***** E.O. 12866 Review –**  **Draft –**  **Do Not Cite, Quote, or Release During Review *****



### 6 - 1 

# Chapter 6: **Results of Final**  **and Alternative Standards**  EO12866_GHG+Fuel Eff Stds for Med- Heavy- Duty Engines+Vehicles 2060 -AP61 FRM RIA_20110 722_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 finaliz ing. This section summarizes the alternatives we considered and presents assessments of technology cost s, CO 2 

### 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 rece ived. 

## 6.1 **What Are**  **the A** **lternatives that the Agencies Considered**  **?** In developing alternatives, NHTSA must consider EI SA's requirement for the MD/HD fuel efficiency

program noted above. 49 U.S.C. 32902(k)(2) and (3) contain the following three requirements speci fic 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 ye ars of regulatory stability . In considering these various requirements, NHTSA will also account for relevant environmental and safety considerations. Each of the alternatives presented b y NHTSA and EPA represents, in part, a different way the agencies could establish a HD program pursuant to EI SA and the CAA . The agenc ies are finaliz ing 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 **Alternati ve 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

### Regulatory Impact Analysis

6 - 2

compare environmental impacts of the other regulatory alternatives. 1 

### The 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 i s considered the reference case. The estimated fleetwide fuel efficiency

of this reference case is included in Table 6 - 1 .***** E.O. 12866 Review –**  **Draft –**  **Do Not Cite, Quote, or Release During Review *****



### 6 - 3 **Table 6**  **- 1**  **Estimated F**  **leet -** **W ide**  **F uel**  **Efficienc y by**  **M odel**  **Y ear for Alternative 1 (** **B aseline)**  **[ gallon**  **s /100**  **mi les**  **]** 

### 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 b y 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 develope d in AEO 2011. 2 

### The agencies converted the fuel economy improvements into CO 2 

### 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 final izing 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 voc ational 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%.

### Regulatory Impact Analysis

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 CO 2 

### emissions reductions relative to a 2010 model year, as depicted in Table 6 - 2 .

**Table 6**  **- 2**  **: CO 2**  **Em ission 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%***** E.O. 12866 Review –**  **Draft –**  **Do Not Cite, Quote, or Release During Review *****



### 6 - 5 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 b y Argonne National Laboratory used in the National Energy Modeling S ystem (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 Improvem ents 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%

### Regulatory Impact Analysis

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



### 6 - 7 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**  **: Estim** **ated F**  **leet -** **W ide**  **F uel**  **Efficienc y by**  **M odel**  **Y ear for Alternative 1**  **a (** **AEO B**  **aseline) [gallons/100 m** **iles]** 

### 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 1 2 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. 3 6 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 aerody namic 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 T IRE ROLLING RESI STANCE COEFFICIENT FROM 2010 MY REDUC TION IN AERODYNAMIC DRAG COEFFICIENT FROM 2010 MY WEIGHT REDUCTION (LBS.) Combination long-haul 9.6% 11% 0 Combination shorthaul 7.0% 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 CO 2 

### reductions for this alternative are listed in Table 6 - 7 . **Table 6**  **- 7**  **Estimated Total Vehicle CO**  **2 Reductions for HD Pickup Trucks and Vans**  **for Alternative 2** 

### GVWR CLASS FUEL MODEL YEARS CO 2 

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



### 6 - 9 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 T IRE RO LLING RESI STANCE COEFFICIENT FROM 2010 MY Vocational Vehicle 0% **Table 6**  **- 9**  Estimated Reductions in Engine CO 2 Emission Rate for Alternative 2 

### GVWR CLASS FUEL MODEL YEARS CO 2 

### 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**  **Estim ated Fleet** **- Wide Fuel Efficiency by Model Year for Alternative**  **2 [gallons/100 m** **iles]**



### 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 Vans diesel 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

### Regulatory Impact Analysis

6 - 10



### 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 engine s, HD pickup trucks and vans , Class 2b through Class 8 vocational vehicles, and Class 7 and 8 combination tractors . D etails regarding modeling of this alter native 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**  **Estim ated**  **F leet** **- W** **ide F**  **uel Efficiency**  **by M**  **odel Y**  **ear for Alternative**  **3 [**  **gallons/100 mi** **les]**



### 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 Vans diesel 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 Alternative s 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 e ach 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 finaliz ing 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 ye ars), 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 f or these technologies. Nor***** E.O. 12866 Review –**  **Draft –**  **Do Not Cite, Quote, or Release During Review *****



### 6 - 11 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 f or 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 preambl e) 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 s ystem would reduce CO 2 

### emissions by 6 percent at a cost of $8,400 per truck. 5 

### The estimated reduction in CO 2 

### 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**  **Estim ated Reductions in Engine CO**  **2 Emission Rates from** **this Alternative 4**  

### GVWR CLASS FUEL MODEL YEARS CO 2 

### REDUCTION FROM 2010 MY HHD (8a - 8b)

– Combination tractors only Diesel 2014 - 2016 5 .8 % 2017+ 8 .8 %

**Table 6**  **- 13**  **Estim ated**  **Reduction in Coefficient of Drag for Com bination Long** **- Haul Tract**  **or s 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 CO 2 

### reductions for this alternative are listed in Table 6 - 14 . The estimated incremental cost increase to HD pickup trucks and vans to replace a stoichi ometric gasoline direct injected V8 engine with coupled cam

### Regulatory Impact Analysis

6 - 12

phasing used in Alternative 3 with a V6 stoichiometric gasoline direct injecti on DOHC , discrete valve lift and twin turbo chargers is estimated to be $1,743. 6

