CO 29,622 1.9% 85,961 6.6% 122,659 8.4%

Formaldehyde 2,121 11.4% 5,978 31.7% 8,475 37.0%

NOX 102,502 7.2% 298,907 26.6% 426,610 32.1%

SOX 386 0.6% 1,883 4.2% 2,815 5.4%

PM2.5 6,070 4.9% 20,777 15.3% 30,000 18.4%

VOC 16,724 5.6% 52,872 18.8% 75,521 22.7%

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
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Table 5-16 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Alternative 4 vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 3% 25 13% 34 16%

Acetaldehyde 673 10% 1,893 30% 2,682 36%

Acrolein 97 10% 273 31% 387 37%

Benzene 152 6% 426 18% 595 22%

CO 31,383 3% 88,047 8% 124,137 10%

Formaldehyde 2,123 11% 5,970 32% 8,460 37%

NOX 105,693 7% 293,918 26% 413,967 31%

PM2.5 639 1% 1,703 4% 2,237 4%

SOX 7,682 6% 20,849 15% 28,385 17%

VOC 18,006 6% 50,189 19% 69,796 22%

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 5-17 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Alternative 4 vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 3% 25 13% 35 16%

Acetaldehyde 672 10% 1,891 30% 2,679 36%

Acrolein 97 10% 273 31% 386 37%

Benzene 153 6% 430 18% 603 22%

CO 31,637 3% 89,514 8% 126,360 10%

Formaldehyde 2,123 11% 5,969 32% 8,460 37%

NOX 106,822 7% 302,575 26% 427,805 32%

PM2.5 689 1% 2,082 5% 2,833 5%

SOX 7,941 6% 22,646 16% 31,151 18%

VOC 18,222 6% 51,924 19% 72,509 23%

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
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Table 5-18 Annual Total Reductions (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions –

Alternative 4 vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene 9 2.8% 26 15.2% 36 19.4%

Acetaldehyde 676 10.1% 1,903 30.6% 2,697 36.0%

Acrolein 97 9.8% 274 31.3% 388 36.9%

Benzene 157 5.7% 450 18.9% 634 22.9%

CO 30,580 1.9% 86,526 6.6% 122,703 8.4%

Formaldehyde 2,125 11.4% 5,980 31.7% 8,476 37.0%

NOX 106,180 7.4% 301,339 26.8% 426,796 32.1%

SOX 646 1.1% 2,036 4.6% 2,827 5.4%

PM2.5 7,450 6.1% 21,550 15.9% 30,364 18.4%

VOC 18,652 6.2% 53,966 19.2% 75,621 22.7%

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

5.2 Introduction

5.2.1 Downstream (Tailpipe) Emissions

As described in more detail in this chapter, the downstream reductions in emissions due 

to the proposed program are anticipated to be achieved through improvements in engine 

efficiency, road load reduction, and APU use during extended idling, with the exception of 

PM2.5.

A

 Absolute reductions in tailpipe emissions are projected to grow over time as the fleet 

turns over to vehicles affected by the proposed standards, meaning that the emissions benefits of 

the program would continue to grow as older vehicles in the fleet are replaced by newer vehicles 

that emit less CO2.

The effect of the regulations on the timing of fleet turnover and total VMT can have an 

impact on downstream GHG and other emissions, as discussed in Section IX of the preamble. If 

the regulations spur firms to increase their purchase of new vehicles before efficiency standards 

are in place (“pre-buy”) or to delay their purchases once the standards are in place then there 

would be a delay in achieving the full GHG and other emission reductions from improved fuel 

economy across the fleet. If the lower per-mile costs associated with higher fuel economy lead 

to an increase in VMT (the “rebound effect”), then the total emission reductions would also be 

reduced. Chapter 8 of the draft RIA provides more detail on how the rebound effect was 

calculated in the agencies’ analysis. The analysis discussed in this chapter incorporates the 

rebound effect into the estimates. However, the impacts of any delayed fleet turnover are not 

estimated. 

 

A The projected increased use of APUs would lead to higher PM2.5 emissions since engines powering APUs are 

currently required to meet less stringent PM standards than on-road engines.
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5.2.2 Upstream Emissions 

In addition to downstream emission reductions, reductions are expected in the emissions 

associated with the processes involved in getting fuel to the pump, including the extraction and 

transportation of crude oil, the production and distribution of finished gasoline and diesel, and 

the production and transportation of renewable fuels. Changes are anticipated in upstream 

emissions due to the expected reduction in the overall volume of gasoline and diesel consumed. 

Less fuel consumed means less fuel transported, less fuel refined, and less crude oil extracted 

and transported to refineries. Thus, there would be reductions in the emissions associated with 

each of these steps in the fuel production and distribution processes. In addition, any changes in 

downstream reductions associated with changes in fleet turnover, and VMT are reflected in a 

corresponding change in upstream emissions associated with fuel processing and distribution.

The agencies recognize that the proposed standards could lower the world price of oil 

(the “monopsony” effect, further discussed in Chapter 8 of the draft RIA). Lowering oil prices 

could lead to an uptick in oil consumption globally, resulting in a corresponding increase in 

GHG emissions in other countries. This global increase in emissions could slightly offset some 

of the emission reductions achieved domestically as a result of the regulation. EPA does not 

provide quantitative estimates of the impact of the proposed regulation on global petroleum 

consumption and GHG emissions in this draft RIA. 

5.2.3 Global Warming Potentials

Throughout this document, in order to refer to the four inventoried greenhouse gases on 

an equivalent basis, Global Warming Potentials (GWPs) are used. In simple terms, GWPs 

provide a common basis with which to combine several gases with different heat trapping 

abilities into a single inventory (Table 5-19). When expressed in CO2eq terms, each gas is 

weighted by its heat trapping ability relative to that of CO2. The GWPs used in this analysis are 

consistent with the 2007 Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment 

Report (AR4) on a 100-year timescale.

7

 

Table 5-19 Global Warming Potentials of GHGs

GAS GLOBAL WARMING POTENTIAL (CO2EQ)

CO2 1

CH4 25

N2O 298

HFC134a 1,430

5.3 Program Analysis and Modeling Methods

5.3.1 Models Used

Different tools exist for estimating potential fuel consumption and emissions impacts 

associated with fuel efficiency and GHG emissions standards. One such tool is EPA’s official 

mobile source emissions inventory model named Motor Vehicle Emissions Simulator

(MOVES).

8

 The agencies used the most current version of the model, MOVES2014, to quantify
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5-10

the impacts of these proposed standards on GHG emissions, fuel consumption, as well as criteria 

pollutants and air toxics emissions. In MOVES, vehicle types are categorized by their use and 

represented by combination tractors, single unit trucks, refuse trucks, motor homes, transit buses, 

intercity buses, school buses, and light commercial trucks. The agencies ran MOVES with user 

input databases that reflected the projected technological improvements resulting from the 

proposed rules, such as the improvements in engine and vehicle efficiency, aerodynamic drag, 

and tire rolling resistance. The changes made to the default MOVES database are described 

below in Section 5.3.2. All the input data, MOVES runspec files, and the scripts used for the 

analysis, as well as the version of MOVES used to generate the emissions inventories, can be 

found in the docket.9

Another such tool is DOT’s CAFE model. For this analysis, the model was reconfigured 

to use the work based attribute metric of “work factor” established in the Phase 1 rule for heavyduty pickups and vans, instead of the light-duty “footprint” attribute metric. The CAFE model 

takes user-specified inputs on, among other things, vehicles that will be produced in a given 

model year, technologies available to improve fuel efficiency on those vehicles, potential 

regulatory standards that would drive improvements in fuel efficiency, and economic 

assumptions. The CAFE model takes every vehicle in each manufacturer’s fleet and decides 

what technologies to add to those vehicles in order to allow each manufacturer to comply with 

the standards in the most cost-effective way and uses a representation of the HD pickup and van 

fleet that captures heterogeneity at the manufacturer, model year, and powertrain (and other 

technology) level. Based on the resulting improved vehicle fleet, the CAFE model then 

calculates total fuel consumption and GHG, criteria, and toxics emissions impacts based on those 

inputs, along with economic costs and benefits. The CAFE model is discussed in greater detail 

in Chapter 10 of the draft RIA. 

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 the impacts resulting from the proposed standards on fuel consumption, GHG emissions, 

as well as criteria pollutants and air toxics emissions. As described in Section 5.3.2, 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. The agencies 

considered both reference cases, reaching corroborative conclusions. The results for all of the 

regulatory alternatives relative to both reference cases, derived via the same methodologies 

discussed in this Chapter, are presented in Chapter 11 of the draft RIA and these different 

analyses all support the reasonableness of the proposed standards. 

For brevity, a subset of these analyses are presented in this section, and the reader is 

referred to both the Chapter 11 of the draft RIA and NHTSA’s DEIS Chapters 3 and 5 for 

complete sets of these analyses. In this Chapter, Method A is presented for both the proposed 
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5-11

standards (i.e., Alternative 3 – the agencies’ preferred alternative) and for the standards the 

agencies considered in Alternative 4. Method A is presented relative to both the more dynamic 

baseline (Alternative 1b) and the less dynamic baseline (Alternative 1a). Method B is presented 

also for the proposed standards and Alternative 4, but relative only to the less dynamic baseline. 

The agencies’ intention for presenting both of these complementary and coordinated analyses is 

to offer interested readers the opportunity to compare the regulatory alternatives considered for 

Phase 2 in both the context of our HD Phase 1 analytical approaches and our light-duty vehicle 

analytical approaches. The agencies view these analyses as corroborative and reinforcing: both

support agencies’ conclusion that the proposed standards are appropriate and at the maximum 

feasible levels.

Because reducing fuel consumption also affects emissions that occur as a result of fuel 

production and distribution (including renewable fuels), the agencies also calculated those 

“upstream” changes using the “downstream” fuel consumption reductions predicted by the 

MOVES model for vocational vehicles and tractor-trailers. As described earlier, for HD pickups 

and vans, parallel and complementary analyses of estimating the emissions from upstream 

processes were conducted using the fuel consumption estimates from both DOT’s CAFE model 

(Method A) and EPA’s MOVES model (Method B), relative to the two reference cases. Method 

A used the CAFE model to estimate vehicular fuel consumption and emissions impacts for HD 

pickups and vans and to calculate upstream impacts. For vocational vehicles and combination 

tractor-trailers, both Method A and Method B estimated the projected corresponding changes in 

upstream emissions using the same tools originally created for the Renewable Fuel Standard 2 

(RFS2) rulemaking analysis,10 used in the LD GHG rulemakings,11 HD GHG Phase 1,12 and 

updated for the current analysis. The estimate of emissions associated with production and 

distribution of gasoline and diesel from crude oil is based on emission factors in the “Greenhouse

Gases, Regulated Emissions, and Energy Use in Transportation” model (GREET) developed by 

DOE's Argonne National Lab. In some cases, the GREET values were modified or updated by

the agencies to be consistent with the National Emission Inventory (NEI) and emission factors 

from MOVES. Method B used the same tool described above to estimate the upstream impacts 

for HD pickups and vans.

Updates and enhancements to the GREET model assumptions include updated crude oil 

and gasoline transport emission factors that account for recent EPA emission standards and 

modeling, such as accounting for impacts of fuel requirements on vapor emissions from storage 

and transport. In addition, GREET does not include air toxics. Thus, emission factors for the 

following air toxics were added: benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and 

acrolein. These upstream toxics emission factors were calculated from the 2005 National 

Emissions Inventory (NEI), a risk and technology review for petroleum refineries, speciated 

emission profiles in EPA's SPECIATE database, or the Mobile Source Air Toxics rulemaking 

(MSAT) inventory for benzene; these pollutant tons were divided by refinery energy use or 

gasoline distribution quantities published by the DOE Energy Information Administration (EIA) 

to get emission factors in terms of grams per million BTU of finished gasoline and diesel. These 

updates are consistent with those used for the upstream analysis included in the LD GHG 

rulemaking and HD GHG Phase 1. The actual calculation of the emission inventory impacts of 

the decreased gasoline and diesel production is done in EPA's tool for upstream emission 

impacts.13
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5-12

5.3.2 Calculation of Downstream Emissions

5.3.2.1 Model inputs and Assumptions for the Less Dynamic Reference Case

The less dynamic reference case (identified as Alternative 1a in Section X of the 

preamble and Chapter 11 of the draft RIA), a “no action” alternative, functions as one the 

baselines against which the impacts of the proposed standards can be evaluated and includes the 

impact of HD GHG Phase 1, but generally assumes that fuel efficiency and GHG emission

standards are not improved beyond the required 2018 model year levels. However, the less 

dynamic reference case projects some improvements in the efficiency of the box trailers pulled 

by combination tractors due to increased penetration of aerodynamic technologies and low 

rolling resistance tires attributed to both EPA’s SmartWay Transport Partnership and California 

Air Resources Board’s Tractor-Trailer Greenhouse Gas regulation, as described in Section IV of 

the preamble. For other HD vehicle sectors, no market-driven improvement in fuel efficiency

was assumed. For HD pickups and vans, the CAFE model was applied in a manner that assumes 

manufacturers would only add fuel-saving technology as needed to continue complying with 

Phase 1 standards. MOVES2014 defaults were used for all other parameters to estimate the less 

dynamic reference case emissions inventories. For the aerodynamic drag and tire rolling 

resistance coefficients of combination tractor-trailers and vocational vehicles, default MOVES 

values for each MOVES source/vehicle type were used that represent a fleet-wide adoption of 

HD GHG Phase 1.

The less dynamic reference case assumed the MOVES2014 default vehicle population 

and vehicle miles traveled (VMT).

