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Chapter 6: Results of Final and Alternative Standards

EO12866_GHG+Fuel Eff Stds for Med-Heavy-Duty Engines+Vehicles 2060-AP61 FRM 

RIA_20110722_Ch 6 Results of the Preferred and Alternative Standards.docx

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

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

trailer manufacturers, truck fleet owners and the public. The final standards that the agencies 

have laid out today are largely shaped to maximize the environmental and fuel savings benefits 

of the program respecting the unique and varied nature of the sector. In developing this final 

rulemaking, we considered a number of alternatives that could have resulted in fewer or 

potentially greater GHG and fuel consumption reductions than the program we are finalizing. 

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

costs, CO2 reductions, and fuel savings associated with each alternative. The agencies reduced 

the number of alternatives analyzed in this final rulemaking from those analyzed in the draft EIS 

and at proposal because we did not receive any comments supporting standard setting for a 

smaller subset than HD pickup trucks, combination tractors, and vocational vehicles. As 

discussed below, the agencies have refined some of the alternatives presented in the draft EIS 

and at proposal in response to the comments received.

6.1 What Are the Alternatives that the Agencies Considered?

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

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

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

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

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

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

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

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

considerations.

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

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

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

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

alternatives in order of increasing fuel efficiency and GHG emissions reductions are:

6.1.1 Alternative 1: No Action

A “no action” alternative assumes that the agencies would not issue a rule regarding a 

MD/HD fuel efficiency improvement program, and is considered to comply with National 

Environmental Policy Act (NEPA) and to provide an analytical baseline against which to 
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6-2

compare environmental impacts of the other regulatory alternatives.1The agencies refer to this 

as the “No Action Alternative” or as a “no increase” or “baseline” alternative. As described in 

RIA Chapter 5, this no-action alternative is considered the reference case. The estimated fleetwide fuel efficiency of this reference case is included in Table 6-1.
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Table 6-1 Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 1 (Baseline) [gallons/100 

miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups and 

Vans - gasoline

6.5 6.5 6.5 6.5 6.5 6.5

HD Pickups and 

Vans- diesel

7.6 7.5 7.5 7.5 7.5 7.5

Vocational –

gasoline

11.3 11.3 11.3 11.3 11.3 11.3

Vocational –

diesel

10.3 10.2 10.2 10.2 10.2 10.2

Comb. tractors 20.3 20.2 20.2 20.2 20.2 20.2

The no action alternative first presented in this final rule is based on the assumption that 

the new vehicle fleet continues to perform at the same level as new 2010 vehicles. In this way, it 

provides a comparison between today’s new trucks and the increased cost and reduced fuel 

consumption of future compliant vehicles. 

The agencies recognize that there is substantial uncertainty in determining an appropriate 

baseline against which to compare the effects of the proposed action. The lack of prior 

regulation of HD fuel efficiency means that there is a lack of historic data regarding trends in this 

sector. Therefore, in this final rule the agencies have also included an analysis using a baseline 

derived from annual projections developed by the U.S. Energy Information Administration (EIA) 

for the Annual Energy Outlook (AEO). For this alternative baseline, the agencies analyzed the 

new truck fuel economy projections for Light Commercial Trucks, along with the Medium- and 

Heavy-Duty Freight Vehicles developed in AEO 2011.2 The agencies converted the fuel 

economy improvements into CO2 emissions reductions relative to a 2010 model year (see RIA 

Chapter 6).

The baseline derived from the AEO forecast provides a comparison between the impacts 

of the proposed standards and EIA’s projection of future new truck performance absent 

regulation. This alternative baseline is informative in showing one possible projection of future 

vehicle performance based on other factors beyond the regulation the agencies are finalizing 

today. The AEO forecast makes a number of assumptions that should be noted. AEO 2011 

assumes improved fuel efficiency for 8500-10,000 heavy-duty pickups due to the light-duty 

2012-2016 CAFE and GHG regulations. We project a similar capability for fuel economy

improvement as AEO does for this class of vehicles; however, the agencies recognize that absent 

regulation manufacturers may decline to add the necessary technologies to reach the level of our 

proposed standards. For medium and heavy-duty vocational trucks, AEO 2011 projects a small 

reduction in fuel efficiency over time (an increase in fuel consumption), similar to that achieved 

under the MY 2010 baseline. For Class 8 combination tractors, the AEO 2011 baseline projects 

an annual improvement of approximately 0.3%.
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6-4

The agencies analyzed the new truck fuel economy projections for the Light Commercial 

Trucks, along with the Medium-Duty Freight Vehicles developed in AEO 2011.3 The agencies 

converted the fuel economy improvements into CO2 emissions reductions relative to a 2010 

model year, as depicted in Table 6-2.

Table 6-2: CO2 Emission Rate Change relative to 2010 MY vehicle

Model Year HD Pickup Trucks & 

Vans

Vocational 

Vehicles -

Gasoline

Vocational 

Vehicles - Diesel

2010 -- -- --

2011 0.05% -0.14% 0.03%

2012 -1.11% -0.22% 0.04%

2013 -1.68% -0.26% 0.05%

2014 -2.57% -0.30% 0.05%

2015 -4.45% -0.35% 0.05%

2016 -6.38% -0.41% 0.05%

2017 -8.50% -0.49% 0.05%

2018 -10.52% -0.61% 0.05%

2019 -10.97% -0.76% 0.05%

2020 -11.65% -0.95% 0.05%

2021 -12.25% -1.19% 0.05%

2022 -12.24% -1.45% 0.05%

2023 -12.23% -1.74% 0.05%

2024 -12.26% -2.02% 0.05%

2025 -12.32% -2.28% 0.05%

2026 -12.42% -2.51% 0.05%

2027 -12.54% -2.70% 0.05%

2028 -12.68% -2.84% 0.05%

2029 -12.83% -2.91% 0.05%

2030 -12.99% -2.91% 0.05%

2031 -13.13% -2.91% 0.05%

2032 -13.27% -2.91% 0.05%

2033 -13.35% -2.91% 0.05%

2034 -13.43% -2.91% 0.05%

2035 -13.51% -2.91% 0.05%

2036 -13.63% -2.91% 0.05%

2037 -13.74% -2.91% 0.05%

2038 -13.86% -2.91% 0.05%

2039 -13.98% -2.91% 0.05%

2040 -14.10% -2.91% 0.05%

2041 -14.22% -2.91% 0.05%

2042 -14.34% -2.91% 0.05%

2043 -14.46% -2.91% 0.05%

2044 -14.57% -2.91% 0.05%

2045 -14.69% -2.91% 0.05%

2046 -14.81% -2.91% 0.05%
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2047 -14.93% -2.91% 0.05%

