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2 - 1 

# Chapter 2: **Te chnology and Cost**  2.1 **Overview of Technologies** In discussing the potential for CO 2 

### emission and fuel consumption reductions, it can be helpful to think of the work flow through the system. The initial work input is fuel. Each gallon of fuel has the potential to produce some amount of work and will produce a set amount of CO 2 

### (about 22 pounds (10 kg) of CO 2 

### per gallon of diesel fuel). The engine converts the chemical energy in the fuel to useable work to move the truck. Any reductions in work demanded of the engine b y the vehicle or improvements in engine fuel conversion efficiency will lead directl y to CO 2 

### emission and fuel consumption reductions. Current diesel engines are around 40 percent efficient over a range of operating conditions depending on engine sizes and applications, while gasoline engine efficiency is much lower than that of diesel engines. This means that approximately one - third of the fuel’s chemical energy is converted to useful work and roughl y two - thirds is lost to friction, gas exchange, and waste heat in the coolant and exhaust. In turn, the truck uses this work delivered by the engine to overcome overall vehicle - related losses such as aerody namic drag, tire rolling resistance, friction in the vehicle driveline, and to provide auxiliary power for components such as air conditioning and lights. Lastl y, the vehicle’s operation, such as vehicle speed and idle time, affects the amount of total energy

required to complete its activity . While it may be intuitive to look first to the engine for CO 2 

### emission and fuel consumption reductions given that only about one - third of the fuel is converted to useable work, it is important to realize that any improvement in vehi cle efficiency proportionall y reduces both the work demanded and the energy wasted. Technology

is one pathway

to improve heavy- duty

truck GHG emissions and fuel consumption. Near- term solutions exist, such as those being deployed b y SmartWay partners in heavy- duty truck long haul applications. Other solutions are currently underway

in the light - duty vehicle segment, especially in the large pickup sector where some of the technologies can appl y to the heavy- duty pickup trucks covered under this rulemaking . Long - term solutions are currentl y under development to improve efficiencies and cost- effectiveness. While there is not a “silver bullet” that will significantly eliminate GHG emissions from heavy- duty trucks like the catal ytic converter has for criteria pollutant emissions, significant GHG and fuel consumption reductions can be achieved through a combination of engine, vehicle s ys tem, and operational technologies. The following sections will discuss technologies in relation to each of the proposed regulatory

subcategories

– Heavy- Duty Pickup Trucks and Vans, Heavy- Duty Engines, Class 7 and 8 Combination Tractors, Trailers, and Class 2b - 8 Vocational Vehicles. In each of these sections, information on technological approaches, costs, and percent improvements is provided. Depending on the segment, the vehicle - level technologies available for consideration may include idle reduction, improved tire rolling resistance, improved transmissions, improved axles, weight reduction, improved accessories, and aerody namic technologies. Depending on the segment, the engine - level technologies available for consideration may include friction reduction, variable valve timing, cylinder deactivation, turbocharging, downsizing, combustion optimization, aftertreatment optimization, and waste heat recovery. The agencies are not

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2 - 2 projecting that all of the technologies discussed in these sections would be used for compliance with the engine and vehicle standards, for reasons that are also discussed in each section. Nevertheless, the potential for there to be technologies other than those which form the basis for the compliance pathway

set forth by

the agencies, or which can be used in different combinations or penetration rates than that projected compliance pathway , is an important consideration in assessing the feasibility

of the proposed standards. Summaries of all of the technologies, along with the corresponding costs, fuel consumption and GHG emissions improvement percentages are provided in this chapter. A summary of engine and vehicle technologies, effectiveness, and costs for HD pickup trucks and vans is provided in Chapter 2.5 . Summaries of engine technologies, effectiveness, and costs are provided in Chapters 2.6 and 2.7 . A summary of technologies , effectiveness, and costs for tractors is provided in Chapter 2.8 . A summary of technologies, effectiveness, and costs for vocational vehicles is provided in Chap ter 2.9 . A summary of technologies, effectiveness, and costs for trailers is provided in Chapter 2.10 . A detailed anal ys is of technology costs is found in Chapters 0 and 2.13 . EPA and NHTSA collected information on the cost and effectiveness of fuel consumption and CO 2 

### emission reducing technologies from several sources. The primary sources of information were the 2010 National Academy of Sciences report on Technologies and Approaches to Reducing the Fuel Consumption of Medium - and Heavy- Duty Vehicles (NAS) 1 

### , TIAX ’s assessment of technologies to support the NAS panel report (TIAX) 2 

### , EPA’s HeavyDuty Lumped Parameter Model 3 

### , the anal ys is conducted by NESCCAF, ICCT, Southwest Research Institute and TIAX for reducing fuel consumption of heavy- duty long haul combinatio n tractors (NESCCAF/ICCT) 4 

### , and the technology cost analysis conducted by I CF for EPA (ICF). 5 

### In addition, the agencies relied on NHTSA’s technology assessment report under contract with SwRIand Tetra T ech. 6 , 7 , 8 

### In addition, the agencies used the vehicl e simulation model (the Greenhouse gas Emissions Model or GEM) to quantify the effectiveness of various technologies on CO 2 

### emission and fuel consumption reductions in terms of vehicle performance as they are evaluated in determining compliance with the HD program. The simulation tool is described in draft RIA Chapter 4 in more detail. 

## 2.2 **Technology Principles –**  **SI Engines** The engine technology

principles described in this chapter for SI and CI engines are ty picall y described as applying for gasoline and dies el - fueled engines, respectivel y. Even so, these technology

principles generally

also appl y for engines powered b y other fuels, including n atural gas. In Section II of the preamble to these rules, the agencies describe regulatory provisions that differ between SI and CI engines . T echnologies related to closed crankcases for natural gas engines are described below in Chapter 2.11 and in the Preamble Section II . The agencies describe technologies and test procedures related to minimizing evaporative emissions from natural gas fuel s ys tems in Chapter 2.11 as well as in Section XI of the preamble to these rules. The agencies’ approach in this document is to first describe the principles of how technologies can work for an engine, without specifying the ty pe of vehicle into which it will be installed, or the test cycle over which it will be certified. Later, in Chapter 2.5, the agencies describe a subset of these technologies as they apply specificall y to complete HD pickup trucks and vans. In Chapter 2 .6, the agencies describe a subset of these technologies as they appl y to SI engines intended for vocational vehicles.

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2 - 3 

## 2.2.1 **Engine Friction Reduction** In addition to low friction lubricants, manufacturers can reduce friction and improve fuel consumption by

improving the design of engine components and subsystems. Examples include improvements in low - tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings, material substitution, more optimal thermal management, and piston and cylinder surface treatments. The 2010 NAS Report , NESCCAF 9 

### and EEA 10 

### reports as well as confidential manufacturer data used in the light - duty vehicle rulemaking suggested a range of effectiveness for engine friction reductio n to be between 1 to 3 percent. Reduced friction in bearings, valve trains, and the piston - to - liner interface would improve efficiency . Any friction reduction must be carefull y developed to avoid issues with durability or performance capability . 

## 2.2.2 **Variable Valve Timing**  Variable valve timing (VVT) classifies a famil y of valve - train designs that alter the timing of the intake valve, exhaust valve, or both, primarily to reduce pumping losses, increase specific power, and control the level of residual gases in the cylinder. VVT reduces pumping losses when the engine is lightly loaded by

controlling valve timing closer to the optimum needed to sustain horsepower and torque. VVT can also improve volumetric efficiency at higher engine speeds and loads. Additional ly , VVT can be used to alter (and optimize) the effective compression ratio where it is advantageous for certain engine operating modes ( e.g. , in the Atkinson Cycle). VVT has now become a widely adopted technology

in the light duty

fleet: in MY 20 14 , most of all new cars and light trucks had engines with some method of variable valve timing. 11 

### Manufacturers are currently using many different types of variable valve timing, which have a variety of different names and methods. Therefore, the degree of further improvement across the fleet is limited by

the level of valvetrain technology already implemented on the vehicles. The three major types of VVT are listed below. Each implementation of VVT uses a cam phaser to adjust the camshaft angular position relative to the crankshaft position, referred to as “camshaft phasing.” This phase adjustment results in changes to the pumping work required by the engine to accomplish the gas exchange process. The majority

of current cam phaser applications use hydraulically- actuated units, powered b y engine oil pressure and managed b y a solenoid that controls the oil pressure supplied to the phaser . 

## 2.2.2.1 Coupled Cam Phasing for Overhead Valve (OHV) and Single Overhead Camshaft (SOHC) Engines Valvetrains with coupled (or coordinated) cam phasing (CCP) can modify the timing of both the inlet valves and the exhaust valves an equal amount by varying the phasing of the camshaft across an engine’s range of operating speeds; also known as VVT. For engines configured as an overhead valv e (OHV) or as a single overhead camshaft (SOHC) only one cam phaser is required per camshaft to achieve CCP .

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2 - 4 Based on the heavy- duty Phase 1 vehicle rulemaking, 201 5 NHTSA Technology Study , and previousl y- received confidential manufacturer data, the agencies estimate the fuel consumption reduction effectiveness of this technology to be between 1 and 3 percent over average driving patterns . 

## 2.2.2.2 Intake Cam Phasing (ICP) for Dual Overhead Camshaft Engines (DOHC) Valvetrains with ICP, which is the simplest of the cam phasing technologies, can modify the timing of the inlet valves by phasing the intake camshaft while the exhaust valve timing remains fixed. This requires the addition of a cam phaser on each bank of intake valves on the engine. An in - line 4 - cylinder engine has one bank of intake valves, while V - configured engines have two banks of intake valves. Some newer Class 2b and 3 market entries are offering dual overhead camshaft (DOHC) engine designs where two camshafts are used to operate the intake and exhaust valves independentl y. Consistent with the heavy- duty 2014 - 2018 MY vehicle rulemaking and the SwRI report, the agencies agree with the effectiveness values of 1 to 2 percent reduction in fuel consumption over average driving patterns, for this technology . 

## 2.2.2.3 Dual Cam Phasing (DCP) for Dual Overhead Camshaft Engines (DOHC) The most flexible VVT design is dual (independent) cam phasing, where the intake and exhaust valve opening and closing events are controlled independentl y. This option allows the option of controlling valve overlap, which can be used as an internal EGR strategy . At low engine loads, DCP creates a reduction in pumping losses, resulting in improved fuel consumption. Incre ased internal EGR also results in lower engine - out NO X 

### emissions. The amount by

which fuel consumption is improved depends on the residual tolerance of the combustion system. Additional improvements are observed at idle, where low valve overlap may result in improved combustion stability, potentially reducing idle fuel consumption. DCP requires two cam phasers on each bank of the engine. S ome newer Class 2b and 3 market entries are offering dual overhead camshaft (DOHC) engine designs where two camshafts are used to operate the intake and exhaust valves independentl y. Consistent with the light - duty 2012 - 2016 MY vehicle rulemaking and the SwRI report, the agencies agree with the effectiveness values of 1 to 3 percent reduction in fuel consumption over average driving patterns, for this technology . 

## 2.2.2.4 Variable Valve Lift (VVL) Controlling the lift of the valves provides a potential for further efficiency improvements. By optimizing the valve - lift profile for specific engine operating regions, the pumping loss es can be reduced b y reducing the amount of throttling required to produce the desired engine power output. By

moving the throttling losses further downstream of the throttle valve, the heat transfer losses that occur from the throttling process are directed into the fresh charge - air mixture just prior to compression, delaying the onset of knock- limited combustion processes. Variable valve lift control can also be used to induce in- cylinder mixture motion, which improves fuel - air mixing and can result in improved thermodynamic efficiency. Variable valve lift control can

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2 - 5 also potentially

reduce overall valvetrain friction. At the same time, such systems may also incur increased parasitic losses associated with their actuation mechanisms. A number of manu facturers have already implemented VVL into their fleets (To yota, Honda, and BMW), but overall this technology

is still available for most of the fleet. There are two major classifications of variable valve lift, described below: 

## 2.2.2.5 Discrete Variable Valve L ift (DVVL) Discrete variable valve lift (DVVL) s ys tems allow the selection between two or three discrete cam profiles b y means of a hydraulicall y- actuated mechanical system. By optimizing the cam profile for specific engine operating regions, the pumping losses can be reduced b y reducing the amount of throttling required to produce the desired engine power output. This increases the efficiency

of the engine. These cam profiles consist of a low and a high - lift lobe, and may include an inert or blank lobe to incorporate cylinder deactivation (in the case of a 3 - step DVVL s ys tem). DVVLis normally applied together with VVT control. DVVL is also known as Cam Profile Switching (CPS). DVVL is a mature technology in LD applications with low technical risk. B ased on the light - duty MY 2017 - 2025 final rule, previously- received confidential manufacturer data, 201 5 NHTSA Technology Study , and report from the Northeast States Center for a Clean Air Future (NESCCAF), the agencies estimate the fuel consumption reduction effectiveness of this technology to be between 1 and 3 percent over average driving patterns . 

## 2.2.3 **Cylinder Deactivation** In conventional spark - ignited engines throttling the airflow controls engine torque output. At partial loads, efficiency can be improved b y using cylinder deactivation instead of throttling. Cylinder deactivation can improve engine efficiency by disabling or deactivating (usuall y) half of the cylinders when the load is less than half of the engine’s total torque capability

– the valves are kept closed, and no fuel is injected

– as a result, the trapped air within the deactivated cylinders is simply

compressed and expanded as an air spring, with reduced friction and heat losses. The active cylinders combust at almost double the load required if all of the cylinders were operating. Pumping losses are significantl y reduced as long as the engine is operated in this “part cylinder” mode. Effectiveness improvements scale roughl y with engine displacement - to vehicle weight ratio: the higher displacement - to - weight vehicles, operating at lower relative loads for normal driving, have the potential to operate in part- cylinder mode more frequentl y. Cylinder deactivation is less effective on heavily- loaded vehicles because they require m ore power and spend less time in areas of operation where onl y partial power is required. The technology

also requires proper integration into the vehicles which is difficult in the vocational vehicle segment where often the engine is sold to a chassis manufacturer or body builder without knowing the type of transmission or axle used in the vehicle or the precise duty cycle of the vehicle. The cylinder deactivation requires fine tuning of the calibration as the engine moves into and out of deactivation mo de to achieve acceptable NVH. Additionally, cylinder deactivation would be difficult to apply to vehicles with a manual transmission because it requires careful gear change control. NHTSA and EPA adjusted the 2017 - 2025 MY light - duty rule estimates using updated power to weight ratings of heavy- duty trucks and confidential business information and downwardl y adjusted the effectiveness to 0 to 3 percent over average

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2 - 6 driving patterns for these vehicles to reflect the differences in drive cycle and operational opportunities compared to light - duty vehicles. 

## 2.2.4 **Stoichiometric Gasoline Direct Injection (SGDI)** Stoichiometric gasoline direct injection (SGDI) engines inject fuel at high pressure directly into the combustion chamber (rather than into the intake port in port fuel injection). SGDIrequires changes to the injector design, an additional high pressure fuel pump, new fuel rails to handle the higher fuel pressures, and changes to the cylinder head and piston crown design. Direct injection of the fuel into the cylinder improves cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios and increased thermody namic efficiency without the onset of combu stion knock. Recent injector design advances, improved electronic engine management systems and the introduction of multiple injection events per cylinder firing cycle promote better mixing of the air and fuel, enhance combustion rates, increase residual exhaust gas tolerance , and improve cold start emissions. SGDIengines achieve higher power density

and match well with other technologies, such as boosting and variable valvetrain designs. Several manufacturers have recently introduced vehicles with SGDI engines, including GM and Ford, who have announced their plans to increase dramatically the number of SGDI engines in their vehicle portfolios. Based on the heavy- duty

2014 - 2018 MY vehicle rulemaking, 201 5 NHTSA Technology Study, and previously- received confidential manufacturer data, the agencies estimate the fuel consumption reduction effectiveness of SGDI to be between 1 and 2 percent over average driving patterns . 

## 2.2.5 **Turbocharging and Downsizing (TRBDS)** The specific power of a naturally aspirated engine is primarily limited by

the rate at which the engine is able to draw air into the combustion chambers. Turbocharging and supercharging (grouped together here as boosting) are two methods to increase the intake manifold pressure and cylinder charge - air mass above naturall y aspirated levels. Boosting increases the airflow into the engine, thus increasing the specific power level, and with it the ability to reduce engine displacement while maintaining performance. This effectivel y reduces the pumping losses at lighter loads in comparison to a larger, naturall y aspirated engine. Almost every

major manufacturer currentl y markets a vehicle with some form of boosting. While boosting has been a common practice for increasing performance for several decades, turbocharging has considerable potential to improve fuel economy and reduce CO 2 

### emissions when the engine displacement is also reduced. Specific power levels for a boosted engine often exceed 100 hp/L , compared to average naturall y aspirated engine power densities of roughl y 70 hp/L. As a result, engines can be downsized roughl y 30 percent or higher while maintaining similar peak output levels. In the last decade, improvements to turbocharger turbine and compressor design have improved their reliability and performance across the entire engine operating range. New variable geometry turbines and ball -bearing center cartridges allow faster turbocharger spool -up (virtually eliminating the once - common “turbo lag”) while maintaining

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2 - 7 high flow rates for increased boost at high engine speeds. Low speed torque output has been dramaticall y improved for modern turbocharged engines. However, even with turbocharger improvements, maximum engine torque at very low engine speed conditions, for example launch from standstill, is increased less than at mid and high engine speed conditions. The potential to downsize engines may

be less on vehicles with low displacement to vehicle mass ratios for example a very

small displacement engine in a vehicle with significant curb weight, in order to provide adequate acceleration from standstill, particularly up grades or at high altitudes. Use of gasoline direct injection (GDI) systems with turbocharged engines and charge air cooling also reduces the fuel octane requirements for knock limited combustion and allows the use of higher compression ratios. Ford’s “EcoBoost” downsized, turbocharged GDI engines introduced on MY 2010 vehicles allow the replacement of V8 engines with V6 engines with improved in 0 - 60 mph accel eration and with fuel economy improvements of up to 12 percent as documented in their technical paper . 12 

### Recently published data with advanced spray- guided injection systems and more aggressive engine downsizing targeted towards reduced fuel consumption and CO 2 

### emissions reductions indicate that the potential for reducing CO 2 

### emissions for turbocharged, downsized GDI engines may

be as much as 15 to 30 percent relative to port - fuel - injected engines. Confidential manufacturer data suggest an incremental range of fuel consumption and CO 2 

### emission reduction of 4.8 to 7.5 percent for turbocharging and downsizing. Other publiclyavailable sources suggest a fuel consumption and CO 2 

### emission reduction of 8 to 13 percent compared to current -production naturally- aspirated engines without friction reduction or other fuel economy technologies: a joint technical paper by Bosch and Ricardo suggesting fuel economy gain of 8 to 10 percent for downsizing from a 5.7 liter port injection V8 to a 3.6 liter V6 with direct injection using a wall - guided direct injection system; 13 

### a Renault report suggesting a 11.9 percent NEDC fuel consumption gain for downsizing from a 1.4 liter port injection in - line 4 - cylinder engine to a 1.0 liter in - line 4 - cylinder engine, also with wal l - guided direct injection; 14 

### and a Robert Bosch paper suggesting a 13 percent NEDC gain for downsizing to a turbocharged DI engine, again with wall - guided injection. 15 

### These reported fuel economy benefits show a wide range depending on the SGDI technology employed. The agencies reviewed estimates from the 201 7 - 20 25 final light - duty rule, the T SD , and existing public literature. The previous estimate from the MYs 201 7 - 20 25 suggested a 12 to 14 percent effectiveness improvement, which included low friction lubricant (level one), engine friction reduction (level one), DCP, DVVL and SGDI, over baseline fixed- valve engines, similar to the estimate for Ford’s EcoBoost engine, which is already in LD production. Additionally, the agencies anal yz ed Ricardo vehicle simulation data and the 201 5 NHTSA Technology Study for various turbocharged engine packages. 

## 2.3 **Technology Principles –**  **CI Engines** 2.3.1 **Low Temperature Exhaust G**  **as Recirculation** Most LHDD, MHDD, and HHDD engines sold in the U.S. market today use cooled EGR, in which part of the exhaust gas is routed through a cooler (rejecting energy to the engine coolant) before being returned to the engine intake manifold. EGR i s a technology employed to

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2 - 8 reduce peak combustion temperatures and thus NO X 

### . Lo w - temperature EGR uses a larger or secondary EGR cooler to achieve lower intake charge temperatures, which tend to further reduce NO X 

### formation. For a given NO X 

### requirement , low - temperature EGR can allow changes such as more advanced injection timing that would increase engine efficiency slightly more than one percent. Because low - temperature EGR reduces the engine’s exhaust temperature, it has not be en considered as part of a technology package that also includes exhaust energy recovery systems such as turbocompounding or a bottoming cycle . 

## 2.3.2 **Combustion System Optimization** Improvements on the fuel injection system that allow more flexible fuel injection capability with higher injection pressure can improve engine fuel efficiency , while maintaining the same emission level. Combustion system optimization, featuring piston bowl, injector tip and the number of holes, in conjunction with the advanced fuel injection s ystem, is able to further improve engine performance and fuel efficiency . Manufacturers have been working to improve engines these areas for some time. At this point, all engine manufacturers have substantial development efforts underway that we project would be translated into production in the near future. Some examples include the combustion development programs conducted b y Cummins 16 

### , Detroit Diesel 17 

### , and Navistar 18 

### funded b y Department of Energy as part of Supertruck program. These manufacturers found the improvement due to combustion alone during this program was 1 to 2 percent. While their findings are still more towards research environment, specifically targ eting one optimal operating point, the results of these research programs do support the possibility that some of technologies they are developing could be applied to production in the time frame of 202 7 . The agencies have determined that it is feasible that fuel consumption and CO 2 

### emissions could be reduced b y as much as 1.0 percent in the agencies’ certification cycles in the 202 7 time frame through the use of these technologies. Some technologies were evaluated but not included in the agencies’ technic al feasibility anal ys is for the Phase 2 regulation since the agencies do not anticipate these technologies will be commerciall y available by 2027. For example, alternative combustion processes such as homogeneous charge compression ignition (HCCI), premix ed charge compression ignition (PCCI), low - temperature combustion (LTI), and reactivity controlled compression ignition (RCCI) technologies were not included in the feasibility anal ys is for Phase 2. While these technologies show good indicated thermal eff iciency , fuel savings over the entire range of engine operation is still a major challenge. At the current level of development it is not clear that the technologies will be in commercial production b y 2027. This, however, does not preclude the use of the se technologies for compliance should manufacturers develop and commercialize these alternative combustion or other approaches . 

## 2.3.3 **Model Based Control** Another important area of potential improvement is advanced engine control incorporating model based calibration to reduce losses of control during transient operation. Improvements in computing power and speed would make it possible to use much more sophisticated algorithms that are more predictive than today ’s controls. Because such controls are onl y bene ficial during transient operation, they would reduce emissions over the Federal Test Procedure (FTP ) cycle, but not over the Supplemental Emission Test ( SET ) cycle. Detroit Diesel

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2 - 9 introduced the next generation model based control concept, achieving 4 percent thermal efficiency improvement while simultaneously reducing emissions in transient operations in their earlier report. 19 

### More recently , this model based control technology was put into their one of vehicles for final demonstration under DOE’s Supertr uck program. 20 

### Their model based concept features a series of real time optimizers with multiple inputs and multiple outputs. This controller contains many physical based models for engine and aftertreatment. It produces full y transient engine performanc e and emissions predictions in a real - time manner. Although we do not project that this control concept would be in 2017 production, it would be a realistic estimate that this ty

pe of real time model control could be in production during the Phase 2 time frame, thus significantl y improving engine fuel economy. 

## 2.3.4 **Turbocharging System** Many advanced turbocharger technologies can be potentially added into production in the time frame between 2021 and 202 7 and some of them are already in production, such as mechanical or electric turbocompound, more efficiency variable geometry

turbine, and Detroit Diesel patented as ymmetric turbocharger. A turbocompound system extracts energy from the exhaust to provide additional power. Mechanical turbocompounding includes a power turbine located downstream of the turbine which in turn is connected to the crankshaft to supply additional power. On - highway demonstrations of this technology began in the earl y 1980s. It ha s been first used in heavy duty production by Detroit Diesel for their DD15 and DD16 engines and they claim a 3 to 5 percent fuel consumption reduction due to the s ys tem. 21 

### Results are duty cycle dependent, and require significant time at high load to see a fuel efficiency improvement. Li ght load factor vehicles can expect little or no benefit. Volvo reports two to four percent fuel consumption improvement in line haul applications , which would be likely in production even before 2020. 22 

### Electric turbo - c ompound is another potential area that can improve engine brake efficiency . These are attained through better vehicle integration and lower backpressure impacts. Since the electric power turbine speed is no longer linked to crankshaft speed, this allows more efficient operation of the turbine. Navistar reports on the order of a 1 to 1.5 percent efficiency improvement over mechanical turbocompound s ys tems at 0.5 to 0.7 gm/hp - hr engine - out NO X 

### levels, but dropping at lower engine - out NO X 

### . 23 

### However, this concept may not work well with lower engine out NO X 

### as indicated in this report, showing z ero benefit is reported at 0.3 to 0.4 gm/hp - hr engine - out NO X 

### , due to lower available temperature. Navistar reports a 1.6 percent fuel efficiency

improvement, again as compared to a mechanical turbocompound system . 24 

### Two - stage turbocharger technology has been used in production by Navistar and other manufacturers. Ford’s new developed 6.7L diesel engine features a twin - compressor turbocharger. Higher boost with wider range of operations and higher efficiency can further enhance engine performance, thus fuel economy. It is expected that this type of technology will continue to be improved by better matching with system and developing higher compressor and turbine effi ciency . Furthermore, improved turbocharger efficiency when combined with turbocompounding was shown in the SwRI study to reduce fuel consumption while maintaining criteria emissions limits. Findings show that there is limited scope for improved turbocharg er efficiency on

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2 - 10 engines which do not use turbocompound, because an increase in turbocharger efficiency would result in reduced or eliminated EGR flow which in turn would cause the engine to exceed NOx emissions requirements . 

## 2.3.5 **Engine Breathing System** Variou s high efficiency

air handling (air and exhaust transport) processes could be produced in the 2020 and 2024 time frame. To maximize the efficiency of such processes, induction systems may

be improved by

manufacturing more efficientl y designed flow paths ( including those associated with air cleaners, chambers, conduit, mass air flow sensors and intake manifolds) and b y designing such s ys tems for improved thermal control. Improved turbocharging and air handling s ys tems must include higher efficiency EGR sys tems and intercoolers that reduce frictional pressure loss while maximizing the ability to thermall y control induction air and EGR. EGR systems that often rely upon an adverse pressure gradient (exhaust manifold pressures greater than intake manifold pres sures) must be reconsidered and their adverse pressure gradients minimized. “Hy brid” EGR strategies which rely upon pressure gradients and EGR pumps may provide pathways for improvement. Other components that offer opportunities for improved flow efficiency include cylinder heads, ports and exhaust manifolds to further reduce pumping losses. Cummins reports 1.4 percent through optimization. 25 

### Detroit Diesel projects a two percent fuel efficiency improvement through air handling s ys tem development . 26 

### Navi star predicts almost four percent through a combination of variable intake valve closing timing (IVC), turbocharger efficiency and match improvements . 24 

### A few plots in this reference show another four percent, but these are not explained. Variable air breathing s ystems such as variable valve actuation may provide additional gains at different loads and speeds. The primary gain in diesel engines is achieved b y varying the EVO event versus engine speed and load, in conjunction with turbocharger optimization to minimize blowdown losses. Navistar reports a 1.25 percent fuel consumption improvem ent . 23 

### Again, all these reference points are referred to a single optimal point conducted at DOE Supertruck program. 

## 2.3.6 **Engine Parasitic and Fricti on Reduction**  Engine parasitic and friction reduction is another key technical area that can be further improved in production moving to the 2020 and 202 7 time frame. Reduced friction in bearings, valve trains, and the piston - to - liner interface can imp rove efficiency . Friction reduction opportunities in the engine valve train and at its roller/tappet interfaces exist for several production engines. The piston at its skirt/cylinder wall interface, wrist pin and oil ring/cylinder wall interface offers opportunities for friction reduction. Use of more advanced oil lubricant that could be available for production in the future can also play a key role in reducing friction. Any friction reduction must be carefull y developed to avoid issues with durability or performance capability . Lube pump as well water pump are another areas that improve efficiency . Navistar identifies a combined improvement of up to two percent through reduced bearing friction, reduced piston and ring friction, and unspecified lube pump improvements. 27 

### Inhis 2012 paper he reports 5.5 percent through a combination of friction reduction and both lube and cooling system improvements. 23 

### Later in the same presentation he specifies 0.45 percent demonstrated through water pump improvements and 0.3 percent through lube pump improvements. The total

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2 - 11 number of 5.5 percent s eems optimistic, even for a single optimal point . Cummins reports a combined number of 3 percent . 25



### . Detroit Diesel reports a combined number of two percent, with 0.5 percent coming from imp roved water pump e fficiency . 26 

### Navistar shows a 0.9 percent benefit for a variable speed water pump and variable displacement oil pump; piston/ring/liner friction reduction as 0.5 percent; bearing friction reduction as 0.6 percent. 24 

### Inaddition, Federal Mogul recentl y announced new piston ring coatings that can lead to a 20 percent reduction in engine friction and looking to the future sees an opportunity to reduce friction by

an additional 30 percent, equivalent to 1. 2 percent reduction in brake specific fuel consumption at road load conditions. 28 

### Itshould be noted that water pump improvements include b oth pump efficiency improvement and variable speed or on/off controls. Lube pump improvements are primaril y achieved using variable displacement pumps and may also include efficiency

improvement. All of these results shown in this paragraph are demonstrated through DOE Supertruck program under single optimal point. 