14

 The growth in vehicle populations and miles traveled in 

MOVES2014 is based on the relative annual VMT growth from AEO2014 Early Release for 

model years 2012 and later.15 For extended idling emission inventories, the MOVES2014 

default auxiliary power unit (APU) penetration rates were used. These rates assume that 30 

percent of all combination long-haul tractors model year 2010 and later use an APU during 

extended idling.B 

5.3.2.2 Model inputs and Assumptions for the More Dynamic Reference Case

The more dynamic reference case (identified as Alternative 1b in Section X of the 

preamble and Chapter 11 of the draft RIA), also includes the impact of Phase 1 and generally 

assumes that fuel efficiency and GHG emission standards are not improved beyond the required 

2018 model year levels. However, for this case, the agencies assume market forces would lead 

to additional fuel efficiency improvements for tractors and trailers. These additional assumed

improvements are described in Section X of the preamble. No additional fuel efficiency

improvements due to market forces were assumed for vocational vehicles. For HD pickups and 

vans, the agencies applied the CAFE model using the input assumption that manufacturers 

having achieved compliance with Phase 1 standards would continue to apply technologies for 

 

B The agencies assessed the current level of automatic engine shutdown and idle reduction technologies used by the 

tractor manufacturers to comply with the 2014 model year CO2 and fuel consumption standards. To date, the 

manufacturers are meeting the 2014 model year standards without the use of this technology. Therefore, the 

agencies are reverting the baseline APU adoption rate back to 30 percent, the value used in the HD GHG Phase 1 

baseline.
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5-13

which increased purchase costs would be “paid back” through corresponding fuel savings within 

the first six months of vehicle operation. The agencies conducted the MOVES analysis of this 

case in the same manner as for the less dynamic reference case.

5.3.2.3 Model Inputs and Assumptions for the Control Case

The control case (identified as Alternative 3 in Chapter 11 of the draft RIA) represents

the agencies’ proposed fuel efficiency and GHG standards for HD engines, HD pickup trucks 

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

trailers. To account for improvements of engine and vehicle efficiency in vocational vehicles 

and combination tractor-trailers, EPA developed additional user input data for MOVES runs to 

estimate the control case inventories. 

The agencies used the percent reduction in aerodynamic drag and tire rolling resistance 

coefficients and absolute changes in average total running weight (gross combined weight) 

expected from the proposed rules to develop the road load inputs for the control case. For 

running emissions, the key concept underlying the definition of operating mode in MOVES is 

scaled tractive power (STP), vehicle speed and vehicle acceleration.16 STP represents the 

vehicle’s tractive power scaled by a constant factor. It is calculated using mass of the vehicle 

and road load factors that include tire rolling resistance, aerodynamic drag, and friction losses in 

the drivetrain. STP is estimated using the equation below:

scale

t t t t t

t

f

Av Bv Cv mv a

STP

  



2 3

Equation 5-1

Where:

A = the rolling resistance coefficient [kWsec/m],

B = the rotational resistance coefficient [kWsec2/m2],

C = the aerodynamic drag coefficient [kWsec3/m3],

m = mass of individual vehicle [metric ton],

fscale = fixed mass factor,

vt = instantaneous vehicle velocity at time t [m/s],

at = instantaneous vehicle acceleration [m/s2]

The proposed improvements in road load factors would reduce the tractive power exerted 

by a vehicle to move itself and its cargo. The emissions emitted by heavy-duty trucks are a 

function of STP as determined from a variety of data sources. Thus, a reduction in road load 

factors are expected to result in reduced GHG and non-GHG emissions. The improvements in 

tire rolling resistance, aerodynamic drag, and absolute changes in average vehicle weight 
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5-14

expected from the technologies which could be used to meet the proposed standards were 

modified in the “sourceusetypephysics” table.C 

For vocational vehicles and tractor-trailers, the agencies also used the percent reduction 

in CO2 emissions expected from the powertrain and other vehicle technologies not accounted for 

in the aerodynamic drag and tire rolling resistance in the proposed rules to develop energy inputs 

for the control case runs. In contrast, for HD pickup trucks and vans, the proposed standards 

were evaluated only in terms of the total vehicle reductions in fuel use and CO2 emissions, since 

nearly all of these vehicles would be certified on a chassis dynamometer. Finally, EPA used an 

assumed percent penetration of APU use during extended idling, based on the expectation that 

manufacturers will use APUs to meet the vehicle GHG standard for combination long-haul 

tractors, as discussed in Section III.D of the preamble. 

5.3.2.3.1 Emission Rate and Road Load Inputs

Both the stringency and the form of the proposed fuel consumption and CO2 emission 

standards vary by vehicle category. Accordingly, the modeling of the proposed standards in 

MOVES varies by the vehicle category. For the vocational vehicles and combination tractortrailers, EPA has analyzed the impacts of the proposed standards by evaluating the technologies 

applied to the energy rates as well as to the road load inputs. However, the impacts on the HD 

pickup trucks and vans were estimated only in terms of reduction in energy rates.

5.3.2.3.1.1 Tractor-Trailers

Similar to the approach used in the HD GHG Phase 1 analysis, EPA aggregated the nine 

tractor subcategories into the two MOVES combination tractor-trailer categories – short-haul and 

long-haul. The agencies used sales distribution data from the HD GHG Phase 1 analysis and 

determined the long-haul reductions in energy rates and road load factors, based on a sales mix 

assumption of 80 percent high roof, 15 percent mid roof, and 5 percent low roof sleeper cabs. 

The short-haul combination tractors were evaluated using a day cab sales distribution assumption 

of 7 percent Class 7 low roof, 10 percent Class 7 high roof, 40 percent Class 8 low roof, 35 

percent Class 8 high roof, and 8 percent vocational tractors, based on the information used in the 

HD GHG Phase 1 analysis. The details of the analyses aggregating the tractor subcategories into 

MOVES categories using the sales mix assumption described above can be found in the docket.17

The trailer category encompasses many types of trailers. As with the tractor category, 

EPA aggregated the trailer subcategories into two MOVES combination tractor-trailer 

categories. EPA used a combination of ACT Research’s 2013 factory shipment data18 for trailer 

distribution by type and “primary trip length” information from the U.S. Census’ 2002 Vehicle 

Inventory and Use Survey19 to distribute each trailer type into long- and short-haul categories. 

EPA applied the trailer market percentages as shown in Table 5-20 to determine the trailer 

impact on the MOVES long- and short-haul combination tractor-trailer categories. 

 

C Class 2b and 3 trucks do not use the STP metric and are regulated, for non-GHG emissions, based on chassis 

testing (gram per mile basis) rather than engine testing (gram per brake horsepower-hour basis), therefore road load 

reductions are not necessarily expected to result in reduced non-GHG emissions. 
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Table 5-20 Aggregation of Trailer Types into MOVES Combination Tractor-Trailer Categories

TRAILER TYPE Combination Long-Haul 

Tractor-Trailers

Combination Short-Haul TractorTrailers

Long Dry Van 55.5% 20.3%

Short Dry Van 12.3% 20.2%

Long Refrigerated Van 18.2% 2.6%

Short Refrigerated Van 5.2% 3.8%

Special Purpose Van 0.0% 6.4%

Container Chassis 0.2% 1.8%

Flatbed 6.9% 10.9%

Tank 0.4% 1.5%

Other On-Highway Trailers 1.2% 2.7%

Off-Road Trailers 0.0% 29.9%

Table 5-21 describes the improvements in the energy rate expected from the heavy-duty

engine, transmission, and driveline technologies which could be applied to meet the proposed 

tractor standards. The percentage reductions from the reference case were applied to the default 

MOVES energy rates in the appropriate source bins within MOVES “emissionrate" table. 

Table 5-21 Estimated Reductions in Energy Rates for the Proposed Standards for Tractor-Trailers

VEHICLE TYPE FUEL MODEL YEARS REDUCTION FROM 

REFERENCE CASE

Long-haul TractorTrailersDiesel 2018-2020 1.3%

2021-2023 5.2%

2024-2026 9.7%

2027+ 10.4%

Short-haul TractorTrailersDDiesel 2018-2020 0.9%

2021-2023 5.0%

2024-2026 9.5%

2027+ 10.4%

Table 5-22 contains the improvements in tire rolling resistance, coefficient of drag, and 

weight reductions expected from the technologies which could be used to meet the proposed 

standards for combination tractor-trailers. The percentage reductions in tire rolling resistance 

and drag coefficients and the absolute changes in average vehicle weight were modified in the 

“sourceusetypephysics” table. 

 

D Vocational tractors are included in the short-haul tractor segment.
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Table 5-22 Estimated Reductions in Road Load Factors for the Proposed Standards for Tractor-Trailers

VEHICLE TYPE MODEL 

YEARS

REDUCTION IN 

TIRE ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT

WEIGHT 

REDUCTION 

(LB)A

Combination Longhaul TractorTrailers2018-2020 5.5% 5.1% -131

2021-2023 9.8% 15.3% -199

2024-2026 15.7% 20.5% -246

2027+ 17.9% 26.9% -304

Combination Shorthaul TractorTrailersE2018-2020 4.0% 1.6% -41

2021-2023 10.5% 9.3% -79

2024-2026 13.9% 12.3% -100

2027+ 17.6% 15.9% -127

Note:

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

improvements.

In addition, the projected use of auxiliary power units (APU) during extended idling, 

shown below in Table 5-23, was included in the modeling for the long-haul combination tractortrailers by modifying the “hotellingactivitydistribution” table in MOVES.

Table 5-23 Assumed APU Use during Extended Idling for Combination Long-haul Tractor-Trailers

VEHICLE TYPE MODEL 

YEARS

APU 

PENETRATION

Combination 

Long-Haul

Trucksa

2010-2020 30%

2021-2023 80%

2024+ 90%

Note:

a The assumed APU penetration remains constant for model years 

2024 and later.

5.3.2.3.1.2 Vocational Vehicles

Similar to the approach for tractor-trailers, EPA aggregated the nine vocational vehicle 

subcategories into each of the seven MOVES vehicle types.F The energy rate inputs were 

derived by applying the anticipated levels of engine, axle, transmission, and idle reduction 

technologies equally across all weight classes and vehicle types. Each of these technology 

packages is described in Chapter 2 of the draft RIA. The differences between gasoline and diesel 

vocational vehicles in energy rate reduction from the reference cases, shown in Table 5-24, are 

due to the differences in anticipated engine-level technology packages, as described in Chapter 2 

of the draft RIA. 

 

E Vocational tractors are included in the short-haul tractor segment.

F

Seven MOVES vehicle types for vocational vehicles are intercity bus, transit bus, school bus, refuse truck, singleunit short-haul truck, single-unit long-haul truck, and motor home.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-17

The percentage reductions from the reference case were applied to the default MOVES 

energy rates in the appropriate source bins within MOVES “emissionrate" table.

Table 5-24 Estimated Reductions in Energy Rates for the Proposed Standards for Vocational Vehicles

VEHICLE TYPE FUEL MODEL 

YEARS

REDUCTION FROM 

REFERENCE CASE

Single-Frame 

VocationalG

Diesel & CNG 2021-2023 5.3%

2024-2026 8.9%

2027+ 13.3%

Gasoline 2021-2023 3.3%

2024-2026 5.4%

2027+ 10.3%

The agencies used MOVES population data for new vehicles expected to be sold in 2018 

for each weight class, as well as assumptions about their distribution among the three new 

vocational vehicle duty cycles. This population allocation is shown in Table 5-25.

Table 5-25 Vocational Vehicle Types and Population Allocation

VEHICLE TYPE RURAL MULTI-PURPOSE URBAN

Short Haul Straight Truck 35% 60% 5%

Long Haul Straight Truck, Motor 

Home, Intercity Bus

100% 0% 0%

School Bus 0% 100% 0%

Transit Bus 0% 75% 25%

Refuse 0% 0% 100%

All Class 4-5 23% 21% 2%

All Class 6-7 15% 19% 1%

All Class 8 7% 8% 4%

Using these population distribution estimates and the technology application rates 

described in Chapter 2 of the draft RIA, EPA derived the levels of improvements in tire rolling 

resistance and weight reduction.

Table 5-26 contains the improvements in tire rolling resistance, coefficient of drag, and 

weight reductions expected from the technologies which could be used to meet the proposed 

standards for vocational vehicles. The percentage reductions in tire rolling resistance and drag 

coefficients and the absolute changes in average vehicle weight were modified in the 

 

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

5-18

“sourceusetypephysics” table in MOVES. The analyses used to develop the MOVES inputs for 

vocational vehicles, described above, can be found in the docket.20

Table 5-26 Estimated Reductions in Road Load Factors for the Proposed Standards for Vocational Vehicles

VEHICLE

TYPE

MODEL 

YEARS

REDUCTION IN TIRE 

ROLLING 

RESISTANCE 

COEFFICIENT

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

WEIGHT 

REDUCTION 

(LB)

Intercity 

Buses

2021-2023 6.5% 0% 0

2024-2026 9.2% 0% 0

2027+ 16.5% 0% 0

Transit Buses 2021-2023 0% 0% 0

2024-2026 2.9% 0% 0

2027+ 3.0% 0% 0

School Buses 2021-2023 0% 0% 0

2024-2026 2.9% 0% 0

2027+ 4.0% 0% 0

Refuse Trucks 2021-2023 0% 0% 20

2024-2026 2.9% 0% 20

2027+ 3.0% 0% 25

Single Unit 

Short-haul 

Trucks

2021-2023 4.8% 0% 5.8

2024-2026 8.3% 0% 5.8

2027+ 13.0% 0% 7

Single Unit 

Long-haul 

Trucks

2021-2023 6.5% 0% 20

2024-2026 9.2% 0% 20

2027+ 16.5% 0% 25

Motor Homes 2021-2023 3.0% 0% 0

2024-2026 6.2% 0% 0

2027+ 7.4% 0% 0

5.3.2.3.1.3 Heavy-Duty Pickup Trucks and Vans

As explained above, the agencies used both DOT’s CAFE model and EPA’s MOVES 

model, using analytical Method A and B, respectively, to project fuel consumption, GHG and 

non-GHG emissions impacts resulting from the proposed standards for HD pickups and vans, 

including downstream vehicular emissions as well as emissions from upstream processes related 

to fuel production, distribution, and delivery. 