2048 -15.05% -2.91% 0.05%

2049 -15.17% -2.91% 0.05%

2050 -15.29% -2.91% 0.05%

The agencies also analyzed the new truck fuel economy projections for the Heavy-Duty

Freight Vehicles developed in AEO 2011. In addition, the agencies obtained the Freight Truck 

Technology Penetration Table 146 from EIA and the technology effectiveness and costs 

developed by Argonne National Laboratory used in the National Energy Modeling System 

(NEMS) by EIA for this segment of vehicles.4 The agencies used this information to apportion 

the fuel economy improvements projected for combination tractors into four categories – engine, 

aerodynamic, tire rolling resistance, and weight improvements. The inputs to MOVES are 

included in Table 6-3 and Table 6-4.

Table 6-3: Inputs to MOVES for Short-Haul Combination Vehicle Improvements relative to 2010 MY

Model Year Engine Aerodynamics Tire Rolling 

Resistance

Weight

2010 -- -- -- --

2011 -0.02% 0.00% 0.88% 0.00%

2012 0.02% 0.09% 2.19% 0.00%

2013 0.10% 0.12% 3.35% 0.00%

2014 0.26% 0.17% 4.44% 0.00%

2015 0.52% 0.23% 5.39% 0.00%

2016 0.91% 0.33% 6.36% 0.00%

2017 1.44% 0.47% 7.33% 0.00%

2018 2.08% 0.65% 8.30% 0.00%

2019 2.63% 0.87% 9.14% 0.00%

2020 3.35% 1.09% 9.82% 0.00%

2021 4.21% 1.27% 10.50% 0.00%

2022 4.98% 1.41% 11.11% 0.01%

2023 5.67% 1.45% 11.59% 0.01%

2024 6.24% 1.45% 11.93% 0.03%

2025 6.93% 1.45% 11.93% 0.05%

2026 7.61% 1.45% 11.94% 0.09%

2027 7.68% 1.45% 11.95% 0.15%

2028 7.68% 1.45% 11.97% 0.27%

2029 7.68% 1.45% 12.00% 0.45%

2030 7.68% 1.45% 12.06% 0.76%

2031 7.68% 1.45% 12.13% 1.21%

2032 7.68% 1.45% 12.24% 1.82%

2033 7.68% 1.45% 12.40% 2.53%

2034 7.68% 1.44% 12.59% 3.25%

2035 7.68% 1.44% 12.80% 3.86%

2036 7.68% 1.44% 12.95% 3.86%
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6-6

2037 7.68% 1.43% 13.10% 3.86%

2038 7.68% 1.43% 13.25% 3.86%

2039 7.68% 1.43% 13.40% 3.86%

2040 7.68% 1.42% 13.54% 3.86%

2041 7.68% 1.42% 13.69% 3.86%

2042 7.68% 1.42% 13.84% 3.86%

2043 7.68% 1.42% 13.99% 3.86%

2044 7.68% 1.41% 14.14% 3.86%

2045 7.68% 1.41% 14.29% 3.86%

2046 7.68% 1.41% 14.44% 3.86%

2047 7.68% 1.40% 14.59% 3.86%

2048 7.68% 1.40% 14.73% 3.86%

2049 7.68% 1.40% 14.88% 3.86%

2050 7.68% 1.40% 15.03% 3.86%

Table 6-4 Inputs to MOVES for Long-Haul Combination Vehicle Improvements relative to 2010 MY

Model Year Engine Aerodynamics Tire Rolling 

Resistance

Weight

2010 -- -- -- --

2011 -0.02% 0.00% 0.48% 0.00%

2012 0.02% 0.08% 1.20% 0.00%

2013 0.10% 0.12% 1.83% 0.00%

2014 0.26% 0.17% 2.42% 0.00%

2015 0.52% 0.22% 2.93% 0.00%

2016 0.91% 0.32% 3.45% 0.00%

2017 1.44% 0.46% 3.97% 0.00%

2018 2.08% 0.64% 4.48% 0.00%

2019 2.63% 0.85% 4.93% 0.00%

2020 3.35% 1.06% 5.28% 0.00%

2021 4.21% 1.24% 5.64% 0.00%

2022 4.98% 1.38% 5.96% 0.01%

2023 5.67% 1.42% 6.21% 0.01%

2024 6.24% 1.42% 6.39% 0.03%

2025 6.93% 1.42% 6.39% 0.05%

2026 7.61% 1.42% 6.39% 0.09%

2027 7.68% 1.42% 6.40% 0.15%

2028 7.68% 1.42% 6.41% 0.27%

2029 7.68% 1.42% 6.43% 0.45%

2030 7.68% 1.42% 6.46% 0.76%

2031 7.68% 1.42% 6.50% 1.21%

2032 7.68% 1.42% 6.55% 1.82%

2033 7.68% 1.41% 6.63% 2.53%

2034 7.68% 1.41% 6.73% 3.25%

2035 7.68% 1.40% 6.84% 3.86%

2036 7.68% 1.40% 6.92% 3.86%

2037 7.68% 1.40% 7.00% 3.86%
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2038 7.68% 1.40% 7.07% 3.86%

2039 7.68% 1.39% 7.15% 3.86%

2040 7.68% 1.39% 7.23% 3.86%

2041 7.68% 1.39% 7.30% 3.86%

2042 7.68% 1.39% 7.38% 3.86%

2043 7.68% 1.38% 7.46% 3.86%

2044 7.68% 1.38% 7.54% 3.86%

2045 7.68% 1.38% 7.61% 3.86%

2046 7.68% 1.37% 7.69% 3.86%

2047 7.68% 1.37% 7.77% 3.86%

2048 7.68% 1.37% 7.84% 3.86%

2049 7.68% 1.37% 7.92% 3.86%

2050 7.68% 1.36% 8.00% 3.86%

The estimated fleet-wide fuel efficiency for each of the vehicle categories in this 

alternative baseline are listed in Table 6-5.