**Table 6**  **- 14**  **Estim ated Total Vehicle CO**  **2 Reductions for HD Pickup Trucks and Vans**  **for Alternative 4**  

### GVWR CLASS FUEL MODEL YEARS CO 2 

### 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 hy brid 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 hy brid 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 hyb rid 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**  **Estim ated Fleet** **- Wide Fuel Efficiency by Model Year for Alternative**  **4 [gallons/100 m** **iles]**



### 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***** E.O. 12866 Review –**  **Draft –**  **Do Not Cite, Quote, or Release During Review *****



### 6 - 13 HD Pickups and Vans diesel 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 hy brid 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 hy brid powertrains to the pickup trucks, vans, vocational vehicles, and tractors. In addition, the agencies applied aerodyn amic 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 b y the agencies. The agencies assumed that a hy brid powertrain would provide a 32 percent reduction in CO 2 

### emissions and fue l 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 hy

brid powertrains installed in tractors was assumed to be 10 percent at a cost of $25,000 based on the NAS report. 11 

### For the analys is of vocational vehicles in this alternative, the agencies assumed that hy brid technology

would be applied only in diesel - f ueled 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 use d 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 aerody namic requirements . The agencies added low rolling resistance tires to all commercial trailers, which are assumed to have 1 5 percent lower rolling resistance than the baseline trailer tire and is equivalent to the target value required b y SmartWay . The aerodyn amics 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 hy brids, the agencies do not believe that it is possible to achieve technology penetration rates at or even near these l evels 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**  **Estim ated Reductions in Rolling Resistance and Aerodynamic Drag Coefficients from** **Reference Case for Alternative 5 (Model Years 2014 and Later)**  

### TRUCK TYPE REDUCTION IN T IRE ROLLING RESI STANCE COEFFICIENT FROM 201 0 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 hy

brid 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 aerodyn amic 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 e fficienc y 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**  **Estim ated**  **F leet** **- W** **ide F**  **uel Efficiency**  **by M**  **odel Y**  **ear for Alternative**  **5 [**  **gallons/100 mi** **les]**



### 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 Vans diesel 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 D**  **o 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 CO 2 

### 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 NO x 

### , CO, PM, and VOC emissions in 2030 for each of the alternatives are included in Table 6 - 22 .

**Table 6**  **- 20**  **: Annual CO 2**  **and Oil Reductions**  **Relative to Alternative 1 in 2030 and 2050**  

### DOWNSTREAM CO 2 

### REDUCTIONS (MMT) OIL REDUCTIONS (BILLION GALLONS) 2030 2050 2030 2050 Alt. 1 Baseline 0 0 0 0 Alt. 1a AEO 2011 Baseline Total 39 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**  **Alternative a**  

### TECHNOLOGY COSTS (20 09$ MILLIONS)

2030 2050 Alt. 1 Baseline $0 $0 Alt. 1a AEO 2011 Baseline Total 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 (20 09$ 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 I**  **mpacts Relative**  **to Alternative 1 of Key Non**  **- GHGs for**  **Each Alter n**  **ative in 2030**  

### NO X 

### 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 Ta ble 6 - 23 and Table 6 - 24 . **Ta ble**  **6 -**  **23 Monetized Net Benefits Associated with Each Alternative**  **Relative to Alternative 1 for Lifetim** **e of**

**2014 through 2018 Model Year Vehicles (** **3% discount rate, Million 200**  **9 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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. **Table 6**  **- 24**  **Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1**  **for Lifetim e of** 

**2014 through 2018 Model Year Vehicles (**  **7% discount rate, Million 200**  **9 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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ 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 Lifetim** **e of 2014 through 2018 Model Year HD Pickup**  **Trucks & Van**  **s (** **3% discount rate, Million 200**  **9 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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. **Table 6**  **- 26**  **Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetim** **e of 2014 through 2018 Model Year**  **Vocational Vehicles (** **3% discount rate, Million 200**  **9 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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. **Table 6**  **- 27**  **Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetim** **e of 2014 through 2018 Model Year**  **Com bination Tractors**  **( 3% discount rate,**  **Million 200 9**  **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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. **Table 6**  **- 28**  **Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetim** **e of 2014 through 2018 Model Year HD Pickup Trucks & Vans**  **( 7**  **% discount rate, Million 200**  **9 dollars)**  ALT.1 BASELINE ALT.2 LESS

STRINGENT ALT.3

PREFERRED ALT.4 MO RE

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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. **Table 6**  **- 29**  **Monetized Net Benefits Associated with Each Alternative Relative to Alternative 1 for Lifetim** **e of 2014 through 2018 Model Year**  **Vocational Vehicles (**  **7 % discount rate,**  **Million 200 9**  **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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ 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 Lifetim** **e of 2014 through 2018 Model Year**  **Com bination Tractors**  **( 7**  **% discount rate, Million 200**  **9 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- CO 2 GHG Im

pacts and Non- GHG Im

pacts 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 N et present value of reduced CO 2 emissions is calculated differently than other benefits. The same discount rate used to discount the value of damages from future emissions (SCC at 5, 3, 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%: $3 6 - $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, NO 2 and SO 2) were not estimated for this analysis . Although EPA has not monetized changes in non- CO 2 GHGs, the value of any increases or reductions should not be interpreted as zero. d “+ c ” indicates additional costs not estimated in this rulemaking. 

## References

1 NEPA re quires agencies to consider a “no action” alternative in their NEPA analyses and to compare the e ffects of not taking action with the effects of the reasonable action 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 enviro nmental 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) (em phasis 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. As sessment 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 1 46.. 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, Tabl e 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.