5.3.2.3.1.3.1 Method A for HD Pickups and Vans

For Method A, the CAFE model calculated fuel consumption rates, then calculated

vehicular CO2 emissions from the fuel consumption based on fuel properties (density and carbon 

content). It also applies per-mile emission factors from MOVES to estimated VMT (for each 

regulatory alternative, adjusted to account for the rebound effect) in order to calculate vehicular 

CH4 and N2O emissions (as well, as discussed below, of non-GHG pollutants), and applies pergallon upstream emission factors from GREET in order to calculate upstream GHG (and nonGHG) emissions.
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5-19

Consistent with HD GHG Phase 1 approach, the proposed standards for HD pickups and 

vans are established as a function of the vehicle work factor, a metric unique to this segment 

which is calculated based on the vehicle capabilities (i.e., payload, towing and four-wheel drive). 

As proposed, the work-factor-based standards would increase in stringency by 2.5 percent per 

year, starting in MY 2021 until they reach the final level of the proposed standards in MY 2027. 

The standards define targets specific to each vehicle model, but no vehicle is required to meet its 

target; instead, the production-weighted averages of the vehicle-specific targets define average

fuel consumption and CO2 emission rates that a given manufacturer’s overall fleet of produced 

vehicles is required to achieve. The standards are specified separately for gasoline and diesel 

vehicles, and vary with work factor. Work factors could change, and today’s analysis assumes 

that some applications of mass reduction could enable increased work factor in cases where 

manufacturers could increase a vehicle’s rated payload and/or towing capacity. Therefore, 

average required levels will depend on the mix of vehicles and work factors of the vehicles 

produced for sale in the U.S., and since these can only be estimated at this time, average required 

and achieved fuel consumption and CO2 emission rates are subject to uncertainty. Between 

today’s notice and issuance of the ensuing final rule, the agencies intend to update the market 

forecast (and other inputs) used to analyze HD pickup and van standards, and expect that doing 

so will lead to different estimates of required and achieved fuel consumption and CO2 emission 

rates (as well as different estimates of impacts, costs, and benefits).

The following four tables present stringency increases and estimated required and 

achieved fuel consumption and CO2 emission rates for the two No Action Alternatives 

(Alternative 1a and 1b) and the proposed standards defining the Preferred Alternative. 

Stringency increases are shown relative to standards applicable in model year 2018 (and through 

model year 2020). As mathematical functions, the standards themselves are not subject to 

uncertainty. By 2027, they are 16.2 percent more stringent (i.e., lower) than those applicable 

during 2018-2020. The DOT’s CAFE model estimate that, by model 2027, the proposed 

standards could reduce average required fuel consumption and CO2 emission rates to about 4.86 

gallons/100 miles and about 458 grams/mile, respectively. The model further estimate that 

average achieved fuel consumption and CO2 emission rates could correspondingly be reduced to 

about the same levels. If, as represented by Alternative 1b, manufacturers would, even absent 

today’s proposed standards, voluntarily make improvements that pay back within six months, 

these model year 2027 levels are about 13.5 percent lower than the agencies estimate could be 

achieved under the Phase 1 standards defining the No Action Alternative. If, as represented by 

Alternative 1a, manufacturers would, absent today’s proposed standards, only apply technology 

as required to achieve compliance, these model year 2027 levels are about 15 percent lower than 

the agencies estimate could be achieved under the Phase 1 standards. As indicated below, the 

agencies estimate that these improvements in fuel consumption and CO2 emission rates would 

build from model year to model year, beginning as soon as model year 2017 (insofar as 

manufacturers may make anticipatory improvements if warranted given planned produce 

cadence).
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Table 5-27 Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved Fuel 

Consumption Rates for Method A, Relative to Alternative 1b

a

MODEL 

YEAR

STRINGENCY 

(VS. 2018)

AVE. REQUIRED FUEL CONS. 

(GAL./100 MI.)

AVE. ACHIEVED FUEL CONS. 

(GAL./100 MI.)

No Action Proposed Reduction No Action Proposed Reduction

2014 MYs 2014-

2020 Subject to 

Phase 1

Standards

6.41 6.41 0.0% 6.21 6.21 0.0%

2015 6.41 6.41 0.0% 6.12 6.12 0.0%

2016 6.27 6.27 0.0% 6.15 6.15 0.0%

2017 6.11 6.11 0.0% 5.89 5.88 0.2%

2018 5.80 5.80 0.0% 5.75 5.70 0.8%

2019 5.78 5.78 0.0% 5.72 5.68 0.7%

2020 5.78 5.78 0.0% 5.69 5.64 0.8%

2021 2.5% 5.77 5.64 2.2% 5.63 5.42 3.8%

2022 4.9% 5.77 5.50 4.7% 5.63 5.42 3.8%

2023 7.3% 5.77 5.38 6.8% 5.63 5.28 6.3%

2024 9.6% 5.77 5.25 9.0% 5.63 5.23 7.1%

2025 11.9% 5.77 5.12 11.4% 5.63 4.99 11.5%

2026 14.1% 5.77 4.98 13.7% 5.63 4.93 12.5%

2027 16.2% 5.77 4.86 15.8% 5.62 4.86 13.7%

2028* 16.2% 5.77 4.86 15.8% 5.62 4.86 13.7%

2029* 16.2% 5.77 4.86 15.8% 5.62 4.85 13.7%

2030* 16.2% 5.77 4.86 15.8% 5.62 4.85 13.7%

Notes:

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

*Absent further action, standards assumed to continue unchanged after model year 2027.
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Table 5-28 Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved CO2

Emission Rates for Method A, Relative to Alternative 1b

a

MODEL 

YEAR

STRINGENCY 

(VS. 2018)

AVE. REQUIRED CO2 RATE 

(G./MI.)

AVE. ACHIEVED CO2 RATE 

(G./MI.)

No 

Action

Proposed Reduction No 

Action

Proposed Reduction

2014 MYs 2014-

2020 Subject to 

Phase 1

Standards

602 602 0.0% 581 581 0.0%

2015 608 608 0.0% 578 578 0.0%

2016 593 593 0.0% 580 580 0.0%

2017 578 578 0.0% 556 554 0.2%

2018 548 548 0.0% 543 538 0.8%

2019 545 545 0.0% 539 535 0.7%

2020 545 545 0.0% 536 532 0.8%

2021 2.5% 544 532 2.2% 530 510 3.8%

2022 4.9% 544 519 4.7% 530 510 3.8%

2023 7.3% 544 507 6.8% 530 496 6.4%

2024 9.6% 544 495 9.1% 530 492 7.2%

2025 11.9% 544 482 11.3% 530 470 11.3%

2026 14.1% 544 470 13.6% 530 465 12.3%

2027 16.2% 544 458 15.8% 529 458 13.4%

2028* 16.2% 544 458 15.8% 529 458 13.4%

2029* 16.2% 544 458 15.8% 529 458 13.5%

2030* 16.2% 544 458 15.8% 529 458 13.5%

Notes:

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

*Absent further action, standards assumed to continue unchanged after model year 2027.
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5-22

Table 5-29 Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved Fuel 

Consumption Rates for Method A, Relative to Alternative 1a

a

MODEL 

YEAR

STRINGENCY 

(VS. 2018)

AVE. REQUIRED FUEL CONS. 

(GAL./100 MI.)

AVE. ACHIEVED FUEL CONS. 

(GAL./100 MI.)

No Action Proposed Reduction No Action Proposed Reduction

2014 MYs 2014-

2020 Subject to 

Phase 1 

Standards

6.41 6.41 0.0% 6.21 6.21 0.0%

2015 6.41 6.41 0.0% 6.12 6.12 0.0%

2016 6.27 6.27 0.0% 6.15 6.15 0.0%

2017 6.11 6.11 0.0% 5.89 5.87 0.3%

2018 5.80 5.80 -0.1%** 5.75 5.70 0.9%

2019 5.78 5.78 0.0% 5.73 5.68 0.8%

2020 5.78 5.78 0.0% 5.73 5.68 0.8%

2021 2.5% 5.77 5.64 2.3% 5.72 5.44 4.8%

2022 4.9% 5.77 5.50 4.7% 5.72 5.44 4.8%

2023 7.3% 5.77 5.38 6.8% 5.72 5.29 7.6%

2024 9.6% 5.77 5.25 9.1% 5.72 5.23 8.5%

2025 11.9% 5.77 5.12 11.4% 5.72 4.98 12.9%

2026 14.1% 5.77 4.98 13.7% 5.72 4.94 13.6%

2027 16.2% 5.77 4.86 15.8% 5.72 4.87 14.9%

2028* 16.2% 5.77 4.86 15.8% 5.72 4.87 14.9%

2029* 16.2% 5.77 4.86 15.8% 5.72 4.86 15.0%

2030* 16.2% 5.77 4.86 15.8% 5.72 4.86 15.0%

Notes:

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

*Absent further action, standards assumed to continue unchanged after model year 2027.

**Increased work factor for some vehicles produces a slight increase in average required fuel consumption.
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Table 5-30 Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved CO2

Emission Rates for Method A, Relative to Alternative 1a

a

MODEL 

YEAR

STRINGENCY 

(VS. 2018)

AVE. REQUIRED CO2 RATE 

(G./MI.)

AVE. ACHIEVED CO2 RATE 

(G./MI.)

No 

Action

Proposed Reduction No 

Action

Proposed Reduction

2014 MYs 2014-

2020 Subject to 

Phase 1

Standards

602 602 0.0% 581 581 0.0%

2015 608 608 0.0% 578 578 0.0%

2016 593 593 0.0% 580 580 0.0%

2017 578 578 0.0% 556 554 0.3%

2018 548 548 -0.1%** 543 538 0.9%

2019 545 546 -0.1%** 539 535 0.8%

2020 545 545 -0.1%** 539 535 0.8%

2021 2.5% 544 532 2.2% 538 512 4.9%

2022 4.9% 544 519 4.7% 538 512 4.9%

2023 7.3% 544 507 6.8% 538 497 7.7%

2024 9.6% 544 495 9.1% 538 492 8.6%

2025 11.9% 544 482 11.4% 538 470 12.7%

2026 14.1% 544 470 13.6% 538 466 13.4%

2027 16.2% 544 458 15.8% 538 459 14.7%

2028* 16.2% 544 458 15.8% 538 459 14.7%

2029* 16.2% 544 458 15.8% 538 459 14.8%

2030* 16.2% 544 458 15.8% 538 459 14.8%

Notes:

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

*Absent further action, standards assumed to continue unchanged after model year 2027.

**Increased work factor for some vehicles produces a slight increase in the average required CO2 emission rate.

While the above tables show the agencies’ estimates of average fuel consumption and 

CO2 emission rates manufacturers might achieve under today’s proposed standards, total U.S. 

fuel consumption and GHG emissions from HD pickups and vans will also depend on how many 

of these vehicles are produced, and how they are operated over their useful lives. Relevant to 

estimating these outcomes, the CAFE model applies vintage-specific estimates of vehicle 

survival and mileage accumulation, and adjusts the latter to account for the rebound effect. This 

impact of the rebound effect is specific to each model year (and, underlying, to each vehicle 

model in each model year), varying with changes in achieved fuel consumption rates. For 

additional details, see Chapter 2 of the draft RIA.

5.3.2.3.1.3.2 Method B for HD Pickups and Vans

For Method B, MOVES model was used to estimate fuel consumption and GHG 

emissions for HD pickups and vans. MOVES evaluated the proposed standards for HD pickup 

trucks and vans in terms of grams of CO2 per mile or gallons of fuel per 100 miles. Since nearly 

all HD pickup trucks and vans are certified on a chassis dynamometer, the CO2 reductions for 

these vehicles were not represented as engine and road load reduction components, but rather as 

total vehicle CO2 reductions. The stringency increases relative to the Phase 1 standards for HD 

pickup trucks and vans (Table 5-32) were modified in the “emissionrate” table in MOVES. 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

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Table 5-31 Estimated Total Vehicle CO2 Reductions for the Proposed Standards and In-Use Emissions for 

HD Pickup Trucks and Vans in Method B a

VEHICLE TYPE FUEL MODEL YEAR CO2 REDUCTION 

FROM REFERENCE 

CASE

HD Pickup Trucks 

and Vans

Gasoline 

and Diesel

2021 2.50%

2022 4.94%

2023 7.31%

2024 9.63%

2025 11.89%

2026 14.09%

2027+ 16.24%

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

5.3.2.3.2 VMT Inputs

The “HPMSVtype” table in MOVES was modified to reflect the VMT rebound (VMT 

rebound is described in more detail in Chapter 8.3 of the draft RIA). This table estimated VMT 

values for all calendar years. For the control case, the absolute VMT for vocational vehicle and 

combination tractor-trailer were increased from the reference cases by 1.83 percent, and 0.79

percent, respectively, to reflect the VMT rebound. Since VMT is applied by calendar year and 

not by model year, post-processing of the results were performed to ensure that only the model 

years affected by the program experienced VMT rebound – the results from the reference cases

were used in the control case inventories for model years not affected by the proposed rules.

For HD pickups and vans, Method A used the CAFE model which simulates VMT in a 

dynamic fashion that responds to changes in vehicle fuel economy and fuel prices and adjusts the 

marginal VMT of each vehicle model, at every age (so in each calendar year). In general, the 

more stringent alternatives considered lead to larger improvements in fuel economy and, thus, a 

greater number of vehicle miles traveled as a result of the rebound effect. In the CAFE model, 

the rebound effect represents a symmetric driver of changes to VMT; if the per-mile price of 

driving declines relative to today (either from improvements in vehicle fuel economy or declines 

in fuel prices), VMT increases by the amount of the rebound effect, conversely, if the per-mile 

price of driving increases relative to today (due to increases in the price of fuel), VMT will 

decline by the amount of the rebound effect. In Method B, the VMT rebound effect was 

modeled using the MOVES model which assumed an increase in VMT from the reference levels 

by 1.18 percent.