## 2.3.7 **Integrated Aftertreatment System** All manufacturers now use diesel particulate filter (DPF) to reduce particulate matter (PM) and use SCR to reduce NO X 

### emissions, and these ty pes of technologies are likel y to be deployed for many ye ars to come. Three areas are considered to improve integrated aftertreament systems. The first is to have better combustion system optimization through increased aftertreatment efficiency . The second is to reduce backpressure through further development of the devices themselves. The third is to reduce ammonia slip out of SCR during transient operation, thus reducing the urea consumption. This is in turn translated into reduced fuel consumption. Navistar reports a seven to eight percent improvement projected through a combination of higher cylinder pressure, injection optimi zation, and engine/aftertreatment optimization. 23 

### Cummins reports a 0.5 percent improvement through improved aftertreatment flow (catalyst size optimization and improved NO X 

### surface utilization) . 25 

### Detroit Diesel projects a two percent fuel efficiency improvement through reduced EGR (thinner wall DPF, improved SCR cell density, and catalyst material optimization) . 26 

## 2.3.8 **Engine D**  **ow nsizing**  Engine downsizing can be more effective if it is combined with the down speeding. This is due to increased vehicle efficiency resulting in lower power demand. This lower power demand shifts the vehicle operating points to lower load zones, which moves the engine away from some of the optimum operation points. In order to compensate for this loss, down speeding allows the engine to move back into the optimum operating points resulting in reduced fuel consumption. Increasin g power density b y reducing the engine size allow the vehicle operating points move back to the optimum operating points, thus further improving fuel economy. Both Detroit Diesel and Volvo show the same methodology of how downsizing should be properl y use d . 29 , 30 

### Detroit Diesel also shows that engine downsizing can reduce the friction due to smaller surface area as opposed to bigger bore engine. 26 

## 2.3.9 **Waste Heat Re covery**  Organic Rankine C ycl e waste heat recovery (WHR) systems have been studied for many ye ars. The agencies’ overall assessment of WHR as a fuel saving technology is that it offers

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2 - 12 great promise in the long term. However, it would take several ye ar s to develop, and initially , it would be viable primarily in line - haul applications. The agencies recognize the many challenges that would need to be overcome, but believe with enough time and development effort, this can be done . The di scussion below highlights these challenges to show why the agencies currently believe WHR would not achieve a substantial market penetration until 2027. The basic approach of these s ys tems is to use engine exhaust waste heat from multiple sources to evaporate a working fluid through a heat exchanger , which is then passed through a turbine or equivalent expander to create mechanical or electrical power. The working fluid is then condensed back to the fluid tank, and pulled back to the flow circuit through a pump to continue the cycle . With support of the Department of Energy , three major engine and vehicle manufacturer s have develop ed the WHR technology under the Supertruck program . Cummins’ WHR system is based on an organic Rankine cycle using refri gerant as the working fluid. 31 , 32 

### The system recovers heat from the EGR cooler , as well as from the exhaust gas downstream of the aftertreatment s ys tem . It converts that heat to power through a mechanic al gear train coupled to the engine output shaft . Some iteration s of the system also sought gains from low - temperature coolant and lubricant heat rejection via a parallel loop. The system includes a recuperator that transfers post - turbine energy back into the working fluid loop prior to the condenser. This recuperator reduces condenser heat rejection requirements and improves overall s ys tem efficiency . Volvo has developed a similar s ys tem to Cummins’ with variations in terms of hardware components, but uses ethanol as the working fluid instead of a refrigerant. 33 

### Daimler, on the other hand, has develop ed a different s ys tem to recover heat from the exhaust gas using an electrical generator to provide power to charge a high - voltage battery , where this battery s ys tem is primarily

used to drive a hy

brid system. Daimler uses ethanol as the working fluid, similar to Volvo’s system. Pre -prototype WHR system s have proven to be very efficient under right conditions. In demonstrations where operation occurred at a single optimal engine operating point, Cummins reports potential efficiency gains from WHR on the order of 2.8 percent points from the engine without WHR31



### . Volvo reports around 2.5 percent points 33



### . Daimler reports 2.3 percent points . 29 

### All of these manufacturers use the type of WHR just described ( including both mechanisms of mechanical work transfer to crankshaft and electric generator) in vehicle demonstrations for the D OE Supertruck program. Itis important to note that all of these WHR systems are still in the pre -prototype stage of research and development . De spite the promising performance of pre -prototy pe WHR system s , the c ost and complexity of the se packages from Cummins, Volvo and Daimler remain high . The agencies believe manufacturers will improve these systems over time just as they have for other advanced technologies that initially had high cost and complexity

at a comparable stage of development. The technolo gy

also poses issues relating to package size and transient response challenges . Thus, the agencies believe that WHR would be less effective in urban traffic and would most likely

be applied to line haul vehicles , consistent with the technology path on which the proposed standards are premised. WHR may offer the benefit of replacing the EGR cooler and decrease cooling s ys tem heat rejection requirements by converting some heat into work . To the extent that WHR systems use exhaust heat, they may increase the overall cooling s ys tem heat rejection requirement, thus

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2 - 13 increasing radiator size, which can have negative impacts on cooling fan power needs, as well as on vehicle aerodynamics . Significant challenges could arise if the space under the vehicl e hood happens to be tight, leaving little or no room for increased radiator size, which would necessitate a redesign of the vehicle front face, sacrificing potential aerodyn amic improvements. This issue becomes more challenging for those truck cooling systems that are already at cooling capacity design limits. Current pre -prototy

pe sy stem s are heavy , estimated to be on the order of 300 - 500 lbs depending on s ys tem design. Without time to optimize designs, any efforts to reduce weight by simply reducing the size of the key components , such as boilers and condensers, would likely negativel y reduce the system efficiency . However, with enough lead time, the agencies believe manufacturers may

be able to improve materials and designs to reduce overall system we ight without compromising efficiency . Manufacturers have not ye t arrived at a consensus on which working fluid(s) to be used in WHR system s to balance concerns regarding performance, global warming potential (GWP), and safety. Current working fluids have a high GWP (conventional refrigerant), are expensive (low GWP refrigerant), are hazardous (ammonia, etc.), are flammable (ethanol/methanol ), or can freeze (water). One of the challenges is determining how to seal the working fluid properl y under the vacuum condition with high temperature to avoid s afety issues for flammable/hazardous working fluids. Addressing leaks would also be an important issue with respect to greenhouse gas emission for a high GWP working fluid. Because of these challenges, choosing a working fluid will be an important factor for s ys tem safety, efficiency, and overall production viability . Other key challenging issues in the WHR system are its reliability , durability , and market acceptance. Durability concerns that have been raised include: boiler fouling and cracking issues associated with high thermal gradients, thermal shock, condenser fouling, and various sensor and actuator durability

under harsh temperature and pressure conditions. It c an be reasonabl y estimated that of the current WHR system s under develop ment by the major manufacturers consists of at least two hundred parts including all major components, such as expanders, boilers, condensers, and fluid pumps, together with many fasteners, wiring cables, sensors, actuators, and piping. Determining overall system efficacy and reliability

involves rigorous testing in support of comprehensive Failure Modes and Effects Analysis (FEMA) . These parts , as well as the entire WHR system as a whole , must undergo severe winter and summer tests. Multiple trucks equipped with the same WHR system must be run on the road, accumulating multiple million s of miles. During these tests, all failures must be recorded, which are associated with specific f ailure modes or error codes. Root causes must be determined. Warranty costs for each failure mode based on the part cost and labor must be assigned. Due to the large number of components of WHR, some of the failure modes might not be identified during the road tests even with multiple extreme weather tests. Itwould be a high risk for any manufacturers to put their new technology into the market without careful WHR system validations and proof of on - the - road tests. Similarly, purchasers might be unlikel y to risk early adoption of such complex technology if deployed prematurel y (without substantial testing) due to significant concerns and costs related to potential down time .

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2 - 14 Based on the literature and preceding discussion, WH R technology can be characterized as being in the technology demonstration stage for purposes such as the DOE Supertruck program . Even though a few trucks with WHR technology have been tested on the road , 33 , 34 , 35 

### many of the components used in the trucks and product - acceptable packaging are still ye ars away from production . Figure 2 - 1 shows a generic form of product process flow. As can be seen from this figure, it would take 5 - 15 years from applied research/development to a prototy pe depending on the complexity

of the te chnology . During the prototy pe stage, all prototy

pe components must be available and extensive engine and vehicle tests with WHR must be conducted. The production start - up phase would follow. After that, significant efforts must be made from a prototype to a commercial product, which t ypically takes about five ye ars for a complex system like WHR. During this approximate five - ye ar period, multiple vehicles should go through all weather condition tests, which would help to detect possible failure modes and determine warranty cost associated with them. I n addition, long lead - time parts and tools should be identified; m arket launch and initial results on operating stabil ity should be completed. Furthermore, design s should be released to production , and all product components should be available . Finally, production parts on customer fleets and all weather road testing should be verified before finally

launching production, and distributing parts to the vehicle service network for maintenance and r epair should be ready.

**Figure 2**  **- 1**  **Product Process Flow** 

### The standards the agencies are proposing can provide an effective incentive for manufacturers to reach commercial product stage earlier than would otherwise occur. Itcan motivate manufacturers to shorten the period for advancing from a complicated prototype s ys tem to a commercial product. Itcan also help to ensure the market penetration after launching a product. Nevertheless, in ord er for WHR to be produced commercially, several things are needed. First, it is critical to optimize the WHR package volume, cooling capability, and aero drag at typical cruise speeds on highway since the most significant benefits of WHR technology would be in line - haul applications. Removal of the exhaust heat exchangers located at the exhaust pipe could reduce the total system volume and weight. Working fluids could be selected with reasonable low GWP and high performance potential. One approach could be to put a few hundred trucks into fleets for trial in the next several years, so that a comprehensive FEMA can be thoroughly

identified and warranty cost analyses can be more precisely conducted before

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2 - 15 launching into full volume production. Manufacturers have shown in the past that a robust FEMA process can address most problems before a technology is more widely

introduced. Therefore, the lead time appears to be one of the most noticeable constraints. We believe that all the issues and hurdles discuss ed could be resolved with adequate lead time . 

## 2.4 **Technology Principles -**  **Vehicles** 2.4.1 **Aerodynamics** The aerodynamic efficiency of heavy- duty vehicles has gained increasing interest in recent ye ars as fuel prices, competitive freight markets, and overall environmental awareness has focused owners and operators on getting as much useful work out of every gallon of diesel fuel as possible. Up to 25 percent of the fuel consumed by a line - haul tractor traveling at highway speeds is used to overcome aerodyn amic drag forces, making aerodynamic drag a significant contributor to a Class 7 or 8 tractor’s GHG emissions and fuel consumption. 36 

### Because aerodynamic drag varies by the square of the vehicle speed, small changes in the tractor aerodynamics can have significant impacts on GHG emissions and fuel efficiency of that vehicle. With much of their driving at highway speed, the benefits of reduced aerodynamic drag for Class 7 or 8 tractors can be significant. 37 

### The common measure of aerodynamic efficiency is the coefficient of drag (Cd). The aerodynamic drag force ( i.e. , the force the vehicle must overcome due to air) is a function of the Cd, the area presented to the wind ( i.e. , the projected area perpendicular to the direction of travel or frontal area), and the square of the vehicle speed. Cd values for today ’s line - haul fleet ty picall y range from greater than 0.80 for a classic body tractor to approximately

0.58 for tractors that incorporate a full package of widely, commerciall y available aerodynamic features on both th e tractor and trailer. While designers of heavy- duty vehicles and aftermarket products try to aerody

namically streamline heavy- duty

vehicles, there are some challenges. Aerody namic design must meet practical and safety

needs such as providing for physical access and visual inspections of vehicle equipment. Since weight added to the vehicle can impact its overall fuel efficiency , GHG emissions and, in limited cases, the amount of freight the vehicle can carry , aerodynamic design and devices must balance th e aerodyn amic benefit with the contribution to the vehicle weight. In addition, aerodynamic designs and devices must balance being as light and streamlined as possible with in -use application durability to withstand the rigors a working freight vehicle encounters while traveling or loading and unloading. However, there are some macro and micro scale techniques that can be employed to reduce vehicle drag such as reducing vehicle size, especiall y, the frontal area; smoothing the shape to make it more aerodyn amicall y efficient, thus reducing the Cd; and/or re - directing air to prevent entry

into areas of high drag (e.g., wheel wells) or to maintain smooth air flow in certain areas of the vehicle. Reducing the size of the vehicle can reduce the frontal area; which reduces the pressure building up on the lateral surface area exposed to the airflow. Improving the vehicle shape may

include revising the fore components of the vehicle such as rearward canting/raking or smoothing/rounding the edges of the front end components (e.g., bumper, headlights, windshield, hood, cab, mirrors) or integrating the components at key interfaces (e.g.,

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2 - 16 windshield/glass to sheet metal) to alleviate fore vehicle drag. Finall y, redirecting the air to prevent areas of low pressure and slow moving air; thus eliminating areas where air builds creating turbulent vortices and increasing drag. Techniques such as blocking gaps in the sheet metal, ducting of components, shaping or extending sheet metal to reduce flow separation and turbulence are methods being considered to direct air from areas of high drag (e.g., underbody, tractor- trailer gap, underbody and/or rear of trailer). The issue for heavy- duty vehicles is that the cab and/or passenger compartment is designed for a specific purpo se such as accommodating an inline cylinder engine or allowing for clear visibility

given the size of the vehicle. Consequently , a reduction in vehicle size and/or frontal area may

not be realistic for some applications. This also may necessitate an expensive, ground -up vehicle redesign and, with a tractor model lifecycle of up to 10 years, may mean that a mid- cycle tractor design is not feasible. In addition, the frontal area is also defined by the shape behind the cab so reducing just the cab frontal area/size reduction may not be effective. Thus, this approach is something that may occur in a long - term timeframe of 10 - 15 years from today . Instead, most heavy- duty tractor manufacturers have explored, or are exploring, the latter two techniques in the s hort - term. Compared to previous generation tractors, every high roof tractor today

has a roof fairing directing air over the top of the cab, fuel tank/chassis fairings that prevent side air from flowing underneath the vehicle, and cab side extenders that prevent flow from being trapped in the tractor- trailer gap. As a compliance strategy for HD Phase 1, many manufacturers refined the aerodyn amic shape of their front end components and other components (e.g., curving or further extending side extenders) re sulting in efficiency difference between pre - and post - HD Phase 1, model year tractor aerodynamic performance. Further, manufacturers have developed new tractor designs that are taking advantage of sealing gaps in sheet metal to redirect the flow and introducing some hard edges to induce turbulent flow on certain surfaces to prevent premature flow separation and downstream turbulent flow. For HD Phase 2 , we anticipate manufacturers would continue to apply these techniques across their models and continue to explore refinements and re - designs in other areas of the tractor. In addition to tractor improvements, there has been growth in the market for trailer aerodynamic devices encouraged b y our successful SmartWay Partnership and Technology Verification Program. These devices function similar to components on the tractor by preventing air intrusion into areas of the trailer prone to high aerodynamic drag including the tractor- trailer gap, the trailer underbody, and the rear of the trailer as shown in Figure 2 - 2 and Figure 2 - 3 below.

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2 - 17 **Figure 2**  **- 2**  **Progression of total drag along a typical line**  **- haul tractor**  **- trailer vehicle** 

**Figure 2**  **- 3**  **Low pressure regions**  **contributing to aerodynamic drag along a typical line -**  **haul tractor -**  **trailer vehicle**  

### To address this, trailer front/nose devices are being used to round the front end and edges of the trailer while also reducing the tractor- trailer gap; skirts on the side of the trailer prevent air entering the underside of the trailer and becoming turbulent on the various underbody structure components; and trailer aft/rear treatments reduce separation of air flow of the rear edge of the trailer to reduce the large wake of turbulent air behind the trailer. Based on current SmartWay Technology

Verification, these devices c an reduce fuel consumption from one to nine percent, depending on the technology , and if it is employed individually or in combination. As a result, we believe there is an opportunity within HD Phase 2 to promote continual improvement of tractor aerodynami cs and capitalize on the potential improvement that aerodynamic trailer devices can provide for trailers, and overall combination tractor- trailer efficiency .

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2 - 18 

## 2.4.2 **Advanced Aerodynamic Co ncepts**  For HD Phase 2, we are proposing standards that w ould be fully phase d in by the 202 7 model year. This represents a significant amount of time from today ’s action. As such, it is possible that by

the time the Phase 2 standards are implemented, the state of heavy- duty aerodynamic technology

and performance may

have signific antly

advanced. Thus, there may be a need to have standards to adequatel y address future tractor- trailer aerodynamic advances. Accordingl y, we are considering aerodyn amic concepts that can achieve aerody namic performance beyond that of the HD Phase 2 aerody namic standards. There are many approaches applicable to today ’s tractors and trailers that are not considered in the HD Phase 2 aerodyn amic standards and advanced research aimed at creating a completel y new design paradigm for tractor- trailer combinations. The advanced aerodyn amic standards would not be required but would rather serve as a marker for future aerodynamic concepts and/or as a metric for HD Phase 2 advanced/innovative aerodynamic technologies. 

## 2.4.2.1 Aerody

namic Improvements to Current Tract or- Trailer Combinations Based on Existing Technology 2.4.2.1.1 **Manufacturer Commercial Initiatives** In order to anticipate technology advancement , it is important to benchmark current technology

improvements based on today ’s tractors and trailers. A number of Class 8 tractor OEM’s have incorporated the technologies requested by their customers to improve fuel economy and to meet the HD Phase 1 standards . These technologies include side skirts, boat tails and roof fairings as well as some driver monitoring tools. Recentl y Jack Roberts released an article on the internet titled: “Photo, video: Western Star introduces re - designed on - highway tractor.” 38

**Figure 2**  **- 4**  **Pictures of the Western Star Class 8 Tractor**  **s** 

### In addition to providing photos and videos of Western Star’s redesigned on - highway tractor, the article describes a multitude of new features that define the new tractor . These features include:

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2 - 19  

### A new sweptback four piece bumper with an under bumper valance that contributes to aerodynamic efficiency.  

### New halogen headlights that are optimized for aerody namic performance and excellent visibility .  

### A state - of

- the - art visor specificall y engineered to work with the impressive slope in the hood’s rear air ramp to direct airflow over the cab without an aerody namic penalty .  

### Roof and cab fairings that sweep back for tighter trailer gap and help direct air flow over and around the trailer.  

### Optional chassis side fairings that reduce drag b y up to 6 percent while s till providing eas y access to batteries and DEF tank.  

### The Western Star Twin Force dual air intake, which feeds a massive centrally mounted air filter to improve efficiency . This example demonstrates that m anufacturers are continuing to find ways to improve tractors and are continually exploring concepts, such as those in used in the SuperTruck initiative, to improve commercially- available products. 

## 2.4.2.1.2 **Supplier Research: SABIC Roof Fairing Technology and**

**Manufacturing** Developments in aerodynamics have long been assumed to yield advancements in vehicle fuel efficiency . SABIC Innovative Plastics US LLC (SABIC) evaluated a variety of injection moldable thermoplastic roof fairing designs for a heavy tractor day cab to quantify efficiencies that could be obtained through advanced aerody namics. Computational Fluid Dy namic (CFD) modeling was performed by Exa Corporation, an industry recognized leader in CFD. Multiple designs exhibited significant reductions in drag compared to a baseline roof fairing (Figure 1 of Figure 2 - 5 ). The baseline represented a top performing roof fairing on the market today . The best performing SABIC concept (Figure 2) achieved a 5.8 percent reduction in drag and fuel use compared to the baseline. Under the well - established 2:1 relationship between delta drag and fuel use, the fuel efficiency improved by

nearl y 3 percent from the baseline design. The design concept optimized the shape to manage the airflow over the vehicle and enable reduced drag and increased fuel economy. Air channels

– developed for injection molding processes

– limit the air stagnation on the front of the trailer as well as accelerate and control the direction of the air flow. This innovative concept has been validated using state of the art CFD methods. On vehicle tests are suggested to validate findings from these studies. (from Matthew D. Marks, Senior Business Manager, Regulatory Automotive and Mass Transportation , November 14, 2014).

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2 - 20 **Figure 2**  **- 5**  **Surface X -** **Force (dimensionless) on Baseline and SABIC Concept Roof Fairing** 

### Aerodynamic (surface) force is the force exerted on a body whenever there is a relative velocity between the body

and the air. These plots represent this force in the direction of the vehicle travel at highway speeds. Red indicates a ‘pushing’ of the vehicle rearward, while blue indicates a ‘pulling’ of the vehicle forward.

**Figure 2**  **- 6**  **SABIC Concept Roof Fairing Operation** 

### We are currentl y coordinating with SABIC on future efforts to determine feasibility and capability of this concept on additional areas of the tractor (e.g., bumper, hood, fuel tank/chassis skirt fairings, cab side extenders). 

## 2.4.2.1.3 **HD Phase 1 Research: External Active Grille Shutter Potential on** 

**Heavy -**  **Duty Tractors** During HD Phase 1 aerody namic assessment, we looked at several trends to understand some of the aerodynamic trends such as removal of tractor chassis fairings and side extenders, different tractor - trailer gap widths, and different trailer leading edge radi i. However, one trend of particular relevance to advanced aerodynamic improvements for current tractors is the case of open versus closed grille.

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2 - 21 We evaluated the open vs. closed grille trend in the full and reduced scale wind tunnel. Below in Figure 3 - 7 is picture of a 1/8 th 

### scale tractor model in the reduced scale wind tunnel with the grille covered with aluminum tape to simulate a fully closed grille.

**Figure 2**  **- 7**  **Photo of 1/8th scale m odel of a tractor with the front, external grille**  **covered with aluminum tape to sim** **ulate a closed grill configuration.** 

### Below in Table 2 - 1 and Table 2 - 2 are the results of our open versus closed grille evaluations in the full and reduced scale wind tunnel separatel y. The tables provide the deltas for an open grille C D 

### minus the closed grille C D 

### ; where the C D 

### s have been corrected for blockage, in the case of the full scale wind tunnel, and normalized for differences in measured frontal area between the full and reduced scale wind tunnels using a nominal frontal area of 10.4 m2 

### (111.95 in2 

### ). For the full scale wind tunnel, only one tractor OEM was tested. In contrast, for the reduced scale wind tunnel, three tractor OEMs were tested.

**Table 2**  **- 1**  **Full Scale Wind Tun nel Results for Open**  **v erses**  **Close Grille Configurations** TRACTOR MODEL DELTA WAC D

@55MPH % DELTA CD VS. OPEN GRILLE CD 1 0.003 0.60%

**Table 2**  **- 2**  **Reduced Scale Wind Tunnel Results for Open versus**  **Close Grille Configurations**  TRACTOR MODEL DELTA WACD

@55MPH % DELTA CD VS. OPEN GRILLE CD A 0.010 1.69% B 0.012 1.89% C 0.009 1.45% 

### Based on the data in these tables, there is a potential wind- average drag improvement of 0.6 percent to 1.45 percent from closing off the external, front grille of the tractor. This indicates the potential of active grille shutter systems on heavy- duty tractors. These systems are currentl y being applied on light duty vehicles behind the external grille to improve aerody namics.

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2 - 22 However, a recent SAE paper determined that the optimal position for active grille shutter systems was the external grille flush with the vehicle sheet metal. 39 

### This technique could be implemented on the external grille designs for current- design, heavy- duty tractors as well. 

## 2.4.2.1.4 **National Research Council of Canada Historical Research on**

**Im proving Heavy** **-**

**Duty Tractors** The National Research Council of Canada (NRC - Can) performed an assessment of the drag benefit or detriment of various tractor components 40 

### and found the following in Ta ble 2 - 3 . **Ta ble**  **2 -**  **3 Reduced Scale Wind Tunnel Results for Open**  **versus Close Grille Configurations** 

COMPONENT DELTA WAC D OEM Side Mirrors - 0.0156 OEM Fender Mirrors - 0.0098 Wheel Covers (Tractor and Trailer) 0.0020 Tractor Drive Axle Wrap - Around Splash Guards 0.0049 Roof Fairing Rear - Edge Filler 0.0137 

### Based on this table, there is the potential to improve tractor aerodyn amics by 206 counts (0.0206 WAC D 

### ) with the addition of wheel covers, drive axle wrap around splash guards, and roof fairing rear edge filler, and up to 460 counts (0.0460) if the OEM side and fender mirrors are replaced with a camera s ys tem, as suggested by the study , and combined with the wheel covers, drive axle wrap around splash guards, and roof fairing rear edge filler. Therefore, considering the current wind- average drag performance of current heavy- duty tractors, this study demonstrates the possibility to improve tractors an additional ~1 percent with some simple changes. 

## 2.4.2.2 Aerody

namic Impro vements to Current Tractor- Trailer Combinations Based on Complete Vehicle Redesign This section contains summaries of ongoing work from various DOE efforts as well as individual efforts such as Airflow Truck Company to develop improved aerody namic Class 8 vehicles. In addition to aerodynamics, there are other technologies such as driver awareness and ability to drive for maximum fuel economy with increased aerodynamics. Overall it is expected that the research being performed over the next year or two wi ll reveal drastic improvements in C d

### A and fuel economy. DOE’s Lawrence Livermore National Laboratory is also looking at the aerodynamics of tankers. 

## 2.4.2.2.1 **Collaborative, Government -**  **Industry Advanced Aerodynamic Research: SuperTruck Program**  DOE’s SuperTruck pro

ject i s one of several initiatives that are part of the 21 st 

### Century Truck Partnership. The partnership i s a public -private initiative to stimulate innovation in the trucking industry through sponsorship from government agencies, companies, national laboratories and universities. DOE’s Vehicle Technologies Program provided matching funds to the program.

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2 - 23 Cummins, Peterbilt and their program partners invested $38.8 million in private funds for the first four years of the project with additional funding provided for future research beyond 2014. The goal of the SuperTruck Initiative was to develop a tractor that could meet or exceed 10 mpg

– where tractor s at this point are averaging between 5.5 and 6.5 mpg. Advances in engines, aerodynamics and more helped the tractor project increase its fuel economy. The SuperTruck objectives included development and demonstration of a highly efficient and clean diesel engine, an advanced waste heat recovery system, an aerodyn amic tractor and trailer combination and a lithium ion battery auxiliary power unit, to reduce engine idling. Eaton Corp, also part of the Cummins - Peterbilt SuperTruck project team, contributed technologies including the design, development and prototy ping of an advanced automated transmission th at facilitated reduced engine - operating speeds. Cummins and Eaton jointly designed shift schedules and other features to yield further improved fuel efficiency . Details of the SuperTruck that achieved 10.7 mpg are in video on the todaystrucking.com website and are presented in four videos. 41 

### Aerodynamic features of the tractor include the following: airflow into the engine compartment (through the front bumper, through the radiator and under the vehicle), less clearance between the road and the bottom of the tractor (rubber skirt under steps), close gaps on tractor/trailer (between hood and bumper, etc.), minimized gap between the trailer and tractor with a ball and socket design, full trailer skirt, roof fairing, smaller mirrors, minimized gap between whe els and wheel wells, wheel covers, boat tail, air foil on rear bumper design, single wide tires, and perforated mud flaps that allow air to by pass through them and reduce drag . A picture of this truck based on a Peterbilt tractor is shown in Figure 2 - 7 below. Even with the addition of these aerody namic features, overall the tractor mass was reduced b y over 1 , 300 lbs. The article states that the CFD anal ys is of the tractor showed a 50 percent reduction in drag and with a 2:1 drag reduction the aero improvements resulted in a 25 percent improvement in fuel economy. In the 300 mile test course shown on the video, it was stated that the tractor achieved 10.7 - 11.1 mpg.

**Figure 2**  **- 7**  **Peterbilt S**  **uper T**  **ruck C**  **oncept (Picture from**  **: http://www.peterbilt.com** **/about/media/2014/396/ )**  

### This effort represents the first s tep in the evolution of improving the aerodynamic efficiency of tractor- trailer by

radicall y redesigning today’s tractor - trailer combination, as a wholly integrated s ys tem rather each component, tractor and trailer, independently .

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2 - 24 

## 2.4.2.2.2 **Government Sponsored Adva nced Aerodynamic Research:** 

**Lawrence Livermore National Laboratory** Lawrence Livermore National Laboratory ’s (LLNL) Kambiz Salari presented information at the 2014 DOE Annual Merit Review on “DOE’s Effort to Improve Heavy Duty Vehicle Fuel Efficiency

through Improved Aerodynamics”. A joint project with Wabash, Navistar, Michelin, Safeway , Frito Lay , Praxair, Freight Wing Inc, ATDynamics, Kentucky Trailer and Spirit with funding for work in 2013 and 2014 , the objective was to develop a new integrated tractor- trailer design from ground up by : first, designing the first generation of an integrated tractor- trailer geometry called Generic Speed Form one (GSF1); and second performing wind tunnel tests of selected aero devices for tractor- trailers and tankers to improve fuel efficiency . The goal was to reduce aerody namic drag of Class 8 tractor- trailers b y approximately

25 percent leading to a 10 - 15 percent increase in fuel efficiency at 65 mph. In addition, the group developed an aerody namic tractor- trailer proto ty pe designed to achieve 50 percent reduced aerodyn amic drag as shown in Figure 2 - 8 . This effort represents the next generation of tractors and trailers: a completel y redesigned, fully integrated, optimized shape for the tractor- trailer combination.

**Figure 2**  **- 8**  **Pictures showing future heavy -**  **duty tractor trailer concept to achieve >50% aerodynam** **ic**

**im provement for Class**  **8 l** **ine h**  **aul h**  **eavy -**  **d uty**  **v ehicles**  

## 2.4.2.2.3 **Independent Advanced Aerodynamic Research: Airflow Truck**

**Com pany Bullet Truck Concept**  In addition to the work being performed by the OEMs and consortiums mentioned above, there are also independent commercial initiative s underway to radicall y redesign the tractortrailer combination similar to the concept b y Lawrence Livermore National Laboratories discussed above . The Class 8 tractor and trailer modifications in Figure 2 - 9 were designed, built, and tested in 2012 by

Mr. Robert Sliwa of the Airflow Truck Company . Mr. Sliwa built his first aerodynamic tractor in the 1983 when he was an owner- operator. After that, Mr. Sliwa became

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2 - 25 interested in computers and used his computer background along with his truck driver and race car driver experience to create the Bullet Truck. His current design is described at www.airflowtruck.c om and his tractor design modifications are similar in appearance to the bullet looking trains used in Europe. The tractor uses a 1999 engine and the test was conducted in the manner in which the tractor was driven at 55 mph by an experienced driver throughout its test while loaded at 65,000 lbs from Newington, Connecticut to Tracy , California. The website shows that the vehicle achieved 13.4 mpg during this trip and included traveling through the Rocky Mountains. CFD analyses of the design after the vehicle was built found a modest decrease in C d

### A, thus giving credence to the design work under the hood (most of which are outlined at airflowtruck.com) and driving techniques. Several new technologies were developed during this work which included retractable tractor steps, all electric air conditioning, crankshaft mounted cooling fan, computer- controlled fan hub, waterless engine coolant, reduced engine parasitic losses, full tractor and trailer side skirts, 4 axle ATI S, and an engine feedback information display .

**Figure 2**  **- 9**  **Figure of the Bullet Truck by Airflow Truck Company 9**  

### Another prototype is in development and it will include further aerody namic optimization of the tractor and trailer, and the combination thereof, as well as the addition of a boat tail. These technologies and more are expected to result in higher mpg under similar test conditions. Other changes in the vehicle makeup and test would include a more modern engine and testing at higher speeds (>55 mpg (60 - 65mpg)) may influence the end results.

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2 - 26 **Figure 2**  **- 10**  **Figure of a Highly Aerodynam ic Conce**  **pt Class 8 Tractor**  

### Although it is difficult to separate the aerodynamic factors from the engine and operational factors that lead to the claimed 13.4 mpg, the designs being explored and built by Mr. Sliwa are indicative of the ty pe of tractor- trailer combinations we anticipate will be built in the future. 

## 2.4.3 **Tires** 2.4.3.1 Improved Rolling Resistance Research indicates that a tire’s contribution to overall vehicle fuel efficiency is approximately proportional to the vehicle weight on it . 42 

### Energy loss associated with tires is mainly due to deformation of the tires under the load of the vehicle , known as hysteresis, but smaller losses result from aerodynamic drag , and other friction forces between the tire and road surface and the tire and wh eel rim. Collectively the forces that result in energy loss from the tires are referred to as rolling resistance. Tires with higher rolling resistance lose more energy , thus using more fuel and producing more CO 2 

### emissions in operation, while tires with lower rolling resistance lose less energy , and use less fuel and produce less CO 2 

### emissions in operation. A tire’s rolling resistance is a factor considered in the design of the tire, and is affected b y the tread and casing compound material s , the architecture of the casing, tread design , and the tire manufacturing process. It is estimated that 35 to 50 percent of a tire’s rolling resistance is from the tread and the other 50 to 65 percent is from the casing. 42 

### Tire inflation can also impact rolling resistance in that under- inflated tires can result in increased deformation and contact with the road surface. In addition to the effect on CO 2 

### emissions and fuel c onsumption, these design and use characteristics of tires also influence durability, traction (both wet and dry grip), vehicle handling, ride comfort, and noise. Tires that have higher rolling resistance are likel y designed to address one or more of these other tire attributes. EPA ’s SmartWay

program identified test methods and established criteria to designate certain tires as having lower rolling resistance (LRR) for use in the program’s emissions tracking system, verification program, and SmartWay vehic le specifications. To measure a tire’s efficiency , the vertical load supported by the tire must be considered, because rolling resistance is a function of the load on a tire. EPA uses a tire’s rolling resistance coefficient (CRR) to characterize LRR tire s. CRR is measured using the I SO 28850 test method (see 40 CFR 1037.520(c),) and reported as the rolling resistance force over vertical load (kg/metric ton). Differences in rolling resistance of up to 50 percent have been identified for tires designed to equip the same vehicle. 43

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2 - 27 LRR tires are commercially available from most tire manufacturers and can be applied to vehicles in all MD/HD classes . According to an energy audit conducted by Argonne National Lab, tires were shown to be the second largest contributor to energy losses for a Class 6 delivery truck at 50 percent load and speeds up to 35 mph (a ty pical average speed of urban delivery vehicles) . 44 

### For Class 8 tractor- trailers, the share of vehicle energy required to overcome rolling resistance is estimated at nearl y 13 percent. 45 

### NHTSA, EPA, and ARB met with stakeholders from the tire industry (Bridgestone, Continental, Cooper, Goodyear, and Michelin) in 2014 to discuss the next generation of LRR tires for the Phase 2 timeframe for all segments of Class 2b - 8 vehicles, including trailers. Manufacturers discussed forecasts for rolling resistance levels and production availability in the Phase 2 timeframe, as well as their plans for improving rolling resistance performance while maintaining other performance parameters such as traction, handling, wear, mass reduction, retreadability , and structural durability . The meetings included specific discussions of the impacts of the current generation of LRR tires on vehicle stopping distance and handling. Manufacturers indicated no known safety disbenefit in the current on - road fleet from use of LRR tires. While the next generation of tires may require some tradeoffs in wear performance and costs over the next 10 years to achieve better tire rolling resistance performance, manufacturers said they will not trade off safety

for performance. They

also emphasized that keeping tires inflated (through proper maintenance or automatic systems) was the best way to assure long term fuel efficiency and safety during vehicle operation. 