Table 6-5: Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 1a (AEO Baseline)

[gallons/100 miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups and

Vans - gasoline

6.5 6.3 6.2 6.1 5.9 5.8

HD Pickups and 

Vans- diesel

7.5 7.3 7.2 7.0 6.9 6.7

Vocational –

gasoline

11.3 11.3 11.3 11.2 11.2 11.2

Vocational –

diesel

10.3 10.2 10.2 10.2 10.2 10.2

Comb. tractors 20.4 20.2 20.1 20.0 19.8 19.6

6.1.2 Alternative 2: 12 Percent Less Stringent than the Preferred Alternative

Alternative 2 represents an alternative stringency level to the agencies’ preferred 

approach. Like Alternative 3 (the preferred alternative as discussed below), Alternative 2 would 

set GHG emissions and fuel efficiency standards for Class 2b through 8 vocational vehicles and 

combination tractors and the engines installed in them and Class 2b and 3 HD pickup trucks and 

vans. The difference between Alternative 2 and 3 is the level of stringency for each of the 

categories. Alternative 2 represents a stringency level which is approximately 12 percent less 

stringent than the preferred approach. The agencies calculated the Alternative 2 stringency level 

in order to meet two goals. First, we sought to create an alternative that was regulated the same 

engine and vehicle categories as the preferred alternative, but at lower stringency (10-20 percent 

lower) than the preferred alternative. Second, we wanted an alternative that reflected removal of 
Regulatory Impact Analysis 

6-8

the least cost effective technology that we believed manufacturers would add last in order to 

meet the preferred alternative. In other words, we wanted an alternative that as closely as 

possible reflected the last increment in stringency prior to reaching our preferred alternative. 

Please see Table 2.36 in RIA Chapter 2 for a list of all of the technologies, their cost and relative 

effectiveness. The resulting Alternative 2 is based on the same technologies used in Alternative 3

except as follows for each of the three categories. 

The combination tractor standard would be based removal of the Bin IV aerodynamic 

package and weight reduction technologies which decreases the average combination tractor 

GHG emissions and fuel consumption reduction by approximately 1 percent. The road load 

impacts of this alternative are listed in Table 6-6.

Table 6-6 Estimated Reductions in Rolling Resistance and Aerodynamic Drag Coefficients from Reference 

Case for Alternative 2 (Model Years 2014 and Later)

TRUCK TYPE REDUCTION IN TIRE 

ROLLING 

RESISTANCE 

COEFFICIENT FROM 

2010 MY

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

FROM 2010 MY

WEIGHT 

REDUCTION 

(LBS.)

Combination long-haul 9.6% 11% 0

Combination shorthaul7.0% 5.6% 0

The HD pickup truck and van standard would be based on removal of the 5 percent mass 

reduction technology which decreases the average truck reduction of fuel consumption and GHG 

emissions by approximately 1.6 percent. The estimated total vehicle CO2 reductions for this 

alternative are listed in Table 6-7.

Table 6-7 Estimated Total Vehicle CO2 Reductions for HD Pickup Trucks and Vans for Alternative 2

GVWR 

CLASS

FUEL MODEL 

YEARS

CO2 REDUCTION FROM 

2010 MY

LHD 2b-3 Gasoline 2014 1.3%

2015 1.7%

2016 3.4%

2017 5.0%

2018+ 8.4%

Diesel 2014 2.0%

2015 2.7%

2016 5.4%

2017 8.0%

2018+ 13.4%
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The vocational vehicle standard would be based on removal of low rolling resistance 

tires. This alternative would also reduce the amount of technologies applied to diesel engines 

used in vocational vehicles such that the engines achieve a 3% reduction in 2014 model year and 

a 5% reduction in 2017 model year, both compared to a 2010 model year baseline. The road 

load inputs for vocational vehicles are included in Table 6-8. The engine reductions are 

included in Table 6-9.

Table 6-8 Estimated Reductions in Rolling Resistance from Reference Case for Alternative 2 (Model Years 

2014 and Later)

TRUCK TYPE REDUCTION IN TIRE ROLLING 

RESISTANCE COEFFICIENT 

FROM 2010 MY

Vocational Vehicle 0%

Table 6-9 Estimated Reductions in Engine CO2 Emission Rate for Alternative 2

GVWR CLASS FUEL MODEL 

YEARS

CO2 REDUCTION 

FROM BASELINE

MHD (6-7) and LHD 4-5 Diesel 2014-2016 3%

2017+ 5%

The estimated fleet-wide fuel efficiency for Alternative 2 is listed in Table 6-10.

Table 6-10 Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 2 [gallons/100 miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups 

and Vans -

gasoline

6.5 6.4 6.4 6.3 6.2 5.9

HD Pickups 

and Vansdiesel

7.6 7.4 7.3 7.1 6.9 6.5

Vocational –

gasoline

11.3 11.3 11.3 10.7 10.7 10.7

Vocational –

diesel

10.3 9.9 9.9 9.9 9.7 9.7

Comb. tractors 20.3 18.4 18.4 18.4 17.9 17.9
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6.1.3 Alternative 3: Preferred Alternative and Final Standards

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

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

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

Details regarding modeling of this alternative are included in Chapter 5 as the control 

case. The estimated fleet-wide fuel efficiency of this alternative is included in Table 6-11.