5.3.3 Calculation of Upstream Emissions
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5-25

The term "upstream emissions" refers to air pollutant emissions generated from all crude 

oil extraction, transport, refining, and finished fuel transport, storage, and distribution; this 

includes all stages prior to the final filling of vehicle fuel tanks at retail service stations. 

Additionally, it includes the production of renewable fuels and transportation of such fuel, either 

separately or mixed with conventional fuels. 

As described in Section 5.3.1, the decreased volumes of the crude based fuels and the 

various crude production and transport emission factors from GREET were used to estimate the 

net impact of fuel use changes on upstream emissions. The analysis for this proposed 

rulemaking assumes that all changes in volumes of fuel used affect only gasoline and diesel, with 

no effects on use of ethanol, biodiesel or other renewable fuels. The production and transport of 

these renewable fuels, although unchanged in volume for this analysis, are still accounted for in 

the total inventory in this proposed rulemaking. Although impacts to agriculture related to 

renewable fuels and the associated transport of these feedstocks were originally included in the 

RFS2 rulemaking, the effects to these sectors from the proposed regulations would be minimal 

and have therefore excluded them from this analysis. 

The agencies recognize the unique GHG emission characteristics associated with 

biofuels, and specifically that in the context of biofuels, “upstream emissions” include not only

GHG emissions, but also any net biological sequestration that takes place. When considered on 

a lifecycle basis (including both tailpipe and upstream emissions), the net GHG emission impact 

of individual biofuels can vary significantly from both petroleum-based fuels and from one 

biofuel to another. EPA’s Renewable Fuel Standard (RFS) program, as modified by EISA, 

examined these differences in lifecycle emissions in detail. For example, EPA found that with 

respect to aggregate lifecycle emissions including non-tailpipe GHG emissions (such as 

feedstock growth, transportation, fuel production, and land use), lifecycle GHG emissions in 

2022 for biodiesel from soy, using certain advanced production technologies, are about 50 

percent less than diesel from petroleum. 

Non-GHG fuel production and distribution emission impacts of the program were 

estimated in conjunction with the development of lifecycle GHG emission impacts, and the GHG 

emission inventories discussed above. The basic calculation is a function of fuel volumes in the 

analysis year and the emission factors associated with each process or subprocess. It relies 

partially on the GREET model, but takes advantage of additional information and models to 

significantly strengthen and expand on the GREET analysis, as discussed in Section 5.3.1. The 

details of the assumptions, data sources, and calculations that were used to estimate the emission 

impacts presented here can be found in the docket memo, “Calculation of Upstream Emissions 

for the GHG Vehicle Rule,” initially created for use in the LD GHG rulemaking.21 The agencies 

note that to the extent future policy decisions involve upstream emissions, the agencies will need 

to consider the unique emission characteristics associated with biofuels. More broadly, the 

agencies recognize that biofuels, including biodiesel, will play an important role in reducing the 

nation’s dependence on foreign oil, thereby increasing domestic energy security. The volumes 

of renewable fuels are defined by the RFS2 standards as well as the Annual RFS rulemakings, 

and are projected using AEO2014. The volumes of renewable fuel for these standards remain in 

place regardless of overall volume of fuel affected by this proposed rulemaking. Therefore, we 

have assumed that the effect of this proposal on biofuels agriculture and transportation of raw 

agricultural goods would be minimal and excluded it from this analysis. 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-26

As described earlier, the agencies estimated the impact of the proposed rules on upstream 

using the downstream fuel consumption reductions predicted by MOVES for vocational vehicles 

and tractor-trailers. For HD pickups and vans, parallel and complementary analyses of 

estimating the emissions from upstream processes were conducted using the fuel consumption 

estimates from DOT’s CAFE model and EPA’s MOVES model, using Method A and B,

respectively. As noted previously, these analyses corroborate each other’s results.

5.3.4 Calculation of HFC EmissionsH

EPA is proposing new air conditioning (A/C) leakage standards for vocational vehicles to 

reduce HFC emissions. The Vintaging Model, developed by EPA Office of Atmospheric 

programs, produces HFC inventories for several categories of stationary and mobiles sources. 

However, it does not include air conditioning systems in medium and heavy-duty trucks within 

its inventory calculations. For this proposal, we conducted an analysis based on the inputs to the 

Vintaging Model and the inputs to the MOVES analysis discussed in Chapter 5.3.2 above. 

The general equation for calculating HFC emissions follows:

HFC emissionsYear x = A/C SystemsYear x x Average Charge Size x HFC loss rate 

We determined the number of functioning A/C systems in each year based on the 

projected sales of vehicles, the fraction of vehicles with A/C systems, and the average lifetime of 

an A/C system. Sales were drawn from the MOVES analysis and we assumed that every vehicle 

had a functioning A/C system when sold. The Vintaging Model assumes that all light-duty 

passenger vehicle A/C systems (in the U.S.) last exactly 12 years.I In the absence of other 

information, we assumed that heavy-duty vehicles A/C systems last for the same period of time 

as light-duty vehicles. Light, medium and heavy-duty vehicles use largely the same components 

in their air conditioning systems (sometimes from the same suppliers), which would indicate 

similar periods of durability. 

The charge size was determined using the Minnesota refrigerant leakage database.22 EPA 

sorted the data based on A/C charge size and evaluated only the largest 25 percent of A/C 

systems to be more representative of HD systems. The average charge size is 1,025 grams of 

refrigerant.

Due to the similarity in system design, we assumed that the light-duty vehicle emission 

rate in the Vintaging Model was applicable to the current analysis, as shown in Table 5-32. The

Vintaging Model assumes that losses occur from three events: leak, service, and disposal. 

Although vehicle A/C systems are serviced during discrete events and not usually every year, 

emissions from those events are averaged over the lifetime of the A/C system in the Vintaging 

 

H The U.S. has submitted a proposal to the Montreal Protocol which, if adopted, would phase-down production and 

consumption of HFCs.

I This is in agreement with the IPCC report IPCC/TEAP 2005 Safeguarding the Ozone Layer and the Global 

Climate System – Issues Related to Hydrofluorocarbons and Perfluorocarbons, which indicates lifetimes 

(worldwide) of 9 to 12 years.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-27

model. Leak and service emissions are considered “annual losses” and are applied every year; 

disposal is considered an “end of life loss” and is applied only once for each vintage of vehicles.J

Table 5-32 Annual In-use Vehicle HFC134a Emission Rate from Vintaging Model

KIND OF LOSS LOSS FRACTION

Leakage 8%

Maintenance /Servicing 10%

End of Life 43%

The Vintaging Model assumes that charge loss is replaced every year; i.e., assuming an 

18 percent rate of charge loss, a vehicle with a charge of 1,000 grams would lose a constant rate 

of 180 grams per year. While this loss rate is not representative of any single given vehicle, it is 

assumed accurate for the fleet as a whole. Other emissions, such as fugitive emissions at a 

production facility, leaks from cylinders in storage, etc., are not explicitly modeled, but such 

emissions are accounted for within the average annual loss rate. 

EPA’s analysis of the Minnesota database of MY 2010 vehicles suggests that many of the 

modeled vehicles likely contain some of the technology required to meet the leakage standard, 

and as a consequence are leaking less. We assume that these improvements are independent of 

EPA regulation, rather than a preemptive response to regulation. Consequently, this rulemaking

does not take credit for these emission reductions. 

Based on the Minnesota database, we determined that it is possible to reduce the HFC 

emissions from these vehicles on average by 13 percent. EPA calculated this based on the 

assumption that vehicles currently in the fleet which meet the MY 2014 standard would not 

make any additional improvements to reduce leakage. We also assumed that the systems which 

currently have leakage rates above the standard will reduce their leakage to the level of the 

standard. We then applied the 13 percent reduction to the baseline 18 percent leakage rate to 

develop a 15.6 percent leakage rate for MY 2014 and later vehicles to determine the reduction in 

emission rate which should be credited to this rulemaking.

K

We calculated our emission reductions based on the difference between the baseline case 

of 2010 vehicle technology (discussed above) and the control scenario where the loss prevention 

technology has been applied to 100 percent of the new vocational vehicles starting in 2021

model year, as would be required by the proposed standards. 

 

J The U.S. EPA has reclamation requirements for refrigerants in place under Title VI of the Clean Air Act.

K Using 18 percent as the base emission rate may overstate the net emission reductions. However, recent number 

from the ERG Report to CARB studying the leakage rate of heavy-duty vehicles are actually much larger (range of 

near 0 to 150 percent annually), and places an 18 percent annual loss rate well within the literature. However, (a) the

net impact is very small, (b) these numbers have significant uncertainty, and (c) it is unclear what the appropriate 

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

5-28

Total HFC reductions are 177 metric tons over the MY 2021 baseline A/C system in 

2035 and 210 metric tons in 2050. This is equivalent to a reduction of 253,118 metric tons of 

CO2eq emissions in 2035; and 299,590 metric tons CO2eq in 2050.L 

EPA reviewed a study conducted by the Eastern Research Group (ERG) of R134a leaks 

in heavy-duty vehicles to California Air Resources Board.23 The study included a total of 70 

medium- and heavy-duty vehicles and off-road equipment; of which 18 of the samples were HD 

tractors ranging between 1990 and 2008 model years. The mobile air conditioning capacity in 

the tractors ranged between 1,080 grams to 1,950 grams. The study measured HFC leakage 

during sample times which ranged between 0.3 and 0.6 years. ERG then calculated an 

annualized in-use leakage rate with an assumed linear projection of measured leak rates to annual 

leak rates, which may be an over-estimate. The annualize leakage rate for tractors ranged 

between nearly 0 to nearly 1.5 grams leakage per gram of MAC capacity. These leakage rates 

did not include other leakage sources such as maintenance or end of life recovery. ERG found 

that the average of all MD and HD trucks and equipment which were 2006 MY or newer had an 

average leakage of 103 grams of R134a per year. Based on these results, the agency believes 

that our estimates for HFC reductions may understate the benefits of the proposed program. The 

agency will continue to analyze this and other studies that may be conducted in the future.

5.4 Greenhouse Gas Emission and Fuel Consumption Impacts

The following subsections summarize two slightly different analyses of the annual GHG 

emissions and fuel consumption reductions expected from the proposed standards, as well as the 

reductions in GHG emissions and fuel consumption expected over the lifetime of each heavyduty vehicle categories. In addition, because the agencies are carefully considering Alternative 4 

along with Alternative 3, the preferred alternative, the results from both are presented here for 

the reader’s reference. Section 5.4.1 shows the impacts of the proposed rules and Alternative 4 

on fuel consumption and GHG emissions using the MOVES model for tractor-trailers and 

vocational vehicles, and the DOT’s CAFE model for HD pickups and vans (Method A), relative 

to two different reference cases – less dynamic and more dynamic. Section 5.4.2 shows the 

impacts of the proposed standards and Alternative 4, relative to the less dynamic reference case

only, using the MOVES model for all heavy-duty vehicle categories.

5.4.1 Impacts of the Proposed Rules and Alternative 4 using Analysis Method A

5.4.1.1 Calendar Year Analysis

5.4.1.1.1 Downstream Impacts

The following two tables summarize the agencies’ estimates of HD pickup and van fuel 

consumption and GHG emissions under the current and proposed standards defining the NoAction and Preferred alternatives, respectively. The first shows results assuming manufacturers 

would voluntarily make improvements that pay back within six months (i.e., Alternative 1b). 

The second shows results assuming manufacturers would only make improvements as needed to 

 

L Using a Global Warming Potential of 1,430 for HFC-134a.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-29

achieve compliance with standards (i.e., Alternative 1a). While underlying calculations are all 

performed for each calendar year during each vehicle’s useful life, presentation of outcomes on a 

model year basis aligns more clearly with consideration of cost impacts in each model year, and 

with consideration of standards specified on a model year basis. In addition, the agencies 

performed explicit analysis of manufacturers’ potential responses to HD pickup and van 

standards on a model year basis through 2030, and any longer-term costs presented in today’s 

notice represent extrapolation of these results absent any underlying analysis of longer-term 

technology prospects and manufacturers’ longer-term product offerings.

Table 5-33 Estimated Fuel Consumption and GHG Emissions over Useful Life of HD Pickups and Vans

Produced in Each Model year for Method A, Relative to Alternative 1b a

MODEL 

YEAR

FUEL CONSUMPTION (B. GAL.)

OVER FLEET’S USEFUL LIFE

GHG EMISSIONS (MMT CO2EQ)

OVER FLEET’S USEFUL LIFE

No Action Proposed Reduction No Action Proposed Reduction

2014 9.41 9.41 0.0% 115 115 0.0%

2015 9.53 9.53 0.0% 117 117 0.0%

2016 9.72 9.72 0.0% 119 119 0.0%

2017 9.49 9.47 0.2% 116 116 0.2%

2018 9.26 9.19 0.7% 113 113 0.7%

2019 9.20 9.14 0.7% 113 112 0.7%

2020 9.19 9.12 0.7% 112 112 0.7%

2021 9.10 8.79 3.4% 111 107 3.4%

2022 9.13 8.82 3.4% 112 108 3.4%

2023 9.11 8.59 5.7% 111 105 5.7%

2024 9.32 8.72 6.4% 114 107 6.4%

2025 9.49 8.49 10.5% 116 104 10.4%

2026 9.67 8.56 11.5% 118 105 11.3%

2027 9.78 8.55 12.6% 120 105 12.3%

2028 9.90 8.66 12.6% 121 106 12.3%

2029 10.02 8.75 12.6% 122 107 12.4%

2030 10.03 8.76 12.6% 123 107 12.4%

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 ***

5-30

Table 5-34 Estimated Fuel Consumption and GHG Emissions over Useful Life of HD Pickups and Vans

Produced in Each Model year for Method A, Relative to Alternative 1a a

MODEL 

YEAR

FUEL CONSUMPTION (B. GAL.)