## 2.4.3.2 Wide Base Singles Low rolling resistance tires can be offered for dual assembly tires and as wide base singles (WBS). Wide base singles are primarily intended for combination tractor- trailers, but some vocational vehicles are able to accommodate them. In the early years of this technology , some states and local governments restricted use of WBS, but many of these restrictions have since been lifted. As of December 2010, NACFE reports that there is virtual acceptance in North America with only

a few provinces in Canada that disallow or require special permitting for the use of wide base tires 

### . 46 

### A wide base single is a larger tire with a lower profile. The common wide base single sizes include 385/65R22.5, 425/65R22.5, 445/65R22.5, 435/50R22.5 and 445/50R22.5. Generall y, a wide base single tire has less sidewall flexing compared to a dual assembly and therefore less hysteresis occurs. Compared to a dual tire assembly , wide base singles also produce less aerodynamic resistance or drag. Wide base singles can contribute to improving a vehicle’s fuel efficiency through design as a low rolling resistance tire and/or through vehicle weight reduction. According to one study, the use of fuel efficient wide base singles can reduce rolling resistance b y 3.7 to 4.9 percent compared to the most equivalent dual tire. 47 

### An EPA study with a tractor - trailer demonstrated an improvement in fuel consumption of 6 percent at 55 mph on the highway , 13 percent at 65 mph on the highway and 10 percent on a suburban loop 48 

### using wide base singles on the drive and trailer axles. EPA attributed the fuel consumption improvement to the reduction in rolling resistance and vehicle weight reduction from using wide base singles . In 2008 the Department of Energy (DOE) compared the effect of different combinations of tires on

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2 - 28 the fuel efficiency

of Class 8 tractors . The data collected based on field testing indicates that tractors equipped with wide base singles on the drive axle experience better fuel efficiency than tractors equipped with dual tires, independent of the ty pe of tire on the trailer. 49 

### This study in particular indicated a 6.2 percent improvement in fuel effic iency from wide base singles . There is also a weight savings associated with wide base singles compared to dual tires. Wide base singles can reduce a tractor and trailer’s weight by as much as 1,000 lbs. when combined with aluminum wheels. Bulk haulers o f gasoline and other liquids recognize the immediate advantage in carrying capacity provided by

the reduction in the weight of tires and have led the transportation industry in retrofitting their tractors and trailers 50



### . New generation wide base singles , which were first introduced in 2000, are designed to replace a set of dual tires on the drive and/or trailer positions. They are designed to be interchangeable with the dual tires without any change to the vehicle 51 

### . I f the vehicle does not have hub -piloted wheels, there may be a need to retrofit axle components . 50 , 52 

### Inaddition to consideration of hub / bearing / axle, other axle - end components m ay be affected by

use of wide base singles . To assure successful operation, suitable components should be fitted as recommended b y the vehicle manufacturer . 53 

### Current wide base singles are wider than earlier models and legal in all 50 states for a 5 - axle, 80,000 GVWR truck47



### . Wide base singles meet the “inch - width” requirements nationwide, but are restricted in certain states up to 17,500 lbs. on a single axle at 500 lbs/inch width limit, and are not allowed on single axle positions on certain double and triple combination vehicles 51



### . An inch - width law regulates the maximum load that a tire can carry as a function of the tire width. Ty

picall y wide base singles are optimized for highway operation and not for city or on/off highway

operation. However, newer wide base singles are being designed for better scrub resistance, which would allow an expansi on of their use. The current market share of wide base singles in combination tractor applications is 5 percent and the potential market is all combination tractors. 47 

### New generation wide base singles represent an estimated 0.5 percent of the 17.5 million tires sold each ye ar in the U.S. 51 

## 2.4.3.3 Tire Pressure Systems Proper tire inflation is critical to maintaining proper stress distribution in the tire, which reduces heat loss and rolling resistance. Tires with reduced inflation pressure exhibit more sidewall flexing and tread shearing, re sulting in greater rolling resistance than a tire operating at its optimal inflation pressure. Bridgestone tested the effect of inflation pressure and found a 2 percent variation in fuel consumption over a 40 psi range. 42 

### Tractor- trailers operating with all tires under- inflated by

10 psi have been shown to increase fuel consumed by up to 1 percent. 54 

### Tires can graduall y lose pressure from small punctures, leaky valves or simply

diffusion through the tire casing. Changes in ambient temperature can also have an effect on tire pressure. Trailers that remain unused for long periods of time between hauls may experience any

of these conditions. To achieve the intended fuel efficiency benefits of low rolling resistance tires, it is critical that tires are maintained at the proper inflation pressure. Although most truck fleets understand the importance of keeping tires properly inflated, it is likely that a substantial proportion of trucks on the road have one or more underinflated tires.

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2 - 29 An industry

survey conducted in 2002 at two truck stops found that fewer than half of the tires checked were within 5 pounds per square inch (psi) of their recommended inflation pressure. Twenty- two percent of the vehicles checked had at least one tire underinflated by at least 20 psi, and 4 percent of the vehicles were running with at least one flat tire, defined as a tire underinflated b y 50 psi or more. The survey also found mismatches in tire pressure exceeding 5 percent for dual tires on axle ends. 55 

### A commercial vehicle tire condition study conducted by the Federal Motor Carrier Safety Administration (FMCSA) in 2003 found similar indicators of poor tire inflation pressure maintenance in commercial fleets. The FMCSA concluded that only 44 percent of all tires on commercial vehicles were inflated within 5 psi of the recommended pressure, while over 7 percent of all tires in operation on commercial vehicles were underinflated by at least 20 psi. It was also determined that the rates of tires used in dual assemblies that differed in pressure b y more than 5 psi was approximately 20 percent for tractor duals and 25 percent for trailer duals. Finally , the FMCSA concluded that there were significant differences in tire inflation maintenance practices between private and for- hire fleets, smaller and larger fleets, and local bus and motor coach fleets. 56 

### If drivers or fleets are not diligent about checking and attending to under- inflated tires, the trailer may

have much higher rolling resistance and much higher CO 2 

### emissions and fuel consumption. Proper tire inflation pressure can be maintained with a rigorous tire inspection and maintenance program and EPA provide s information on proper tire inflation pressure through it s SmartWay

program . 57 

### Tire pressure monitoring (TPM) and automatic tire inflation (ATI) systems are designed to address under - inflated tires. Both systems alert drivers if a tire’s pressure drops below its set point. TP M systems monitor the tires and require user- interaction to reinflate to the appropriate pressure. Yet unless the vehicle experiences a catastrophic tire failure, simply

alerting the driver that a tire’s pressure is low may not necessarily

result in actio n to correct the problem. A driver may continue driving to their final destination before addressing the tires, resulting in many miles of driving with improperl y inflated tires. Current ATI s ys tems take advantage of trailers’ air brake s ys tems to supply air back into the tires (continuously or on demand) until a selected pressure is achieved. In the event of a slow leak, ATI s ys tems have the added benefit of maintaining enough pressure to allow the driver to get to a safe stopping area. 58 

### The agencies b elieve TPM systems cannot sufficiently guarantee the proper inflation of tires due to the inherent user - interaction required. Therefore, ATI s ys tems are the only pressure s ys tems the agencies are proposing to recognize in GEM . Estimates of the benefits of ATI s ys tems vary depending on the base level of maintenance already performed by the driver or fleet, as well as the number of miles the trailer travels. Vehicles that are well maintained or that travel fewer miles would experience less benefits from ATI s ys tems compared to vehicles that log many miles or have a history

of driving with poorly

inflated tires. The agencies believe ATIs ys tems can provide a CO 2 

### and fuel consumption benefit to most tractors and trailers . Drivers and fl eets that diligently maintain their tires will spend less time and money to inspect each tire knowing that they are properl y inflated. Vehicles that have lower annual VMT due to long periods between uses would be less susceptible to low tire pressures when they resume activity . Vehicles with high annual VMT would experience the fuel savings associated with consistent tire pressures.

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2 - 30 

## 2.4.3.4 Retreaded Tires The tread life of a tire is a measure of durability and some tires are designed specificall y for greater d

urability . Commercial vehicle tires are designed to be retreaded, a process in which a new tread is bonded to the tire casing. The original tread of a tire will last any where from 100,000 miles to over 300,000 miles, depending on vehicle operation, original tread depth, tire axle position, and proper tire maintenance. Retreading can extend the tire’s useful life by 100,000 miles or more. 59 

### In 2005, the Tire Industry Association estimated that approximately 17.6 million retreaded truck tires were sold in North America 60



### . All of the top commercial vehicle tire manufacturers are involved in tire retread manufacturing. Bridgestone Bandag Tire Solutions accounts for 42 percent of the domestic retreaded vehicle tire market with its Bandag retread products; Goodye ar Tire and Rubber Company accounts for 28 percent, mostl y through its Wingfoot Commercial Tire Systems; Michelin Retread Technologies Incorporated, with Megamile, Oliver, and Michelin retread products, accounts for 23 percent. Other tire companies like Continental and independent retread suppliers like Marangoni Tread North America (which also produces the Continental “ContiTread” retread product) make up the remaining 7 percent. 61 

### The retreading industry itself consists of hundreds of retreaders who se ll and service retreaded tires, often (but not always) using machinery

and practices identified with one of the major retread producers. There are about 800 retread plants in North America. 62 

### The top 100 retreaders in the U.S. retread 47,473 truck tires p er day . To maintain the quality

of the casing and increase the likelihood of retreading, a tire should be retreaded before the tread depth is reduced to its legal limit. At any time, steer tire s must have a tread depth of at least 4/32 of an inch and other tires, including drive tire s and trailer tires, must have a tread depth of at least 2/32 of an inch (49 CFR § 393.75). Trucking fleets often retread tires before tire treads reach this minimum depth in order to preserve the integrity of the tire casing for retreading. If the casing remains in good condition, a truck tire can be safel y retreaded multiple times. Heavy truck tires in line haul operation can be retread 2 to 3 times and medium - duty

truck tires in urban use can be retread 5 or more times. 63 

### To accommodate this practice, many commercial vehicle tire manufacturers warranty their casings for up to five ye ars, excluding damage from road hazards or improper maintenance. To protect the casing, a steer tire is generall y retreaded once the tread is worn down to 6/32 of an inch and a drive tire is retreaded once the tread is worn down to 8/32 of an inch. 64 

### Tires used on Class 8 vehicles are retreaded as many as three times. Both the casing and the tread contribute to a tire’s rolling resistance. It is estimated that 35 to 50 percent of a tire’s rolling resistance is the result of the tread. Differences in drive tire rolling resistance of up to 50 percent for the same casing with various tread compounds have been demonstrated. For example, a fuel efficient tread (as defined b y the manufacturer) was added to two different casings resulting in an average increase in rolling resistance of 48 percent. When a nonfuel efficient tread (also defined b y the manufacturer) was added to the same casings, the rolling resistance increased b y 125 percent on average. This characterizes the effect of the tread on the rolling resistance of a tire.

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2 - 31 Because tires can be retreaded multip le times, changes in the casing due to wear, damage and material aging may

impact rolling resistance to a greater degree than would occur in an original tire. Additionally , as evidenced above, if a tread compound different than the original tread is used, a retreaded tire can have higher or lower rolling resistance than the original tire. Since the agencies have no way of knowing whether the rolling resistance of retreaded tires will be higher or lower than the rolling resistance of the original tires, we similarly have no way

of knowing whether low rolling resistance tire benefits will continue to accrue for a vehicle’s entire lifetime. 

## 2.4.4 **Transmissions** Transmissions are a significant vehicle component. They are part of the drive train, which also include s axles and tires. Ways to improve transmissions include shift strategy , gear efficiency , gear ratios, etc. The relative importance of having an efficient transmission increases when vehicles operate in conditions with a higher shift density . Each shift represents an opportunity

to lose speed or power that would have to be regained after the shift is completed. Further, each shift engages gears that have their own inherent inefficiencies. Optimization of vehicle gearing to engine performance through selection of transmission gear ratios, final drive gear ratios and tire size can play a significant role in reducing fuel consumption and GHGs. Optimization of gear selection versus vehicle and engine speed accomplished through driver training or automated transmission gear selection can provide additional reductions. The 2010 NAS report found that the opportunities to reduce fuel consumption in heavy- duty vehicles due to transmission and driveline technologies in the 2015 time frame ranged between 2 and 8 percent. 65 

### The design goal is for the transmission to deliver the needed power to the vehicle while maintaining engine operation within the engine’s “sweet spot” for most efficient operation. Truck and chassis manufacturers today offer a wide range of tire s izes, final gear ratios and transmission choices so that owners can work with application engineers to specify an optimal combination given the intended vehicle service class and other performance needs . 

## 2.4.4.1 Optimizing Number of Gears and Gear Ratios Manufacturers can choose to replace 6 - speed transmissions with 8 - speed or more automatic transmissions. Additional ratios allow for further optimization of engine operation over a wider range of conditions, but this is subject to diminishing returns as the number of speeds increases. As additional planetary gear sets are added (which may be necessary

in some cases to achieve the higher number of ratios), additional weight and friction are introduced. Also, the additional shifting of such a transmission can be p erceived as bothersome to some consumers, so manufacturers need to develop strategies for smooth shifts. The Phase 1 rulemaking projected that 8 - speed transmissions could incrementally reduce fuel consumption by

1 to 3 percent from a baseline 6 - speed automatic transmission over some test cycles . The SwRI report uses 2 to 3 percent fuel consumption reduction when replacing 6 - speed baseline automatic transmissions with improved 8 - speed automatic transmissions.

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2 - 32 

## 2.4.4.2 Gear Efficiencies As described elsewhere for axles and engines, the efficiency of gears can be improved by reducing friction and minimizing mechanical losses. This can be done b y reducing the friction between the two gears in contact. This friction is reduced mainl y b y improving the surface finish o f the gears. The other way of doing is by

reducing the amount of distance the gear faces are sliding against each other. 

## 2.4.4.3 Shift Strategies Calibrating the transmission shift schedule to upshift earlier and quicker, and to lock up or partiall y lock up the torque converter under a broader range of operating conditions can reduce fuel consumption and CO 2 

### emissions. However, this operation can result in a perceptible degradation in noise, vibration, and harshness. The degree to which NVH can be degraded before it becomes noticeable to the driver is strongl y influenced b y characteristics of the vehicle, and although it is somewhat subjective, it always places a limit on how much fuel consumption can be improved b y transmission control changes. During operation , an automatic transmission’s controller manages the operation of the transmission by

scheduling the upshift or downshift, and locking or allowing the torque converter to slip based on a preprogrammed shift schedule. The shift schedule contains a number of lookup table functions, which define the shift points and torque converter lockup based on vehicle speed and throttle position, and other parameters such as temperature. Aggressive shift logic can be employed in such a way as to maximize fuel efficiency b y modifying the shift schedule to upshift earlier and inhibit downshifts under some conditions, which reduces engine pumping losses and engine friction. The application of this technology does require a manufacturer to confirm that drivability, durability , and NVH are not significantl y degraded. A torque converter is a fluid coupling located between the engine and transmission in vehicles with automatic transmissions and continuously- variable transmissions (CVT). This fluid coupling allows for slip so the engine can run while the vehicle is idling in gear (as at a stop light), provides for smoothness of the powertrain, and also provides for torque multiplication during acceleration, and especiall y launch. During l ight acceleration and cruising, the inherent slip in a torque converter causes increased fuel consumption, so modern automatic transmissions utilize a clutch in the torque converter to lock it and prevent this slippage. Fuel consumption can be further red

uced by locking up the torque converter at lower vehicle speeds, provided there is sufficient power to propel the vehicle, and noise and vibration are not excessive. If the torque converter cannot be fully locked up for maximum efficiency , a partial lockup strategy can be employed to reduce slippage. Early torque converter lockup is applicable to all vehicle types with automatic transmissions. Some torque converters would require upgraded clutch materials to withstand additional loading and the slipping conditions during partial lock-up. As with aggressive shift logic, confirmation of acceptable drivability , performance, durability and NVH characteristics would be required to successfull y i mplement this technology .

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2 - 33 

## 2.4.4.4 Architectures The manual transmis sion architecture has traditionally been considered the most efficient architecture since it did not experience the losses inherent in a torque converter required on a traditional automatic transmission (a traditional automatic transmission being a transmi ssion with fully automated shifting and using a hydraulic lock-up torque converter for smooth vehicle launching from a stop). However, this traditional understanding has been called into question as advances in electronics and computer processing power al low for more efficiency from a manual transmission architecture with fully automated shifting. The two primary manual transmission architectures emplo ying automated shifting are the automated manual transmission (AMT) and the dual - clutch transmission (DCT ). When implemented well, these mechanicall y more efficient designs c ould inherentl y provide better fuel efficiency and lower greenhouse gas emissions than conventional torque converter automatic transmission designs and, potentially , even fully manual transmissions . These transmissions offer the inherently lower losses of a manual transmission with the efficiency

and shift quality

advantages of electronic controls. The lower losses stem from the elimination of the conventional lock-up torque converter, and a greatly reduced need for high pressure hydraulic circuits to hold clutches to maintain gear ratios (in automatic transmissions). 

## 2.4.4.4.1 **AMT** An AMT is mechanically similar to a conventional manual transmission, but shifting and launch functions are automatic ally controlled by

electronics. The term AMT generally refers to a single clutch design (differentiating it from a dual - clutch transmission, or dual - clutch AMT, described below) which is essentially a manual transmission with automated clutch and shifting . Because of shift quality

issues with single - clutch designs, dual - clutch designs are more common in light - duty

applications where driver acceptance is of primary importance. Inthe HD sector, shift quality

remains important but is less so when compared to light - duty. As a result, the single - clutch AMT architecture can be an attractive technology for HD vehicles. 

## 2.4.4.4.2 **DCT** A DCT uses separate clutches (and separate gear shafts) for the even - numbered and the odd- numbered gears. In this way , the next expected gear is pre - selected thereby allowing for faster and smoother shifting. For example, in a 6 speed DCT, if the vehicle is accelerating in third gear, the shaft with gears one, three and five has gear three engaged and is transmitting power to the wheels. The shaft with gears two, four, and six is idle but has gear four engaged. When a shift is required, the controller disengages the odd - gear clutch while simultaneously engaging the even - gear clutch, thus making a smooth shift. If, on the other hand, the driver slows the vehicle instead of continuing to accelerate, the transmission would have to change to second gear on the idling shaft to anticipate a downshift. This shift can be made quickl y on the idling shaft since there is no torque being transferred on it. There are variations of the DCT design, with some having wet clutches and some dry clutches, and more recent versions that incorporate a torque converter similar to but smaller than the torque converter of a traditional automatic transmission. The wet clutch designs offer a higher torque capacity

that comes from the use of a hydraulic s ys tem that cools the clutches. Wet

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2 - 34 clutch systems are also less efficient than dry clutch systems due to the losses associated with the hydraulic pumping. They als o are more costl y due to the hydraulics. 

## 2.4.4.5 Hy

brid Powertrain Systems The industry

is currentl y developing many variations of hybrid powertrain systems. The hy brids developed to date have seen fuel consumption and CO 2 

### emissions reductions between 20 and 50 percent in the field. However, there are still some key issues that are restricting the penetration of hybrids, including overall s ys tem cost, battery technology , and lack of cost effective electrified accessories. A hy brid vehicle is a vehicle that combines two significant sources of propulsion energy, where one uses a consumable fuel (like diesel ), and one is rechargeable (during operation, or b y another energy

source). Hy

brid technology

is well established in the U.S. light - duty market , some manufacturers have been producing heavy- duty hy brid models for many

years, and others are looking to develop hybrid models in future years. Hy brids reduce fuel consumption through three major mechanisms:

• The internal combus tion engine can be optimized (through downsizing, modifying the operating cycle, or other control techniques) to operate at or near its most efficient point more of the time. Power loss from engine downsizing can be mitigated b y employing power assist fro m the secondary power source.

• Some of the energy normally lost as heat while braking can be captured and stored in the energy

storage s ys tem for later use.

• The engine is turned off when it is not needed, such as when the vehicle is coasting or when stopped. Hy brid vehicles utilize some combination of the three above mechanisms to reduce fuel consumption and CO 2 

### emissions. The effectiveness of fuel consumption and CO 2 

### reduction depends on the utilization of the above mechanisms and how aggressivel y they are pursued. One area where this variation is particularl y prevalent is in the choice of engine size and its effect on balancing fuel economy and performance. Some manufacturers choose not to downsize the engine when applying hybrid technologies. In these cases, performance is vastly improved, while fuel efficiency

improves significantl y less than if the engine w ere downsized to maintain the same performance as the conventional version. The non - downsizing approach is used for vehicles where towing and/or hauling are an integral part of their performance requirements. In these cases, if the engine is downsized, the battery can be quickl y drained during a long hill climb with a heavy load, leaving onl y a downsized engine to carry the entire load. Bec ause towing capability

is currently

a heavily- marketed HD pickup truck attribute, manufacturers are hesitant to offer a truck with a downsized engine that can lead to a significantly diminished towing performance when the battery state of charge level is l ow, and therefore engines are traditionally

not downsized for these vehicles.

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2 - 35 Strong hybrid technology utilizes an axial electric motor connected to the transmission input shaft and connected to the engine crankshaft through a clutch. The axial motor is a motor/generator that can provide sufficient torque for launch assist, all electric operation, and the ability to recover significant levels of braking energy . A hy brid drive unit is complex and consists of discrete components such as the electric traction motor, transmission, generator, inverter, controller and cooling devices. Certain types of drive units may

work better than others for specific vehicle applications or performance requirements. Several types of motors and generators have been developed for hybrid- electric drive systems, many

of which merit further evaluation and development on specific applications. Series HEVs typicall y have larger motors with higher power ratings because the motor alone propels the vehicle, which may be applicable to C lass 3 - 5 applications. In parallel hybrids, the power plant and the motor combine to propel the vehicle. Motor and engine torque are usuall y blended through couplings, planetary gear sets and clutch/brake units. The same mechanical components that make parallel heavy- duty hy brid drive units possible can be designed into series hy brid drive units to decrease the size of the electric motor(s) and power electronics. An electrical energy

storage s ys tem is needed to capture energy from the generator, to store energy

captured during vehicle braking events, and to return energy when the driver demands power. This technology has seen a tremendous amount of improvement over the last decade and recent ye ars. Advanced battery technologies and other types of energy storage are emerging to give the vehicle its needed performance and efficiency gains while still providing a product with long life. The focus on the more promising energy storage technologies such as nickel metal - hydride (NiMH) and lithium technology batteries along with ultra- capacitors for the heavy- duty fleet should yield interesting results after further research and applications in the light - duty fleet. Heavy- duty hybrid vehicles also use regenerative braking for improved fuel economy , emissions, b rake heat, and wear. A conventional heavy vehicle relies on friction brakes at the wheels, sometimes combined with an optional engine retarder or driveline retarder to reduce vehicle speed. During normal braking, the vehicle’s kinetic energy is wasted wh en it is converted to heat b y the friction brakes. The conventional brake configuration has large components, heavy brake heat sinks, and high temperatures at the wheels during braking, audible brake squeal, and consumable components requiring maintenance and replacement. Hy brid electric s ys tems recover some of the vehicle’s kinetic energy through regenerative braking, where kinetic energy

is captured and directed to the energy storage s ys tem. The remaining kinetic energy

is dissipated through convention al wheel brakes or in a driveline or transmission retarder. Regenerative braking in a hyb rid electric vehicle can require integration with the vehicle’s foundation (friction) braking s ys tem to maximize performance and safety. Today ’s systems function by simultaneousl y using the regenerative features and the friction braking s ys tem, allowing only some of the kinetic energy to be saved for later use. Optimizing the integration of the regenerative braking s ys tem with the foundation brakes would increase the benefits and is a focus for continued work. This ty pe of hy brid regenerative braking system improves fuel economy , GHG emissions, brake heat, and wear.

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2 - 36 In a hydraulic hyb rid system, deceleration energy is taken from the drivetrain by an inlin e hydraulic pump/motor unit by pumping hydraulic fluid into high pressure cylinders. The fluid, while not compressible, pushes against a membrane in the cylinder that compresses an inert gas to 5,000 PSIor more when fully charged. Upon acceleration, the energy stored in the pressurized tank pushes hydraulic fluid back into the drivetrain pump/motor unit, allowing it to motor into the drivetrain and assist the vehicle’s engine with the acceleration event. This heavyduty vehicle hy

brid approach has been demonstrated successfull y, producing good results on a number of commercial and military trucks. Despite the significant future potential for hybrids discussed above, there are no simple solutions applicable for each heavy- duty hybrid application due to th e large vocational vehicle fleet variation. A choice must be made relative to the requirements and priorities for the application. Challenges in motor subsystems such as gear reductions and cooling s ys tems must be considered when comparing the specific p ower, power density, and cost of the motor assemblies. High speed motors can significantl y reduce weight and size, but they require speed reduction gear sets that can offset some of the weight savings, reduce reliability and add cost and complexity . Air - cooled motors are simpler and generall y less expensive than liquid cooled motors, but they are larger and heavier, and they require access to ambient air, which can carry dirt, water, and other contaminants. Li quid- cooled motors are generall y s mall er and lighter for a given power rating, but they may require more complex cooling systems that can be avoided with air- cooled versions. Various coolant options, including water, water- glycol, and oil, are available for liquid- cooled motors but must be further researched for long term durability . Electric motors, power electronics, electrical safety, regenerative braking, and power-plant control optimization have been identified as the most critical technologies requiring further research to enable the development of higher efficiency hy brid electric propulsion systems. 

## 2.4.5 **Axles** 2.4.5.1 Axle Efficiency Axle efficiency

is improved by

reducing generally

two categories of losses; mechanical losses and spin losses. Mechanical losses can be reduced b y reducing the friction between the two gears in contact. This friction is reduced mainl y b y improving the surface finish of the gears. The other way of doing is by

reducing the amount of distance the gear faces are sliding against each other. Generally speaking frictional losses are proportional to the torque on the axle not a function of rotational speed of the axle. Spin losses on the other hand are a function of speed and not torque. One of the main ways to reduce the spin losses of the axle is by using a lower viscosity

lubricant. Some high performance lower viscosity formulations have been designed to have superior performance at high operating temperatures, and may have extended change interval s . A study conducted by

researchers at Shell Global Solutions on a Merce des Benz OM 460LA heavy- duty diesel engine run under the World Harmonized Transient Cycle (WHTC) and World Harmonized Stationary Cycle (WHSC), used a combination of a SAE 5W - 30 engine oil,

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2 - 37 SAE 75W - 80 gearbox oil and SAE 75W - 90 axle oil. The combination yi elded average fuel economy improvements of 1.8 percent over the WHTC and 1.1 percent over the WHSC, relative to a SAE 15W - 40 engine oil, SAE 80W gearbox and SAE 90 axle oil [VT - 27]. The baseline lubricants represent current mainstream products, and the new lubricants were top - tier formulations focusing on modified viscometric effects. Using the WHSC cycle, significant variations in the individual lubricant contribution under different speed and load conditions within the cycle were identified. Additional ly , an average fuel economy improvement of 1.8 percent was observed using medium - duty trucks under a range of typical European driving conditions in a controlled field trial . 66 

### Spin losses can also be reduced b y lower the volume of lubricant in the sump. This reduces the surface area of the gears that is churning through the lubricant. One of the main challenges of doing this is making sure that there is still adequate coverage of lubricant on the gears and bearings as well as adequate circulation so that the lubricant temperature doesn’t rise too high and accelerate the aging of the lubricant. If a manufacturer wishes to demonstrate a benefit specific to any technology that improves axle efficiency, an axle efficiency test could be performed to support an off - cycle technology

credit application. See draft RIA Chapter 3 for a description of the proposed test procedure for rear axle efficiency . 

## 2.4.5.2 Gear Ratio Combining with transmission ratio, selection of the axle ratio can play a significant role in vehicle p erformance. For an on - highway tractor, the axle ratio must be selected in such a way that the engine can constantly run inside the sweet spot, where the engine efficiency is optimal for a typical constant cruise speed like 65 mile per mile. Although many vehicles on the road already use the fast axle ratio as low as 2.64:1 with the direct drive of transmission, which moves the engine speed in the range of 1200 rpm or even lower, most vehicles still use higher or slower axle ratio, which puts the engine speed in the range of 1300 - 1400 rpm. In order to take advantage of optimal engine speed, which is typically in the range of 1100 - 1150 rpm for HHD diesel vehicles, it is expected that the faster axle ratio lower than 2.64:1 would be widely used in 2018 and beyond for tractors. Furthermore, in order to enhance vehicle performance, many axle manufacturers are developing dual speed axles, allowing vehicles to switch to the higher axle ratio during transient driving conditions, such as city traffic. On the voc ational side, the ability to start a heavy vehicle, climb hills, and operate smoothly at low speed is strongl y influenced b y axle ratio, and therefore, one can see a large of variation of axle ratios depending on the application. 

## 2.4.5.3 Tandem Drive Axle Improv ements Manufacturers are developing technologies to enable heavy trucks with two rear drive axles to be driven solely

by the lead rear axle either permanentl y or on a part time basis.

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2 - 38 

## 2.4.5.3.1 **6 x 2** Most tractors and heavy heavy- duty vocational vehicles today have three axles

– a steer axle and two rear drive axles, which is commonly referred to as a 6x4 configuration. Manufacturers offer 6x2 tractors that include one rear drive axle and one rear non- driving axle. The 6x2 tractors offer three distinct benefits. First, the non - driving rear axle does not have internal friction and therefore reduces the overall parasitic losses in the drivetrain. In addition, the 6x2 configuration typ ically weighs approximately

300 to 400 pounds less than a 6x4 configuration. 67 

### Finally , the 6x2 ty pically costs less or is cost neutral when compared to a 6x4 tractor. Sources cite the effectiveness of 6x2 axles at between 1 and 3 percent. 68 

### Similarly, with the increased use of double and triple trailers, which reduce the weight on the tractor axles when compared to a single trailer, manufacturers offer 4x2 axle configurations. The 4x2 axle configuration would have as good as or better fuel efficiency performance than a 6x2. 