Table 6-11 Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 3 [gallons/100 miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups 

and Vans -

gasoline

6.5 6.4 6.4 6.2 6.1 5.8

HD Pickups 

and Vansdiesel

7.6 7.4 7.3 7.1 6.8 6.4

Vocational –

gasoline

11.3 11.3 11.3 10.7 10.7 10.7

Vocational –

diesel

10.3 9.8 9.8 9.8 9.4 9.4

Comb. tractors 20.3 18.3 18.3 18.3 17.7 17.7

6.1.4 Alternative 4: 20 Percent More Stringent than Preferred Alternative

Like Alternatives 2 and 3, this alternative would set GHG emissions and fuel efficiency

standards for HD pickup trucks and vans and for Class 2b through 8 vocational vehicles and 

combination tractors and the engines installed in them. The difference between Alternative 3 and 

4 is the level of stringency for each of the standards. Alternative 4 represents a stringency level 

which is 20 percent more stringent than the preferred approach. The agencies derived the 

stringency level based on similar goals as for Alternative 2. Specifically, we wanted an 

alternative that would reflect an incremental improvement over the preferred alternative based on 

adding the next most cost effective technology in each of the categories. In general, we thought 

these were the technologies most likely to be applied by manufacturers if a more stringent 

standard were set. However, as discussed in the feasibility discussion in Section III.A.2.vi, III.B, 

and III.C.2.v of the preamble to the final rules, we are not finalizing this level of stringency

because we do not believe that there is adequate lead time for these technologies to be developed 

and introduced in the timeframe of this rulemaking. Reflecting that given unlimited resources it 

might be possible to introduce these technologies in this timeframe by, for example, constructing 

new factories in one to two years and otherwise operating entirely outside the normal redesign 

cycle, we are unable to estimate what those real costs might be (e.g. to build new factories in 

only one to two years), we have denoted the cost for this alternative with a +c. The +c is intended 

to make clear that the cost estimates we are showing do not include additional costs related to 

pulling ahead the development and expanding manufacturing base for these technologies. Nor 
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have we estimated the cost of the capital to do so, whether capital would be available. See 75 FR 

at 25,451 (May 7, 2010). The resulting Alternative 4 is based on the same technologies used in 

Alternative 3 except as follows for each of the three categories.

The combination tractor standard would be based on the addition of Rankine waste heat recovery

(which, as the agencies have found will not be available in the time frame of this rule; see 

Section III.A.2.b.ii of the preamble) and 100 percent application of Bin IV aerodynamics to high 

roof sleeper cab combination tractors. The agencies assumed 59 percent of all combination 

tractors are long-haul tractors and of those, 80 percent are high roof sleeper cabs. The agencies 

assumed a 12 kWh waste heat recovery system would reduce CO2 emissions by 6 percent at a 

cost of $8,400 per truck.5 The estimated reduction in CO2 emissions from the engine for this 

alternative is included in Table 6-12. The impact of 100 percent application of Bin IV

aerodynamic technology package would lead to a total 20.7 percent reduction in Cd values for 

high roof sleeper cabs over a 2010 MY baseline tractor. The incremental cost of this technology

over the preferred case is $1,027 for each high roof sleeper cab tractor. The impact of the 

aerodynamic package on the road load is included in Table 6-13.

Table 6-12 Estimated Reductions in Engine CO2 Emission Rates from this Alternative 4

GVWR CLASS FUEL MODEL YEARS CO2 REDUCTION 

FROM 2010 MY

HHD (8a-8b) –

Combination tractors only

Diesel 2014-2016 5.8%

2017+ 8.8%

Table 6-13 Estimated Reduction in Coefficient of Drag for Combination Long-Haul Tractors for this 

Alternative 4

TRUCK TYPE REDUCTION IN 

AERODYNAMIC DRAG 

COEFFICIENT FROM 

2010 MY

Combination long-haul 17.7%

The HD pickup truck and van standard would be based on the addition of turbo downsized 

gasoline engine technology which would bring the total reduction for gasoline HD pickup trucks 

and vans to 15 percent and match the level of reduction for the diesel pickup trucks (although, as 

noted in Section III.B.1 of the preamble, downsized engines may reduce towing utility and thus 

interfere with a chief purpose of these vehicles). The estimated total vehicle CO2 reductions for 

this alternative are listed in Table 6-14. The estimated incremental cost increase to HD pickup 

trucks and vans to replace a stoichiometric gasoline direct injected V8 engine with coupled cam 
Regulatory Impact Analysis 

6-12

phasing used in Alternative 3 with a V6 stoichiometric gasoline direct injection DOHC, discrete 

valve lift and twin turbochargers is estimated to be $1,743.6

Table 6-14 Estimated Total Vehicle CO2 Reductions for HD Pickup Trucks and Vans for Alternative 4

GVWR 

CLASS

FUEL MODEL 

YEARS

CO2 REDUCTION FROM 

2010 MY

LHD 2b-3 Gasoline 2014 2.3%

2015 3%

2016 6%

2017 9%

2018+ 15%

Diesel 2014 2.3%

2015 3%

2016 6%

2017 9%

2018+ 15%

The vocational vehicle standard would be based on the addition of hybrid powertrains to 

6 percent of the vehicles. The agencies assumed a 32 percent per vehicle reduction in GHG 

emissions and fuel consumption due to the hybrid with a cost of $26,667 per vehicle based on the 

average effectiveness and costs developed in the NAS report for box trucks, bucket trucks, and 

refuse haulers.7 The agencies project the hybrid penetration for this alternative, as described in

Table 6-15.

Table 6-15 Hybrid Penetration for Vocational Vehicles for Alternative 4

MY 2014 MY 2017

Vocational Vehicles 0% 6%

The estimated fleet-wide fuel efficiency for Alternative 4 is listed in Table 6-16.