OVER FLEET’S USEFUL LIFE

GHG EMISSIONS (MMT CO2EQ)

OVER FLEET’S USEFUL LIFE

No Action Proposed Reduction No Action Proposed Reduction

2014 9.41 9.41 0.0% 115 115 0.0%

2015 9.53 9.53 0.0% 117 117 0.0%

2016 9.72 9.72 0.0% 119 119 0.0%

2017 9.49 9.46 0.3% 116 116 0.3%

2018 9.27 9.19 0.8% 114 113 0.8%

2019 9.20 9.14 0.7% 113 112 0.7%

2020 9.25 9.18 0.7% 113 112 0.8%

2021 9.23 8.82 4.4% 113 108 4.4%

2022 9.26 8.85 4.4% 113 108 4.4%

2023 9.23 8.60 6.9% 113 105 6.9%

2024 9.45 8.72 7.7% 116 107 7.7%

2025 9.62 8.48 11.8% 118 104 11.7%

2026 9.81 8.58 12.5% 120 105 12.3%

2027 9.93 8.57 13.7% 121 105 13.5%

2028 10.05 8.68 13.7% 123 106 13.5%

2029 10.17 8.77 13.7% 124 108 13.5%

2030 10.18 8.78 13.7% 124 108 13.5%

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

To more clearly communicate these trends visually, the following two charts present the 

above results graphically for Method A, relative to Alternative 1b. As shown, fuel consumption 

and GHG emissions follow parallel though not precisely identical paths. Though not presented, 

charts for analysis relative to Alternative 1a would appear sufficiently similar that differences 

between Alternative 1a and Alternative 1b remain best communicated by comparing values in 

the above tables.
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5-31

Figure 5-1 Fuel Consumption (b. gal.) over Useful Life of HD Pickups and Vans Produced in Each Model 

Year for Method A
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5-32

Figure 5-2 GHG Emissions (MMT CO2eq) over Useful Life of HD Pickups and Vans Produced in Each 

Model Year for Method A
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-33

Table 5-35 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1b using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT 

CO2EQ)

N2O 

(MMT 

CO2EQ)A

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -2.4 0 0 -2.4

Vocational -2.4 0 0 -2.4

Tractor-Trailers -22.1 -0.4 0 -22.4

Total -26.9 -0.4 0 -27.2

2035 HD Pickups and 

Vans -9.4 0 0 -9.4

Vocational -11.9 0 0 -11.9

Tractor-Trailers -64.7 -1 0 -65.6

Total -86.0 -1 0 -86.9

2050 HD Pickups and 

Vans -11.8 0 0 -11.8

Vocational -17.2 0 0 -17.2

Tractor-Trailers -92.6 -1.4 0 -94.0

Total -121.6 -1.4 0 -123.0

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 5-36 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1a using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT 

CO2EQ)

N2O 

(MMT 

CO2EQ)A

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -2.9 0 0 -2.9

Vocational -2.4 0 0 -2.4

Tractor-Trailers -22.5 -0.4 0 -22.8

Total -27.7 -0.4 0 -28.1

2035 HD Pickups and 

Vans -10.5 0 0 -10.5

Vocational -11.9 0 0 -11.9

Tractor-Trailers -71.1 -1 0 -72.1

Total -93.6 -1 0 -94.6

2050 HD Pickups and 

Vans -13.1 0 0 -13.1

Vocational -17.2 0 0 -17.2

Tractor-Trailers -103.2 -1.4 0 -104.6

Total -133.5 -1.4 0 -134.9

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 ***

5-34

Table 5-37 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Alternative 4 vs. Alt 1b using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT 

CO2EQ)

N2O 

(MMT 

CO2EQ)A

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -3.3 0 0 -3.3

Vocational -4.0 0 0 -4.0

Tractor-Trailers -25.9 -0.4 0 -26.2

Total -33.2 -0.4 0 -33.5

2035 HD Pickups and 

Vans -10.3 0 0 -10.3

Vocational -12.9 0 0 -12.9

Tractor-Trailers -66.7 -1 0 -67.7

Total -89.9 -1 0 -90.9

2050 HD Pickups and 

Vans -12.6 0 0 -12.6

Vocational -17.3 0 0 -17.3

Tractor-Trailers -92.8 -1.4 0 -94.2

Total -122.6 -1.4 0 -124.0

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 5-38 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Alternative 4 vs. Alt 1a using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT 

CO2EQ)

N2O 

(MMT 

CO2EQ)A

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -4.0 0 0 -4.0

Vocational -4.0 0 0 -4.0

Tractor-Trailers -26.2 -0.4 0 -26.6

Total -34.3 -0.4 0 -34.6

2035 HD Pickups and 

Vans -11.6 0 0 -11.6

Vocational -12.9 0 0 -12.9

Tractor-Trailers -73.2 -1 0 -74.2

Total -97.7 -1 0 -98.7

2050 HD Pickups and 

Vans -14.0 0 0 -14.0

Vocational -17.3 0 0 -17.3

Tractor-Trailers -103.3 -1.4 0 -104.7

Total -134.6 -1.4 0 -136.0

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 ***

5-35

Table 5-39 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Preferred Alternative vs. Alt 1b using Analysis Method A a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.1 0.1

Vocational 0.2 0

Tractor-Trailers 2.2 0

Total 2.5 0.2

2035 HD Pickups and Vans 0.3 0.7

Vocational 1.0 0.2

Tractor-Trailers 6.3 0

Total 7.6 0.9

2050 HD Pickups and Vans 0.3 0.9

Vocational 1.4 0.3

Tractor-Trailers 9.1 0

Total 10.8 1.2

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

Table 5-40 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Preferred Alternative vs. Alt 1a using Analysis Method A a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.1 0.2

Vocational 0.2 0

Tractor-Trailers 2.2 0

Total 2.5 0.2

2035 HD Pickups and Vans 0.3 0.8

Vocational 1.0 0.2

Tractor-Trailers 7.0 0

Total 8.3 1.0

2050 HD Pickups and Vans 0.4 1.0

Vocational 1.4 0.3

Tractor-Trailers 10.1 0

Total 11.9 1.3

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 ***

5-36

Table 5-41 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Alternative 4 vs. Alt 1b using Analysis Method A a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.1 0.2

Vocational 0.3 0.1

Tractor-Trailers 2.5 0

Total 3.0 0.3

2035 HD Pickups and Vans 0.3 0.8

Vocational 1.0 0.2

Tractor-Trailers 6.5 0

Total 7.9 1.0

2050 HD Pickups and Vans 0.4 1.0

Vocational 1.4 0.3

Tractor-Trailers 9.1 0

Total 10.8 1.3

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

Table 5-42 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Alternative 4 vs. Alt 1a using Analysis Method A a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.2 0.3

Vocational 0.3 0.1

Tractor-Trailers 2.6 0

Total 3.1 0.3

2035 HD Pickups and Vans 0.4 0.8

Vocational 1.0 0.2

Tractor-Trailers 7.2 0

Total 8.6 1.1

2050 HD Pickups and Vans 0.5 1.0

Vocational 1.4 0.3

Tractor-Trailers 10.1 0

Total 12.0 1.3

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

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

5-37

Table 5-43 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1b using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)A

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -0.6 -0.1 0 -0.7

Vocational -0.7 -0.1 0 -0.8

Tractor-Trailers -7.0 -0.7 0 -7.8

Total -8.4 -0.9 -0.1 -9.3

2035 HD Pickups and 

Vans -2.5 -0.4 -0.1 -2.9

Vocational -3.6 -0.4 0 -4.0

Tractor-Trailers -20.6 -2.1 -0.1 -22.8

Total -26.6 -2.8 -0.2 -29.7

2050 HD Pickups and 

Vans -3.1 -0.4 -0.1 -3.7

Vocational -5.1 -0.6 0 -5.7

Tractor-Trailers -29.5 -3.0 -0.1 -32.6

Total -37.7 -4.0 -0.3 -42.0

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 5-44 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1a using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)A

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -0.7 -0.1 0 -0.9

Vocational -0.7 -0.1 0 -0.8

Tractor-Trailers -7.1 -0.7 0 -7.9

Total -8.6 -0.9 -0.1 -9.6

2035 HD Pickups and 

Vans -2.8 -0.4 -0.1 -3.3

Vocational -3.6 -0.4 0 -4.0

Tractor-Trailers -22.6 -2.3 -0.1 -25.0

Total -29.0 -3.1 -0.2 -32.3

2050 HD Pickups and 

Vans -3.5 -0.5 -0.1 -4.1

Vocational -5.1 -0.6 0 -5.7

Tractor-Trailers -32.8 -3.3 -0.2 -36.3

Total -41.4 -4.4 -0.3 -46.1

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 ***

5-38

Table 5-45 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Alternative 4 vs. Alt 1b using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)A

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -0.9 -0.1 0 -1.0

Vocational -1.2 -0.1 0 -1.3

Tractor-Trailers -8.2 -0.8 0 -9.1

Total -10.3 -1.1 -0.1 -11.5

2035 HD Pickups and 

Vans -2.7 -0.4 -0.1 -3.2

Vocational -3.8 -0.4 0 -4.3

Tractor-Trailers -21.2 -2.2 -0.1 -23.5

Total -27.8 -3.0 -0.2 -31.0

2050 HD Pickups and 

Vans -3.3 -0.5 -0.1 -4.0

Vocational -5.1 -0.6 0 -5.7

Tractor-Trailers -29.5 -3.0 -0.1 -32.7

Total -38.0 -4.0 -0.3 -42.3

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

Table 5-46 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Alternative 4 vs. Alt 1a using Analysis Method A a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)A

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans -1.0 -0.2 0 -1.2

Vocational -1.2 -0.1 0 -1.3

Tractor-Trailers -8.4 -0.8 0 -9.2

Total -10.6 -1.1 -0.1 -11.8

2035 HD Pickups and 

Vans -3.1 -0.4 -0.1 -3.6

Vocational -3.8 -0.4 0 -4.3

Tractor-Trailers -23.3 -2.4 -0.1 -25.8

Total -30.2 -3.2 -0.2 -33.7

2050 HD Pickups and 

Vans -3.7 -0.5 -0.1 -4.4

Vocational -5.1 -0.6 0 -5.7

Tractor-Trailers -32.9 -3.3 -0.2 -36.4

Total -41.7 -4.4 -0.3 -46.5

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 ***

5-39

5.4.1.1.1 HFC Impacts

The projected HFC emission reductions due to the proposed AC leakage standards are 

estimated to be 93,272 metric tons of CO2eq in 2025, 253,118 metric tons of CO2eq in 2035, and 

299,590 metric tons CO2eq in 2050.

5.4.1.1.2 Total (Downstream + Upstream + HFC) Impacts

Table 5-47 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Preferred 

Alternative vs. Alt 1b using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -27.2 -86.9 -123.0

Upstream -9.3 -29.7 -42.0

HFC -0.09 -0.25 -0.3

Total -36.6 -116.9 -165.3

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

Table 5-48 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Preferred 

Alternative vs. Alt 1a using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -28.1 -94.6 -134.9

Upstream -9.6 -32.3 -46.1

HFC -0.09 -0.25 -0.3

Total -37.8 -127.2 -181.3

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

Table 5-49 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. 

Alt 1b using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -33.5 -90.9 -124.0

Upstream -11.5 -31.0 -42.3

HFC -0.09 -0.25 -0.3

Total -45.1 -122.2 -166.6

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 ***

5-40

Table 5-50 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. 

Alt 1a using Analysis Method A a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -34.6 -98.7 -136.0

Upstream -11.8 -33.7 -46.5

HFC -0.09 -0.25 -0.3

Total -46.5 -132.7 -182.8

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

5.4.1.1 Model Year Lifetime Analysis

Table 5-51 Lifetime GHG Reductions and Fuel Savings by Heavy-Duty Vehicle Category – Summary for 

Model Years 2018-2029 using Analysis Method A

a

ALTERNATIVE 3 

(PROPOSED)

ALTERNATIVE 4

NO-ACTION ALTERNATIVE 

(BASELINE)

1b (More 

Dynamic)

1a (Less 

Dynamic)

1b (More 

Dynamic)

1a (Less 

Dynamic)

Fuel Savings (Billion Gallons) 72.2 76.7 81.9 86.7

 HD Pickups and Vans 7.8 8.9 9.4 10.8

 Vocational 8.3 8.3 10.9 10.9

 Tractor/Trailers 56.1 59.5 61.6 65.0

Total GHG Reductions (MMT CO2eq) 986.5 1,047.4 1,114.8 1,181.1

 HD Pickups and Vans 94.8 108.5 113.7 132.8

 Vocational 109.7 109.7 143.0 143.0

 Tractor/Trailers 782.0 829.2 858.1 905.3

Note:

a

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

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

5.4.2 Impacts of the Proposed Rules and Alternative 4 using Analysis Method B

5.4.2.1 Calendar Year Analysis

5.4.2.1.1 Downstream Impacts

After all the MOVES runs and post-processing was completed, the less dynamic 

reference (Alternative 1a) and control case (Alternative 3) inventories were totaled for all heavyduty vehicle types and emission processes to estimate total downstream GHG and fuel 

consumption impacts of the program. 