## 2.4.5.3.2 **Enhanced 6x2** One of the drawbacks of 6x2 axle is lack of traction, specificall y during the winter condition and high grade road when the road is slippery . In order to overcome this deficiency , some axle manufacturers offer products that perform similar to the 6x4 configurations. SMARTandem offered by Meritor is just one of the examples. 69 

### Inthis system, the axle runs 6x2 for most time. Once the conditions that require more traction are experienced, the vehicle activates the s ys tem to add more loads into one the powered axle, thus instantly increasing traction. This system offers weight savings in the range of 300 to 400 lbs, as well as 2 percent fuel saving as compared with conventional 6x4 axle. 

## 2.4.5.3.3 **2.4.4.3.3 Disconnect 6x4**  **Axle** Based on confidential stakeholder discussions, the agencies anticipate that the axle market may

offer, in the proposed time frame of Phase 2, a Class 8 version of the ty pe of axle disconnect that today

allows 4x4 operators of HD pickup trucks to automatically disconnect or reco nnect the front axle depending on needs for traction in varying driving conditions. The Class 8 version would likely

function for the two tandem drive axles in a similar manner as the HD pickup trucks do for the front axle. The switching could be automated or user- commanded. In these cases, the axle actuator housing, sometimes called the axle disconnect housing, is part of the differential that houses the gears and shift fork required to lock two axles together. The axle actuator works together with the transfer case to send torque to all four wheel - ends. Recentl y, Dana Holding Corporation has developed an axle system that switches between the two modes based on driving conditions to maximize driveline efficiency . 70 

### When high traction is required, the s ys tem operates in 6x4 mode. When 6x4 tractive effort is not required, the system operates in 6x2 mode. Itis reported that this ty pe of s ys tem can offer 2.5 percent benefits. In the 4x4 example, the transfer case connects the input from the transmission to the rear and front driveshafts. The axle actuator housing is found on the differential. Inthe 4x4 example, a shift fork inside the axle actuator housing slides a locking collar over two gears locking both driver and passenger side axles together. In some 4x4 vehicles, those with automatic 4WD, this process occurs automaticall y. Inothers, with selective 4WD, the driver can choose to engage 4WD or RWD with a switch. These have slightl y different axle actuator

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2 - 39 housings and have actuator solenoids mounted to them. 71 

### These s ys tems would not provide the weight reduction benefit of the permanent 6x2 configuration, and may offer less fuel savings, especiall y with operator- switchable s ys tems. 

## 2.4.6 **Weight Reduction**  Mass reduction is a technology that can be use d in a manufacturer’s strategy to meet the proposed Phase 2 standards. Vehicle mass reduction (also referred to as “down - weighting” or ‘light - weighting”), decreases fuel consumption and GHG emissions by reducing the energy demand needed to overcome inerti a forces, and rolling resistance. Reduced mass in heavy- duty vehicles can benefit fuel efficiency and CO 2 

### emissions in two ways. If a truck is running at its gross vehicle weight limit with high density freight, more freight can be carried on each trip, increasing the truck’s ton - miles per gallon. If the vehicle is carrying lower density freight and is below the GVWR (or GCW) limit, the total vehicle mass is decreased, reducing rolling resistance and the power required to accelerate or climb grades. Many vehicle components are typicall y made of heavier material, such as steel. Manufacturers have worked with mass reduction technologies for many ye ars and a lot of these technologies have been used in production vehicles. The weight savings achieved b y adopting mass reduction technologies offset weight gains due to increased vehicle size, larger powertrains, and increased feature content (sound insulation, entertainment systems, improved climate control, etc.). Generally , an empty truck makes up about one - third of the total vehicle weight. Every 10 percent drop in vehicle weight reduces fuel use about 5 percent. 72 

### Although many gains have been made to reduce vehicle mass, many of the features being added to modern tractors to benefit fuel efficiency , such as additional aerody namic features or idle reduction s ys tems, have the effect of increasing vehicle weight, causing mass to stay relativel y constant. Material and manufacturing technologies can also play a significant role in vehicle safety b y reduc ing vehicle weight, and in the improved performance of vehicle passive and active safety s ys tems. Hy brid powertrains, fuel cells and auxiliary power would not onl y present complex packaging and weight issues, they would further increase the need for reductions in the weight of the body , chassis, and powertrain components in order to maintain vehicle functionality. Manufacturers may employ a s ys tematic approach to mass reduction, where the net mass reduction is the addition of a direct component or system mass reduction, also referred to as primary mass reduction, plus the additional mass reduction taken from indirect ancillary s ys tems and components, also referred to as secondary mass reduction or mass compounding. Mass reduction can be achieved through a number of approaches, even while maintaining other vehicle functionalities. As summarized by NAS in its 2011 light duty vehicle report, there are two key

strategies for primary

mass reduction: 1) substituting lighter materials for heavier materials ; and 2) changing the design to use less material . 73

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2 - 40 

## 2.4.6.1 Material Substitution S ubstitution of a material used in an assembl y or a component for one with lower density and/or higher strength includes replacing a common material such as mild steel with higherstrength and advanced steels, aluminum, magnesium, and composite materials. Inpractice, material substitution tends to be quite specific to the manufacturer and situation. Some materials work better than others for particular vehicle components, and unless strength is matched, some substituted components may need to be more numerous ( i.e. two brackets instead of one). Further, one choices of material may lead a manufacturer to invest more heavily in adjusting its manufacturing process to its properties, thus p ossibly impeding its ability

to consider other material s. The agencies recognize that like any type of mass reduction, material substitution has to be conducted not onl y with consideration to maintaining equivalent component strength, but also to maintaining all the other attributes of that component, system or vehicle, such as crashworthiness, durability , and noise, vibration and harshness (NVH). One example that combines material substitution with component - elimination is the use of wide -based single tires and aluminum rims to replace traditional dual tires and rims, eliminating eight steel rims and eight tires from a tractor . Using aluminum, metal alloys, metal matrix composites, and other lightweight components where appropriate can reduce empty vehicl e weight (known as “tare weight”), improve fuel efficiency, and reduce greenhouse gas emissions. Inaddition, in weight - sensitive applications, lightweight components can allow more cargo and increased productivity . A report by the National Commission on Energy Policy estimates that a fuel economy gain of 5.0 percent on certain applications could be achieved by vehicle mass reduction further illustrating the fuel economy gains possible on heavy- duty applications. 74 

### A report for the U.S. DOT estimated potential reductions in modal GHG emissions are 4.6 percent, though it also found that current light - weight materials are costly and are application - and vehicle - specific with need for further research and development for advanced materials. 75 

### Th e principal barriers to overcome in reducing the weight of heavy vehicles are associated with the cost of lightweight materials, the difficulties in forming and manufacturing lightweight materials and structures, the cost of tooling for use in the manufact ure of relatively low - volume vehicles (when compared to automotive production volumes), and ultimately , the extreme durability

requirements of heavy vehicles. While light - duty vehicles may

have a life span requirement of several hundred thousand miles, ty pical heavy- duty

commercial vehicles must last over 1 million miles with minimum maintenance, and often are used in secondary applications for many m ore years. This requires high strength, lightweight materials that provide resistance to fatigue, corrosio n, and can be economically repaired. Additionally , because of the limited production volumes and the high levels of customization in the heavy- duty market, tooling and manufacturing technologies that are used by the light - duty automotive industry are often uneconomical for heavy vehicle manufacturers. Li ghtweight materials such as aluminum, titanium and carbon fiber composites provide the opportunity for significant weight reductions, but their material cost and difficult forming and manufacturing requirements make it difficult for them to compete with low - cost steels. In addition, although mass reduction is currentl y occurring on both vocational vehicles and line haul tractors, the addition of other s ys tems for fuel economy, performance or comfort increa ses the vehicle mass offsetting the mass reduction that has already occurred, thus is not captured in the overall vehicle mass measurement (e.g. 500 lbs

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2 - 41 for WHR) . Most vehicle manufacturers offer lightweight tractor models that are 1,000 or more pounds li ghter than comparable models. Li ghter- weight models combine different weight - saving options that may

include: 76



###  Cast aluminum alloy

wheels can save up to 40 pounds each for total savings of 400 pounds  Aluminum axle hubs can save over 120 pounds compared to ductile iron or steel  Centrifug e brake drums can save nearl y 100 pounds compared to standard brake drums  Aluminum clutch housing can save 50 pounds compared to iron clutch housing  Composite front axle leaf springs can save 70 pounds compared to steel springs  Aluminum cab frames can save hundreds of pounds compared to standard steel frames 

## 2.4.6.2 Sy

nergistic Effects - Reduced Power Demand Manufacturers emplo y a systematic approach to mass reduction, where the net mass reduction is the addition of a direct component or system mass reduction plus the additional mass reduction that can be taken from indirect ancillary systems and components, as a result of full vehicle optimization, effectivel y compounding or obtaining a secondary mass reduction from a primary mass re duction. The strategy of using less material compared to the baseline component or system can be achieved by optimizing the design and structure of vehicle components, systems and vehicle structure. Vehicle manufacturers have long used these continuallyimproving CAE tools to optimize vehicle designs. For example, the Future Steel Vehicle (FSV) project sponsored b y WorldAutoSteel used three levels of optimization: topology optimization, low fidelity

3G (Geometry

Grade and Gauge) optimization, and subsystem optimization, to achieve 30 percent mass reduction in the body structure of a vehicle with a mild steel unibody structure. 77 

### Using less material can also be achieved through improving the manufacturing process, such as b y using improved joining technolo gies and parts consolidation. This method is often used in combination with applying new materials. If vehicle mass is reduced sufficiently through application of the two primary strategies of using less material and material substitution described above, secondary mass reduction options may

become available. Secondary mass reduction is enabled when the load requirements of a component are reduced as a result of primary mass reduction. If the primary mass reduction reaches a sufficient level, a manufacturer may use a smaller, lighter, and potentially more efficient powertrain while maintaining vehicle p erformance. If a powertrain is downsized, a portion of the mass reduction may be attributed to the reduced torque requirement that results from the lower vehicle mass. The lower torque requirement enables a reduction in engine displacement, changes to transmission torque converter and gear ratios, and changes to final drive gear ratio. The reduced powertrain torque may enable the downsizing and/or mass reduction of powertrain components and accompanying reduced rotating mass (e.g., for transmission, driveshafts/halfshafts, wheels, and tires) without sacrificing powertrain durability . However, there may

trade - offs, as it is possible that use of a downsized engine may require a transmission with more gears. The combined mass reductions of the engin e, drivetrain, and body would reduce stresses on the suspension components, steering components, wheels, tires, and brakes, which can allow further reductions in the mass of these subs ys tems. Reducing the

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2 - 42 unsprung masses such as the brakes, control arms, wheels, and tires further reduce stresses in the suspension mounting points, which would allow for further optimization and po tential mass reduction. One example of a s ynergistic effect is rotational inertia. Reducing the weight o f rotating components provides an enhanced fuel efficiency benefit over reducin g the weight o f static components. In theory , as components such as brake rotors, brake drums, wheels, tires, crankshafts, camshafts, and piston assemblies become lighter, the power consumption to rotate the masses would be directly proportional to the mass decrease. Using phys ical properties of a rotating component such as a wheel, it is relatively straightforward to calculate an equivalent mass. However, we do not have enough information to derive industry average values for equivalent mass, nor have we evaluated the best way for GEM to account for this. Using typical values for a heavy- duty

steel wheel compared to a similar- sized aluminum wheel, the agencies estimate the equivalent mass ratio is in the range of 1.2 to 1.3. That means that by reducing the mass of a wheel b y 20 pounds, the vehicle could theoreticall y perfo rm as if 26 pounds had been reduced. Estimates of the sy

nergistic effects of mass reduction and the compounding effect that occurs along with it can vary significantl y from one report to another. For example, in discussing its estimate, an Auto - Steel Partnership report states that “These secondary mass changes can be considerable

—estimated at an additional 0.7 to 1.8 times the initial mass change.” 78 

### This means for each one pound reduction in a primary component, up to 1.8 pounds can be reduced from other structures in the vehicle ( i.e. , a 180 percent factor). The report also discusses that a primary

variable in the realized secondary weight reduction is whether or not the powertrain components can be included in the mass reduction effort, with the lower end estimates being applicable when powertrain elements are unavailable for mass reduction. However, another report by the Aluminum Association, which primaril y focuses on the use of aluminum as an alternative material for steel, estimated a factor of 64 p ercent for secondary mass reduction even though some powertrain elements were considered in the analysis. 79 

### That report also notes that ty

pical values for this factor vary from 50 to 100 percent. Although there is a wide variation in stated estimates, sy n ergistic mass reductions do exist, and the effects result in tangible mass reductions. Mass reductions in a single vehicle component, for example a door side impact/intrusion system, may actuall y result in a significantly higher weight savings in the total vehicle, depending on how well the manufacturer integrates the modification into the overall vehicle design. Accordingl y, care must be taken when reviewing reports on weight reduction methods and practices to ascertain if compounding effects have been c onsidered or not . 

## 2.4.7 **Vehicle Speed Limiter**  The power required to move a vehicle increases as the vehicle speed increases. Travelling at lower speeds provides additional efficiency to the vehicle performance. Most vehicles today

have the ability

to electroni cally

control the maximum vehicle speed through the engine controller. This feature is used today by fleets and owners to provide increased safety and fuel economy . Currently , these features are designed to be able to be changed b y the owner and/or dealer.

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2 - 43 The impact of this feature is dependent on the difference between the governed speed and the speed that would have been travelled, which is dependent on road ty pe, state speed limits, traffic congestion, and other factors. The agencies plan to assess the benefit of a vehicle speed limiter by reducing the maximum drive cycle speed on the 65 mph Cruise mode of the cycle. The maximum speed of the drive cycle is 65 mph, therefore any vehicle speed limit with a setting greater than this would show no benefit for purposes of these regulations, but may still show benefit in the real world in states where the interstate truck speed limit is greater than the national average of 65.5 mph. The benefits of this simple technology are widel y recognized. The American Trucking Association (ATA) developed six recommendations to reduce carbon emissions from trucks in the United States. Their first recommendation is to enact a national truck speed limit of 65 mph and require that trucks manufactured after 1992 have speed governors set at not greater than 65 mph. 80 

### The SmartWay

program includes speed management as one of their key Clean Freight Strategies and provides information to the public regarding the benefit of lower highway speeds. 81 

### Some countries have enacted regulations to reduce truck speeds. For example, the United Kingdom introduced regulations in 2005 which require new trucks used for goods movement to have a vehicle speed limiter not to exceed 90 km/hr (56 mph). 82 

### The Canadian Provinces of Ontario and Quebec developed regulations which took effect in January 2009 that requires on highway commercial heavy- duty trucks to have speed limiters which limit the truck’s speed to 105 km/hr (65 mph). 83 

### Many truck fleets consider speed limiter application a good business practice in their operations. A Canadian assessment of heavy- duty truck speed limiters estimated that 60 percent of heavy truck fleets in North America use speed limiters. 83 

### Con Way Freight, Con Way Truckload, and Wal - Mart currentl y govern the speeds of their fleets between 62 and 65 mph. 84 

### A potential disbenefit of this technology is the additional time required for goods movement, o r loss of productivity . The elasticity between speed reduction and productivity loss has not been well defined in industry . The Canadian assessment of speed limiters cited above found that the fuel savings due to the lower operating speeds outweigh any p roductivity losses. A general consensus among the OEMs is that a one percent decrease in speed might lower productivity

by approximately

0.2 percent. 84 

## 2.4.8 **Reduced Idling Time** 2.4.8.1 Engine Shutdown with Alternate Power Source during Hoteling Class 8 heavy- duty diesel truck extended engine idling expends significant amounts of fuel in the United States . Department of Transportation regulations require a certain amount of rest for a corresponding period of driving hours, as discussed in Chapter 1. Extended idle occurs when Class 8 long haul drivers rest in the sleeper/cab compartment during rest periods as drivers find it more convenient and economical to rest in the truck cab itself. In many cases it is the only option available. During this rest period a driver will generall y idle the truck in order to provide heating or cooling or run on -board appliances. During rest periods the truck’s main propulsion

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2 - 44 engine is running but not engaged in gear and it remains in a stationary position. In some cases the engine can idle in excess of 10 hours. During this period of time, fuel consumption will generall y average 0.8 gallons per hour. 113 

### Average overnight fuel usage would exceed 8 gallons in this example. When multiplied by the number of long haul trucks without idle control technology

that operate on national highways on a daily basis, the number of gallons consumed by extended idling would exceed 3 million gallons per day . Fortunatel y, a number of alternatives (idling reduction technologies) are available to alleviate this situation. 

## 2.4.8.1.1 **Idle Control Technologies** Idle reduction technologies in general utilize an alternative energy source in place of operating the main engine. By using these devices the truck driver can obtain needed power for services and app liances without running the engine. A number of these devices attach to the truck providing heat, air conditioning, or electrical power for microwave ovens, televisions, etc. The idle control technologies (along with their ty pical hourly

fuel rate) availa

ble today include the following: 85



###  Auxiliary

Power Unit (APU) powers the truck’s heating, cooling, and electrical s ys tem. The fuel use of an APU is ty picall y 0.2 gallons per hour  Fuel Operated Heater (FOH) provides heating services to the truck through smal l diesel fired heaters. The fuel use is ty picall y 0.04 gallons per hour  Battery

Air Conditioning Systems (BAC ) provides cooling to the truck  Thermal Storage S ystems provide cooling to trucks Another alternative involves electrified parking spaces, with or without modification to the truck. An electrified parking space s ys tem operates independentl y of the truck’s engine and allows the truck engine to be turned off while it supplies heating, cooling, and electrical power. These s ys tems provide off -board electrical power to operate either: 1. A single s ys tem electrification which requires no on -board equipment b y providing an independent heating, cooling, and electrical power system, or 2. A dual system which allows driver to plug in on -board equipment In the first case, power is provided to stationary equipment that is temporarily attached to the truck. In the second, the truck is modified to accept power from the electrical grid to operate on -board truck equipment. The retail price of idle reduction s ys tems varies depending on the level of sophistication. For example, on -board technologies such as APUs can retail for over $7,000 while options such as electrified parking spaces require negligible up - front costs for equipment for the tractor itself, but will accrue fees with usage. 86 

### CO 2 

### emissions and fuel consumption during extended idling are significant contributors to emissions and fuel consumption from Class 8 sleeper cabs. The federal test procedure does evaluate idle emissions and fuel consumption as part of the drive cycle and related emissions measurement. However, long duration extended idle emissions and fuel consumption are not fully represented during the prescribed test cycle. To address the fact that real - world fuel and

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2 - 45 emissions savings can occur with idle reduction technologies that cannot be reflected on the test cycle, the agencies adopted in Phase 1 a credit mechanism for manufacturers who provide for idle control using an automatic engine shutdown (AES) system on the tractor. This credit recognizes the CO 2 

### reductions and fuel consumption savings attributed to idle control systems and allows vehicle manufacturers flexibility in product design and performance capabilities, compared to an alternative where the agencies would allow credits for specific idle control technologies. 

## 2.4.8.2 Stop Start For heavy- duty vehicles to apply engine stop - start technology without a reduction in vehicle function, some additional vehicle technologies are needed. To some extent this could be considered similar to a m ild hy brid s ys tem , but it is not the same as the mild hy brid s ys tem described for HD pickups and vans described below in Chapter 2.5. The agencies are projecting the presence of a battery

sufficient to offer electrified p ower steering, and some other electrified accessories . Some systems may replace the conventional alternator with a belt or crank driven starter/alternator and may add high voltage electrical accessories (which may include electric power steering and an auxiliary automatic transmissio n pump). The limited electrical requirements of these s ys tems allow the use of lead- acid batteries or supercapacitors for energy storage, or the use of a small lithium - ion battery pack. The NACFE Idle Reduction Confidence report was written with long haul tractors in mind ; however the section on vehicle electrification discusses inverters and on - vehicle solar energy capture, and offers some insights relevant to vocational vehicle electrification as it pertains to stop - start systems. 87 

### Inverters and beltles s alternators can use DC power stored in batteries to power on -board electrical devices and re - start engines . One example of a company that supplies battery- inverter idle reduction systems for vocational vehicle s is Vanner. 88 

### There are also s ys tems available today that are designed to capture solar energy and store this energy for distribution to electrified accessories and engine re - starting. One example of a company that supplies on - vehicle solar energy capture for vocatio nal vehicle s is eNow . 89 

## 2.4.8.3 Neutral Idle Automatic transmissions historically appl y torque to an engine when in gear at zero speed, such as when stopped at a traffic light. These transmissions can be programmed to place a smaller load on the engine, resulting in lower rpm and lower fuel consumption, essentially shifting the transmission to neutral at zero speed. 

## 2.4.9 **Air Conditioning**  2.4.9.1 Refrigerant Leakage Hydrofluorocarbon (HFC) refrigerants, which are powerful GHG pollutants, can be emitted to the atmosphere through component and system leaks during operation, during maintenance and servicing, and with disposal at the end of the vehicle’s life. The current widelyused refrigerant

– R134a, has a much higher global warming potential (GWP) than CO 2 

### ,

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2 - 46 therefore a small le akage of this refrigerant has a much greater global warming impact than a similar amount of emissions of CO 2 

### or other mobile source GHGs. Direct emissions of HFC from air conditioning s ys tems can be reduced b y minimizing system leaks. Based on measurements from 300 European light - duty vehicles (collected in 2002 and 2003), Schwarz and Harnisch estimate that the average HFC direct leakage rate from modern A/C systems was estimated to be 53 g/y r. 90 

### This corresponds to a leakage rate of 6.9 percent per ye ar. This was estimated by extracting the refrigerant from recruited vehicles and comparing the amount extracted to the amount originally filled (as per the vehicle specifications). The fleet and size of vehicles differs from Europe and the United States, th erefore it is conceivable that vehicles in the United States could have a different leakage rate. The authors measured the average charge of refrigerant at initial fill to be about 747 grams (it is somewhat higher in the U.S. at 770g), and that the smaller cars (684 gram charge) emitted less than the higher charge vehicles (883 gram charge). Moreover, due to the climate differences, the A/C usage patterns also vary between the two continents, which may influence leakage rates. Vincent et al., from the Cali fornia Air Resources Board estimated the in -use refrigerant leakage rate to be 80 g/yr . 91 

### This is based on consumption of refrigerant in commercial fleets, surveys of vehicle owners and technicians. The study assumed an average A/C charge size of 950 gram s and a recharge rate of 1 in 16 years (lifetime). The recharges occurred when the system was 52 percent empty and the fraction recovered at end- of - life was 8.5 percent. Manufacturers today

are complying with the HD Phase 1 program requirements to reduce A/C leakage emissions by utilizing high - quality , low - leakage air conditioning s ys tem components in the production of new tractors , and HD pickup trucks and vans. Some of the components available to manufacturers are low -permeation flexible hoses, multiple o - ring or seal washer connections, and multiple - lip compressor shaft seals. The availability of low leakage components in the market is being driven b y the air conditioning credit program in the light- duty GHG rulemaking. The cooperative industry and go vernment Improved Mobile Air Conditioning (IMAC) program has demonstrated that new - vehicle leakage emissions can be reduced b y 50 percent b y reducing the number and improving the quality of the components, fittings, seals, and hoses of the A/C system. 92 

## 2.4.9.2 Sys tem Efficiency A program could be developed that includes efficiency improvements. CO 2 

### - equivalent emissions and fuel consumption are also associated with air conditioner efficiency , since air conditioners create load on the engine. See 74 FR at 49529. However, as in Phase 1, the agencies are not proposing air conditioning efficiency standards for heavy- duty vehicles, as the fuel consumption and CO 2 

### emissions due to air conditioning systems in heavy- duty trucks are minimal (compared to their overall fuel consumption and emissions of CO 2 

### ). For example, EPA conducted modeling of a Class 8 sleeper cab using GEM to evaluate the impact of air conditioning and found that it leads to approximately 1 gram of CO 2

### /ton - mile. Therefore, a projected 24 percent improvement of the air conditioning system (the level projected in the light duty GHG rulemaking), would only reduce CO 2 

### emissions by less than 0.3 g CO 2

### /ton - mile, or approximately

0.3 percent of the baseline Class 8 sleeper cab CO 2 

### emissions.

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## 2.4.9.3 Solar Control S olar reflective paint and solar control glazing can reduce the temperature inside a vehicle, and therefore reduce the air conditioning requirements. The reduction in air conditioning load can lead to reductions in fuel consumption and GHG emissions. CARB ’s Low Emission Vehicle III Regulations (LEVIII) include a GHG credit for this technology . 93 

### Solar reflective paints reflect approximately a half of the solar energy by reflecting the infrared portion of the solar spectrum. A study conducted by

National Renewable Energy L aboratory

found benefits to sleeper cab tractors using reflective paint. 94 

### Solar control glazing reflects some of the solar energy

from the glass. CARB found that most heavy- duty trucks today use solar absorbing glass. There are many factors that influence the level of emissions and fuel consumption reductions due to solar control glazing and solar reflective paint. The fraction of time spent idling during the day

time hours, the fraction of hours of the day that are sunny , the ambient temperatures, the wind conditions and/or vehicle speed, the fraction of the vehicles that are painted colors other than white, and other factors influence the potential impact of these technologies. Because of the difficulty in assessing the potential emissi on reductions from solar control paint and glazing, the agencies are not proposing this technology as part of HD Phase 2 , but these ty

pes of technologies could be considered under the innovative technology program . 

## 2.4.10 **Other Accessory I**  **mprovements** Electric pow er steering (EPS) provides a potential reduction in CO 2 

### emissions and fuel consumption over hydraulic power steering because of reduced overall accessory loads. This eliminates the parasitic losses associated with belt - driven power steering pumps which co nsistently

draw load from the engine to pump hydraulic fluid through the steering actuation systems even when the wheels are not being turned. EPS is an enabler for all vehicle hy bridization technologies since it provides power steering when the engine is off. EPS may be implemented on most vehicles with a standard 12V system. Some heavier vehicles such as Class 2b and 3 may

require a higher voltage s ys tem which may add cost and complexity . The 2017 light - duty final rule estimated a one to two percent ef fectiveness based on the 2002 NAS report, a Sierra Research report, and confidential manufacturer data. The SwRI report estimated 0.8 percent to 1 percent effectiveness. The agencies reviewed these SwRI effectiveness estimates and found them to be accurate, thus they have been retained for this propos al . In addition to the purel y hy brid technologies, which decreases the proportion of propulsion energy

coming from the fuel by

increasing the proportion of that energy coming from electricity, there are other steps that can be taken to improve the efficiency of auxiliary functions ( e.g. , power- assisted steering or air- conditioning) which also reduce CO 2 

### emissions and fuel consumption. Optimization of the auxiliary functions is collectively

referred to as vehicle or accessory load electrification because they generally use electricity instead of engine power. These improvements are considered enablers for hybrid s ys tems.

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## 2.4.11 **Predic tive**  **Cruise Control** Cruise control is commonly used in light - duty

and heavy- duty applications to maintain a vehicle at a set speed. However, cruise control systems with additional intelligence and predictive control in are much more complex but offer oppo rtunities to reduce fuel consumption and GHG emissions. Many of the heavy- duty

manufacturers are developing intelligent cruise control systems and though they resemble each other in overall function, each manufacturer is doing it differently . As an exampl e, an intelligent cruise control s ys tem partnered with a source of elevation information could detect when the vehicle is on a hill and know when it is close to cresting the hill. During this time, the vehicle may be allowed to temporarily travel at a low er speed to prevent the need for a transmission downshift, which consumes more fuel because it requires the engine to increase the rpm and run in a less efficient part of the fuel map. Similarly, predictive cruise control allo w s a vehicle to exceed the speed set point by a specified amount so that the vehicle will start the next hill at a higher speed and reduce the likelihood of needing to downshift on the next hill. The amount of reduction in fuel consumption and CO 2 

### emissions depends significantl y on the terrain. Sources estimate that the overall savings is approximately two percent. 95 

## 2.5 **Technology Application and Estimated Costs –**  **HD Pickups and Vans** 2.5.1 **Gasoline Engines** Spark ignited (gasoline) engines used in complete Class 2b and 3 pickups and vans include engines offered in a manufacturer’s light- duty truck counterparts, as well as engines specific to the Class 2b and 3 segment. Based on 2014 MY specifications, these engines ty picall y range in displacement between 5 and 7 liters, though smaller and larger engines have also been used in this market. The majority of these engines are a V8 configuration, although the V10 configuration is also marketed. The engine technologies are based on the technologies described in the Light - Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards Joint Technical Support Document and Sections 2.2 and 2.3 above . 96 

### Some of the references come from the 2010 NAS Report, Technologies and Approaches to Reducing the Fuel Consumption of Medium and Heavy- Duty Vehicles. These technologies include engine friction reduction, cam phasing, cylinder deactivation and stoichiometric gas direct injection. Included with each technology

description is an estimate of the improvement in fuel consumption and GHGs that is achievable through the use of the technology in heavy- duty

pickup trucks and vans. 

## 2.5.1.1 Low Friction Lubricants One of the most basic methods of reducing fuel consumption in both gasoline and diesel engines is the use of lower viscosity engine lubricants. More advanced multi - viscosity engine oils are available today

with improved performance in a wider temperature band and with better lubricating properties. This can be accomplished by changes to the oil base stock ( e.g. ,

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2 - 49 switching engine lubricants from a Group I base oils to lower- friction, lower viscosity Group III sy nthetic) and through changes to lubricant additive packages ( e.g. , friction modifiers and viscosity improvers). The use of 5W - 30 motor oil is now widespread and auto manufacturers are introducing the us e of even lower viscosity oils, such as 5W - 20 and 0W - 20, to improve coldflow properties and reduce cold start friction. However, in some cases, changes to the crankshaft, rod and main bearings and changes to the mechanical tolerances of engine components may

be required. In all cases, durability testing would be required to ensure that durability is not compromised. The shift to lower viscosity and lower friction lubricants would also improve the effectiveness of valvetrain technologies such as cylinder deactivation, which rely on a minimum oil temperature (viscosity) for operation. Based on light - duty 201 7 - 20 25 MY vehicle rulemaking, and previousl y- received confidential manufacturer data, the agencies have estimated the effectiveness of low friction lubricants to be between 0 to 1 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.2 Engine Friction Reduction Manufacturers can reduce friction and improve fuel consumption by improving the design of engine component s and subsystems. Approximately 10 percent of the energy consumed b y a vehicle is lost to friction, and just over half is due to frictional losses within the engine. Examples include improvements in low - tension piston rings, piston skirt design, roller c am followers, improved crankshaft design and bearings, material coatings, material substitution, more optimal thermal management, and piston and cylinder surface treatments. Additionally, as computer- aided modeling software continues to improve, more opportunities for evolutionary friction reductions may

become available. Estimations of fuel consumption improvements due to reduced engine friction from the 201 5 NHTSA Technology Study range from 1 percent to 2 percent. The agencies believe that this range is accurate. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.3 Engine Parasitic Demand Reduction Manufacturers can reduce mechanical engine loads and improve fuel consumption by implementing variable - displacement oil pumps, higher- efficiency direct injection fuel pumps, and variable speed/displacement coolant pumps. Estimations of fuel consumption improvements due to reduced engine parasitic demand from the 201 5 NHTSA Technolo gy Study range from 1 percent to 2 percent. The agencies believe that this range is accurate. We present cost estimates for this technology in Chapter 2.12 of this draft RIA.