Table 6-16 Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 4 [gallons/100 miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups 

and Vans -

gasoline

6.5 6.4 6.3 6.1 5.9 5.5
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HD Pickups 

and Vansdiesel

7.6 7.4 7.3 7.1 6.8 6.4

Vocational –

gasoline

11.3 11.3 11.3 10.5 10.5 10.5

Vocational –

diesel

10.3 9.5 9.5 9.5 9.0 9.0

Comb. tractors 20.3 17.7 17.7 17.7 17.2 17.2

6.1.5 Alternative 5: Maximum Technology Penetration plus Trailers

Alternative 5 builds on Alternative 4 through additional hybrid powertrain application 

rates in the HD sector and by adding a performance standard for fuel efficiency and GHG 

emissions of commercial trailers. This alternative includes all elements of Alternative 4, plus the 

application of additional hybrid powertrains to the pickup trucks, vans, vocational vehicles, and 

tractors. In addition, the agencies applied aerodynamic technologies to commercial box trailers, 

along with tire technologies for all commercial trailers. 

The agencies set the hybrid penetration for each category, as described in Table 6-17. 

The agencies do not believe that it is possible to achieve hybrid technology penetration rates at or 

even near these levels in the timeframe of this rulemaking. However, we believe it is useful to 

consider what a future standard based on the use of such advanced technologies could achieve. 

As with Alternative 4, we include a +c in our cost estimates for this alternative to reflect 

additional costs not estimated by the agencies. The agencies assumed that a hybrid powertrain 

would provide a 32 percent reduction in CO2 emissions and fuel consumption of a vocational 

vehicle at a projected cost of $26,667 per vehicle, based on the average of the NAS report

findings for box trucks, bucket trucks, and refuse vehicles.

8

 The agencies are projecting a cost of 

$9,000 per vehicle for the HD pickup trucks and vans with an effectiveness of 18 percent, again 

based on the NAS report.9 The effectiveness of hybrid powertrains installed in tractors was 

assumed to be 10 percent at a cost of $25,000 based on the NAS report.10 Lastly, the 

effectiveness of hybrid powertrains installed in tractors was assumed to be 10 percent at a cost of 

$25,000 based on the NAS report.11

For the analysis of vocational vehicles in this alternative, the agencies assumed that 

hybrid technology would be applied only in diesel-fueled trucks. In HD pickups and vans, the 

agencies assumed that hybrid technology would be evenly divided between diesel and gasoline 

vehicles. 

Table 6-17: Hybrid Penetration by Vehicle Class

MY 2014 MY 2017

HD Pickup Trucks & Vans 10,000 units 50%

Vocational Vehicles 10,000 units 50%
Regulatory Impact Analysis 

6-14

Combination tractors 0% 5%

The combination tractor technology package for Alternative 5 includes the preferred 

alternative technologies, waste heat recovery (assuming, against our technical finding, that the 

technology will be available) and Advanced SmartWay aerodynamic package used in Alternative 

4, application of hybrid powertrains discussed above, in addition to a regulation for commercial 

trailers pulled by combination tractors. The agencies assumed a trailer program would mirror the 

SmartWay program and include tire and aerodynamic requirements. The agencies added low 

rolling resistance tires to all commercial trailers, which are assumed to have 15 percent lower 

rolling resistance than the baseline trailer tire and is equivalent to the target value required by 

SmartWay. The aerodynamics of the box trailers were assumed to improve the coefficient of 

drag for the combination tractor-trailer by 10 percent through the application of technologies 

such as trailer skirts and gap reducers.12 These technologies would result in further reductions in 

drag coefficient and rolling resistance coefficient from the MY 2010 baseline. The agencies 

assessed the benefits of a commercial trailer regulation by changing the road load associated with 

the combination tractors. Table 6-18 describes the road load reductions. As stated above for 

hybrids, the agencies do not believe that it is possible to achieve technology penetration rates at 

or even near these levels in the timeframe of this rulemaking. However, we believe it is useful to 

consider what a future standard based on the use of such technologies could achieve. 

Table 6-18 Estimated Reductions in Rolling Resistance and Aerodynamic Drag Coefficients from Reference 

Case for Alternative 5 (Model Years 2014 and Later)

TRUCK TYPE REDUCTION IN TIRE 

ROLLING RESISTANCE 

COEFFICIENT FROM 2010 

MY

REDUCTION IN 

AERODYNAMIC DRAG 

COEFFICIENT FROM 

2010 MY

Combination long-haul 14.9% 24%

Combination short-haul 12.3% Same as Alt.3

The combination tractor costs for this alternative are equal to the costs in Alternative 4, 

plus $25,000 for hybrid powertrains in ten percent of tractors, plus the costs of trailers. The costs 

for the trailer program of Alternative 5 were derived based on the assumption that trailer 

aerodynamic improvements would cost $2,150 per trailer. This cost assumes side fairings and 

gap reducers and is based on the ICF cost estimate.13 The agencies applied the aerodynamic 

improvement to only box trailers, which represent approximately 60 percent of the trailer sales. 

The agencies used $528 per trailer for low rolling resistance based on the agencies’ estimate of 

$66 per tire in the tractor program. Lastly, the agencies assumed the trailer volume is equal to 

three times the tractor volume based on the 3:1 ratio of trailers to tractors in the market today. 

The fuel efficiency results for Alternative 5 are summarized in Table 6-19.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-15

Table 6-19 Estimated Fleet-Wide Fuel Efficiency by Model Year for Alternative 5 [gallons/100 miles]

MY 2010-2013 MY 2014 MY 2015 MY 2016 MY 2017 MY 2018

HD Pickups 

and Vans -

gasoline

6.5 6.3 6.3 6.1 5.4 5.0

HD Pickups 

and Vansdiesel

7.6 7.3 7.3 7.1 6.2 5.8

Vocational –

gasoline

11.3 11.3 11.3 10.5 10.5 10.5

Vocational –

diesel

10.3 9.5 9.5 9.5 7.8 7.8

Comb. tractors 20.3 17.4 17.4 17.4 16.8 16.8

6.2 How Do These Alternatives Compare in Overall GHG Emissions 

Reductions and Fuel Efficiency and Cost?