To estimate the fuel savings from the proposed rules, the total energy consumption for all 

HD segments was run as a surrogate in MOVES since fuel consumption is not directly modeled 

in MOVES. Then, the total energy consumption was converted to fuel consumption based on 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-41

fuel heating values assumed in the Renewable Fuels Standard rulemakingMand used in the 

development of MOVES emission and energy rates.N 

Table 5-52 and Table 5-53 summarize these downstream GHG impacts in calendar years

2025, 2035, and 2050, relative to Alternative 1a, for the preferred alternative and Alternative 4, 

respectively. Table 5-54 and Table 5-55 show the estimated fuel savings from the preferred 

alternative and Alternative 4 in 2025, 2035, and 2050, relative to Alternative 1a. The reductions 

in CO2 emissions result from all heavy-duty vehicle categories (including the engines associated 

with tractor-trailer combinations and vocational vehicles) due to engine and vehicle 

improvements. N2O emissions show a very slight increase because of a rebound in vehicle miles 

traveled (VMT). However, since N2O is produced as a byproduct of fuel combustion, the 

increase in N2O emissions is expected to be more than offset by the improvements in fuel 

efficiency from the proposed rules.O The methane emissions decrease primarily due to 

differences in hydrocarbon emission characteristics between on-road diesel engines and APUs. 

The amount of methane emitted as a fraction of total hydrocarbons is expected to be significantly 

less for APUs than for diesel engines. Overall, downstream GHG emissions would be reduced 

significantly. In addition, substantial fuel savings would be achieved from improved fuel 

efficiency. All emissions impacts reflect the heavy-duty sector only, and do not include 

emissions from light-duty vehicles or any other vehicle sector.

 

M Renewable Fuels Standards assumptions of 115,000 BTU/gallon gasoline (E0) and 76,330 BTU/gallon ethanol 

(E100) were weighted 90% and 10%, respectively, for E10 and 85% and 15%, respectively, for E15 and converted 

to kJ at 1.055 kJ/BTU. The conversion factors are 117,245 kJ/gallon for gasoline blended with ten percent ethanol 

(E10) and 115,205 kJ/gallon for gasoline blended with fifteen percent ethanol (E15).

N The conversion factor for diesel is 138,451 kJ/gallon. See MOVES2004 Energy and Emission Inputs. EPA420-P05-003, March 2005. http://www.epa.gov/otaq/models/ngm/420p05003.pdf

O MOVES is not capable of modeling the changes in exhaust N2O emissions from the improvements in fuel 

efficiency. Due to this limitation, a conservative approach was taken to only model the VMT rebounds in estimating 

the emissions impact on N2O from the proposed rules, resulting in a slight increase in downstream N2O inventory.
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-42

Table 5-52 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1a using Analysis Method B a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans

-2.1 0.0003 0.0005 -2.1

Vocational -2.4 0.0009 0.0007 -2.4

Tractor-Trailers -22.5 -0.4 0.0006 -22.9

Total -27.0 -0.4 0.002 -27.4

2035 HD Pickups and 

Vans

-10.6 0.0007 0.001 -10.6

Vocational -11.9 0.002 0.002 -11.9

Tractor-Trailers -71.2 -1.0 0.001 -72.2

Total -93.7 -1.0 0.004 -94.7

2050 HD Pickups and 

Vans

-14.8 0.0009 0.001 -14.8

Vocational -17.2 0.003 0.002 -17.2

Tractor-Trailers -103.1 -1.4 0.002 -104.5

Total -135.1 -1.4 0.005 -136.5

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

Table 5-53 Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category –Alternative 4 vs. Alt 1a using Analysis Method B a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)

TOTAL 

DOWNSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans

-3.1 0.0003 0.0005 -3.1

Vocational -4.0 0.0009 0.0007 -4.0

Tractor-Trailers -26.2 -0.4 0.0006 -26.6

Total -33.3 -0.4 0.002 -33.7

2035 HD Pickups and 

Vans

-11.2 0.0007 0.001 -11.2

Vocational -12.9 0.0024 0.002 -12.9

Tractor-Trailers -73.2 -1.0 0.001 -74.2

Total -97.3 -1.0 0.004 -98.3

2050 HD Pickups and 

Vans

-14.9 0.0009 0.001 -14.9

Vocational -17.3 0.003 0.002 -17.3

Tractor-Trailers -103.3 -1.4 0.002 -104.7

Total -135.5 -1.4 0.005 -136.9

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 ***

5-43

Table 5-54 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Preferred Alternative vs. Alt 1a using Analysis Method B a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.1 0.1

Vocational 0.2 0.05

Tractor-Trailers 2.2 0

Total 2.5 0.2

2035 HD Pickups and Vans 0.5 0.6

Vocational 1.0 0.2

Tractor-Trailers 7.0 0

Total 8.5 0.8

2050 HD Pickups and Vans 0.8 0.8

Vocational 1.4 0.3

Tractor-Trailers 10.1 0

Total 12.3 1.1

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

Table 5-55 Annual Fuel Savings in Calendar Years 2025, 2035 and 2050 by Heavy-Duty Vehicle Category –

Alternative 4 vs. Alt 1a using Analysis Method B a

CY VEHICLE CATEGORY DIESEL SAVINGS

(BILLION GALLONS)

GASOLINE SAVINGS

(BILLION GALLONS)

2025 HD Pickups and Vans 0.2 0.2

Vocational 0.3 0.1

Tractor-Trailers 2.6 0

Total 3.1 0.3

2035 HD Pickups and Vans 0.6 0.6

Vocational 1.0 0.3

Tractor-Trailers 7.2 0

Total 8.8 0.9

2050 HD Pickups and Vans 0.8 0.8

Vocational 1.4 0.3

Tractor-Trailers 10.1 0

Total 12.3 1.1

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

5.4.2.1.2 Upstream Impacts

The upstream GHG impacts of preferred alternative and Alternative 4 associated with the 

production and distribution of gasoline and diesel from crude oil, relative to Alternative 1a, are 

summarized in Table 5-56 and Table 5-57, for calendar years 2025, 2035, and 2050. These 

estimates show impacts for domestic emission reductions only. Additionally, since this 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

5-44

rulemaking is not expected to impact biofuel volumes mandated by the Annual Renewable Fuel 

Standards (RFS) regulations, the impacts on upstream emissions from changes in biofuel 

feedstock (i.e., agricultural sources such as fertilizer, fugitive dust, and livestock) are not 

included. The reductions in upstream GHGs are proportional to the amount of fuel saved.

Table 5-56 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Preferred Alternative vs. Alt 1a using Analysis Method B a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans

-0.6 -0.1 -0.003 -0.7

Vocational -0.7 -0.1 -0.004 -0.8

Tractor-Trailers -7.1 -0.7 -0.03 -7.8

Total -8.4 -0.9 -0.04 -9.3

2035 HD Pickups and 

Vans

-2.9 -0.3 -0.02 -3.2

Vocational -3.6 -0.4 -0.02 -4.0

Tractor-Trailers -22.6 -2.3 -0.1 -25.0

Total -29.1 -3.0 -0.1 -32.2

2050 HD Pickups and 

Vans

-4.0 -0.5 -0.02 -4.5

Vocational -5.1 -0.6 -0.03 -5.7

Tractor-Trailers -32.8 -3.3 -0.2 -36.3

Total -41.9 -4.4 -0.2 -46.5

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 ***

5-45

Table 5-57 Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 by HeavyDuty Vehicle Category – Alternative 4 vs. Alt 1a using Analysis Method B a

CY VEHICLE 

CATEGORY

CO2

(MMT)

CH4

(MMT CO2EQ)

N2O 

(MMT CO2EQ)

TOTAL 

UPSTREAM 

(MMT CO2EQ)

2025 HD Pickups and 

Vans

-0.8 -0.1 -0.005 -1.0

Vocational -1.2 -0.1 -0.01 -1.3

Tractor-Trailers -8.4 -0.8 -0.04 -9.2

Total -10.4 -1.0 -0.1 -11.5

2035 HD Pickups and 

Vans

-3.0 -0.4 -0.02 -3.4

Vocational -3.8 -0.4 -0.02 -4.2

Tractor-Trailers -23.3 -2.4 -0.1 -25.8

Total -30.1 -3.2 -0.1 -33.4

2050 HD Pickups and 

Vans

-4.0 -0.5 -0.02 -4.5

Vocational -5.1 -0.6 -0.03 -5.7

Tractor-Trailers -32.9 -3.3 -0.2 -36.4

Total -42.0 -4.4 -0.2 -46.6

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

5.4.2.1.3 HFC Impacts

Based on projected HFC emission reductions due to the proposed AC leakage standards, 

EPA estimates the HFC reductions to be 93,272 metric tons of CO2eq in 2025, 253,118 metric 

tons of CO2eq in 2035, and 299,590 metric tons CO2eq in 2050. 

5.4.2.1.4 Total (Downstream + Upstream + HFC) Impacts

The combined annual GHG emissions reductions of preferred alternative from 

downstream, upstream, and HFC, relative to Alternative 1a, are summarized in Table 5-58 for 

calendar years 2025, 2035 and 2050. The combined impact of Alternative 4 on total GHG 

emissions are shown in Table 5-59. Because of the differences in lead time, as expected, 

Alternative 4 shows greater annual GHG reductions in earlier years (i.e., calendar year 2025), but 

by 2050, the preferred alternative and Alternative 4 show the same magnitude of reductions in 

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

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Table 5-58 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Preferred 

Alternative vs. Alt 1a using Analysis Method B a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -27.4 -94.7 -136.5

Upstream -9.3 -32.2 -46.5

HFC -0.1 -0.25 -0.3

Total -36.8 -127.2 -183.3

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

Table 5-59 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. 

Alt 1a using Analysis Method B a

CY 2025 (MMT CO2EQ) 2035 (MMT CO2EQ) 2050 (MMT CO2EQ)

Downstream -33.7 -98.3 -136.9

Upstream -11.5 -33.4 -46.6

HFC -0.1 -0.25 -0.3

Total -45.3 -132.0 -183.8

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

Figure 5-3 graphically illustrates the total annual GHG trends for both Phase 1 and Phase 

2 proposal, using Method B, for calendar years from 2014 to 2050. The less dynamic baseline 

from Phase 2 proposal is assumed to be equivalent to the Phase 1 program. 
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Figure 5-3 Total Annual GHG Trends for Phase 1 and Phase 2 Proposal, using Analysis Method B

5.4.2.2 Model Year Lifetime Analysis

In addition to the annual GHG emissions and fuel consumption reductions expected from 

the proposed rules and Alternative 4, the combined (downstream and upstream) GHG and fuel 

consumption impacts over the model year lifetimes of the impacted vehicles sold in the 

regulatory timeframe were estimated. In contrast to the calendar year analysis, the model year 

lifetime analyses show the impacts of the program on each of these model year fleets over the 

course of their lifetimes. Table 5-60 shows the fleet-wide GHG reductions and fuel savings from 

the proposed rules and Alternative 4 through the lifetimePof heavy-duty vehicles, relative to 

Alternative 1a. In addition, because the agencies are carefully considering Alternative 4 along 

with the preferred alternative, the lifetime GHG reductions and fuel savings of Alternative 4 are 

presented as well in Table 5-60. Compared to the preferred alternative, Alternative 4 shows 

greater lifetime GHG reductions and fuels savings by 12 percent and 13 percent, respectively. 

 

P A lifetime of 30 years is assumed in MOVES.
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Table 5-60 Lifetime GHG Reductions and Fuel Savings by Heavy-Duty Vehicle Category – Summary for 

Model Years 2018-2029 using Analysis Method B a

ALTERNATIVE 3 

(PROPOSED)

ALTERNATIVE 4

NO-ACTION ALTERNATIVE (BASELINE) 1a (Less Dynamic) 1a (Less Dynamic)

Fuel Savings (Billion Gallons) 75.8 85.4

 HD Pickups and Vans 8.0 9.5

 Vocational 8.3 10.9

 Tractor/Trailers 59.5 65.0

Total GHG Reductions (MMT CO2eq) 1,036.4 1,163.1

 HD Pickups and Vans 97.5 114.8

 Vocational 109.7 143.0

 Tractor/Trailers 829.2 905.3

Note:

a

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

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

Furthermore, the combined lifetime GHG reductions and fuel savings of Phase 1 and 

proposed Phase 2 programs are presented in Table 5-62. To be consistent with the emissions 

modeling done for this proposed program, the lifetime GHG reductions and fuel savings from 

Phase 1 were estimated using the same modeling tools used in the proposed program. 

Table 5-61 Combined Lifetime GHG Reductions and Fuel Savings of Phase 1 and Proposed Phase 2 Program

using Analysis Method B a

TOTAL GHG REDUCTIONS

(MMT CO2EQ)

FUEL SAVINGS 

(BILLION GALLONS)

Phase 1

 MY 2014-2018 313 23

 MY 2019-2029 1,020 75

Phase 2 - Proposed

 MY 2018-2029 1,036 76

Combined Total 2,369 174

Note:

a

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

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

5.5 Non-Greenhouse Gas Emission Impacts

The proposed heavy-duty vehicle standards and Alternative 4 are expected to influence 

the emissions of criteria air pollutants and several air toxics. Similar to Section 5.4, the 

following subsections summarize two slightly different analyses of the annual non-GHG 

emissions reductions expected from the proposed standards. Section 5.5.1 shows the impacts of 

the proposed rules and Alternative 4 on non-GHG emissions using the analytical Method A,

relative to two different reference cases – less dynamic and more dynamic. Section 5.5.2 shows 
*** E.O. 12866 Review – REVISED – Do Not Cite, Quote, or Release During Review ***

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the impacts of the proposed standards and Alternative 4, relative to the less dynamic reference 

case only, using the MOVES model for all heavy-duty vehicle categories. 