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## 2.5.1.4 Variable Valve Timing Variable valve timing (VVT) classifies a famil y of valve - train designs that alter the timing of the intake valve, exhaust valve, or both, primarily to reduce pumping losses, increase specific power, and control the level of residual gases in the cylinder. VVT reduces pumping losses when the engine is lightly loaded by

controlling valve timing closer to the optimum needed to sustain horsepower and torque. VVT can also improve volumetric efficiency at higher engine speeds and loads. Additionally , VVT can be used to alter (and optimize) the effective compression ratio where it is advantageous for certain engine operating modes ( e.g. , in the Atkinson Cycle). VVT has now become a widely adopted technology

in the light duty

fleet: in MY 20 14 , most of all new cars and light trucks had engines with some method of variable valve timing. 97 

### Manufacturers are currently using many different types of variable valve timing, which have a variety of different names and methods. Therefore, the degree of further improvement across the fleet is limited by

the level of valvetrain te chnology already implemented on the vehicles. The three major types of VVT are listed below. Each of the implementations of VVT uses a cam phaser to adjust the camshaft angular position relative to the crankshaft position, referred to as “camshaft phasing .” The phase adjustment results in changes to the pumping work required b y the engine to accomplish the gas exchange process. The majority of current cam phaser applications use hydraulicall y- actuated units, powered b y engine oil pressure and managed by a solenoid that controls the oil pressure supplied to the phaser. 

## 2.5.1.4.1 **Coupled Cam Phasing for Overhead Valve (OHV) and Single**

**Overhead Camshaft (SOHC) Engines** Valvetrains with coupled (or coordinated) cam phasing (CCP) can modify the timing of both the inlet v alves and the exhaust valves an equal amount by varying the phasing of the camshaft across an engine’s range of operating speeds; also known as VVT. For engines configured as an overhead valve (OHV) or as a single overhead camshaft (SOHC) only one cam pha ser is required per camshaft to achieve CCP . Based on the heavy- duty

2014 - 2018 MY vehicle rulemaking, 201 5 NHTSA Technology Study, and previously- received confidential manufacturer data, the agencies estimate the fuel consumption reduction effectiveness of this technology to be between 1 and 3 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.4.2 **Intake Cam Phasing (ICP) for Dual Overhead Camshaft Engines**

**(DOHC)** Valvetrains with ICP, which is the simplest of the cam phasing technologies, can modify the timing of the inlet valves by phasing the intake camshaft while the exhaust valve timing remains fixed. This requires the addition of a cam phaser on each bank of intake valves on the

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2 - 51 engine. An in - line 4 - cylinder engine has one bank of intake valves, while V - configured engines have two banks of intake valves. Some newer Class 2b and 3 market entries are offering dual overhead camshaft (DOHC) engine designs where two camshafts are used to operate the intake and exhaust valves independentl y. Consistent with the heavy- duty 2014 - 2018 MY vehicle rulemaking and the SwRI report, the agencies agree with the effectiveness values of 1 to 2 percent reduction in fuel consumption for this technology . 

## 2.5.1.4.3 **Dual Cam Phasing (DCP) for Dual Overhead Camshaft Engines** 

**(DOHC)** The most flexible VVT design is dual (independent) cam phasing, where the intake and exhaust valve opening and closing events are controlled independentl y. This opti on allows the option of controlling valve overlap, which can be used as an internal EGR strategy . At low engine loads, DCP creates a reduction in pumping losses, resulting in improved fuel consumption. Increased internal EGR also results in lower engine - out NO X 

### emissions. The amount by

which fuel consumption is improved depends on the residual tolerance of the combustion system. Additional improvements are observed at idle, where low valve overlap could result in improved combustion stability, potentially reducing idle fuel consumption. DCP requires two cam phasers on each bank of the engine. Some newer Class 2b and 3 market entries are offering dual overhead camshaft (DOHC) engine designs where two camshafts are used to operate the intake and exhaust valves independentl y. Consistent with the light - duty 2012 - 2016 MY vehicle rulemaking and the SwRI report, the agencies agree with the effectiveness values of 1 to 3 percent reduction in fuel consumption for this technology . We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.5 Variable Valve Lift (VVL) Controlling the lift of the valves provides a potential for further efficiency improvements. By optimizing the valve - lift profile for specific engine operating regions, the pumping losses can be reduced b y reducing the amount of throttling required to produce the desired engine power output. By

moving the throttling losses further downstream of the throttle valve, the heat transfer losses that occur from the throttling process are directed into the fresh charge - air mixture just prior to compression, delaying the onset of knock- limited combustion processes. Variable valve lift control can also be used to induce in- cylinder mixture motion, which improves fuel - air mixing and can result in improved thermodynamic efficiency. Variable valve lift control can also potentially

reduce overall valvetrain friction. At the same time, such systems may also incur increased parasitic losses associated with their actuation mechanisms. A number of manufacturers have already implemented VVL into their fleets (To yota, Honda, and BMW) . There are two major classifications of va riable valve lift, described below:

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## 2.5.1.5.1 **Discrete Variable Valve Lift (DVVL)** Discrete variable valve lift (DVVL) s ys tems allow the selection between two or three discrete cam profiles b y means of a hydraulicall y- actuated mechanical system. By optimizing the cam profile for specific engine operating regions, the pumping losses can be reduced by reducing the amount of throttling required to produce the desired engine power output. This increases the efficiency

of the engine. These cam profiles consist of a low and a high - lift lobe, and may include an inert or blank lobe to incorporate cylinder deactivation (in the case of a 3 - step DVVL s ys tem). DVVLis normally applied together with VVT control. DVVL is also known as Cam Profile Switching (CPS). DVVL is a mat ure technology

with low technical risk. Based on the light - duty MY 2017 - 2025 final rule, previously- received confidential manufacturer data, 201 5 NHTSA Technology Study , and report from the Northeast States Center for a Clean Air Future (N ESCCAF), the agencies estimate the fuel consumption reduction effectiveness of this technology to be between 1 and 3 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.6 Cylinder Deactivation In conventional spark - ignited engines throttling the airflow controls engine torque output. At partial loads, efficiency can be improved b y using cylinder deactivation instead of throttling. Cylinder deactivation can improve engine efficiency by disabling or deactivating (usuall y) half of the cylinders when the load is less than half of the engine’s total torque capability

– the valves are kept closed, and no fuel is injected

– as a result, the trapped air within the deactivated cylinders is simply

compressed and expanded as an air spring, with reduced friction and heat losses. The active cylinders combust at almost double the load required if all of the cylinders were operating. Pumping losses are significantl y reduced as long as the engine is operated in this “part - cylinder” mo de. Cylinder deactivation control strategy relies on setting maximum manifold absolute pressures or predicted torque within which it can deactivate the cylinders. Noise and vibration issues reduce the operating range to which cylinder deactivation is all owed, although manufacturers are exploring vehicle changes that enable increasing the amount of time that cylinder deactivation might be suitable. Some manufacturers may choose to adopt active engine mounts and/or active noise cancellations systems to address Noise Vibration and Harshness (NVH) concerns and to allow a greater operating range of activation. Effectiveness improvements scale roughl y with engine displacement - to - vehicle weight ratio: the higher displacement - to - weight vehicles, operating at lower relative loads for normal driving, have the potential to operate in part- cylinder mode more frequently . Based on the 201 5 NHTSA Technology Study and previously- received confidential manufacturer data, the agencies estimate the fuel co nsumption reduction effectiveness of this technology

to be between 2.5 and 3.5 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA.

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## 2.5.1.7 Stoichiometric Gasoline Direct Injection Stoichiometric gasoline direct injection (SGDI) engines inject fuel at high pressure directly into the combustion chamber (rather than the intake port in port fuel injection). SGDI requires changes to the injector design, an additional high pressure fuel pump, new fuel rails to handle the higher fuel pressures, and changes to the cylinder head and piston crown design. Direct injection of the fuel into the cylinder improves cooling of the air/fuel charge within the cylinder, which allows for higher compression ratios and increased thermody namic effi ciency without the onset of combustion knock. Recent injector design advances, improved electronic engine management systems and the introduction of multiple injection events per cylinder firing cycle promote better mixing of the air and fuel, enhance combustion rates, increase residual exhaust gas tolerance and improve cold start emissions. SGDIengines achieve higher power density and match well with other technologies, such as boosting and variable valvetrain designs. Several manufacturers have recently introduced vehicles with SGDIengines, including GM and Ford, who have announced their plans to increase dramatically the number of SGDI engines in their light - duty portfolios. Based on the heavy- duty

2014 - 2018 MY vehicle rulemaking, 201 5 NHTSA Technology Study, and previously- received confidential manufacturer data, the agencies estimate the fuel consumption reduction effectiveness of SGDI to be between 1 and 2 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.1.8 Turbocharging and Downsizing (TRBDS) The specific power of a naturally aspirated engine is primarily limited by

the rate at which the engine is able to draw air into the combustion chambers. Turbocharging and supercharging (grouped together here as boosting) are two methods to increase the intake manifold pressure and cylinder charge - air mass above naturall y aspirated levels. Boosting increases the airflow into the engine, thus increasing the specific power level, and with it the ability to reduce engine displacement while maintaining performance. This effectivel y reduces the pumping losses at lighter loads in comparison to a larger, naturall y aspirated engine. Almost every

major manufacturer currentl y markets a vehicle with some form of b oosting. While boosting has been a common practice for increasing performance for several decades, turbocharging has considerable potential to improve fuel economy and reduce CO 2 

### emissions when the engine displacement is also reduced. Specific power leve ls for a boosted engine often exceed 100 hp/L , compared to average naturall y aspirated engine power densities of roughl y 70 hp/L. As a result, engines can be downsized roughl y 30 percent or higher while maintaining similar peak output levels. In the last decade, improvements to turbocharger turbine and compressor design have improved their reliability and performance across the entire engine operating range. New variable geometry turbines and ball -bearing center cartridges allow faster turbocharger spool -up (virtually eliminating the once - common “turbo lag”) while maintaining high flow rates for increased boost at high engine speeds. Low speed torque output has been dramaticall y improved for modern turbocharged engines. However, even with turbocharger improvements, maximum engine torque at very low engine speed conditions, for example launch

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2 - 54 from standstill, is increased less than at mid and high engine speed conditions. The potential to downsize engines may

be less on vehicles with low displacement to vehicle mass ratios for example a very

small displacement engine in a vehicle with significant curb weight, in order to provide adequate acceleration from standstill, particularly up grades or at high altitudes. Use of GDI s ys tems with turbocharged engin es and charge air cooling also reduces the fuel octane requirements for knock limited combustion and allows the use of higher compression ratios. Ford’s “Eco B oost” downsized, turbocharged GDI engines introduced on MY 2010 vehicles allow the replacement of V8 engines with V6 engines with improved in 0 - 60 mph acceleration and with fuel economy improvements of up to 12 percent. 98 

### Recently published data with advanced spray- guided injection systems and more aggressive engine downsizing targeted towards reduced fuel consumption and CO 2 

### emissions reductions indicate that the potential for reducing CO 2 

### emissions for turbocharged, downsized GDI engines may

be as much as 15 to 30 percent relative to port - fuel - injected engines. 14,15,16,17,18 

### Confidential manufacturer data suggests an incremental range of fuel consumption and CO 2 

### emission reduction of 4.8 to 7.5 percent for turbocharging and downsizing. Other publiclyavailable sources suggest a fuel consumption and CO 2 

### emission reduction of 8 to 13 percent compared to current -production naturally- aspirated engines without friction reduction or other fuel economy technologies: a joint technical paper by Bosch and Ricardo suggesting fuel economy gain of 8 to 10 percent for downsizing from a 5.7 liter port injection V8 to a 3.6 liter V6 with direct injection using a wall - guided direct injection system; 99 

### a Renault report suggesting a 11.9 percent NEDC fuel consumption gain for downsizing from a 1.4 liter port injection in - line 4 - cylinder engine to a 1.0 liter in - line 4 - cylinder engine, also with wall - guided direct injection; 100 

### and a Robert Bosch paper suggesting a 13 percent NEDC gain for downsizing to a turbocharged DI engine, again with wall - guided injection. 101 

### These reporte d fuel economy benefits show a wide range depending on the SGDI technology employed. The agencies reviewed estimates from the LD 201 7 - 20 25 final rule, the T SD , and existing public literature. The previous estimate from the MYs 201 7 - 20 25 suggested a 12 to 14 percent effectiveness improvement, which included low friction lubricant (level one), engine friction reduction (level one), DCP, DVVL and SGDI, over baseline fixed- valve engines, similar to the estimate for Ford’s EcoBoost engine, which is already in production. Additionally , the agencies anal yz ed Ricardo vehicle simulation data and the 201 5 NHTSA Technology Study for various turbocharged engine packages. Based on th e s e data, and considering the widespread nature of the public estimates, the agencies assume that turbocharging and downsizing, would provide a 16.4 percent effectiveness improvement over naturally aspirated engines as applied to Class 2b and 3 vehicles. We present cost estimates for this technolo gy in Chapter 2.12 of this draft RIA. Note that for this anal ys is we determined that this technology path is only

applicable to heavy duty applications that have operating conditions more closely associated with light duty vehicles. This includes vans des igned mainl y for cargo volume or modest payloads having similar GCWR to light duty applications. These vans cannot tow trailers heavier than similar light duty vehicles and are largel y already sharing engines of significantl y s maller displacement and cylinder count compared to heavy duty vehicles designed mainl y for trailer towing.

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## 2.5.1.9 Cooled Exhaust - Gas Recirculation Cooled exhaust gas recirculation or Boosted EGR is a combustion concept that involves utilizing EGR as a charge diluent for controlling combustion temperatures and cooling the EGR prior to its introduction to the combustion system. Higher exhaust gas resi dual levels at part load conditions reduce pumping losses for increased fuel economy. The additional charge dilution enabled b y cooled EGR reduces the incidence of knocking combustion and obviates the need for fuel enrichment at high engine power. This allows for higher boost pressure and/or compression ratio and further reduction in engine displacement and both pumping and friction losses while maintaining performance. Engines of this ty pe use GDI and both dual cam phasing and discrete variable valve li ft. The EGR systems considered in this proposal would use a dual - loop s ys tem with both high and low pressure EGR loops and dual EGR coolers. The engines would also use single - stage, variable geometry turbocharging with hi gher intake boost pressure available across a broader range of engine operation than conventional turbocharged SI engines. Such a s ys tem is estimated to be capable of an additional 3 to 5 percent effectiveness relative to a turbocharged, downsized GDIengine without cooled - EGR. The agencies have also considered a more advanced version of such a cooled EGR s ys tem that employs very high combustion pressures by using dual stage turbocharging. 

## 2.5.2 **Diesel Engines** Diesel engines in this class of vehicle have emissi ons characteristics that present challenges to meeting federal NO X 

### emissions standards. It is a significant systems - engineering challenge to maintain the fuel consumption advantage of the diesel engine while meeting U.S. emissions regulations. Fuel consumption can be negativel y impacted b y emissions reduction strategies depending on the combination of strategies employed. Emission compliance strategies for diesel vehicles sold in the U.S. are expected to include a combination of improvements of combustio n, air handling system, aftertreatment, and advanced s ys tem control optimization. These emission control strategies are being introduced on Tier 2 light- duty diesel vehicles today . Some of the engine technologies are described in the Light - Duty Vehicle Gre enhouse Gas Emission Standards and Corporate Average Fuel Economy Standards Joint Technical Support Document. 102 

### Others are from the 2010 NAS Report, Technologies and Approaches to Reducing the Fuel Consumption of Medium - and Heavy- Duty Vehicles , and the 201 5 NHTSA Technology

Study . Several key

advances in diesel technology have made it possible to reduce emissions coming from the engine prior to aftertreatment. These technologies include engine friction and parasitic loss reduction, improved fuel systems (higher injection pressure and multiple - injection capability), advanced controls and sensors to optimize combustion and emissions performance, higher EGR levels and EGR cooling to reduce NO X 

### , and advanced turbocharging s ys tems. 

## 2.5.2.1 Low Frictio n Lubricants Consistent with the discussion above for gasoline engines (see Section 2.5.1.1 ), the agencies are expecting some engine changes to accommodate low fri ction lubricants. Based on the light - duty 201 4 - 201 8 MY HD vehicle rulemaking, and previously- received confidential

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2 - 56 manufacturer data, the agencies estimated the effectiveness of low friction lubricants to be between 0 to 1 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. Based on a survey

of the current powertrains being applied to the Class 2b and 3 segment and the level of powertrain sharing with the light duty vehicle market for these vehicles, the majority of l ight heavy duty

gasoline engines in the 2014 Class 2b and 3 vehicle models are utilizing some form of low friction lubricants to achieve power and emission goals, and so this technology

is considered to be in the baseline. 

## 2.5.2.2 Engine Friction Reduction Reduce d friction in bearings, valve trains, and the piston - to - liner interface will improve efficiency . Friction reduction opportunities in the engine valve train and at its roller/tappet interfaces exist for several production engines. In virtually all production engines, the piston at its skirt/cylinder wall interface, wrist pin and oil ring/cylinder wall interface offer opportunities for friction reduction. Use of more advanced oil lubricant that could be available for production in the future may

also eventually

play a key role in reducing friction. Mechanical loads can also be reduced b y converting the water, oil, and fuel pumps in the engine from fixed displacement to variable displacement. Estimations of fuel consumption improvements due to reduced engine friction from the 201 5 NHTSA Technology Study range from 1 percent to 2 percent . The agencies believe that this range is accurate. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.2.3 Turbocharger Technology Compact two stage turbochargers can increase the boost level with wider operation range, thus improving engine thermal efficiency . Ford’s new developed 6.7L Scorpion engine features a twin - compressor turbocharger 103 

### . Cummins has also developed its own two stage turbochargers. 104 

### Itis expected that this ty pe of technology

will continue to be improved by better s ys tem matching and development of higher compressor and turbine efficiency . Based on the 201 5 NHTSA Technology Study and previously- received confidential manufacturer data, the agencies estimate the fuel consumption reduction effectiveness of this technology

to be between 2 and 3 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.2.4 Reduction of Parasitic Loads Accessories that are traditionally gear- or belt - driven by

a vehicle’s engine can be optimized and/or converted to electric power. Examples include the engine water pump, oil pump, fuel injection pump, air compressor, power- steering pump, coo ling fans, and the vehicle’s air- conditioning s ys tem which can be converted to full electricall y driven loads or an electro -

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2 - 57 mechanical arrangement that retains some mechanically connected aspects . Optimization and improved pressure regulation may signific antl y reduce the parasitic load of the water, air and fuel pumps. Electrification may result in a reduction in power demand, because electricall ypowered accessories (such as the air compressor or power steering) operate only when needed if they are electrically

powered, but they

impose a parasitic demand all the time if they are engine driven. In other cases, such as cooling fans or an engine’s water pump, electric power allows the accessory to run at speeds independent of engine speed, which can reduce p ower consumption. The 201 5 NHTSA Technology Study used a 1 to 2 percent fuel consumption reduction for diesel engine parasitic improvements. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.2.5 Aftertreatment Im provements The HD diesel pickup and van segment has largely adopted the SCR ty

pe of aftertreatment s ys tem to comply with criteria pollutant emission standards. As the experience base for SCR expands over the next few ye ars, many improvements in this aftertreatment s ys tem such as construction of the catal ys t, thermal management, and reductant optimization may result in a reduction in the amount of fuel used in the process. However, due to uncertainties with these improvements regarding the extent of current optimization and future criteria emissions obligations, the agencies are not considering aftertreatment improvements as a fuel - saving technology

in the rulemaking analysis for HD pickups and vans . 

## 2.5.3 **Drivetrain** The agencies have also reviewed the transmission technology estimates used in the light duty 2012 - 2016 MY vehicle rulemaking. In doing so, the agencies have considered or reconsidered all available sources and updated the estimates as appropriate. The section below describes each of the transmission technologies considered for this rulemaking. 

## 2.5.3.1 Automatic 8 - Speed Transmissions Manufacturers can also choose to replace 6 - speed transmissions with transmissions capable of 8 - speeds or more . Additional ratios allow for further optimization of engine operation over a wider range of conditions, but this is subject to diminishing returns as the number of speeds increases. As additional gear sets are added (which may be necessary

in some cases to achieve the higher number of ratios), additional weight and friction are introduced. Also, the additional shifting of such a transmission can be perceived as bothersome to some consumers, so manufacturers continue to develop strategies for smooth operation . As discussed in the heavy- duty 2014 - 2018 MY vehicle rulemaking along with confidential manufacturer data projected that 8 - speed transmissions could incrementall y reduce fuel consumption by

1 to 3 percent from a baseline 6 - speed automatic transmission. The SwRI report uses 2 to 3 p ercent fuel consumption reduction when replacing 6 - speed baseline automatic transmissions with improved 8 - speed automatic transmissions.

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2 - 58 The agencies reviewed and revised these effectiveness estimates based on usage and testing methods for Class 2b and 3 vehicles. The agencies estimate the effectiveness for a conversion from a 6 to 8 - speed transmission to be 2.7 percent. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.3.2 High Efficiency

Transmission For this proposal , a high efficiency transmission refers to some or all of a suite of incremental transmission improvement technologies that should be available within the 2019 to 2025 timeframe. The majority of these improvements address mechanical friction within the transmiss ion . These improvements include but are not limited to: shifting clutch technology improvements , improved kinematic design, dry sump lubrication systems, more efficient seals, bearings and clutches (reducing drag), component superfinishing and improved transmission lubricants. 

## 2.5.3.3 Electric Power Steering (EPS) Electric power steering (EPS) provides a potential reduction in CO 2 

### emissions and fuel consumption over hydraulic power steering because of reduced overall accessory loads. This eliminates the parasitic losses associated with belt - driven power steering pumps which consistently

draw load from the engine to pump hydraulic fluid through the steering actuation systems even when the wheels are not being turned. EPS is an enabler for all vehicle hy bridization technologies since it provides power steering when the engine is off. EPS may be implemented on most vehicles with a standard 12V system. Some heavier vehicles such as Class 2b and 3 may

require a higher voltage s ys tem which may add cost and complexity . The 2017 light - duty final rule estimated a one to two percent effectiveness based on the 2002 NAS report, a Sierra Research report, and confidential manufacturer data. The SwRI report estimated 0.8 percent to 1 percent effectiveness. The agencies review ed these SwRI effectiveness estimates and found them to be accurate, thus they have been retained for this propos al . We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.3.4 Improved Accessories The accessories on an engine, including the alternator, coolant and oil pumps are traditionally

mechanically- driven. A reduction in CO 2 

### emissions and fuel consumption can be realized by

driving them electrically , and only when needed (“on - demand”). Electric water pumps and el ectric fans can provide better control of engine cooling. For example, coolant flow from an electric water pump can be reduced and the radiator fan can be shut off during engine warm -up or cold ambient temperature conditions which would reduce warm -up time, reduce warm -up fuel enrichment, and reduce parasitic losses. Indirect benefit may

be obtained by

reducing the flow from the water pump electrically during the engine warm - up period, allowing the engine to heat more rapidly and thereb y

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2 - 59 reducing the f

uel enrichment needed during cold operation and warm -up of the engine. Faster oil warm -up may

also result from better management of the coolant warm -up period. Further benefit may be obtained when electrification is combined with an improved, higher effic iency engine alternator used to suppl y power to the electrified accessories . Intelligent cooling can more easil y be applied to vehicles that do not ty pically carry heavy payl oads, so larger vehicles with towing capacity present a challenge, as these vehi cles have high cooling fan loads. A 

### However, towing vehicles tend to have large cooling s ys tem capacity and flow scaled to required heat rejection levels when under full load situations such as towing at GCWR in extreme ambient conditions. During almost all other situations, this design characteristic may

result in unnecessary

energy usage for coolant pumping and heat rejection to the radiator. The agencies considered whether to include electric oil pump technology for the rulemaking. Because it is nec essary to operate the oil pump any time the engine is running, electric oil pump technology has insignificant effect on efficiency . Therefore, the agencies decided to not include electric oil pump technology . 

## 2.5.3.5 Mild H ybrid (MHEV) Mild hy brid s ys tems offer i dle - stop functionality and a limited level of regenerative braking and power assist. These s ys tems replace the conventional alternator with a belt or crank driven starter/alternator and may add high voltage electrical accessories (which may include electric power steering and an auxiliary automatic transmission pump). The limited electrical requirements of these s ys tems allow the use of lead- acid batteries or supercapacitors for energy storage, or the use of a small lithium - ion battery pack. For the MHEV technology the agencies sized the system using a 7 kW starter/generator and 8 kWh Li - ion battery pack. The estimates were developed b y Argonne National Laboratory as a supplement to the 201 5 NHTSA Technology Study, resulting in an effectiv eness range of 4 to 5 percent depending on the vehicle’s engine . We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.3.6 Strong H yb rid (SHEV) A hy brid vehicle is a vehicle that combines two significant sources of propulsion energy, where one uses a consumable fuel (like gasoline), and one is rechargeable (during operation, or by another energy

source). Hy

brid technology

is well established in the U.S. market and more manufacturers are adding hy brid models to their lineups. Hy bri ds reduce fuel consumption through three major mechanisms:  The internal combustion engine can be optimized (through downsizing, modifying the operating cycle, or other control techniques) to operate at or near its most efficient

A In the CAFE model, improved accessories refers solely to improved engine cooling. However, EPA has included a high efficiency alternator in this category, as well as improvements to the cooling system.

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2 - 60 point more of the time. Po wer loss from engine downsizing can be mitigated by employing power assist from the secondary power source.  Some of the energy

normally lost as heat while braking can be captured and stored in the energy

storage s ys tem for later use.  The engine is turned off when it is not needed, such as when the vehicle is coasting or when stopped. Hy brid vehicles utilize some combination of the three above mechanisms to reduce fuel consumption and CO 2 

### emissions. The effectiveness of fuel consumption and CO 2 

### reduction depends on the utilization of the above mechanisms and how aggressivel y they are pursued. One area where this variation is particularl y prevalent is in the choice of engine size and its effect on balancing fuel economy and performance. Some manufacturers choose not to downsize the engine when applying hybrid technologies. In these cases, performance is vastly improved, while fuel efficiency

improves significantl y less than if the engine was downsized to maintain the same performance as the conventional version. The non - downsizing approach is used for vehicles like trucks where towing and/or hauling are an integral part of their performance requirements. In these cases, if the engine is downsized, the battery can be quickly drained during a long hill climb with a heavy load, leaving onl y a downsized engine to carry the entire load. Because towing capability is currently

a heavily- marketed truck attribute, manufacturers are hesitant to offer a truck with downsized engine which can lead to a significantly diminished towing performance when the battery state of charge level is low, and therefore engines are traditionally

not downsized for these vehicles. Strong Hy

brid technology

utilizes an axial electric motor connected to the transmission input shaft and co nnected to the engine crankshaft through a clutch. The axial motor is a motor/generator that can provide sufficient torque for launch assist, all electric operation, and the ability to recover significant levels of braking energy . For SHEV, the agencies also relied on the study by Argonne National Laboratory to supplement the 201 5 NHTSA Technology Study to determine that the effectiveness of these systems in terms of CO 2 

### reduction . For the S HEV technology the agencies sized the system using a 50 kW starter/generator and a70 kWh Li - ion battery pack. The estimates resulted in an effectiveness range of 18 to 22 percent depending on the engine. The estimates assume no engine downsizing in order to maintain vehicle performance and/or maintain towing and hauling performance. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.4 **Aerodynamics** Aerodynamic drag is an important aspect of the power requirements for Class 2b and 3 trucks. Because aerodyn amic drag is a function of the cube of vehicle speed, small changes in the aerodyn amics of a Class 2b and 3 can reduce drag, fuel consumption, and GHG emissions. Some of the opportunities to reduce aerodyn amic drag in Class 2b and 3 vehicles are similar to those in Class 1 and 2 ( i.e. , light - duty) vehicles. In general, these transferable features make the

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2 - 61 cab shape more aerodynamic by streamlining the airflow over the bumper, grill, windshield, sides, and roof. Class 2b and 3 v ehicles may also borrow from light - duty vehicles certain drag reducing accessories ( e.g. , streamlined mirrors, operator steps, and sun visors). The great variety of applications for Class 2b and 3 trucks result in a wide range of operational speed profile s ( i.e. , in -use drive cycles) and functional requirements ( e.g. , shuttle buses that must be tall enough for standing passengers, trucks that must have racks for ladders). This variety makes it challenging to develop aerodyn amic solutions that consider the entire vehicle. Many factors affect a vehicle’s aerody namic drag and the resulting power required to move it through the air. While these factors change with air density and the square and cube of vehicle speed, respectively , the overall drag effect is determined b y the product of its frontal area and drag coefficient. Reductions in these quantities can therefore reduce fuel consumption and CO 2 

### emissions. Although frontal areas tend to be relativel y similar within a vehicle class (mostly due to market - c ompetitive size requirements), significant variations in drag coefficient can be observed. Significant changes to a vehicle’s aerodyn amic performance may need to be implemented during a redesign ( e.g. , changes in vehicle shape). However, shorter- term aerody namic reductions, with a somewhat lower effectiveness, may be achieved through the use of revised exterior components (ty pically at a model refresh in mid- cycle) and add- on devices that are currentl y being applied. The latter list would include revised front and rear fascias, modified front air dams and rear valances, addition of rear deck lips and underbody panels, and lower aerodynamic drag exterior mirrors. For this proposal, the agencies considered two levels of aero improvements. The first level includes such body features as air dams, tire spats, and perhaps one underbody panel resulting in a 5 percent aerodynamic drag reduction. The agencies estimated the CO 2 

### and fuel consumption effectiveness of this first level of aerody namic drag at 0.75 perc ent . The second level which includes the features of level 1 plus additional body features such as active grille shutters B 

### , rear visors, larger under body panels or low -profile roof racks resulting in a 10 percent aerodynamic drag reduction. The agencies estimated the CO 2 

### and fuel consumption effectiveness of this second level of aerodynamic drag at 1.5 percent . We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.5 **Tires** Ty pically , tires used on Class 2b/3 vehicles are not designed specifically for the vehicle. These tires are designed for broader use and no single parameter is optimized. Similar to vocational vehicles, the market has not demanded tires with improved rolling resistance thus far; therefore, manufacturers have not traditionally designed tires with low rolling resistance for Class 2b/3 vehicles. The agencies believe that a regulatory program that incentivizes the optimization of tire rolling resistance, traction and durability can bring about GHG emission and fuel consumption reductions of 1.1 percent from this segment based on a 10 percent reduction in rolling resistance.

B For details on how

active aerodynamics are considered for off - cycle credits, see TSD Chapter 5.2.2.