The agencies analyzed all five alternatives through MOVES to evaluate the impact of 

each alternative, as shown in Table 6-20. The table contains the annual CO2 and fuel savings in 

2030 and 2050 for each alternative (relative to the reference scenario of Alternative 1), 

presenting both the total savings across all regulatory categories, and for each regulatory

category. 

Table 6-21 presents the annual technology costs associated with each alternative (relative 

to the reference scenario of Alternative 1) in 2030 and 2050 for each regulatory category. In 

addition, the total annual downstream impacts of NOx, CO, PM, and VOC emissions in 2030 for 

each of the alternatives are included in Table 6-22. 

Table 6-20: Annual CO2 and Oil Reductions Relative to Alternative 1 in 2030 and 2050

DOWNSTREAM CO2

REDUCTIONS (MMT)

OIL REDUCTIONS

(BILLION GALLONS)

2030 2050 2030 2050

Alt. 1 Baseline 0 0 0 0

Alt. 1a AEO 2011 BaselineTotal39 90 3.9 9.0

Tractors 29 73 2.9 7.1

HD Pickup Trucks 9 16 0.9 1.7

Vocational Vehicles 1 2 0.1 0.2

Alt. 2 Less Stringent- Total 54 78 5.4 7.7
Regulatory Impact Analysis 

6-16

Tractors 42 59 4.2 5.8

HD Pickup Trucks 7 11 0.8 1.2

Vocational Vehicles 5 7 0.4 0.7

Alt. 3 Preferred – Total 61 88 6.0 8.7

Tractors 45 63 4.4 6.2

HD Pickup Trucks 8 13 0.9 1.3

Vocational Vehicles 7 11 0.7 1.1

Alt. 4 More Stringent–

Total

74 107 7.4 10.7

Tractors 53 74 5.2 7.3

HD Pickup Trucks 10 15 1.0 1.6

Vocational Vehicles 11 18 1.1 1.8

Alt. 5 Max Technology–

Total

99 146 9.8 14.5

Tractors 61 85 6.0 8.3

HD Pickup Trucks 15 24 1.6 2.5

Vocational Vehicles 23 37 2.2 3.6

Table 6-21: Technology Cost Projections Relative to Alternative 1 for Each Alternativea

TECHNOLOGY COSTS (2009$ MILLIONS)

2030 2050

Alt. 1 Baseline $0 $0

Alt. 1a AEO 2011 BaselineTotal b-- --

Tractors -- --

HD Pickup Trucks -- --

Vocational Vehicles -- --

Alt. 2 Less Stringent - Total $1,676 $2,440

Tractors $743 $1,227

HD Pickup Trucks $817 $1,029

Vocational Vehicles $117 $185

Alt. 3 Preferred – Total $2,210 $3,287

Tractors $1,076 $1,777

HD Pickup Trucks $918 $1,156

Vocational Vehicles $216 $354

Alt. 4 More Stringent– Total $5,211+c $6,996+c

Tractors $1,953+c $3,225+c
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-17

TECHNOLOGY COSTS (2009$ MILLIONS)

HD Pickup Trucks $1,442+c $1,816+c

Vocational Vehicles $1,816+c $1,954+c

Alt. 5 Max Technology– Total $17,909+c $27,306+c

Tractors $2,747+c $4,292+c

HD Pickup Trucks $5,669+c $7,142+c

Vocational Vehicles $9,493+c $15,873+c

a The +c is intended to make clear that the cost estimates we are showing do not include additional costs related to 

pulling ahead the development and expanding manufacturing base for these technologies.

b The agencies did not conduct a cost analysis for the AEO2011 baseline.

Table 6-22 Downstream Impacts Relative to Alternative 1 of Key Non-GHGs for Each Alternative in 2030

NOX CO PM2.5 VOC

Alt. 1 Baseline 0% 0% 0% 0%

Alt. 1a AEO 2011 Baseline 8.8% 1.0% -3.8% 7.2%

Alt. 2 Less Stringent -21.9% -2.0% 8.4% -19.0%

Alt. 3 Preferred -22.0% -2.0% 8.5% -19.1%

Alt. 4 More Stringent -22.5% -2.0% 8.7% -19.5%

Alt. 5 Max Technology -22.9% -2.1% 8.4% -20.0%

Also, the agencies project the monetized net benefits associated with each alternative for 

the 2014 through 2018 MY vehicles over their lifetimes as shown in Table 6-23 and Table 6-24.

Table 6-23 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Vehicles(3% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0

-$5,900 -$8,100 -$20,700+c -$37,200+c

Fuel Savings (pre-tax) $0 $45,000 $50,100 $63,900 $79,100

Energy Security Impacts 

(price shock)

$0

$2,400 $2,700 $3,400 $4,200

Accidents, Congestion, Noise $0 -$1,300 -$1,500 -$1,600 -$1,600

Refueling Savings $0 $300 $400 $500 $600

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $1,100 $1,200 $1,600 $1,900

3% (avg SCC) $0 $5,100 $5,700 $7,200 $9,000

2.5% (avg SCC) $0 $8,400 $9,400 $12,000 $15,000

3% (95th percentile) $0 $16,000 $17,000 $22,000 $27,000

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $41,600 $44,800 $47,100+c $47,000+c
Regulatory Impact Analysis 

6-18

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

3% (avg SCC) $0 $45,600 $49,300 $52,700+c $54,100+c

2.5% (avg SCC) $0 $48,900 $53,000 $57,500+c $60,100+c

3% (95th percentile) $0 $56,500 $60,600 $67,500+c $72,100+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero. 

d “+c” indicates additional costs not estimated in this rulemaking.