5.5.1 Impacts of the Proposed Rules and Alternative 4 using Analysis Method A

5.5.1.1 Calendar Year Analysis

5.5.1.1.1 Downstream Impacts

Table 5-62 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Preferred Alternative vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -3% -21 -12% -30 -16%

Acetaldehyde -669 -10% -1,882 -31% -2,667 -36%

Acrolein -97 -10% -272 -31% -385 -37%

Benzene -123 -6% -347 -19% -490 -24%

CO -26,485 -3% -75,199 -8% -106,756 -9%

Formaldehyde -2,100 -12% -5,910 -32% -8,376 -37%

NOX -92,444 -7% -260,949 -28% -370,663 -34%

PM2.5 643 2% 1,722 8% 2,410 10%

SOX -229 -4% -715 -13% -1,026 -15%

VOC -13,161 -6% -38,051 -21% -54,139 -26%

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 5-63 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Preferred Alternative vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -3% -21 -12% -30 -16%

Acetaldehyde -669 -10% -1,880 -31% -2,664 -36%

Acrolein -97 -10% -271 -31% -384 -37%

Benzene -123 -6% -346 -19% -490 -24%

CO -26,576 -3% -75,571 -8% -107,287 -9%

Formaldehyde -2,100 -12% -5,904 -32% -8,369 -37%

NOX -93,197 -8% -266,890 -29% -380,303 -35%

PM2.5 632 2% 1,635 8% 2,267 9%

SOX -232 -4% -776 -14% -1,125 -16%

VOC -13,210 -6% -38,964 -22% -55,628 -26%

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
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Table 5-64 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Alternative 4 vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -2% -21 -12% -30 -16%

Acetaldehyde -669 -10% -1,882 -31% -2,667 -36%

Acrolein -97 -10% -271 -31% -385 -37%

Benzene -124 -6% -347 -19% -490 -24%

CO -26,705 -3% -75,407 -8% -106,874 -9%

Formaldehyde -2,100 -12% -5,908 -32% -8,375 -37%

NOX -93,984 -8% -262,150 -28% -370,704 -34%

PM2.5 619 2% 1,705 8% 2,412 10%

SOX -280 -5% -742 -13% -1,029 -15%

VOC -13,925 -7% -38,472 -22% -54,150 -26%

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 5-65 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Alternative 4 vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -2% -21 -12% -29 -16%

Acetaldehyde -668 -10% -1,880 -31% -2,664 -36%

Acrolein -97 -10% -271 -31% -384 -37%

Benzene -124 -6% -346 -19% -489 -24%

CO -26,821 -3% -75,795 -8% -107,414 -9%

Formaldehyde -2,099 -12% -5,902 -32% -8,367 -37%

NOX -94,724 -8% -268,075 -29% -380,328 -35%

PM2.5 609 2% 1,618 8% 2,269 9%

SOX -282 -5% -803 -14% -1,127 -16%

VOC -13,971 -7% -39,383 -22% -55,638 -26%

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

5.5.1.1.2 Upstream Impacts
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Table 5-66 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Preferred Alternative vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -5% -3 -14% -5 -17%

Acetaldehyde -3 -3% -10 -11% -15 -13%

Acrolein 0 -4% -1 -12% -2 -15%

Benzene -21 -4% -74 -13% -104 -15%

CO -3,798 -5% -12,087 -14% -17,120 -17%

Formaldehyde -19 -5% -59 -14% -84 -17%

NOX -9,472 -5% -30,333 -14% -42,839 -17%

PM2.5 -1,019 -5% -3,257 -14% -4,609 -17%

SOX -5,983 -5% -19,190 -14% -27,074 -17%

VOC -3,066 -4% -11,029 -13% -15,386 -15%

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 5-67 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Preferred Alternative vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -5% -4 -15% -5 -18%

Acetaldehyde -3 -3% -11 -12% -16 -14%

Acrolein 0 -4% -1 -13% -2 -15%

Benzene -22 -4% -80 -14% -113 -16%

CO -3,911 -5% -13,153 -15% -18,794 -18%

Formaldehyde -19 -5% -65 -15% -92 -18%

NOX -9,787 -5% -33,021 -15% -47,028 -18%

PM2.5 -1,051 -5% -3,545 -15% -5,058 -18%

SOX -6,189 -5% -20,896 -15% -29,726 -18%

VOC -3,193 -4% -11,848 -13% -16,625 -16%

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 ***

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Table 5-68 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Alternative 4 vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -6% -3 -15% -5 -17%

Acetaldehyde -4 -5% -11 -12% -15 -14%

Acrolein -1 -5% -1 -13% -2 -15%

Benzene -28 -5% -78 -13% -105 -16%

CO -4,679 -6% -12,640 -15% -17,263 -17%

Formaldehyde -23 -6% -62 -15% -85 -17%

NOX -11,708 -6% -31,769 -15% -43,263 -17%

PM2.5 -1,259 -6% -3,408 -15% -4,649 -17%

SOX -7,402 -6% -20,107 -15% -27,356 -17%

VOC -4,081 -5% -11,717 -13% -15,645 -15%

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 5-69 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Alternative 4 vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -6% -4 -16% -5 -18%

Acetaldehyde -4 -5% -12 -12% -16 -14%

Acrolein -1 -5% -1 -13% -2 -16%

Benzene -29 -5% -84 -14% -114 -17%

CO -4,816 -6% -13,720 -16% -18,945 -18%

Formaldehyde -24 -6% -67 -16% -93 -18%

NOX -12,098 -6% -34,501 -16% -47,477 -18%

PM2.5 -1,298 -6% -3,700 -16% -5,101 -18%

SOX -7,658 -6% -21,843 -16% -30,024 -18%

VOC -4,251 -5% -12,541 -14% -16,870 -16%

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

5.5.1.1.3 Total Impacts
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Table 5-70 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -3% -25 -13% -34 -16%

Acetaldehyde -672 -10% -1,893 -30% -2,682 -36%

Acrolein -97 -10% -273 -31% -387 -37%

Benzene -145 -5% -421 -18% -595 -22%

CO -30,282 -3% -87,286 -8% -123,876 -10%

Formaldehyde -2,119 -11% -5,969 -32% -8,460 -37%

NOX -101,916 -7% -291,282 -26% -413,501 -31%

PM2.5 -376 -1% -1,535 -3% -2,199 -4%

SOX -6,213 -5% -19,905 -14% -28,101 -17%

VOC -16,227 -6% -49,080 -18% -69,525 -22%

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 5-71 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -3% -25 -13% -35 -16%

Acetaldehyde -672 -10% -1,891 -30% -2,680 -36%

Acrolein -97 -10% -273 -31% -386 -37%

Benzene -145 -5% -425 -18% -603 -22%

CO -30,487 -3% -88,724 -8% -126,081 -10%

Formaldehyde -2,119 -11% -5,969 -32% -8,461 -37%

NOX -102,983 -7% -299,911 -26% -427,332 -32%

PM2.5 -419 -1% -1,910 -4% -2,791 -5%

SOX -6,421 -5% -21,672 -15% -30,850 -18%

VOC -16,403 -6% -50,812 -19% -72,253 -23%

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 ***

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Table 5-72 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1b using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -3% -25 -13% -34 -16%

Acetaldehyde -673 -10% -1,893 -30% -2,682 -36%

Acrolein -97 -10% -273 -31% -387 -37%

Benzene -152 -6% -426 -18% -595 -22%

CO -31,383 -3% -88,047 -8% -124,137 -10%

Formaldehyde -2,123 -11% -5,970 -32% -8,460 -37%

NOX -105,693 -7% -293,918 -26% -413,967 -31%

PM2.5 -639 -1% -1,703 -4% -2,237 -4%

SOX -7,682 -6% -20,849 -15% -28,385 -17%

VOC -18,006 -6% -50,189 -19% -69,796 -22%

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 5-73 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1a using Analysis Method A a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -3% -25 -13% -35 -16%

Acetaldehyde -672 -10% -1,891 -30% -2,679 -36%

Acrolein -97 -10% -273 -31% -386 -37%

Benzene -153 -6% -430 -18% -603 -22%

CO -31,637 -3% -89,514 -8% -126,360 -10%

Formaldehyde -2,123 -11% -5,969 -32% -8,460 -37%

NOX -106,822 -7% -302,575 -26% -427,805 -32%

PM2.5 -689 -1% -2,082 -5% -2,833 -5%

SOX -7,941 -6% -22,646 -16% -31,151 -18%

VOC -18,222 -6% -51,924 -19% -72,509 -23%

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 ***

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5.5.1.2 Model Year Lifetime Analysis

Table 5-74 Lifetime Non-GHG Reductions by Heavy-Duty Vehicle Category – Summary for Model Years 

2018-2029 using Analysis Method A (US Short Tons) a

ALTERNATIVE 3 

(PROPOSED)

ALTERNATIVE 4

NO-ACTION ALTERNATIVE 

(BASELINE)

1b (More 

Dynamic)

1a (Less 

Dynamic)

1b (More 

Dynamic)

1a (Less 

Dynamic)

NOX 2,359,548 2,409,738 2,420,931 2,472,021

 HD Pickups and Vans 24,663 27,772 30,213 34,222

 Vocational 15,810 15,810 24,265 24,265

 Tractor/Trailers 2,319,075 2,366,156 2,366,453 2,413,534

PM2.5 13,496 15,706 17,524 19,839

 HD Pickups and Vans 2,502 2,842 3,038 3,484

 Vocational 2,509 2,509 3,421 3,421

 Tractor/Trailers 8,485 10,355 11,065 12,934

SOX 167,415 177,948 189,670 200,992

 HD Pickups and Vans 19,221 21,813 23,395 26,776

 Vocational 17,295 17,295 22,416 22,416

 Tractor/Trailers 130,899 138,840 143,859 151,800

Note:

a

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

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

5.5.2 Impacts of the Proposed Rules and Alternative 4 using Analysis Method B

5.5.2.1 Calendar Year Analysis

5.5.2.1.1 Downstream Impacts

After all the MOVES runsQand post-processing were completed, the less dynamic 

reference (Alternative 1a) and control case (Alternative 3) inventories were aggregated for all 

vehicle types and emission processes to estimate the total downstream non-GHG impacts of the 

proposed program. Table 5-75 and Table 5-76 summarize these downstream non-GHG impacts 

of preferred alternative and Alternative 4 for calendar years 2025, 2035 and 2050, relative to 

Alternative 1a. The results are shown both in changes in absolute tons and in percent reductions 

from the less dynamic reference to alternatives for the heavy-duty sector. 

The agencies expect the proposed program to impact the downstream emissions of nonGHG pollutants. These pollutants include oxides of nitrogen (NOX), oxides of sulfur (SOX),

 

Q

For non-GHGs, MOVES was run only for January and July and the annual emissions were extrapolated by scaling 

up each month by a factor of 5.88 for all pollutants except particulate matter (PM). For PM, to offset the 

disproportionate effect of the cold temperature on January results, a scaling factor of 4.3 was applied to January and 

7.5 to July; these factors were determined based on analysis of annual PM emissions during modeling for the RFS2 

rule. Note that for GHGs, MOVES was run for all months.
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5-56

volatile organic compounds (VOC), carbon monoxide (CO), fine particulate matter (PM2.5), and 

air toxics. The agencies are expecting reductions in downstream emissions of NOX, VOC, SOX, 

CO, and air toxics. Much of these estimated net reductions are a result of the agencies’ 

anticipation of increased use of auxiliary power units (APUs) in combination tractors during 

extended idling; APUs emit these pollutants at a lower rate than on-road engines during extended 

idle operation, with the exception of PM2.5. 

Additional reductions in tailpipe emissions of NOX and CO and refueling emissions of 

VOC would be achieved through improvements in engine efficiency and reduced road load 

(improved aerodynamics and tire rolling resistance), which reduces the amount of work required 

to travel a given distance and increases fuel economy. 

For vehicle types not affected by road load improvements, such as HD pickups and 

vansR, non-GHG emissions would increase very slightly due to VMT rebound. In addition, 

brake wear and tire wear emissions of PM2.5 would also increase very slightly due to VMT 

rebound. The agencies estimate that downstream emissions of SOX would be reduced, because 

they are roughly proportional to fuel consumption. Alternative 4 would have directionally 

similar effects as the preferred alternative. 

Table 5-75 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Preferred Alternative vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -2.6% -22 -15.1% -31 -19.6%

Acetaldehyde -670 -10.3% -1,884 -31.0% -2,671 -36.5%

Acrolein -97 -9.9% -272 -31.6% -385 -37.3%

Benzene -125 -5.9% -353 -21.0% -501 -25.7%

CO -25,824 -1.7% -72,960 -6.0% -103,887 -7.6%

Formaldehyde -2,102 -11.5% -5,911 -32.1% -8,379 -37.5%

NOX -93,220 -7.5% -267,125 -29.1% -380,721 -35.2%

PM2.5 634 1.6% 1,631 7.6% 2,257 9.1%

SOX -254 -4.8% -876 -15.0% -1,264 -18.1%

VOC -13,440 -6.4% -40,148 -21.7% -57,308 -26.1%

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

 

R HD pickups and vans are subject to gram per mile (distance) emissions standards, as opposed to larger heavy-duty

vehicles which are certified to a gram per brake horsepower (work) standard. 
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Table 5-76 Annual Downstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 

and 2050 – Alternative 4 vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -8 -2.6% -22 -15.1% -31 -19.6%

Acetaldehyde -670 -10.3% -1,884 -31.0% -2,671 -36.5%

Acrolein -97 -9.9% -272 -31.6% -385 -37.3%

Benzene -126 -5.9% -354 -21.0% -501 -25.7%

CO -25,919 -1.7% -73,041 -6.0% -103,891 -7.6%

Formaldehyde -2,101 -11.5% -5,910 -32.1% -8,378 -37.5%

NOX -94,787 -7.6% -268,373 -29.2% -380,810 -35.2%

PM2.5 610 1.5% 1,611 7.5% 2,256 9.1%

SOX -313 -5.9% -909 -15.6% -1,267 -18.1%

VOC -14,310 -6.8% -40,640 -22.0% -57,348 -26.1%

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

As shown in Table 5-77, a net increase in downstream PM2.5 emissions is expected in 

both 2035 and 2050. Although the improvements in engine efficiency and road load are 

expected to reduce tailpipe emissions of PM2.5, the projected increased use (Table 5-23) of APUs 

would lead to higher PM2.5 emissions that more than offset the reductions from the tailpipe, since 

engines powering APUs are currently required to meet less stringent PM standards than on-road 

engines. Therefore, EPA conducted an evaluation of a program that would reduce the 

unintended consequence of increase in PM2.5 emissions from increased APU use by fitting the 

APU with a diesel particulate filter or having the APU exhaust plumbed into the vehicle’s 

exhaust system upstream of the particulate matter aftertreatment device. Such program requiring 

additional PM2.5 controls on APU could significantly reduce PM2.5 emissions, as shown in Table 

5-77 below. For additional details, see Section III.C.3 of the preamble. 