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2 - 62 We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.5.6 **Mass Reduction** Mass reduction is a technology that can be used in a manufacturer’s strategy to meet the Heavy Duty Greenhouse Gas Phase 2 standards. Vehicle mass reduction (also referred to as “down - weighting” or ‘light - weighting”), decreases fuel consumption and GHG emissions by reducing the energy

demand needed to overcome inertia forces, and rolling resistance. Automotive companies have worked with mass reduction technologies for many ye ars and a lot of these technologies have been used in production vehicles. The weight savings achieved b y adopting mass reduction technologies offset weight gains due to increased vehicle size, larger powertrains, and increased feature content (sound insulation, entertainment systems, improved climate control, panoramic roof, etc.). Sometimes mass reduction has been used to increase vehicle towing and payload capabilities. Manufacturers emplo y a systematic approach to mass reduction, where the net mass reduction is the addition of a direct component or system mass reduction, also referred to as primary mass reduction, plus the additional mass reduction taken from indirect ancillary s ys tems and components, also referred to as secondary mass reduction or mass compounding. There are more secondary

mass reductions achievable for light - duty vehicles compared to heavy- duty vehicles, which are limited due to the higher towing and payload requirements for these vehicles. Mass reduction can be achieved through a number of approaches, even while maintaining other vehicle functionalities. As summarized by NAS in its 2011 light duty vehicle report, there are two key

strategies for primary

mass reduction: 1) changing the design to use less material; 2) substituting lighter materials for heavier materials. 105 

### The first key

strategy of using les s material compared to the baseline component can be achieved b y optimizing the design and structure of vehicle components, systems and vehicle structure. Vehicle manufacturers have long used these continuall y- improving CAE tools to optimize vehicle designs. For example, the Future Steel Vehicle (FSV) project sponsored b y WorldAutoSteel used three levels of optimization: topology optimization, low fidelity 3G (Geometry

Grade and Gauge) optimization, and subsystem optimization, to achieve 30 percent mass reduction in the body structure of a vehicle with a mild steel unibody structure. 106 

### Using less material can also be achieved through improving the manufacturing process, such as b y using improved joining technologies and parts consolidation. This method is often used in combination with applying new materials. The second key

strategy to reduce mass of an assembly or component involves the substitution of lower density and/or higher strength materials. Material substitution includes replacing materials, such as mild steel, with higher - strength and advanced steels, aluminum, magnesium, and composite materials. In practice, material substitution tends to be quite specific to the manufacturer and situation. Some materials work better than others for particula r vehicle components, and a manufacturer may invest more heavily

in adjusting to a particular type of advanced material, thus complicating its ability to consider others. The agencies recognize that like any typ e of mass reduction, material substitution h as to be conducted not only with consideration to maintaining equivalent component strength, but also to maintaining all the other

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2 - 63 attributes of that component, system or vehicle, such as crashworthiness, durability , and noise, vibration and harshness (NVH ). If vehicle mass is reduced sufficiently through application of the two primary strategies of using less material and material substitution described above, secondary mass reduction options may

become available. Secondary mass reduction is enabled when the load requirements of a component are reduced as a result of primary mass reduction. If the primary mass reduction reaches a sufficient level, a manufacturer may use a smaller, lighter, and potentially more efficient powertrain while maintaining vehicl e acceleration performance. If a powertrain is downsized, a portion of the mass reduction may be attributed to the reduced torque requirement which results from the lower vehicle mass. The lower torque requirement enables a reduction in engine displacement, changes to transmission torque converter and gear ratios, and changes to final drive gear ratio. The reduced powertrain torque enables the downsizing and/or mass reduction of powertrain components and accompanying reduced rotating mass (e.g., for trans mission, driveshafts/halfshafts, wheels, and tires) without sacrificing powertrain durability . Likewise, the combined mass reductions of the engine, drivetrain, and body in turn reduce stresses on the suspension components, steering components, wheels, tires, and brakes, which can allow further reductions in the mass of these subsystems. Reducing the unsprung masses such as the brakes, control arms, wheels, and tires further reduce stresses in the suspension mounting points, which allow s for further optimization and potential mass reduction. However, pickup trucks have towing and hauling requirements which must be taken into account when determining the amount of secondary mass reduction that is possible and so it is less than that of passenger cars. Ford’s MY 2015 F - 150 is one example of a light duty manufacturer who has begun producing high volume vehicles with a significant amount of mass reduction identified, specificall y 250 to 750 lb per vehicle. 107 

### The vehicle is an aluminum intensive design and includes an aluminum cab structure, body panels, and suspension components, as well as a high strength steel frame and a smaller, lighter and more efficient engine. The Executive Summary to Ducker Worldwide’s 2014 report states that state that the MY 2015 F - 150 contains 1080 pounds of aluminum with at least half of this being aluminum sheet and extrusions for body and closures. 108 

### Ford engine range for its light duty truck fleet includes a 2.7L EcoBoost V - 6. It is possible that the strategy

of aluminum body

panels would be applied to the heavy duty F - 250 and F - 350 versions when they are redesigned. 109 

### The US EPA recently

completed a multi - ye ar study with FEV North America, Inc. on the lightweighting of a light- duty pickup truck, a 2011 GMC Silverado, titled “Mass Reduction and Cost Analysis

–Li ght - Duty Pickup Trucks Model Years 2020 - 2025”. 110 

### Results contain a cost curve for various mass reduction percentages with the main solution being evaluated for a 21.4 percent (511 kg/1124 lb) mass reduction re sulting in an increased direct incremental manufacturing cost of $2228. Inaddition, the report outlines the compounding effect that occurs in a vehicle with performance requirements including hauling and towing. Secondary mass evaluation was performed o n a component level based on an overall 20 percent vehicle mass reduction. Results revealed 84 kg of the 511 kg, or 20 percent, were from secondary mass reduction. Information on this study is summarized in SAE paper 2015 - 01 - 0559. The US DOT has also spo nsored an on - going pickup truck lightweighting project. This project uses a more recent baseline vehicle, a MY 2014 GMC Silverado, and the project will be finished by earl y

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2 - 64 2016. Both projects will be utilized for the light- duty GHG Phase 2 Midterm Evaluation mass reduction baseline characterization and may be used to update assumptions of mass reduction for HD pickups and vans for the final Phase 2 rulemaking. In order to determine if technologies identified on light duty trucks are applicable to heavy- duty

pickups, the U . S . EPA also contracted with FEV North America, Inc. to perform a scaling study in order to evaluate the technologies identified for the light- duty truck would be applicable for a heavy- duty pickup truck, in this study a Silverado 2500, a Mercedes Sprinter and a Renault Master. This report is currently being drafted and will be peer reviewed and finalized between the NPRM and FRM. In general, the heavy- duty pickup truck scaling study reveals results similar to the light - duty truck study ; however , the mass reduction and cost for the Sprinter and Master were less in percent mass reduction and with much higher costs than the heavy- duty pickup truck. The specific results will be included in the final rulemaking. We present cost estimates for this technology in Chapter 2.12 of this draft RIA. 

## 2.6 **Technology Application –**  **SI Engines** This section summarizes the technologies the agencies project as a feasible path to meeting the proposed engine standards for spark- ignition engines used in vocational vehicles

– that is engines that are engine - certified and intended for vocational vehicles that will be GEM certified. These standards apply with respect to emissions measured over the FTP test cycle. This cycle is described in Chapter 3.1. See Chapter 2.5 f or spark- ignited engine technologies projected for the proposed Phase 2 HD pickup and van vehicle standards. Heavy- duty spark- ignited (SI) engines are used in almost 30 percent of vocational vehicle s . Operators that choose gasoline engines do so for reasons similar to those for HD complete pickups and vans. Gasoline engines have the advantage of being less expensive and lower weight than diesels, but tend to also be less durable and have higher fuel consumption. Thus, gasoline engines are most like ly to be purchased for applications with lower annual VMT, where fuel costs are less important than upfront costs. Today some SI -powered vocational vehicles are sold as incomplete vehicles by a verticall y integrated chassis manufacturer, where the Phase 1 rules allow manufacturers to choose to certify

incomplete vehicles with weight ratings between 8,501 and 14,000 lbs GVWR as vocational vehicles under the GEM certification procedures including sepa rate engine GHG certification , if the engine is also engine - certified for criteria pollutants . C 

### Inthis case, vertically integrated means both the engine and chassis are manufactured b y the same entity. In Phase 1 we generally required that vehicles that are chassis - certified for criteria pollutants be chassis - certified for GHGs and fuel consumption, and likewise that vehicles with engines certified for criteria pollutants (which in this case would be engines installed in vocational vehicles exclusively) be certified to the vocational vehicle standards for GHGs and fuel consumption, with minor exceptions. We believe that this approach involving consistent

C See 76 FR 57106 (September 15, 2011) and 40 CFR 1037.104(f)

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2 - 65 chassis - and engine - certification for criteria pollutants and GHG’s is the most sensible way to structure a program to minimize both the testing burden and the potential for gaming. There is a Phase 1 optional provision that allows manufacturers to certify Class 4 or 5 (14,001 to 19,500 lb GVWR) complete or incomplete vehicles to be chassis certified and thereb y included within the Class 2b/3 fleet average . D 

### In Section XIV of the preamble to this rulemaking, EPA is requesting comment on some specific issues related to chassis certification of vehicles over 14,000 lbs GVWR for criteria pollutants. As adopted in Phase 1 , the engines in these vehicles must be engine - certified for criteria pollutants, but the manufacturers may include the vehicles in their fleet average standard and annual compliance GHG calculations, using the same certification and compliance provisions as for the lighter vehicles. Such v ehicles are not required to meet the vocational vehicle standards. Because sales volumes of Class 4 and 5 trucks are relativel y small, and because we expect these Class 4 and 5 and Class 2b and 3 trucks to generall y use the same technologies and face roughly the same technology

challenge in meeting their standards targets, we do not believe that this provision dilutes the stringency of the fleet average standards. Another, less common way that SI -powered vocational vehicles are built is by a non integrated chassis manufacturer purchasing an engine from a company that also produces complete and/or incomplete HD pickup trucks and vans. The Phase 1 program allows SIengine manufacturers to sell these so - called “loose” SI engines to other chassis manufacturers for use in vocational vehicles . The primary certification path designed in the Phase 1 program in this scenario is for the “loose” engin e to be engine certified and the vehicle to be GEM certified under the GHG rules. This is common practice for CIengines, and in Phase 2 the agencies propose to continue this as the primary certification path for SI engines intended for vocational vehicles. In Phase 1 we adopted a special provision aimed at simplifying compliance for manufacturers of complete HD pickups and vans that also sell a relativel y s mall number of loose engines. This flexibility

provision enables these manufacturers to avoid meeting the separate SI engine standard, instead averaging them into the applicable HD pickup and van fleet- wide average. E 

### Lo ose engine sales account for the vast majority of CI -powered vocational vehicles, but represent a very

small fraction of the SI -powered vocational vehicle market. The SI engines certified and sold as loose engines into the heavy- duty vocational vehicle market are typicall y large V8 and V10 engines produced b y General Motors and Ford. The number of engine families certified in the past for this segment of vehicles is very limited and has ranged between three and five engine models. F 

### Unlike the heavy- duty diesel engines typical of this segment that are built for vocational vehicles, these SI engines are primarily developed for chassis - certified heavy- duty pickup trucks and vans, but are also installed in incomplete vocational vehicles.

D See 76 FR 57259 - 57260, September 15, 2011 and 78 FR 36374, June 17, 2013 E See 4 0 CFR 10 37.150(m) and 49 CFR 535.5(a)(7). F See EPA’s heavy - duty

engine certification database at http://www.epa.gov/otaq/certdata.htm#largeng .

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2 - 66 Under this special Phase 1 provision, these loose engines need not be certified to engine based GHG and fuel consumption standards, but instead may be treated under the regulations as though they are additional sales of the manufacturer’s complete pickup and van products, on a one - for - one basis. The pickup/van vehicle so chosen must be the vehicle with the highest emission test weight that uses the engine (as this vehicle is likely to have the highest GHG emissions and fuel consumption). G 

### However, if this vehicle is a credit - generator under the HD pickup and van fleet averaging program, no credits would be generated by these engine - as vehicle contributors to the fleet average; they would be treated as just achieving the target standard. If, on the other hand, the vehicle i s a credit -user, the appropriate number of additional credits would be needed to offset the engine - as - vehicle contributors. The purchaser of the engine would treat it as any other certified engine, and would still need to meet applicable vocational vehicl e standards for the vehicles in which the engine is installed. 

## 2.6.1 **Defining the Baseline Engines** In deriving the stringency of the proposed Phase 2 SIengine standard, the agencies first reviewed the technology

that was presumed in the MY 2010 Phase 1 baseline and the technology that was projected would be adopted to meet the MY 2016 SI engine standard, finalized as part of the Phase 1 program. Engines certified to this standard would represent a logical level at which to set a Phase 2 baseline performance level. The agencies finalized MY 2016 standards that require manufacturers to achieve a five percent reduction in CO 2 

### compared to the Phase 1 MY 2010 baseline. That MY 2010 baseline engine was described in the Phase 1 preamble at Section III.B.2.a.iii, as a naturally aspirated, overhead valve V8 engine. H 

### In deriving the stringency of the MY 2016 gasoline engine standards, the agencies projected 100 percent adoption of engine friction reduction, coupled cam phasing, and s toichiometric gasoline direct injection ( SGDI) to produce an overall five percent reduction from the reference engine, over the engine FTP test cycle. Table 2 - 4 presents the technologies projected to be present on an engine following this technology path. **Table 2**  **- 4**  **MY 2016 Technology Projection for SI Engines** 

### TECHNOLOGY ADOPTION RATE Coupled Cam Phasing 100% Engine friction reduction 100% Gasoline direct injection 100% In deciding whether to consider the above package as representing the Phase 2 baseline performance of SI engines, the agencies reviewed available certification information and G Equivalent test weight is defined at 40 CFR 1037.104(d)(11) and is determined based on a vehicle’s adjusted loaded vehicle weight as specified in 40 CFR 86.129, except that for vehicles over 14,000 pounds, this may be rounded to the nearest 500 pound increment . H See 76 FR 57231

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2 - 67 consulted with stakeholders to determine the degree to which these projections match with engines being produced today and engine product plans during the Phase 1 time frame. The agencies have learned that no SIengine manufacturer has applied SGDI to this ty pe of engine to date, though cam phasing and engine friction reduction are widel y being employed. Furthermore, no SI engine manufacturer has yet certified an engine to the future MY 2016 SI engine standard, and the agencies do not have specific information about what alternate technology

paths the manufacturers may take. Another possible method to establish a Phase 2 SIengine baseline performance level would be to assess the engines that are currently being produced for complete HD SI pickup trucks. These vehicles are powered b y engines that closely resemble engines intended for vocational vehicles. Further, cab - complete and box - delete vehicles sold into vocational applications are often derived from HD pickup truck chassis. The SI engine technologies assessed for the reference fleet for the HD pickup and van program are described in the preamble Section VI and in the draft RIA Chapter 10. As described in the draft RIA Chapter 10, vehicle m anufacturers ty

picall y offer few models (i.e. only a pickup truck and/or a cargo van) and while there are a large number of variants of each model, the degree of component sharing across the variants can make diversified technology application either economically impractical or impossible. Similarly , these manufacturer s produce a limited number of engines and tune them for slight variants in output for a variety of car and truck applications. Manufacturers limit complexity

in their engine portfolio for much the same reason as they limit complexity

in vehicle variants: they

face engineering manpower limitations, and supplier, production and s ervice costs that scale with the number of parts produced . The SIengine technologies that were considered in developing the proposed Phase 2 HD pickup truck standards and their projected adoption rates are shown in Table 2 - 5 , as taken from Table VI - 10 of the preamble. The vehicle - level technologies considered for the gasoline HD pickup truck standards and shown in Table VI - 10 are not presented here. Considering the a bove described constraints on engine technology adoption, it’s not surprising the projections for technology

packages for the Phase 2 HD pickup and van program include a limited set of SI engine technologies for HD pickup trucks.

**Table 2**  **- 5**  **CAFE Model Technology Adoption Rates for HD Gasoline Pickup Trucks**  TECHNOLOGY REFERENCE CASE a PROPOSAL (2.5% PER YEAR) b 2018 With strong

hybrids Without strong

hybrids 

### Level 1 Low friction lubricants and Engine friction reduction 100% 100% 100% Level 2 Low friction lubricants and Engine friction reductionc 

### 35 to 40% 100% 100% Cylinder deactivation (overhead valve) 8 to 9% 56% 56% Variable valve timing 0% 56% 56% Gasoline direct injection 0% 0% 56% Notes: a These values are taken from a spreadsheet file with CAFE model output, representing technology adoption rates projected in the no - action scenario. b These values are taken from Section VI.C.8, Table VI - 10 of the preamble, and represent technology adoption rates projected in the flat baseline scenario.

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2 - 68 c Level 2 friction reduction as shown here is incremental to Level 1 friction reduction. 

### In comparing the technologies and projected adoption rates in Table 2 - 4 and Table 2 - 5 , there are notable differences between what is projected for complete vehicles in MY 20 18 and what was projected for engine - certified engines in MY 2016. The CAFE model used by the agencies treats different ty pes of variable valve timing technologies as a group, so that coupled cam phasing would be included under the heading variable valve timing. The only type of variable valve timing that is feasible on an overhead valve engine is coupled cam phasing. I 

### In light of the differences in projected adoption rates of SGDI and variable valve timing, there is uncertainty about the technology pathways that may

be taken by

SI engine manufacturers in the Phase 1 time frame. Thus, the agencies have concluded that it would be more appropriate to set the Phase 2 baseline performance level equal to the Phase 1 MY 2016 engine standard, rather than a perf

ormance level representing more or less technology than is represented by

that standard. 

## 2.6.2 **Phase 2 Technology Feasibility and Effectiveness** A detailed description of many technologies potentially

available to improve the fuel efficiency of SI engines can be found above in draft RIA Chapter 2.2. In deriving the stringency of the proposed Phase 2 SIengine standard, the agencies excluded the technologies already presumed in the baseline engine (see Table 2 - 4 ), and rejected technologies not considered as part of the proposed HD pickup truck standards (see Table 2 - 5 ). The agencies hav e not identified a single SI engine technology that we believe belongs on engine - certified vocational engines that we do not also project to be used on complete heavy- duty pickups and vans. It is also important to consider how these engines will be used. Engines in pickup trucks are likel y to be driven very differently than engines in vocational vehicles. For example, a complete pickup truck may do an extensive amount of towing while vocati onal vehicles rarel y tow trailers. Further, the most popular applications for SIengines in vocational vehicles are motor homes and school buses, which each have very different driving patterns, which also differ from those of pickup trucks. The agencies believe these differences in application and intended use may lead manufacturers to offer engines that may have small differences, and that such differences would be captured by the vehicle test procedures applicable to those applications. Specificall y, c omplete HD pickups are certified using a chassis test procedure that is described in 40 CFR part 86, while vocational vehicles are certified using the GEM vehicle simulation tool described in 40 CFR part 1037. In light of the market structure described ab ove in Chapter 2.6 , when the agencies considered the feasibility of more stringent Phase 2 standards for SI vocational engines, we identified the following key questions: 1. Will there be technologies available that could reduce in -use emissions from vocational SIengines?

I See Preamble at Section VI.C.5(a)(iv)

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2 - 69 2. Would these technologies be applied to complete vehicles and carried- over to engine certified engines without a new standard? 3. Would these technologies be applied to meet the vocational vehicle standards? 4. What are the drawbacks associated with setting a technology- forcing Phase 2 standard for SI engines? With respect to the first question, the agencies have identified Level 2 lubricants, Level 2 engine friction re d

uction, and cylinder deactivation as technologies available to be considered for a Phase 2 SI engine standard. With respect to the second question, based on Table 2 - 5 , we project that these may

be applied to complete vehicles. The agencies have further determined that to the extent these technologies would be viable for complete vehicles, they would also be applied to engine - certified engines, to the extent they would not detract from performance required b y vocational vehicle owners. With resp ect to the third question, we believe that to the extent these engine technologies are viable and effective, they would be applied to meet the GEM -based standards for vocational vehicles. As described elsewhere in this proposal, the Phase 2 GEM would reco gnize engine technologies through interpolation of engine data generated by engine manufacturers and submitted to EPA and NHTSA for vehicle certification. Thus, it would be possible for cylinder deactivation to be recognized over the vocational vehicle GEM test cycles, if it were present on a vocational SIengine. Nevertheless , significant uncertainty remains about how much benefit would be provided by the identified Phase 2 candidate SI engine technologies. It is possible that the combined improvement of these technologies would be one percent or less. The degree of improvement for friction reduction is generally not cycle - dependent, but the effectiveness of cylinder deactivation is highly cycle - dependent. It appears the fourth question regarding drawback s is the most important. The agencies could propose a technology forcing standard for engine - certified SI engines based on a projection of each of these identified candidate technologies being effective for all engines. However, the agencies see value in setting the standard at a level that would not require every projected technology

to work as expected. Effectively requiring technologies to match our current projections would create the risk that the standard would not be feasible if even a single one of the technologies failed to match our projections. This risk is amplified for SI engines because of the very

limited product offerings, which provide far fewer opportunities for averaging than exist for CIengines. Given the relativel y small improvement projected, and the likelihood that most or all of this improvement would result anyway from the complete HD pickup and van standards and the vocational vehicle standard s , we do not believe such risk is justified at the engine level. Because on e of the guiding principles of the Phase 2 program is maintaining customer choice, we have a strong interest in structuring a program that would enable SIengine manufacturers to continue supplying loose engines to the vocational vehicle market. For the reasons discussed above, rather than proposing a more stringent engine standard, the agencies are propos ing to maintain the MY 2016 fuel consumption and CO 2 

### emission standards for SI engines

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2 - 70 for use in vocational vehicles : 7.06 gallon/100 bhp - hr and 627 g CO 2

### /bhp - hr , as measured over the Heavy- duty FTP engine test cycle. In the preamble Section V and the draft RIA Chapter 2.9, the agencies describe the vocational vehicle standards, including details about ways we considered SI engine technologies such as advanced friction reduction over the GEM vehicle test cycles, as part of the proposed Phase 2 vocational vehicle standards. 

## 2.7 **Technology Application and Estimated Costs –**  **CI Engines** 2.7.1 **Phase 1 Engines** For analy tical purposes, the agencies are projecting the technologies that may be used to meet the 2017 diesel engine standard. This technology package serves as a baseline for costs for this proposal. The agencies project that such engines will be equipped with an aftertreatment system which meets EPA’s 0.20 grams of NO X

### /bhp - hr standard with a selective catal ytic reduction (SCR) system along with EGR and meets the PM emissions standard with a diesel particulate filter (DPF) with active regeneration. The following discussion of technologies describes improvements over the 2017 model ye ar engine performance, unless otherwise note d. The CO 2 

### performance over the FTP as well as SET for the baseline engines were developed through manufacturer reporting of CO 2 

### in their non - GHG certification applications for 2014 model year. This data was carefully considered to ensure that the basel ine represented an engine meeting the 0.20 g/bhp - hr NO X 

### standard. For those engines that were not at this NO X 

### level or higher, the agencies derived a CO 2 

### correction factor to bring them to a 0.20 g/bhp - hr NO X 

### emissions rate. The CO 2 

### correction factor is derived based on available experimental data obtained from manufacturers and public literature. The agencies then sales - weighted the CO 2 

### performance to derive a baseline CO 2 

### performance for each engine subcategory . In order to establish baseline SET performance for the tractor engine and FTP performance for the vocational, several sources were considered. Some engine manufacturers provided the agencies with SET modal and FTP results or fuel consumption maps to represent their engine ranging from 2011 to 2 013 model year engine fuel consumption performance. As a supplement to this, complete engine map CO 2 

### data (including SET modes) acquired in EPA test cells as well as those obtained from Southwest Research Institute under the agency contract were also cons idered. Those maps are subsequentl y adjusted to represent 20 21 and 2024 model year engine maps by

using predefined technologies that are being used in current 201 4 production. In summary , the baseline CO 2 

### performance for each diesel engine category is included in Table 2 - 6 . **Table 2**  **- 6**  **Baseline CO 2**  **Perform ance (g/bhp**  **- hr)**  LHDD - FTP MHDD - FTP HHDD - FTP HHDD - SET HHDD - SET 576 576 555 4 87 460

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2 - 71 

## 2.7.2 **Individual Technology Feasibility and Cost** The cost for combustion system optimization includes costs associated with several individual technologies, specificall y, improved cylinder head, turbo efficiency improvements, EGR cooler improvements, higher pressure fuel rail, improved fuel injectors and improved pistons. The cost estimates for each of these technologies are presented in Section 2.12 of this draft RIA for heavy HD, medium HD and light HD engines, respectivel y. The agencies have included the costs of model -based control development in the research and development costs applied separately to each engine manufacturer. 

## 2.7.3 **Test Cycle Weighting** The current SET modes used for tractor engine certification in Phase 1 has relative large weighting in C speed as shown in the middle column of the following table: **Table 2**  **- 7**  **SET Modes Weighting Factors** SPEED/% LOAD WEIGHTING FACTOR IN PHASE 1 (%) PROPOSED WEIGHTING FACTOR IN PHASE 2 (% ) Idle 15 12 A, 100 8 9 B, 50 10 10 B, 75 10 10 A, 50 5 12 A, 75 5 12 A, 25 5 12 B, 100 9 9 B, 25 10 9 C, 100 8 2 C, 25 5 1 C, 75 5 1 C, 50 5 1 Total 100 100 A: 23 45 B: 39 38 C: 23 5 

### It can be seen from the above table that 23 percent weighting is in C speed, which is ty picall y in the range of 1800 rpm for HHD engine s . However, many of today’s HHD engine s do not commonly

operate in such a high speed in real world driving condition s , specificall y during cruise vehicle speed between 55 and 65 mph. The agencies received confidential business information from a few vehicle manufacturers that support thi s observation. Furthermore, one of the key technology

trends is to down speed, moving the predominant engine speed from the range of 1300 - 1400 rpm to the range of 1150 - 1200 rpm at vehicle speed of 65mph. This trend would make the predominant engine speed even further away from C speed. Therefore, it can be argued that , if the current SET weighting factors were retained in Phase 2, the test would even more poorly reflect real - world driving operations . Further, some technologies developed the standard may not be as effective over real world driving conditions, while technologies that would be more likel y to deliver real world reductions could be under -

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2 - 72 represented on the test. Accordingl y, the agencies are proposing to adjust the weighting of the various modes in the SET cycle as presented in the third column of Table 2 - 7 . As shown, the new proposed SET mode weighting basically would move most of the C weighting to A speed. It also would slightly reduce the weighting factor on the idle speed. These proposed values are based on the confidential business information obtained from vehicle manufacturers. 

## 2.7.4 **Technology Packages** The agencies assessed the impact of technologies over each of the SET modes to project an overall improvement for a tractor engine. The agencies considered improvements in parasitic and friction losses through piston designs to reduce friction, improved lubrication, and improved water pump and oil pump designs to reduce parasitic losses. The aftertreatment improvements are available through additional improvements to lower backpressure of the systems, further optimization of the engine - out NO X 

### levels, and further reduction on ammonia slop out of SCR. Improvements to the EGR system and air flow through the intake and exhaust s ys tems, along with turbochargers, can also produce engine efficiency improvements. Improvement of combustion and controls can reduce fuel consumption of the engine. Engine downsizing is part of consideration for improving efficiency , specifically when this technology is used together with down speeding. Although one of the most effective technologies to improve engine efficiency is the use of waste heat recovery (WHR) with Rankine cycle concept, the agencies do not project that this technology will have noticeable market penetration until MY 2024. The reason is that this ty

pe of WHR system involves many components that require extensive field testing to assure reliability. See Chapter 2.3.9 above . The high technology cost, longer pay

back period (if th e cost and benefit of using WHR is considered in isolation), concern about commercial acceptance (given the technology complexity, cost, concern about demurrage costs and warranty claims in early model years) again point to longer necessary lead time for introducing this technology . During the stringency development based on various technologies, the agencies received strong supports from various stakeholders, provided as many confidential business information (CBI). Table 2 - 8 lists those potential technologies together with the agencies’ estimated market penetration for tractor engine. However, as can be seen from this table, the agencies would not be able to release the more detailed numbers along each mode of 13 SET modes to justify

our stringency

proposal due to nature of CBI. It should be pointed out that the stringency

developed in Table 2 - 8 is based on the new proposed reweighting SET factors. With respect to market penetration, the agencies use the current market information and literature values to project what would be in the time frame beyond 202 1. For example, only Daimler uses turbo - compound in their DD15 and DD16 engines currentl y . However, they are phasing out turbo - compound with the replacement of as ymmetric turbo technology for most applications. In the meantime , Volvo ju st announced that they would put their new developed turbo - compound technology into the market. Combining both manufacturers’ market share s , the agencies estimate 5 percent market share in 2021 . With the assumption that this technology could prove to be cost effective and be accepted by market well, more production from existing manufacturers or even some of other manufacturers could adopt this technology in some of their trucks , and therefore the market share could pick up 10 percent after 2024. The agencies assume

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2 - 73 that the WHR with Rankine cycle will pick up momentum with more lead time because of the nature of high performance. However, as pointed out in Chapter 2.3.9, it would be hard to see massive production in the 2021 because of many potential issues. The agencies expect a small market penetration with one percent in 2021. Based on the industrial trend for ty pical complicated s ys tem like WHR, it would take time to have a sizeable market penetration, and therefore, it is estimated that 5 percent in 2024, and 15 percent in 2027. Excep t down sizing, all other technologies, such as parasitic/friction loss, aftertreatment, air breathing s ys tem, and combustion use the same assumption on the market penetration, such as 45 percent in 2021, 95 percent in 2024, and 100 percent in 2027. With re spect to engine downsizing, the agencies don’t expect high market penetration as others, because downsizing always has the trade - off with reliability and resale values. However, we do see the potential that this ty pe of technology

can be effective when co mbining with down speeding, specificall y when power demand drops due to more efficient engine and vehicle. It is a matter of choices. We assume 10 percent , 20 percent , and 30 percent market penetration in 2021, 2024, and 2027 respectivel y. It should be p ointed out that the technology road maps shown in Table 2 - 8 including both reduction and market penetration would be onl y one of many paths manufacturers might adopt in order to achieve 1.5 percent , 3. 7 , and 4. 2 percent reduction goals in 2021 , 2024 and 2027 respectivel y . In addition, u se of 1 percent , 5 percent , and 15 percent market penetration on WHR in 2021 , 2024, and 202 7 is one of many potential paths. Considering relatively small assumed market penetration, this only translates into very

small percent improvements due to WHR. The manufacturers should be able to make up the difference or achieve the same reduction goals for 2021 , 2024 and 202 7 by

either increasing individual technology improvement factors or increasing market penetration or combination of both. **Table 2**  **- 8**  **Projected Tractor Engine Technologies and Reduction, Percent Improvements Beyond Phase 1,**  **2017 Engine as Baseline** SET MODE SET WEIGH T ED REDUCTION (%) 2020 - 2027 MARKET

PENETRATION (2021) MARKET

PENETRATION (2024) MARKET

PENETRATION (2027) Turbo compound with clutch 1.8 % 5% 10% 10% WHR (Rankine cycle) 3.6 % 1% 5% 15% Parasitic/Friction (Cyl Kits, pum ps, FIE), lubrication 1.4 % 45% 95% 100% Aftertreatment (lower dP) 0.6% 45% 95% 100% EGR/Intake & exhaust manifolds/Turbo /VVT/Ports 1.1% 45% 95% 100% Com bustion/FI/Control 1.1 % 45% 95% 100% Downsizing 0.3 % 10% 20% 30% Weighted reduction (%) 1.5% 3. 7 % 4. 2 % 

### For the vocational engines, the agencies considered the same technology package developed for the HHD diesel engines as for the LHD diesel and MHD diesel engines. Similar to tractor engines, the package includes parasitic and friction reduction, improved lubrication, aftertreatment improvements, EGR system and air flow improvements, and combustion improvement. However, WHR technology is not part of the package. The reason is that WHR is

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2 - 74 not as efficient in transient mode, and since this is the principal operating mode for vocational vehicles, we project limited benefit for using WHR for vocational applications . Table 2 - 9 below lists those potential technologies together with the agencies’ estimated market penetration for vocational engines, which is developed b y combining the vari ous CBI data with the agencies’ engineering judgment. The market penetration estimate shown in this table use s the same principl e as the one discussed in the tractor engine. In terms of effectiveness, the model based control would be one of the most effective technologies . However, it would take significant efforts to develop it and put into production, such as neural network approach developed by Daimler 19 , 20 

### , becaus e one of the issues is that it is still not clear how this type of technology interact with on -board diagnostics (OBD). Therefore, we expect 25 percent market penetration in 2021, 30 percent in 2024, and finally

40 percent in 2027. In contrast, all other technologies, such as parasitic/friction, air breathing s ys tem, aftertreatment, and combustion are relatively more mature than the model based control, and therefore, higher market penetration is assumed. **Table 2**  **- 9**  **Projected Vocational Engine Technologies and Reduction, Percent Improvem**  **ents Beyond Phase 1, 2017 Engine as Baseline**  TECHNOLOGY GHG EMISSIONS REDUCTION 2020 - 2027 MARKET

PENETRATION 2021 MARKET

PENETRATION 2024 MARKET

PENETRATION 2027 Model based control 2.0% 25% 30% 40% Parasitic /Friction 1.5% 60% 90% 100% EGR/Air/VVT /Turbo 1.0% 50% 90% 100% Im proved AT 0.5% 50% 90% 100% Com bustion Optimization 1.0% 50% 90% 100% Weighted reduction (%) - L/M/HHD 2.0% 3.5% 4.0% 

## 2.7.5 **2021 Model Year HHD Diesel Engine Package for Tractor** As can be seen from Table 2 - 8 the weighted reduction for a MY2021 tractor engine is 1.5 percent. With this reduction, the numerical stringency values for 2021 can be derived from the Phase 1 rule s . These proposed standards are shown in Table 2 - 10 . **Table 2**  **- 10**  **2021 Model Year Proposed Standards –**  **Tractors** MHDD - SET HHD D - SET CO 2 Emissions (g CO 2/bhp - hr) 4 79 453 Fuel Consumption (gal/100 bhp -hr) 4. 71 4.45 

### The cost estimates for the complete HHD diesel engine packages can be developed accordingl y as shown in Table 2 - 11 .