Table 6-24 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Vehicles(7% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$5,900 -$8,100 -$20,700+c -$37,200+c

Fuel Savings (pre-tax) $0 $30,900 $34,400 $43,800 $53,900

Energy Security Impacts (price 

shock)

$0 $1,600 $1,800 $2,300 $2,900

Accidents, Congestion, Noise $0 -$900 -$1,000 -$1,100 -$1,100

Refueling Savings $0 $200 $200 $300 $400

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $1,100 $1,200 $1,600 $1,900

3% (avg SCC) $0 $5,100 $5,700 $7,200 $9,000

2.5% (avg SCC) $0 $8,400 $9,400 $12,000 $15,000

3% (95th percentile) $0 $16,000 $17,000 $22,000 $27,000

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $27,000 $28,500 $26,200+c $20,800+c

3% (avg SCC) $0 $31,000 $33,000 $31,800+c $27,900+c

2.5% (avg SCC) $0 $34,300 $36,700 $36,600+c $33,900+c

3% (95th percentile) $0 $41,900 $44,300 $46,600+c $45,900+c
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-19

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.
Regulatory Impact Analysis 

6-20

Lastly, the agencies project the monetized net benefits associated with each alternative by

vehicle class for the 2014 through 2018 MY vehicles over their lifetimes as shown in Table 6-25

through Table 6-27 at a 3% discount rate for HD pickup trucks & vans, vocational vehicles and 

combination tractors, respectively, and in Table 6-28 through Table 6-30 at a 7% discount rate

for HD pickup trucks & vans, vocational vehicles and combination tractors, respectively.

Table 6-25 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year HD Pickup Trucks & Vans (3% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$1,780 -$1,970 -$3,220+c -$9,890+c

Fuel Savings (pre-tax) $0 $3,480 $4,060 $4,910 $7,700

Energy Security Impacts (price 

shock)

$0

$190 $220 $270 $420

Accidents, Congestion, Noise $0 -$330 -$350 -$370 -$350

Refueling Savings $0 $40 $50 $60 $90

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $100 $100 $100 $200

3% (avg SCC) $0 $500 $500 $600 $900

2.5% (avg SCC) $0 $800 $900 $1,100 $1,500

3% (95th percentile) $0 $1,400 $1,600 $1,900 $2,800

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $1,700 $2,110 $1,750+c -$1,830+c

3% (avg SCC) $0 $2,100 $2,510 $2,250+c -$1,130+c

2.5% (avg SCC) $0 $2,400 $2,910 $2,750+c -$530+c

3% (95th percentile) $0 $3,000 $3,610 $3,550+c $770+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.

Table 6-26 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Vocational Vehicles (3% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$670 -$1,140 -$9,140+c -$15,840+c

Fuel Savings (pre-tax) $0 $3,420 $5,420 $8,930 $14,270

Energy Security Impacts (price 

shock)

$0

$180 $290 $480 $760
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-21

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Accidents, Congestion, Noise $0 -$540 -$650 -$670 -$500

Refueling Savings $0 $40 $60 $110 $170

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $100 $100 $200 $300

3% (avg SCC) $0 $400 $600 $1,000 $1,500

2.5% (avg SCC) $0 $700 $1,100 $1,700 $2,600

3% (95th percentile) $0 $1,300 $1,900 $3,100 $4,700

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $2,530 $4,080 -$90+c -$840+c

3% (avg SCC) $0 $2,830 $4,580 $710+c $360+c

2.5% (avg SCC) $0 $3,130 $5,080 $1,410+c $1,460+c

3% (95th percentile) $0 $3,730 $5,880 $2,810+c $3,560+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.

Table 6-27 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Combination Tractors (3% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$3,300 -$4,950 -$8,430+c -$11,540+c

Fuel Savings (pre-tax) $0 $38,140 $40,650 $50,030 $57,190

Energy Security Impacts (price 

shock)

$0

$2,030 $2,160 $2,660 $3,040

Accidents, Congestion, Noise $0 -$450 -$480 -$590 -$770

Refueling Savings $0 $230 $250 $300 $350

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $900 $1,000 $1,200 $1,400

3% (avg SCC) $0 $4,200 $4,500 $5,600 $6,500

2.5% (avg SCC) $0 $7,000 $7,500 $9,300 $11,000

3% (95th percentile) $0 $13,000 $14,000 $17,000 $20,000

Monetized Net Benefits at Each Assumed SCC Value a,b
Regulatory Impact Analysis 

6-22

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

5% (avg SCC) $0 $37,550 $38,630 $45,170+c $49,670+c

3% (avg SCC) $0 $40,850 $42,130 $49,570+c $54,770+c

2.5% (avg SCC) $0 $43,650 $45,130 $53,270+c $59,270+c

3% (95th percentile) $0 $49,650 $51,630 $60,970+c $68,270+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.

Table 6-28 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year HD Pickup Trucks & Vans (7% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$1,780 -$1,970 -$3,220+c -$9,890+c

Fuel Savings (pre-tax) $0 $2,180 $2,550 $3,090 $4,830

Energy Security Impacts (price 

shock)

$0

$120 $140 $170 $260

Accidents, Congestion, Noise $0 -$220 -$230 -$250 -$230

Refueling Savings $0 $30 $30 $40 $60

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $100 $100 $100 $200

3% (avg SCC) $0 $500 $500 $600 $900

2.5% (avg SCC) $0 $800 $900 $1,100 $1,500

3% (95th percentile) $0 $1,400 $1,600 $1,900 $2,800

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $430 $620 -$70+c -$4,770+c

3% (avg SCC) $0 $830 $1,020 $430+c -$4,070+c

2.5% (avg SCC) $0 $1,130 $1,420 $930+c -$3,470+c

3% (95th percentile) $0 $1,730 $2,120 $1,730+c -$2,170+c
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-23

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.