Table 5-77 Projected Impact on PM2.5 Emissions of Further PM2.5 Control on APUs using Analysis Method 

B

a

CY PROPOSED 

PROGRAM 

INVENTORY 

WITHOUT 

FURTHER PM2.5

CONTROL ON 

APUS

PROPOSED 

PROGRAM 

INVENTORY 

WITH FURTHER 

PM2.5 CONTROL 

ON APUS

NET IMPACT OF 

FURTHER PM2.5

CONTROL ON 

APUS

2035 23,083 19,999 -3,084

2050 26,932 22,588 -4,344

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
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It is worth noting that the emission reductions shown in Table 5-75 are not incremental to 

the emissions reductions projected in the Phase 1 rulemaking. This is because the agencies have 

revised their assumptions about the adoption rate of APUs. This proposal assumes that without 

the proposed Phase 2 program (i.e., in the Phase 2 reference case), the APU adoption rate will be 

30 percent for model years 2010 and later, which is the value used in the Phase 1 reference case. 

This decision was based on the agencies’ assessment of how the current level of automatic 

engine shutdown and idle reduction technologies are used by the tractor manufacturers to comply 

with the 2014 model year CO2 and fuel consumption standards. To date, the manufacturers are 

meeting the 2014 model year standards without the use of this technology. Compared to Phase 

1, the proposed program projects much delayed penetration of APUs starting in model year 2021 

( Figure 5-4).

Figure 5-4 Comparison of Assumed APU Use during Extended Idle in Phase 1 and Phase 2

Considering the change in assumptions about APU use and the magnitude of impact of 

APUs on criteria emissions, EPA conducted an analysis estimating the combined emissions 

impacts of the Phase 1 and proposed Phase 2 programs for NOX, VOC, SOX and PM2.5 in 

calendar year 2050. The analysis estimated the combined Phase 1 and Phase 2 emissions 

impacts by comparing the Phase 2 control case inventories to the Phase 1 reference case

inventories. To be consistent with the emissions modeling done for this proposed program, the 

emissions inventories for Phase 1 reference case were estimated using MOVES2014.

S

 The 

results are shown in Table 5-78. The differences in downstream reduction estimates between 

 

S The emissions modeling for Phase 1 was performed using MOVES2010a.
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Phase 2 alone (Table 5-75) and combined Phase 1 and Phase 2 (Table 5-78) reflect the 

improvements in road loads from Phase 1. For NOX and PM2.5 only, we also estimated the 

combined Phase 1 and Phase 2 downstream and upstream emissions impacts for calendar year 

2025, and project that the two rules combined would reduce NOX by up to 120,000 tons and 

PM2.5 by up to 2,000 tons in that year.

Table 5-78 Combined Phase 1 and Phase 2 Annual Downstream Reductions of Heavy-Duty Criteria 

Emissions in Calendar Year 2050 using Analysis Method B a

CY NOX VOC SOX PM2.5 

b

2050 403,915 69,415 2,111 -1,890

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

b Negative reduction reflects an increase in emissions. 

5.5.2.1.2 Upstream Impacts

The proposed program is projected to provide emissions reductions in all pollutants 

associated with upstream from production and distribution as the projected fuel savings reduce 

the demands for gasoline and diesel. Table 5-79 and Table 5-80 summarize the annual upstream 

reductions of preferred alternative and Alternative 4 for criteria pollutants and individual air 

toxic pollutants in calendar years 2025, 2035 and 2050, relative to Alternative 1a. The results 

are shown both in changes in absolute tons and in percent reductions from the less dynamic 

reference to alternatives for the heavy-duty sector. 

Table 5-79 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Preferred Alternative vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -5.0% -4 -15.3% -5 -18.4%

Acetaldehyde -4 -3.0% -18 -11.9% -26 -14.6%

Acrolein -0.5 -3.4% -2 -12.7% -3 -15.5%

Benzene -24 -3.8% -92 -13.4% -132 -16.3%

CO -3,798 -4.9% -13,001 -15.3% -18,772 -18.4%

Formaldehyde -19 -4.7% -67 -14.9% -98 -18.0%

NOX -9,282 -4.9% -31,782 -15.3% -45,888 -18.4%

PM2.5 -1,020 -4.9% -3,514 -15.2% -5,072 -18.2%

SOX -5,817 -4.9% -19,902 -15.3% -28,736 -18.4%

VOC -3,283 -3.7% -12,724 -13.2% -18,214 -16.1%

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
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Table 5-80 Annual Upstream Impacts of Heavy-Duty Non-GHG Emissions in Calendar Years 2025, 2035 and 

2050 – Alternative 4 vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -1 -6.1% -4 -15.9% -5 -18.4%

Acetaldehyde -6 -4.3% -20 -12.6% -26 -14.7%

Acrolein -1 -4.7% -2 -13.3% -3 -15.5%

Benzene -32 -5.0% -97 -14.0% -133 -16.3%

CO -4,661 -6.1% -13,485 -15.9% -18,812 -18.4%

Formaldehyde -24 -5.9% -70 -15.5% -97 -18.0%

NOX -11,393 -6.1% -32,965 -15.9% -45,986 -18.4%

PM2.5 -1,256 -6.0% -3,647 -15.7% -5,083 -18.3%

SOX -7,137 -6.1% -20,641 -15.9% -28,797 -18.4%

VOC -4,342 -4.9% -13,326 -13.8% -18,273 -16.1%

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

5.5.2.1.3 Total Impacts

As shown in Table 5-81 and Table 5-82, the agencies estimate that this proposed program 

and Alternative 4 would result in overall net reductions of NOX, VOC, SOX, CO, PM2.5, and air 

toxics emissions. The downstream increase in PM2.5 due to APU use is expected to be more than 

offset by reductions in PM2.5 from upstream.T The results are shown both in changes in absolute 

tons and in percent reductions from the less dynamic reference to the alternatives for the heavyduty sector. By 2050, the total impacts of the proposed program and Alternative 4 on criteria 

pollutants and air toxics are indistinguishable. 

 

T Although a net reduction in PM2.5 is expected at the national level, it is unlikely that the geographic location of 

increases in downstream PM2.5 emissions will coincide with the location of decreases in upstream PM2.5 emissions. 

For the final rulemaking, a national-scale air quality modeling analysis will be performed to estimate the future year 

ambient PM2.5 concentrations for 2040. For further details, see Section VIII.D of this preamble and Chapter 8 of the 

draft RIA.
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Table 5-81 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Preferred Alternative vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -2.7% -25 -15.1% -36 -19.4%

Acetaldehyde -674 -10.1% -1,902 -30.5% -2,697 -36.0%

Acrolein -97 -9.8% -274 -31.3% -388 -36.9%

Benzene -149 -5.4% -445 -18.8% -633 -22.9%

CO -29,622 -1.9% -85,961 -6.6% -122,659 -8.4%

Formaldehyde -2,121 -11.4% -5,978 -31.7% -8,475 -37.0%

NOX -102,502 -7.2% -298,907 -26.6% -426,610 -32.1%

PM2.5 -386 -0.6% -1,883 -4.2% -2,815 -5.4%

SOX -6,070 -4.9% -20,777 -15.3% -30,000 -18.4%

VOC -16,724 -5.6% -52,872 -18.8% -75,521 -22.7%

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 5-82 Annual Total Impacts (Upstream and Downstream) of Heavy-Duty Non-GHG Emissions in 

Calendar Years 2025, 2035 and 2050 – Alternative 4 vs. Alt 1a using Analysis Method B a

POLLUTANT CY2025 CY2035 CY2050

US Short 

Tons

% Reduction US Short 

Tons

% Reduction US Short 

Tons

% Reduction

1,3-Butadiene -9 -2.8% -26 -15.2% -36 -19.4%

Acetaldehyde -676 -10.1% -1,903 -30.6% -2,697 -36.0%

Acrolein -97 -9.8% -274 -31.3% -388 -36.9%

Benzene -157 -5.7% -450 -18.9% -634 -22.9%

CO -30,580 -1.9% -86,526 -6.6% -122,703 -8.4%

Formaldehyde -2,125 -11.4% -5,980 -31.7% -8,476 -37.0%

NOX -106,180 -7.4% -301,339 -26.8% -426,796 -32.1%

PM2.5 -646 -1.1% -2,036 -4.6% -2,827 -5.4%

SOX -7,450 -6.1% -21,550 -15.9% -30,064 -18.4%

VOC -18,652 -6.2% -53,966 -19.2% -75,621 -22.7%

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

5.5.2.2 Model Year Lifetime Analysis

In addition to the annual non-GHG emissions reductions expected from the proposed 

rules and Alternative 4, the combined (downstream and upstream) non-GHG impacts for the 

lifetime of the impacted vehicles were estimated by heavy-duty vehicle category. Table 5-83
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5-62

shows the fleet-wide reductions of NOX, PM2.5 and SOX from the preferred alternative and 

Alternative 4, relative to Alternative 1a, through the lifetimeUof heavy-duty vehicles. 

Table 5-83 Lifetime Non-GHG Reductions by Heavy-Duty Vehicle Category – Summary for Model Years 

2018-2029 using Analysis Method B (US Short Tons) a

ALTERNATIVE 3 

(PROPOSED)

ALTERNATIVE 4

NO-ACTION ALTERNATIVE 

(BASELINE) 1a (Less Dynamic) 1a (Less Dynamic)

NOX 2,399,990 2,459,497

 HD Pickups and Vans 18,024 21,698

 Vocational 15,810 24,265

 Tractor/Trailers 2,366,156 2,413,534

PM2.5 15,206 19,151

 HD Pickups and Vans 2,342 2,796

 Vocational 2,509 3,421

 Tractor/Trailers 10,355 12,934

SOX 169,436 189,904

 HD Pickups and Vans 13,301 15,688

 Vocational 17,295 22,416

 Tractor/Trailers 138,840 151,800

Note:

a

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

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

 

U A lifetime of 30 years is assumed in MOVES.
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5-63

References

1

Intergovernmental Panel on Climate Change Working Group I. 2007. Climate Change 2007 – The Physical 

Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on 

Climate Change (IPCC).

2 U.S. EPA. 2014. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. EPA 430-R-14-003. 

Available at

http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2014-Main-Text.pdf

3 U.S. EPA. 2009. Technical Support Document for Endangerment and Cause or Contribute

Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, DC. pp. 180-194. Available 

at

http://epa.gov/climatechange/endangerment/downloads/Endangerment%20TSD.pdf 

4 U.S. EPA. 2014. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. EPA 430-R-14-003. 

Available at

http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2014-Main-Text.pdf

5 MOVES2014 homepage: http://www.epa.gov/otaq/models/moves/index.htm 

6 Argonne National Laboratory. The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation 

(GREET) Model versions 1.8.c. http://www.transportation.anl.gov/modeling_simulation/GREET/.

7

2007 Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (AR4)

8 MOVES2014 homepage: http://www.epa.gov/otaq/models/moves/index.htm

9 Memorandum to the Docket “Runspecs, Model Inputs, MOVES Code and Database for HD GHG Phase 2 NPRM 

Emissions Modeling” Docket No. EPA-HQ-OAR-2014-0827

10 U.S. EPA. Draft Regulatory Impact Analysis: Changes to Renewable Fuel Standard Program. Chapters 2 and 3. 

May 26, 2009. Docket No. EPA-HQ-OAR-2009-0472-0119

11 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel 

Economy Standards (77 FR 62623, October 15, 2012)

12 Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and 

Vehicles (76 FR 57106, September 15, 2011)

13 Memorandum to the Docket “Upstream Emissions Modeling Files for HDGHG Phase 2 NPRM” Docket No. 

EPA-HQ-OAR-2014-0827

14 U.S. EPA. 2015. Population and Activity of On-road Vehicles in MOVES2014 – Draft Report” Docket No. EPAHQ-OAR-2014-0827.

15 Annual Energy Outlook 2014. http://www.eia.doe.gov/oiaf/aeo/

16 U.S. EPA. 2015. “Exhaust Emission Rates for Heavy-Duty On-road Vehicles in MOVES2014 – Draft Report” 

Docket No. EPA-HQ-OAR-2014-0827.

17 Memorandum to the Docket “NPRM - Tractor-Trailer Inputs to MOVES” Docket No. EPA-HQ-OAR-2014-0827

18 ACT Research Co., LLC. U.S. Trailers Monthly Market Indicators. Available at www.actresearch.net/reports

Accessed 7/28/2014

19 U.S. Census Bureau. 2002 Vehicle Inventory and Use Survey. Available at 

https://www.census.gov/svsd/www/vius/2002.html Accessed 6/30/2014

20 Memorandum to the Docket “NPRM - Vocational Inputs to MOVES” Docket No. EPA-HQ-OAR-2014-0827

21 Craig Harvey, EPA, “Calculation of Upstream Emissions for the GHG Vehicle Rule.” 2009. Docket No. EPAHQ-OAR-2009-0472-0216

22 The Minnesota refrigerant leakage data: http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata

23 Eastern Research Group. “A Study of R134a Leaks in Heavy Duty Vehicles.” CARB Contract 06-342. Presented 

during CARB Seminar on January 6, 2011.