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2 - 75 **Table 2**  **- 11**  **Technology Costs as Applied in Expected Packages for MY2021 Tractor Diesel Engines under the** 

**Preferred Alternative relative to the Less Dynamic Baseline**  **(2012$) a**  MEDIUM HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $ 7 $ 7 Valve Actuation $ 82 $ 82 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $3 $3 Turbocharger (improved efficiency) $ 9 $ 9 Turbo Compounding $50 $50 EGR Cooler (improved efficiency) $2 $2 Water Pump (optimized, variable vane, variable speed) $4 3 $4 3 Oil Pump (optimized) $2 $2 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $2 $2 Fuel Rail (higher working pressure) $5 $5 Fuel Injector (optimized, improved multiple event control, higher working pressure) $ 5 $ 5 Piston (reduced friction skirt, ring and pin) $1 $1 Valve Train (reduced friction, roller tappet) $ 39 $ 39 Waste Heat Recovery $ 105 $ 105 “Right sized” engine - $40 - $40 Total $ 314 $ 314 Note: a Costs presented here include application rates. 

## 2.7.6 **2021 Model Year LHD/MHD/HHD Diesel Engine Package for Vocational**  **Vehicles** From Table 2 - 9 , the proposed weighted reduction for 2021 model years of all LHD/MHD/HHD vocational diesel engines is 2.0 percent. Table 2 - 12 list s the numerical stringency

values in 2021 model year.

**Table 2**  **- 12**  **2021 Model Year Proposed Standards --**  **Vocational** LHDD - FTP MHDD -

FTP HHDD -

FTP CO 2 Emissions (g CO 2/bhp - hr) 56 5 56 5 544 Fuel Consumption (gal/100 bhp -hr) 5.5 5 5.5 5 5.34 

### The cost estimates for the MY2021 vocational diesel engines are shown in Tab le 2 - 13 . We present technology

cost estimates along with adoption rates in Chapter 2.12 of this draft RIA. We present package cost estimates in greater detail in Chapter 2.13 of this draft RIA.

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2 - 76 **Tab le**  **2 -**  **13 Technology Costs as Applied in Expected Packages for MY2021 Vocational Diesel Engines**  **under**

**the Preferred Alternative relative to the Less Dynamic Baseline (2012$)**  **a** LIGHT HD MEDIUM

HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $8 $8 $8 Valve Actuation $91 $91 $91 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $6 $3 $3 Turbocharger (improved efficiency) $10 $10 $10 EGR Cooler (improved efficiency) $2 $2 $2 Water Pump (optimized, variable vane, variable speed) $ 57 $ 57 $ 57 Oil Pump (optimized) $ 3 $ 3 $ 3 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $ 3 $ 3 $ 3 Fuel Rail (higher wo rking pressure) $ 7 $ 6 $ 6 Fuel Injector (optimized, improved multiple event control, higher working pressure) $8 $6 $6 Piston (reduced friction skirt, ring and pin) $1 $1 $1 Valve Train (reduced friction, roller tappet) $ 69 $ 52 $ 52 Model Based Controls $2 8 $2 8 $2 8 Total $ 293 $ 270 $ 270 Note: a Costs presented here include application rates. 

## 2.7.7 **2024 Model Year HHDD Engine Package for Tractor** The agencies assessed the impact of technologies over each of the SET modes to project an overall improvement in the 2024 model year. The agencies considered additional improvements in the technologies included in the 2021 model year package. Compared to 2021 technology

package, the technology

package in 2024 considers higher market adoption as shown in Table 2 - 8 , thus deriving the stringency at 3. 7 percent. Table 2 - 14 below shows the proposed 2024 model year tractor engine standards. **Table 2**  **- 14**  **2024 Model Year Proposed Standards –**  **Tractors** MHDD - SET HHDD - SET CO 2 Emissions (g CO 2/bhp - hr) 4 69 44 3 Fuel Consumption (gal/100 bhp -hr) 4. 61 4.3 5 

### The costs for the MY2024 tractor diesel engines are shown in Table 2 - 15 . We present technology

cost estimates along with adoption rates in Chapter 2.12 of this draft RIA. We present package cost estimates in greater detail in Chapter 2.13 of this draft RIA.

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2 - 77 **Table 2**  **- 15**  **Technology Costs as Applied in Expected Packages for MY2024 Tractor Diesel Engines**  **under the**

**Preferred Alternative relative to the Less Dynamic Baseline (2012$)**  **a** MEDIUM HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $1 4 $1 4 Valve Actuation $1 66 $1 66 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $6 $6 Turbocharger (improved efficiency) $1 7 $1 7 Turbo Compounding $ 92 $ 92 EGR Cooler (improved efficiency) $3 $3 Water Pump (optimized, variable vane, variable speed) $ 84 $ 84 Oil Pump (optimized) $4 $4 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $4 $4 Fuel Rail (higher working pressure) $9 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $10 $10 Piston (reduced friction skirt, ring and pin) $ 3 $ 3 Valve Train (reduced friction, roller tappet) $7 5 $7 5 Waste Heat Recovery $ 502 $ 502 “Right sized” engine - $85 - $85 Total $ 904 $ 904 Note: a Costs presented here include application rates. 

## 2.7.8 **2024 Model Year LHD/MHD/HHD Diesel Engine Package for**  **Vocational Vehicles**  The agencies developed the 2024 model year LHD/MHD/HHD diesel engine package based on additional improvements in the technologies included in the 2021 model year package as shown in Table 2 - 9 . The projected impact of these technologies provides an overall reduction of 3.5 percent over the 2017 model year baseline. Table 2 - 16 below shows the proposed 2024 model year standards in numerical values. **Table 2**  **- 16**  **2024 Model Year Proposed Standards –**  **Vocational** LHDD - FTP MHDD -

FTP HHDD -

FTP CO 2 Emissions (g CO 2/bhp - hr) 556 556 536 Fuel Consumption (gal/100 bhp -hr) 5.46 5.46 5.26 

### Costs for MY 2024 vocational diesel engines are shown in Tab le 2 - 17 . We present technology

cost estimates along with adoption rates in Chapter 2.12 of this draft RIA. We present package cost estimates in greater detail in Cha p ter 2.13 of this draft RIA.

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2 - 78 **Tab le**  **2 -**  **17 Technology Costs as Applied in Expected Packages for MY2024 Vocational Diesel Engines**  **under**

**the Preferred Alternative relative to the Less Dynamic Baseline (2012$)**  **a** LIGHT HD MEDIUM

HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $13 $13 $13 Valve Actuation $157 $157 $157 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $10 $6 $6 Turbocharger (improved efficiency) $16 $16 $16 EGR Cooler (improved efficiency) $3 $3 $3 Water Pump (optimized, variable vane, variable speed) $79 $79 $79 Oil Pump (optimized) $4 $4 $4 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $4 $4 $4 Fuel Rail (higher wo rking pressure) $10 $9 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $13 $10 $10 Piston (reduced friction skirt, ring and pin) $2 $2 $2 Valve Train (reduced friction, roller tappet) $95 $71 $71 Model Based Controls $3 1 $3 1 $3 1 Total $4 37 $4 05 $4 05 Note: a Costs presented here include application rates. 

## 2.7.9 **2027 Model Year HHDD Engine Package for Tractor**  The agencies assessed the impact of technologies over each of the SET modes to project an overall improvement in the 2027 model year. The agencies considered additional improvements in the technologies included in the 2021 model year package. Compared to 2021 technology

package , the technology

package in 2027 considers higher market adoption as shown in Table 2 - 8 , thus deriving the stringency at 4. 2 percent. Table 2 - 18 below shows the proposed 2027 model year tractor engine standards. **Table 2**  **- 18**  **2027 Model Year Proposed Standards**  **– Tractors**  MHDD - SET HHDD - SET CO 2 Emissions (g CO 2/bhp - hr) 4 66 44 1 Fuel Consumption (gal/100 bhp -hr) 4. 58 4.3 3 

### The costs for the MY2027 tractor diesel engines are shown in Table 2 - 19 . We present technology

cost estimates along with adoption rates in Chapter 2.12 of this draft RIA. We present package cost estimates in greater detail in Chapter 2.13 of this draft RIA.

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2 - 79 **Table 2**  **- 19**  **Technology Costs as Applied in Expected Packages for MY202 7**  **Tractor Diesel E ngines**  **under the**

**Preferred Alternative relative to the Less Dynamic Baseline (2012$)**  **a** MEDIUM HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $14 $14 Valve Actuation $169 $169 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $6 $6 Turbocharger (improved efficiency) $17 $17 Turbo Compounding $87 $87 EGR Cooler (improved efficiency) $3 $3 Water Pump (optimized, variable vane, variable speed) $84 $84 Oil Pump (optimized) $4 $4 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $4 $4 Fuel Rail (higher working pressure) $9 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $10 $10 Piston (reduced friction skirt , ring and pin) $3 $3 Valve Train (reduced friction, roller tappet) $75 $75 Waste Heat Recovery $1,340 $1,340 “Right sized” engine - $127 - $127 Total $1,698 $1,698 Note: a Costs presented here include application rates. 

## 2.7.10 **202 7**  **Model Year LHD/MHD/HHD Diesel Engine Package for Vocational**  **Vehicles** The agencies developed the 202 7 model year LHD/MHD/HHD diesel engine package based on additional improvements in the technologies included in the 2021 model year package as shown in Table 2 - 9 . The projected impact of these technologies provides an overall reduction of 4.0 percent over the 2017 model year baseline. Table 2 - 20 below shows the proposed 202 7 model year standards in numerical values. **Table 2**  **- 20**  **202 7**  **Model Year Proposed Standards –**  **Vocational** LHDD - FTP MHDD - FTP HHDD - FTP CO 2 Emissions (g CO 2/bhp - hr) 5 53 5 53 5 33 Fuel Consumption (gal/100 bhp -hr) 5. 43 5. 43 5. 23 

### Costs for MY 202 7 vocational diesel engines are shown in Ta ble 2 - 21 . We present technology

cost estimates along with adoption rates in Chapter 2.12 of this draft RIA. We present package cost estimates in greater detail in Cha p ter 2.13 of this draft RIA.

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2 - 80 **Ta ble**  **2 -**  **21 Technology Costs as Applied in Expected Packages for MY202**  **7 Vocational Diesel Engines**  **under**

**the Preferred Alternative relative to the Less Dynamic Baseline (2012$)**  **a** LIGHT HD MEDIUM

HD HEAVY

HD Aftertreatment system (improved effectiveness SCR, dosing, DPF) $14 $14 $14 Valve Actuation $169 $169 $169 Cylinder Head (flow optimized, increased firing pressure, improved thermal management) $10 $6 $6 Turbocharger (improved efficiency) $17 $17 $17 EGR Cooler (improved efficiency) $3 $3 $3 Water Pump (optimized, variable vane, variable speed) $84 $84 $84 Oil Pump (optimized) $4 $4 $4 Fuel Pump (higher working pressure, increased efficiency, improved pressure regulation) $4 $4 $4 Fuel Rail (higher wo rking pressure) $11 $9 $9 Fuel Injector (optimized, improved multiple event control, higher working pressure) $13 $10 $10 Piston (reduced friction skirt, ring and pin) $3 $3 $3 Valve Train (reduced friction, roller tappet) $100 $75 $75 Model Based Controls $39 $39 $39 Total $471 $437 $437 Note: a Costs presented here include application rates. 

## 2.7.11 **HD Diesel Engine Packages under the More Stringent Alternative 4** The more stringent alternative 4 would impose new standards in MYs 2021 and 2024, with the MY2024 standards essentially equivalent to the MY2027 standards under the preferred alternative. The resultant HDD engine costs for both tractors and vocational engines in MYs 2021 and 2024 are shown in Table 2 - 22 . Note that, while the technology application rates in MY2024 under alternative 4 are essentiall y identical to those for MY2027 under alternative 3, the costs are higher under alternative 4 due to learning effects and markup changes that are estimated to have occurred by MY2027 under alternative 3. **Table 2**  **- 22**  **Technology Cos ts as Applied in Expected Packages for**  **HD Diesel Engines**  **under the More**

**Stringent Alternative 4 relative to the Less Dynamic Baseline (2012$)**  **a** MODEL YEAR MHDD

TRACTOR HHDD

TRACTOR LHDD

VOCATIONAL MHDD

VOCATIONAL HHDD

VOCATIONAL 2021 $656 $656 $372 $345 $345 2024 $1,885 $1,885 $493 $457 $457 Note: a Costs presented here include application rates. 

## 2.8 **Technology Application and Estimated Costs**  **– Tractors**  2.8.1 **Defining the Baseline Tractors**  The fuel efficiency

and CO 2 

### emissions of combination tractors vary depending on the configuration of the tractor. Many aspects of the tractor impact its performance, including the

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2 - 81 engine, transmission, drive axle, aerodynamics, and rolling resistance. For each tractor subcategory , the agencies selected a theoretical tractor to represent the average 2017 model ye ar tractor that meets the Phase 1 standards (see 76 FR 57212, September 15, 2011) . These tractors are used as baselines from which to evaluate costs and effectiveness of additional technologies and standards. The specific attributes of each tractor subcategory are listed below in Table 2 - 23 . Using these values, the agencies assessed the CO 2 

### emissions and fuel consumption performance of the proposed ba seline tractors using the proposed version of Phase 2 GEM. The results of these simulations are shown below in Table 2 - 24 . The Phase 1 2017 model year tractor standards and the baseline 2017 model year tractor results are not directly

comparable. The same set of aerody namic and tire rolling resistance technologies were used in both setting the Phase 1 standards and determining the baseline of the Phase 2 tractors. However, there are several aspects that differ. First, a new version of GEM was developed and validated to provide additional capabilities, including more refined modeling of transmissions and engines. Second, the determination of the proposed HD Phase 2 CdA value takes into account a revised test procedure, a new standard reference trailer, and wind averaged drag. In addition, the proposed HD Phase 2 version of GEM includes road grade in the 55 mph and 65 mph highway

cycles, as discussed in preamble Se ction III.E. Finally , the agencies assessed the current level of automatic engine shutdown and idle reduction technologies used by the tractor manufacturers to comply with the 2014 model year CO 2 

### and fuel consumption standards. To date, the manufacturers are meeting the 2014 model ye ar standards without the use of this technology . Therefore, the agencies are revising the baseline APU adoption rate back to 30 percent, the value used in the Phase 1 baseline. **Table 2**  **- 23**  **GEM Inputs for the Baseline Class 7 and 8 Tractor**  CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Lo w Roof Mid

Roof High Roof Lo w Roof Mid Roof High Roof Lo w Roof Mid Roof High

Roof Engine 2017 MY 11L Engine 350 HP 2017 MY

11L Engine 350 HP 2017 MY

11L Engine 350 HP 2017 MY

15L Engine 455 HP 2017 MY

15L Engine 455 HP 2017 MY

15L Engine 455 HP 2017 MY

15L Engine 455 HP 2017 MY

15L Engine 455 HP 2017 MY

15L Engine 455 HP Aerodynamics (CdA in m 2 ) 5.00 6.40 6.42 5.00 6.40 6.42 4.95 6.35 6.22 Steer Tires (CRR in kg/metric ton) 6.99 6.99 6.87 6.99 6.99 6.87 6.87 6.87 6.54 Drive Tires (CRR in kg/metric ton) 7.38 7.38 7.26 7.38 7.38 7.26 7.26 7.26 6.92 Extended Idle Reduction Adoption Rate N/A N/A N/A N/A N/A N/A 30% 30% 30% **Transmission =** 10 Speed Manual Transmission **Gear Ratios =** 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 Drive Axle Ratio = 3.70

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2 - 82 **Table 2**  **- 24**  **Class 7 and 8 Tractor Baseline CO 2**  **Emissions and Fuel Consumption** CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Lo w Roof Mid Roof High

Roof Lo w

Roof Mid Roof High Roof Lo w

Roof Mid

Roof High

Roof CO 2 (grams CO 2/ton- mile) 10 7 11 8 121 8 6 9 3 95 79 87 88 Fuel Consumption (gal/1,000 tonmile) 10. 5 11. 6 11.9 8. 4 9. 1 9.3 7.8 8.5 8.6 

### The 2017 model year baseline fuel maps in the HD Phase 2 version of GEM are different than those used in 2017 year fuel maps in the HD Phase 1 version. The baseline map in the HD Phase 2 version takes two major factors into consideration. The first is the likelihood of engine down speeding beyond the 2020 model year and the second is to make the gradient of brake specific fuel consumption rate (BSFC) around the fuel consumption sw eet spot less radical when compared to the HD P hase 1 version’s engine fuel map. Figure 2 - 11 gives an example of an engine fuel map for a 455hp rated engine.

18 3 18

3 18 3

1

8 3 18 4 18

4 18

4 18

4

1

8 4 1 8 6 18

6 18 6 18 6

1

8 6 19 0 19 0 1

9 0 19

0

1

9 0 19 3 19 3 1

9 3 19

3

1

9 3 19 6 19 6 1

9 6 1

9 6

20 3 20 3 20 3 20

3

20 3 21 8 21 8 21 8 2

1 8

23 9 23 9 23 9 18 3 

### 455 **HP / 1**  **5 L**  **: 2018**  **Ba sel**  **in e**  **BSFC (g**  **/k W-**  **hr )** 

**Engi ne**  **Speed (R**  **PM )** **T o** **r q** **u e** **( N** **m )** 



### 600 800 1000 1200 1400 1600 1800 2000 0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200

**Figure 2**  **- 11**  **2018MY 15L Engine Fuel Map**

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2 - 83 

## 2.8.2 **Defining the Proposed Tractor Technology Packages** The agencies’ assessment of the proposed technology effectiveness was developed through the use of GEM in coordination with modeling conducted b y Southwest Research Institute. The agencies developed the proposed standards through a three - step process, similar to the approach used in Phase 1. First, the agencies developed technology performance characteristics for each technology , as described below. Each technology is associated with an input parameter which in turn would be used as an input to the Phase 2 GEM simulation tool and its effectiveness thereb y modeled. Second, the agencies combined the technology performanc e levels with a projected technology adoption rate to determine the GEM inputs used to set the stringency

of the proposed standards. Third, the agencies input these parameters into Phase 2 GEM and used the output to determine the proposed CO 2 

### emissions and fuel consumption levels. All percentage improvements noted below are over the 2017 baseline tractor. 

## 2.8.2.1 Aerody

namics The aerodynamic packages are categorized as Bin I, Bin II, Bin III, Bin IV, Bin V, Bin VI , or Bin VII based on the wind averaged drag aerody namic performance determined through testing conducted b y the manufacturer. In general, the proposed CdA values for each package and tractor subcategory

were developed through EPA’s coastdown testing of tractor - trailer combinations, the 2010 NAS report, and SAE papers. 

## 2.8.2.2 Tire Rolling Resistance The proposed rolling resistance coefficient target for Phase 2 was develope d from SmartWay ’s tire testing to develop the SmartWay verification , testing a selection of tractor tires as part of the Phase 1 and Phase 2 programs, and from 2014 MY certification data. Even though the coefficient of tire rolling resistance comes in a range of values, to anal yze this range, the tire performance was evaluated at four levels determined by the agencies. The four levels are the baseline (average) from 2010, Level I and Level 2 from Phase 1, and Level 3 that achieves an additional 25 percent improvement over Level 2. The Level 1 rolling resistance performance represents the threshold used to develop SmartWay designated tires for long haul tractors. The Level 2 threshold represents an incremental step for improvements beyond today ’s SmartWay level and represents the best in class rolling resistance of the tires we tested. The Level 3 values represent the long - term rolling resistance value that Michelin predicts could be achieved in the 2025 timeframe. 111 

### The tire rolling resistance level assumed to meet the 2017 MY Phase 1 standard high roof sleeper cab is considered to be a weighted average of 10 percent baseline rolling resistance, 70 percent Level 1, and 20 percent Level 2. The tire rolling resistance to meet the 2017MY Phase 1 standards for the high roof day cab, low roof sleeper cab, and mid roof sleeper cab includes 30 percent baseline, 60 percent Level 1 and 10 percent Level 2. Finall y, the low roof day

cab 2017MY standard can be met with a weighted average rolling resistance consisting of 40 percent baseline, 50 percent Level 1, and 10 percent Level 2.

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2 - 84 

## 2.8.2.3 Idle Reduction The benefits for the extended idle reductions were developed from literature, SmartWay work, and the 2010 NAS report. Additional details regarding the comments and calcul ations are included in RIA Section 2.4. 

## 2.8.2.4 Transmission The benefits for automated manual, automatic, and dual clutch transmissions were developed from literature and from simulation modeling conducted b y Southwest Research Institute. The benefit of these transmissions is proposed to be set to a two percent improvement over a manual transmission due to the automation of the gear shifting. 

## 2.8.2.5 Drivetrain The reduction in friction due to low viscosity axle lubricants is set to 0.5 percent. 6x4 and 4x2 axle configurations lead to a 2.5 percent improvement in vehicle efficiency . Downspeeding would be as demonstrated through the Phase 2 GEM inputs of transmission gear ratio, drive axle ratio, and tire diameter. Downspeeding is projected to improve the fuel consumpti on by

1.8 percent. 

## 2.8.2.6 Accessories and Other Technologies Compared to 2017MY air conditioners, air conditioners with improved efficiency compressors could reduce CO 2 

### emissions by 0.5 percent. Improvements in accessories, such as power steering, can lead to an efficiency improvement of 1 percent over the 2017MY baseline. Based on literature information, intelligent controls such as predictive cruise control could reduce CO 2 

### emissions by two percent while automatic tire inflation systems improve fuel consumption by one percent by keeping tire rolling resistance to its optimum based on inflation pressure. 

## 2.8.2.7 Weight Reduction The weight reductions were developed from tire manufacturer information, the Aluminum Association, the Department of Energy, SABIC and TIAX. 

## 2.8.2.8 Vehicle Speed Limiter The agencies did not include vehicle speed limiters in setting the Phase 1 stringency levels. The agencies are not including vehicle speed limiters in the technolo gy package for setting the proposed standards for Class 7 and 8 tractors. 

## 2.8.2.9 Summary of Technology Performance Table 2 - 25 describes the performance levels for the range of Class 7 and 8 tractor vehicle technologies.

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2 - 85 **Table 2**  **- 25**  **Proposed Phase 2 Technology Inputs** 

### CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Low Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Engine 2021M

Y 11L Engine 350 HP 2021M

Y 11L Engine 350 HP 2021M

Y 11L Engine 350 HP 2021M

Y 15L Engine 455 HP 2021M

Y 15L Engine 455 HP 2021M

Y 15L Engine 455 HP 2021MY

15L Engine 455 HP 2021M

Y 15L Engine 455 HP 2021MY

15L Engine 455 HP Aerodynamics (CdA in m2) Bin I 5.3 6.7 7.6 5.3 6.7 7.6 5.3 6.7 7.4 Bin II 4.8 6.2 7.1 4.8 6.2 7.1 4.8 6.2 6.9 Bin III 4.3 5.7 6.5 4.3 5.7 6.5 4.3 5.7 6.3 Bin IV 4.0 5.4 5.8 4.0 5.4 5.8 4.0 5.4 5.6 Bin V 5.3 5.3 5.1 Bin VI 4.9 4.9 4.7 Bin VII 4.5 4.5 4.3 Steer Tires (CRR in kg/metric ton) Base 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 Level 1 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 Level 2 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7 Level 3 4.3 4.3 4.3 4.3 4.3 4.3 4.3 4.3 4.3 Drive Tires (CRR in kg/metric ton) Base 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2 Level 1 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0 7.0 Level 2 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 Level 3 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 4.5 Idle Reduction (% reduction) APU N/A N/A N/A N/A N/A N/A 5% 5% 5% Other N/A N/A N/A N/A N/A N/A 7% 7% 7% Transmission Type (% reduction) Manual 0% 0% 0% 0% 0% 0% 0% 0% 0% AMT 2% 2% 2% 2% 2% 2% 2% 2% 2% Auto 2% 2% 2% 2% 2% 2% 2% 2% 2% Dual Clutch 2% 2% 2% 2% 2% 2% 2% 2% 2% Driveline (% reduction) Axle Lubricant 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 6x2 or 4x2 Axle 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% Downspeed 1.8% 1.8% 1.8% 1.8% 1.8% 1.8% 1.8% 1.8% 1.8% Accessory Improvements (% reduction) A/C 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% 0.5% Electric or Mech. Access. 1% 1% 1% 1% 1% 1% 1% 1% 1%

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2 - 86 Off - Cycle Technologies (% reduction) Predictive Cruise Control 2% 2% 2% 2% 2% 2% 2% 2% 2% Automated Tire Inflation System 1% 1% 1% 1% 1% 1% 1% 1% 1% 

## 2.8.3 **Tractor Technology Adoption Rates** As explained above, tractor manufacturers often introduce major product changes together, as a package. In this manner the manufacturers can optimize their available resources, including engineering, development, manufacturing and marketing activities to create a product with multiple new features. In addition, manufacturers recognize that a vehicle design will need to remain competitive over the intended life of the design and meet future regulatory requirements. In some limited cases, manufacturers may implement an individual technology outside of a vehicle’s redesign cycle. With respect to the levels of technology adoption used to develop the proposed HD Phase 2 standards, NHTSA and EPA established technology adoption constraints. The first ty pe of constraint was established based on the application of fuel consumption and CO 2 

### emission reduction technologies into the different types of tractors. For example, extended idle reduction technologies are limited to Class 8 sleeper cabs using the assumptio n that day cabs are not used for overnight hoteling. A second type of constraint was applied to most other technologies and limited their adoption based on factors reflecting the real world operating conditions that some combination tractors encounter. This second type of constraint was applied to the aerodynamic, tire, powertrain, and vehicle speed limiter technologies. Table 2 - 26 , Table 2 - 27 and Table 2 - 28 specify the adoption rates that EPA and NHTSA used to develop the proposed standards. NHTSA and EPA believe that within each of these individual vehicle categories there are particular applications where the use of the identified technologies would be either ineffective or not technicall y feasible. The addition of ineffective technologies provides no environmental or fuel efficiency

benefit, increases costs and is not a basis upon which to set a maximum feasible improvement under 49 USC S ection 32902 (k), or appropriate under 42 U.S.C. S ection 7521 (a)(2). For example, the agencies are no t predicating the proposed standards on the use of full aerodynamic vehicle treatments on 100 percent of tractors , because we know that in many applications (for example gravel truck engaged in local aggregate delivery) the added weight of the aerodyn amic technologies would increase fuel consumption and hence CO 2 

### emissions to a greater degree than the reduction that would be accomplished from the more aerodyn amic nature of the tractor. 

## 2.8.3.1 Aerody

namics Adoption Rate The impact of aerodynamics on a tractor - trailer’s efficiency increases with vehicle speed. Therefore, the usage pattern of the vehicle will determine the benefit of various aerodynamic technologies. Sleeper cabs are often used in line haul applications and drive the majority of their

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2 - 87 miles on the highway

travelling at speeds greater than 55 mph. The industry has focused aerodynamic technology

development, including SmartWay tractors, on these ty

pes of trucks. Therefore the agencies are proposing the most aggressive aerodynamic technology app lication to this regulatory

subcategory . All of the major manufacturers today offer at least one SmartWay sleeper cab tractor model, which is represented as Bin III aerodyn amic performance. The proposed aerodynamic adoption rate for Class 8 high roof sle eper cabs in 2024 (i.e., the degree of technology

adoption on which the stringency of the proposed standard is premised) consists of 30 percent of Bin IV, 25 percent Bin V, 13 percent Bin VI, and 2 percent Bin VII reflecting our assessment of the fraction of tractors in this segment that could successfully appl y these aerodynamic packages. We believe that there is sufficient lead time to develop aerodyn amic tractors that can move the entire high roof sleeper cab aerody namic performance to be as good as or better than today ’s SmartWay designated tractors. The changes required for Bin IV and better performance reflect the kinds of improvements projected in the Department of Energy ’s SuperTruck program. That program assumes that such systems can be demonstrated on vehicles by 2017. In this case, the agencies are projecting that truck OEMs would be able to begin implementing these aerody namic technologies as earl y as 2021 MY on a limited scale. Importantly , our averaging, banking and trading provisions p rovide manufacturers with the flexibility to implement these technologies over time even though the standard changes in a single step. The aerodynamic adoption rates used to develop the proposed standards for the other tractor regulatory

categories are l ess aggressive than for the Class 8 sleeper cab high roof. Aerodynamic improvements through new tractor designs and the development of new aerodynamic components is an inherently slow and iterative process. The agencies recognize that there are tractor a

pplications which require on/off - road capability

and other truck functions which restrict the type of aerodynamic equipment applicable. We also recognize that these types of trucks spend less time at highway speeds where aerody

namic technologies have the greatest benefit. The 2002 VIUS data ranks trucks by major use. 112 

### The heavy trucks usage indicates that up to 35 percent of the trucks may be used in on/off

- road applications or heavier applications. The uses include construction (16 percent), agriculture (12 percent), waste management (5 percent), and mining (2 percent). Therefore, the agencies analyzed the technologies to evaluate the potential restrictions that would prevent 100 percent adoption of more advanced aerodyn amic technologies for all of the tractor regulatory subcategories. 

## 2.8.3.2 Low Rolling Resistance Tire Adoption Rate For the tire manufacturers to further reduce tire rolling resistance, the manufacturers must consider several performance criteria that affect tire selection. The characteristics of a tire also influence durability, traction control, vehicle handling, comfort, and retreadability . A single performance parameter can easil y be enhanced, but an optimal balance of all the criteria would require improvements in materials and tread design at a higher cost, as estimated by the agencies. Tire design requires balancing performance, since changes in design may change different performance characteristics in opposing directions. Similar to the discussion regarding lesser aerodynamic technology

application in tractor segments other than sleeper cab high roof, the agencies believe that the proposed standards should not be premised on 100 percent application of Level IV tires in all tractor segments given the potential interference with vehicle utility that could result.

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2 - 88 

## 2.8.3.3 Weight Reduction Technology Adoption Rate The agencies propose setting the 2021 through 202 7 model year tractor standards without using weight reduction as a technology to demonstrate the feasibility . The agencies view weight reduction as a technology with a high cost that offers a small benefit in the tractor sector. For example, our estimate of a 400 pound weight reduction would cost $2,050 (2012$) in MY2021, but offer a 0.3 percent reduction in fuel consumption and C O 2 

### emissions. 

## 2.8.3.4 Idle Reduction Technology Adoption Rate Idle reduction technologies provide significant reductions in fuel consumption and CO 2 

### emissions for Class 8 sleeper cabs and are available on the market today . There are several different technologies available to reduce idling. These include APUs, diesel fired heaters, and battery powered units. Our discussions with manufacturers indicate that idle technologies are sometimes installed in the factory , but it is also a common practice to have the unit s installed after the sale of the truck. We would like to continue to incentivize this practice and to do so in a manner that the emission reductions associated with idle reduction technology occur in use. Therefore, as adopted in Phase 1, we are allowing only idle emission reduction technologies which include an automatic engine shutdown (AES) with some override provisions. Inthe preamble in Section III , we request comment on other approaches that would appropriatel y quantify the reductions that would be experienced in the real world. We propose a 90 percent adoption rate for this technology for Class 8 sleeper cabs. The agencies are unaware of reasons why AES with extended idle reduction technologies could not be applied to this high fraction of tractors with a sleeper cab, except those deemed a vocational tractor, in the available lead time. The agencies are interested in extending the idle reduction benefits beyond Class 8 sleepers, including day

cabs. The agencies reviewed literature to quantify the amount of idling which is conducted outside of hoteling operations. One study , conducted by Argonne National Laboratory , identified several different types of trucks which might idle for extended amounts of time during the work day. 113 

### Idling may occur during the delivery process, queuing at loading docks or border crossings, during power take off operations, or to provide comfort during the work day . However, the study provided onl y “rough estimates” of the idle time and energy use for these vehicles. The agencies are not able to appropriatel y develop a baseline of workday idling for day

cabs and identify

the percent of this idling which could be reduced through the use of AES. 