Table 6-29 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Vocational Vehicles (7% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$670 -$1,140 -$9,140+c -$15,840+c

Fuel Savings (pre-tax) $0 $2,280 $3,630 $5,970 $9,410

Energy Security Impacts (price 

shock)

$0

$120 $190 $320 $500

Accidents, Congestion, Noise $0 -$380 -$450 -$460 -$350

Refueling Savings $0 $30 $40 $70 $110

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $100 $100 $200 $300

3% (avg SCC) $0 $400 $600 $1,000 $1,500

2.5% (avg SCC) $0 $700 $1,100 $1,700 $2,600

3% (95th percentile) $0 $1,300 $1,900 $3,100 $4,700

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $1,480 $2,370 -$3,040+c -$5,870+c

3% (avg SCC) $0 $1,780 $2,870 -$2,240+c -$4,670+c

2.5% (avg SCC) $0 $2,080 $3,370 -$1,540+c -$3,570+c

3% (95th percentile) $0 $2,680 $4,170 -$140+c -$1,470+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.
Regulatory Impact Analysis 

6-24

Table 6-30 Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetime of 

2014 through 2018 Model Year Combination Tractors (7% discount rate, Million 2009 dollars)

ALT.1

BASELINE

ALT.2 LESS 

STRINGENT

ALT.3

PREFERRED

ALT.4 MORE 

STRINGENT

ALT.5 MAX 

TECHNOLOGY

Truck Program Costs d$0 -$3,300 -$4,950 -$8,430+c -$11,540+c

Fuel Savings (pre-tax) $0 $26,420 $28,170 $34,710 $39,680

Energy Security Impacts (price 

shock)

$0

$1,410 $1,500 $1,850 $2,110

Accidents, Congestion, Noise $0 -$320 -$340 -$420 -$550

Refueling Savings $0 $160 $170 $210 $240

Non-CO2 GHG Impacts and 

Non-GHG Impacts c

N/A N/A N/A N/A N/A

Reduced CO2 Emissions at Each Assumed SCC Value a,b

5% (avg SCC) $0 $900 $1,000 $1,200 $1,400

3% (avg SCC) $0 $4,200 $4,500 $5,600 $6,500

2.5% (avg SCC) $0 $7,000 $7,500 $9,300 $11,000

3% (95th percentile) $0 $13,000 $14,000 $17,000 $20,000

Monetized Net Benefits at Each Assumed SCC Value a,b

5% (avg SCC) $0 $25,270 $25,550 $29,120+c $31,340+c

3% (avg SCC) $0 $28,570 $29,050 $33,520+c $36,440+c

2.5% (avg SCC) $0 $31,370 $32,050 $37,220+c $40,940+c

3% (95th percentile) $0 $37,370 $38,550 $44,920+c $49,940+c

Notes: 

a Net present value of reduced CO2 emissions is calculated differently than other benefits. The same 

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

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

b

Section VIII.G notes that SCC increases over time. Corresponding to the years in this table, the SCC 

estimates range as follows: for Average SCC at 5%: $5-$16; for Average SCC at 3%: $22-$46; for 

Average SCC at 2.5%: $36-$66; and for 95th percentile SCC at 3%: $66-$139. Section VIII.G also 

presents these SCC estimates.

c Due to analytical and resource limitations, MY non-GHG emissions (direct PM, VOCs, NO2 and SO2) 

were not estimated for this analysis. Although EPA has not monetized changes in non-CO2 GHGs, the 

value of any increases or reductions should not be interpreted as zero.

d “+c” indicates additional costs not estimated in this rulemaking.

References

1 NEPA requires agencies to consider a “no action” alternative in their NEPA analyses and to compare the effects of 

not taking action with the effects of the reasonable action alternatives to demonstrate the different environmental 

effects of the action alternatives. See 40 CFR 1502.2(e), 1502.14(d).CEQ has explained that “[T]he regulations 

require the analysis of the no action alternative even if the agency is under a court order or legislative command to 

act. This analysis provides a benchmark, enabling decision makers to compare the magnitude of environmental 

effects of the action alternatives. It is also an example of a reasonable alternative outside the jurisdiction of the 

agency which must be analyzed. [See 40 CFR 1502.14(c).] * * * Inclusion of such an analysis in the EIS is 

necessary to inform Congress, the public, and the President as intended by NEPA. [See 40 CFR 1500.1(a).]'' Forty 

Most Asked Questions Concerning CEQ's National Environmental Policy Act Regulations, 46 FR 18026 (1981) 

(emphasis added).
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

6-25

2 U.S. Energy Information Administration. Annual Energy Outlook 2011 Early Release. Last viewed on March 29, 

2011 at http://www.eia.doe.gov/forecasts/aeo/. See Supplemental Tables 7, 63, and 68.

3 U.S. Energy Information Administration. Annual Energy Outlook 2011 Early Release. Last viewed on March 29, 

2011 at http://www.eia.doe.gov/forecasts/aeo/. See Supplemental Tables 7, 63, and 68.

4 AEO BASELINE CALCULATIONS TO THE DOCKET.

5 TIAX. Assessment of Fuel Economy Technologies for Medium- and Heavy- Duty Vehicles, Final Report, Nov. 19 

2009. Page 4-20.

6

See Chapter 2 of this RIA, Table 2.35.

7 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium- and 

Heavy-Duty Vehicles. March 2010. Page 146..

8 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium- and 

Heavy-Duty Vehicles. March 2010. Page 146..

9 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium- and 

Heavy-Duty Vehicles. March 2010. Page 146..

10 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium- and 

Heavy-Duty Vehicles. March 2010. Page 146..

11 National Academy of Science. Technologies and Approaches to Reducing the Fuel Consumption of Medium- and 

Heavy-Duty Vehicles. March 2010. Page 146.

12 The Cd improvement of 10 percent for trailer improvements was derived from the TIAX report, Table 4-26 on 

page 4-50.

13 Assumed retail prices of $1,300 for side skirts and $850 for gap reducers based on the ICF Cost Report, page 90.