## 2.8.3.5 Vehicle Speed Limiter Adoption Rate As adopted in Phase 1, we propose to continue the approach where vehicle speed limiters may be used as a technology

to meet the proposed standard. In setting the proposed standard, however, we assume d a zero percent adoption rate of vehicle speed limiters. Although we believe vehicle speed limiters are a simple, eas y to implement, and inexpensive technology, we want to leave the use of vehicles speed limiters to the truck purchaser. Since truck fleets purchase tractors today

with owner- set vehicle speed limiters, we considered not including VSLs in our compliance model. However, we have concluded that we should allow the use of VSLs

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2 - 89 that cannot be overridden by the operator as a means of compliance for vehicle manufacturers that wish to offer it and truck purchasers that wish to purchase the technology . In doing so, we are providing another means of meeting that standard that can lower compliance cost and provide a more optimal vehicle solution for some truck fleets. For example, a local beverage distributor may operate trucks in a distribution network of primarily local roads. Under those conditions, aerodynamic fairings used to reduce aerodyn amic drag provide little benefit due to the low vehicle speed while adding additional mass to the vehicle. A vehicle manufacturer could choose to install a VSLset at 55 mph for this customer. The resulting tractor would be optimized for its intended application and would be fully compliant with our program all at a lower cost to the ultimate tractor purchaser. J 

### As in Phase 1, we have chosen not to base the proposed standards on performance of VSL s because of concerns about how to set a realistic adoption rate that avoids unintended adverse impacts. Although we expect there will be some use of VSL, currently it is used when the fleet involved decides it is feasible and practicable and increases the overall efficiency of the freight system for that fleet operator. To date, the compliance data provided by manufacturers indicate that none of the tractor configurations include a tamper-proof VSLsetting less than 65 mph. At this point the agencies are not in a position to determine in how many additional situations use of a VSLwould result in similar benefits to overall efficiency or how many customers would be willing to accept a tamper- proof VSLsetting. We are not able at this time to quantify the potential loss in utility due to the use of VSL s. Absent this information, we cannot make a determination regarding the reasonableness of setting a standard based on a particular VSLlevel. Therefore, the agencies are not premising the proposed standards on use of VSL , and instead would continue to rely on the industry

to select VSL when circumstances are appropriate for its use. The agencies have not included either the cost or benefit due to VSL s in anal ys is of the proposed program’s costs and benefits. 

## 2.8.3.6 Summary of the Adoption Rates used to Determine the Proposed Standards Table 2 - 26 , Table 2 - 27 , and Table 2 - 28 provide the adoption rates of each technology broken down b y weight class, cab configuration, and roof height. **Table 2**  **- 26**  **Technology Adoption R ates for Class 7 and 8 Tractors for Determ** **ining the Proposed 2021 MY Standards**  

### CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Low Roof Mid Roof High

Roof Low

Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof 2021 MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100% Aerodynamics Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0%

J The agencies note that because a VSL value can be input into GEM, its benefits can be directly assessed with the mo del and off cycle credit applications therefore are not necessary even though the proposed standard is not based on performance of VSLs (i.e. VSL is an on- cycle technology) .

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2 - 90 Bin II 75% 75% 0% 75% 75% 0% 75% 75% 0% Bin III 25% 25% 40% 25% 25% 40% 25% 25% 40% Bin IV 0% 0% 35% 0% 0% 35% 0% 0% 35% Bin V 20% 20% 20% Bin VI 5% 5% 5% Bin VII 0% 0% 0% Steer Tires Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 60% 60% 60% 60% 60% 60% 60% 60% 60% Level 2 25% 25% 25% 25% 25% 25% 25% 25% 25% Level 3 10% 10% 10% 10% 10% 10% 10% 10% 10% Drive Tires Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 60% 60% 60% 60% 60% 60% 60% 60% 60% Level 2 25% 25% 25% 25% 25% 25% 25% 25% 25% Level 3 10% 10% 10% 10% 10% 10% 10% 10% 10% Extended Idle Reduction APU N/A N/A N/A N/A N/A N/A 8 0 % 8 0% 8 0% Transmission Type Manual 45% 45% 45% 45% 45% 45% 45% 45% 45% AMT 40% 40% 40% 40% 40% 40% 40% 40% 40% Auto 10% 10% 10% 10% 10% 10% 10% 10% 10% Dual Clutch 5% 5% 5% 5% 5% 5% 5% 5% 5% Driveline Axle Lubricant 20% 20% 20% 20% 20% 20% 20% 20% 20% 6x2 or 4x2 Axle 10% 10% 20% 10% 10% 20% Downspeed 20% 20% 20% 20% 20% 20% 20% 20% 20% Accessory Improvements A/C 10% 10% 10% 10% 10% 10% 10% 10% 10% Electric Access. 10% 10% 10% 10% 10% 10% 10% 10% 10% Off - Cycle Technologies Predictive Cruise Control 20% 20% 20% 20% 20% 20% 20% 20% 20% Automated Tire Inflation System 20% 20% 20% 20% 20% 20% 20% 20% 20%

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2 - 91 **Table 2**  **- 27**  **Technology Adoption Rates for Class 7 and 8 Tractors for Determ ining the Proposed 2024 MY**  **Standards** 

### CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Low Roof Mid Roof High

Roof Low

Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof 2024MY Engine Technology Package

100% 100% 100% 100% 100% 100% 100% 100% 100% Aerodynamics Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0% Bin II 60% 60% 0% 60% 60% 0% 60% 60% 0% Bin III 38% 38% 30% 38% 38% 30% 38% 38% 30% Bin IV 2% 2% 30% 2% 2% 30% 2% 2% 30% Bin V 25% 25% 25% Bin VI 13% 13% 13% Bin VII 2% 2% 2% Steer Tires Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 50% 50% 50% 50% 50% 50% 50% 50% 50% Level 2 30% 30% 30% 30% 30% 30% 30% 30% 30% Level 3 15% 15% 15% 15% 15% 15% 15% 15% 15% Drive Tires Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 50% 50% 50% 50% 50% 50% 50% 50% 50% Level 2 30% 30% 30% 30% 30% 30% 30% 30% 30% Level 3 15% 15% 15% 15% 15% 15% 15% 15% 15% Extended Idle Reduction APU N/A N/A N/A N/A N/A N/A 9 0 % 9 0 % 9 0 % Transmission Type Manual 20% 20% 20% 20% 20% 20% 20% 20% 20% AMT 50% 50% 50% 50% 50% 50% 50% 50% 50% Auto 20% 20% 20% 20% 20% 20% 20% 20% 20% Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10% Driveline Axle Lubricant 40% 40% 40% 40% 40% 40% 40% 40% 40% 6x2 or 4x2 Axle 20% 20% 60% 20% 20% 60% Downspeed 40% 40% 40% 40% 40% 40% 40% 40% 40% Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50% 

### Accessory Improvements A/C 20% 20% 20% 20% 20% 20% 20% 20% 20% Electric Access. 20% 20% 20% 20% 20% 20% 20% 20% 20% Other Technologies Predictive Cruise 40% 40% 40% 40% 40% 40% 40% 40% 40%

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2 - 92 Control Automated Tire Inflation System 40% 40% 40% 40% 40% 40% 40% 40% 40%

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2 - 93 **Table 2**  **- 28**  **Technology Adoption Rates for Class 7 and 8 Tractors for Determ ining the Proposed 2027 MY**  **Standards** CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Lo w Roof Mid

Roof High

Roof Lo w

Roof Mid

Roof High

Roof Lo w

Roof Mid

Roof High

Roof **2027 MY Engine Technology Package** 100% 100% 100% 100% 100% 100% 100% 100% 100% **Aerodynam ics**  Bin I 0% 0% 0% 0% 0% 0% 0% 0% 0% Bin II 50% 50% 0% 50% 50% 0% 50% 50% 0% Bin III 40% 40% 20% 40% 40% 20% 40% 40% 20% Bin IV 10% 10% 20% 10% 10% 20% 10% 10% 20% Bin V 35% 35% 35% Bin VI 20% 20% 20% Bin VII 5% 5% 5% **Steer Tires** Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20% Level 2 50% 50% 50% 50% 50% 50% 50% 50% 50% Level 3 25% 25% 25% 25% 25% 25% 25% 25% 25% **Drive Tires** Base 5% 5% 5% 5% 5% 5% 5% 5% 5% Level 1 20% 20% 20% 20% 20% 20% 20% 20% 20% Level 2 50% 50% 50% 50% 50% 50% 50% 50% 50% Level 3 25% 25% 25% 25% 25% 25% 25% 25% 25% **Extended Idle Reduction** APU N/A N/A N/A N/A N/A N/A 90% 90% 90% **Transmission Type** Manual 1 0% 1 0% 1 0% 1 0% 1 0% 1 0% 1 0% 1 0% 1 0% AMT 50% 50% 50% 50% 50% 50% 50% 50% 50% Auto 30% 30% 30% 30% 30% 30% 30% 30% 30% Dual Clutch 10% 10% 10% 10% 10% 10% 10% 10% 10% **Driveline** Axle Lubricant 40% 40% 40% 40% 40% 40% 40% 40% 40% 6x2 Axle 20% 20% 60% 20% 20% 60% Downspeed 60% 60% 60% 60% 60% 60% 60% 60% 60% Direct Drive 50% 50% 50% 50% 50% 50% 50% 50% 50% **Accessory Improvements** A/C 30% 30% 30% 30% 30% 30% 30% 30% 30% Electric Access. 30% 30% 30% 30% 30% 30% 30% 30% 30% **Other Technologies** Predictive Cruise Control 40% 40% 40% 40% 40% 40% 40% 40% 40% Automated 40% 40% 40% 40% 40% 40% 40% 40% 40%

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

2 - 94 Tire Inflation System 

## 2.8.4 **Derivation of the Proposed Tractor Standards**  The agencies used the technology effectiveness inputs and technology adoption rates to develop GEM inputs to derive the proposed HD Phase 2 fuel consumption and CO 2 

### emissions standards for each subcategory of Class 7 and 8 combination tractors. Note that we have anal yz ed one technology

pathway for each proposed level of stringency as required b y the Clean Air Act, but manufacturers would be free to use any combination of technology to meet the standards on average. As such, the agencies derived a scenario tractor for each subcategory by weighting the individual GEM input parameters included in Table 2 - 25 with the adoption rates in Table 2 - 26 , Table 2 - 27 , and Table 2 - 28 . For example, the proposed CdA value for a 2021MY Class 8 Sleeper Cab High Roof scenario case was derived as 40 percent times 6.3 plus 35 percent times 5.6 plus 20 percent times 5.1 plus 5 percent times 4.7, which is equal to a CdA of 5.74 m2



### . Similar calculations were made for tire rolling resistance, transmission ty pes, idle reduction, and other technologies. To account for the proposed engine standards and engine technologies, the agencies assumed a compliant engine fuel map in GEM , as described in the section below . K 

### The agencies then ran GEM with a single set of vehicle inputs, as shown in Table 2 - 30 , to derive the proposed standards for each subcategory . 

## 2.8.4.1 2021 through 2027 MY Engine Fuel Maps One of the most significant changes in the HD Phase 2 version of GEM is the allowance for manufacturers to enter their own engine fuel maps by following the test procedure described in the Chapter 3 Test Procedure section of this draft RIA. The GEM engine fuel map input file consists of three ty

pes of information in csv format. The first set of information contains the engine fueling map and includes three columns: engine speed in rpm, engine torque in Nm, and engine fueling rate in g/s. In the second set of information contains the engine full torque or lug curve in two columns: engine speed in rpm and torque in NM. The third set of information contains the motoring torque and uses the same format and units as the full load torque curve . The agencies developed default engine fuel maps for all subcategories, utilizing the same format that the manufacturers would be required to provide. Fuel maps were developed for the 2021 , 2024, and 202 7 model years by applying the technologies assumed in deriving the proposed engine standards to the 2018 baseline engine fuel maps. Those default maps are derived from multiple sources of confidential business information from different stakeholders togeth er with engineering judgment. These maps cover a total of 18 vehicles subcategories including nine tractor subcategories. We would like to point out that some of the subcategories share the same engine fuel maps. A list of all of the engine fuel maps use d in setting the

K See draft RIA C hapter 2. 7 explaining the derivation of the proposed engine standards.

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2 - 95 standards for each subcategory is given in Table 2 - 29 . The model ye ars covered b y the maps are 2021, 2024, and 2027 and are shown in Figure 2 - 12 , Figure 2 - 13 , and Figure 2 - 14 .

**Table 2**  **- 29**  **GEM Default CI Engine Fuel Maps for Tractor Vehicles**  

### REGULATORY SUBCATEGO RY ENGINE FUEL MAP Class 8 Combination Sleeper Cab - High Roof 15L - 455 HP Class 8 Combination Sleeper Cab - Mid Roof 15L - 455 HP Class 8 Combination Sleeper Cab - Low Roof 15L - 455 HP Class 8 Combination Day Cab - High Roof 15L - 455 HP Class 8 Combination Day Cab - Mid Roof 15L - 455 HP Class 8 Combination Day Cab - Low Roof 15L - 455 HP Class 7 Combination Day Cab - High Roof 11L - 350 HP Class 7 Combination Day Cab - Mid Roof 11L - 350 HP Class 7 Combination Day Cab - Low Roof 11L - 350 HP

**Figure 2**  **- 12**  **455 HP Engine**  **fuel m ap used in**  **HD Phase 2 version of GEM to Set 2021MY Standards** 

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2 - 96 **Figure 2**  **- 13**  **455 HP Engine fuel m ap used in**  **HD Phase**  **2 version of GEM to Set 2024MY Standards**

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2 - 97 **Figure 2**  **- 14**  **455 HP Engine fuel m ap used in**  **HD Phase**  **2 version of GEM to Set 2027MY Standard**

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2 - 98 **Table 2**  **- 30**  **GEM Inputs for the Proposed 2021MY Class 7 and 8 Tractor Standa**  **rd Setting** 

### CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Low Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Engine 2021MY 11L Engine 350 HP 2021MY

11L Engine 350 HP 2021MY

11L Engine 350 HP 2021MY

15L Engine 455 HP 2021MY

15L Engine 455 HP 2021MY

15L Engine 455 HP 2021MY

15L Engine 455 HP 2021MY

15L Engine 455 HP 2021MY

15L Engine 455 HP Aerodynamics (CdA in m2) 4.68 6.08 5.94 4.68 6.08 5.94 4.68 6.08 5.74 Steer Tires (CRR in kg/metric ton) 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 Drive Tires (CRR in kg/metric ton) 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 Extended Idle Reduction Weighted Effectiveness N/A N/A N/A N/A N/A N/A 2.5% 2.5% 2.5% Transmission = 10 speed Automated Manual Transmission Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 Drive axle Ratio = 3.55 6x2 Axle Disconnect Weighted Effectiveness N/A N/A N/A 0. 3 % 0. 3 % 0.5% 0. 3 % 0. 3 % 0.5% Low Friction Axle Lubrication = 0.1% Transmission benefit = 1.1% Predictive Cruise Control =0.4% Accessory Improvements = 0.1% Air Conditioner Efficiency Improvements = 0.1% Automatic Tire Inflation Systems = 0.2% Weight Reduction = 0 pounds

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2 - 99 **Table 2**  **- 31**  **GEM Inputs for the Proposed**  **2024MY Class 7 and 8 Tractor Standard Setting** 

### CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Low Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Low

Roof Mid

Roof High

Roof Engine 2024MY 11L Engine 350 HP 2024MY

11L Engine 350 HP 2024MY

11L Engine 350 HP 2024MY

15L Engine 455 HP 2024MY

15L Engine 455 HP 2024MY

15L Engine 455 HP 2024MY

15L Engine 455 HP 2024MY

15L Engine 455 HP 2024MY

15L Engine 455 HP Aerodynamics (CdA in m2) 4.59 5.99 5.74 4.59 5.99 5.74 4.59 5.99 5.54 Steer Tires (CRR in kg/metric ton) 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 Drive Tires (CRR in kg/metric ton) 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 6.2 Extended Idle Reduction Adoption Rate N/A N/A N/A N/A N/A N/A 3% 3% 3% Transmission = 10 speed Automated Manual Transmission Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73 Drive axle Ratio = 3.36 6x2 Axle Disconnect Weighted Effectiveness N/A N/A N/A 0 .5% 0 .5% 1.5% 0 .5% 0 .5% 1.5% Low Friction Axle Lubrication = 0.2% Transmission benefit = 1.8% Predictive Cruise Control =0.8% Accessory Improvements = 0.2% Air Conditioner Efficiency Improvements = 0.1% Automatic Tire Inflation Systems = 0.4% Weight Reduction = 0 pounds Direct Drive Weighted Efficiency = 1% for sleeper cabs; 0.8% for day cabs

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2 - 100 **Table 2**  **- 32**  **GEM Inputs for the Proposed 2027MY Class 7 and 8 Tractor Standard Setting**  CLASS 7 CLASS 8 Day Cab Day Cab Sleeper Cab Lo w Roof Mid

Roof High Roof Lo w Roof Mid Roof High Roof Lo w Roof Mid Roof High

Roof **Engine** 2027MY 11L Engine 350 HP 2027MY

11L Engine 350 HP 2027MY

11L Engine 350 HP 2027MY

15L Engine 455 HP 2027MY

15L Engine 455 HP 2027MY

15L Engine 455 HP 2027MY

15L Engine 455 HP 2027MY

15L Engine 455 HP 2027MY

15L Engine 455 HP **Aerodynam ics (CdA in m**  **2 )**  4.52 5.92 5.52 4.52 5.92 5.52 4.52 5.92 5.32 **Steer Tires (CRR in kg/metric ton)** 5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6 5.6 **Drive Tires (CRR in kg/metric ton)** 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 5.9 **Extended Idle Reduction Weighted Effectiveness**  N/A N/A N/A N/A N/A N/A 3% 3% 3%

**Transmission = 10 speed Autom ated Manual Transmission**  **Gear Ratios =** 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73

**Drive axle Ratio** = 3.2 **6x2 Axle Disconnect Weighted Effectiveness**  N/A N/A N/A 0.5% 0.5% 1.5% 0.5% 0.5% 1.5% **Low Friction Axle Lubrication** = 0.2% **Transmission benefit** = 1.8% **Predictive Cruise Control** =0.8% **Accessory Improvements** = 0.3% **Air Conditioner Efficiency Improvements** = 0.2% **Autom atic Tire Inflation Systems**  = 0.4% **Weight Reduction** = 0 pounds **Direct Drive Weighted Efficiency** = 1% for sleeper cabs; 0.8% for day cabs 

### The level of the 2021 , 2024, and 202 7 model year proposed standards for each subcategory

are included in Table 2 - 33 .

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2 - 101 **Table 2**  **- 33**  **Proposed 2021 , 2024,**  **and 202**  **7 Model Year Tractor Standards**  

### 2021 MODEL YEAR CO 2 

### GRAMS PER TON - MILE

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 97 78 70 Mid Roof 107 84 78 High Roof 109 86 77 2021 Model Year Gallons of Fuel per 1,000 Ton - Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 9.5285 7.5639 6.8762 Mid Roof 10.5108 8.2515 7.6621 High Roof 10.7073 8.4479 7.5639 2024 Model Year CO 2 

### Grams per Ton - Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 90 72 64 Mid Roof 100 78 71 High Roof 101 79 70 2024 Model Year and Later Gallons of Fuel per 1,000 Ton - Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 8.8409 7.0727 6.2868 Mid Roof 9.8232 7.5639 6.9745 High Roof 9.9214 7.7603 6.8762 202 7 Model Year CO 2 

### Grams per Ton - Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 87 70 62 Mid Roof 96 76 69 High Roof 96 76 67 202 7 Model Year and Later Gallons of Fuel per 1,000 Ton - Mile

Day Cab Sleeper Cab Class 7 Class 8 Class 8 Low Roof 8.5462 6.8762 6.0904 Mid Roof 9.4303 7.4656 6.7780 High Roof 9.4303 7.4656 6.5815 

## 2.8.4.2 Heavy- Haul Tractor Standards For Phase 2, the agencies propose to add a tenth subcategory to the tractor category

for heavy- haul tractors. The agencies recognize the need for manufacturers to build these ty pes of

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2 - 102 vehicles for specific applications and believe the appropriate way to p revent penalizing these vehicles is to set separate standards recognizing a heavy- haul vehicle’s unique needs, such as requiring a higher horsepower engine or different transmissions. The agencies are proposing this change in Phase 2 because unlike in Pha se 1 the engine, transmission, and drivetrain technologies are included in the technology packages used to determine the stringency of the proposed tractor standards and are included as manufacturer inputs in GEM. The agencies recognize that certain technologies used to determine the stringency of the proposed Phase 2 tractor standards are less applicable to heavy- haul tractors. Heavy- haul tractors are not typicall y used in the same manner as long - haul tractors with extended highway driving, therefore would experience less benefit from aerody namics. Aerody

namic technologies are very effective at reducing the fuel consumption and GHG emissions of tractors, but only when traveling at highway speeds. At lower speeds, the aerody namic technologies may

have a detrimental impact due to the potential of added weight. The agencies therefore are not considering the use of aerody namic technologies in the development of the proposed Phase 2 heavy- haul tractor standards. Moreover, because aerody namics would not play a role in the heavy- haul standards, the agencies propose to combine all of the heavy- haul tractor cab configurations (day

and sleeper) and roof heights (low, mid, and high) into a single heavy- haul tractor subcategory . L 

### Certain powertrain and drivetrain components are also impacted during the design of a heavy- haul tractor, including the transmission, axles, and the engine. Heavy- haul tractors ty picall y require transmissions with 13 or 18 speeds to provide the ratio spread to ensure that the tractor is able to start pulling the load from a stop. Downsped powertrains are typicall y not an option for heavy- haul operations because these vehicles require more torque to move the vehicle because of the heavier load. Finall y, due to the loading requirements of the vehicle, it is not likely that a 6x2 axle configuration can be used in heavy- haul applications. The agencies used the following heavy- haul tractor inputs for developing the proposed 2021, 2024, and 2027 MY standards, as shown in Table 2 - 34 .

L Since aerodynamic improvements are not part of the technology package, the agencies likewise are not proposing any bin structure for the heavy -haul tractor subcategory.

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2 - 103 **Table 2**  **- 34**  **GEM Inputs for Proposed 2021, 2024 and 2027 MY Heavy** **- Haul Tractor Standard**  **s HEAVY** **- HAUL TRACTOR**  **Baseline 2021MY**  **2024MY 2027MY**  Engine = 2017 MY 15L Engine with 600 HP Engine = 2021 MY 15L Engine with 600 HP Engine = 2024 MY 15L Engine with 600 HP Engine = 2027 MY 15L Engine with 600 HP Aerodynamics (CdA in m 2 ) = 5.00 Steer Tires (CRR in kg/metric ton) = 7.0 Steer Tires (CRR in kg/metric ton) = 6.2 Steer Tires (CRR in kg/metric ton) = 6.0 Steer Tires (CRR in kg/metric ton) = 5.8 Drive Tires (CRR in kg/metric ton) = 7.4 Drive Tires (CRR in kg/metric ton) = 6.6 Drive Tires (CRR in kg/metric ton) = 6.4 Drive Tires (CRR in kg/metric ton) = 6.2 Transmission = 13 speed Manual Transmission Gear Ratios = 12.29, 8.51, 6.05, 4.38, 3.20, 2.29, 1.95, 1.62, 1.38, 1.17, 1.00, 0.86, 0.73 Transmission = 13 speed Automated Manual Transmissi on Gear Ratios = 12.29, 8.51, 6.05, 4.38, 3.20, 2.29, 1.95, 1.62, 1.38, 1.17, 1.00, 0.86,

0.73 Transmission = 13 speed

Automated Manual Transmission Gear Ratios = 12.29, 8.51, 6.05, 4.38, 3.20, 2.29, 1.95, 1.62, 1.38, 1.17, 1.00, 0.86,

0.73 Transmission = 13 speed

Automated Manual Transmission Gear Ratios = 12.29, 8.51, 6.05, 4.38, 3.20, 2.29, 1.95, 1.62, 1.38, 1.17, 1.00, 0.86,

0.73 Drive axle Ratio = 3.55 Drive axle Ratio = 3.55 Drive axle Ratio = 3.55 Drive axle Ratio = 3.55 6x2 Axle Disconnect Wei ghted Effectiveness = 0% 6x2 Axle Disconnect Weighted Effectiveness =

0% 6x2 Axle Disconnect

Weighted Effectiveness = 0% Lo w Friction Axle Lubrication = 0.1% Lo w Friction Axle Lubrication = 0.2% Lo w Friction Axle Lubrication = 0.2% AMT benefit = 1.1% AMT benefit = 1.8% AMT benefit = 1.8% Predictive Cruise Control =0.4% Predictive Cruise Control =0.8% Predictive Cruise Control =0.8% Accessory Improvements =

0.1% Accessory Improvements = 0.2% Accessory Improvements = 0.3% Air Conditioner Efficiency Im provements = 0.1% Air Conditioner Efficiency Im provements = 0.1% Air Conditioner Efficiency Im provements = 0.2% Automatic Tire Inflation Systems = 0.2% Automatic Tire Inflation Systems = 0.4% Automatic Tire Inflation Systems = 0.4% Weight Reduction = 0 pounds Weight Reduction = 0 pounds Weight Reduction = 0 pounds 

### The baseline 2017 MY heavy- haul tractor would emit 57 grams of CO 2 

### per ton - mile and consume 5.6 gallons of fuel per 1,000 ton - mile. The agencies propose the heavy- haul standards shown in Table 2 - 35 . **Table 2**  **- 35**  **Proposed Heavy -**  **Haul Tractor Standards HEAVY** **- HAUL TRACTOR**  **2021 MY 2024 MY**  **2027 MY** Grams of CO 2 per Ton- Mile Standard 54 52 51 Gallons of Fuel per 1,000 Ton - Mile 5.3045 5.1081 5.010

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2 - 104 

## 2.8.4.3 Tractor Package Costs under the Preferred and Alternative Standards A summary

of the draft technology

package costs under the preferred alternative and relative to the less dynam ic baseline is included in Table 2 - 36 through Table 2 - 39 for MYs 2021, 2024, and 2027, respectively . A summary of the draft technology

package costs under alternative 4 and relative to the less dy namic baseline is included in Table 2 - 40 and Table 2 - 41 for MYs 2021 and 2024, respectivel y.

**Table 2**  **- 36**  **Class 7 and 8 Tractor Technology Increm**  **ental Costs in the 20**  **21 Model Year**  **a ,b** 

**Preferred Alternative vs. the Less Dynamic Baseline (20**  **12 $**  **per vehicle )**  

### CLASS 7 CLASS 8 Day Cab Day

Cab Sleeper Cab Low/Mid Roof High

Roof Low/ Mid Roof High

Roof Low

Roof Mid

Roof High Roof Engine c $314 $314 $314 $314 $314 $314 $314 

### Aerodynamics $687 $511 $687 $511 $656 $656 $535 

### Tires $49 $9 $81 $15 $59 $59 $15 

### Tire inflation system $180 $180 $180 $180 $180 $180 $180 

### Transmission $3,969 $3,969 $3,969 $3,969 $3,969 $3,969 $3,969 

### Axle & axle lubes $50 $50 $70 $90 $70 $70 $90 

### Idle reduction with APU $0 $0 $0 $0 $2,449 $2,449 $2,449 

### Air conditioning $45 $45 $45 $45 $45 $45 $45 

### Other vehicle technologies $174 $174 $174 $174 $174 $174 $174 

### Total $5,468 $5,252 $5,520 $5,298 $7,916 $7,916 $7,771 Notes: a Costs shown are for the 20 21 mo del year and are incremental to the costs of a tractor meeting the phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2 .12 in particular). c Engine costs are for a heavy HD diesel engine meant for a combination tractor.

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2 - 105 **Table 2**  **- 37**  **Class 7 and 8 Tractor Technology Increm**  **ental Costs in the 20**  **24 Model Year**  **a ,b** 

**Preferred Alternative vs. the Less Dynamic Baseline (20**  **12 $**  **per vehicle )**  

### CLASS 7 CLASS 8 Day Cab Day

Cab Sleeper Cab Low/Mid Roof High

Roof Low/ Mid Roof High

Roof Low

Roof Mid

Roof High Roof Engine c $904 $904 $904 $904 $904 $904 $904 

### Aerodynamics $744 $684 $744 $684 $712 $712 $723 

### Tires $47 $11 $78 $18 $58 $58 $18 

### Tire inflation system $330 $330 $330 $330 $330 $330 $330 

### Transmission $5,883 $5,883 $5,883 $5,883 $5,883 $5,883 $5,883 

### Axle & axle lubes $92 $92 $128 $200 $128 $128 $200 

### Idle reduction with APU $0 $0 $0 $0 $2,687 $2,687 $2,687 

### Air conditioning $82 $82 $82 $82 $82 $82 $82 

### Other vehicle technologies $318 $318 $318 $318 $318 $318 $318 

### Total $8,400 $8,304 $8,467 $8,419 $11,102 $11,102 $11,145 Notes: a Costs shown are for the 20 21 mo del year and are incremental to the costs of a tractor meeting the phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and ho w it im pacts technology costs for other years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indic ated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). c Engine costs are for a heavy HD diesel engine meant for a combination tractor.

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2 - 106 **Table 2**  **- 38**  **Class 7 and 8 Tractor Technology Increm**  **ental Costs in the 20**  **27 Model Year**  **a ,b** 

**Preferred Alternative vs. the Less Dynamic Baseline (20**  **12 $**  **per vehicle )**  

### CLASS 7 CLASS 8 Day Cab Day

Cab Sleeper Cab Low/Mid Roof High

Roof Low/ Mid Roof High

Roof Low

Roof Mid

Roof High Roof Engine c $1,698 $1,698 $1,698 $1,698 $1,698 $1,698 $1,698 

### Aerodynamics $771 $765 $771 $765 $733 $733 $802 

### Tires $45 $10 $75 $17 $56 $56 $17 

### Tire inflation system $314 $314 $314 $314 $314 $314 $314 

### Transmission $6,797 $6,797 $6,797 $6,797 $6,797 $6,797 $6,797 

### Axle & axle lubes $97 $97 $131 $200 $131 $131 $200 

### Idle reduction with APU $0 $0 $0 $0 $2,596 $2,596 $2,596 

### Air conditioning $117 $117 $117 $117 $117 $117 $117 

### Other vehicle technologies $302 $302 $302 $302 $302 $302 $302 

### Total $10,140 $10,099 $10,204 $10,209 $12,744 $12,744 $12,842 Notes: a Costs shown are for the 20 21 mo del year and are incremental to the costs of a tractor meeting the phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated tractor c lasses. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12 in particular). c Engine costs are for a heavy HD diesel engine meant for a combination tractor.

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2 - 107 **Table 2**  **- 39**  **Heavy -** **Haul Tractor Technology**  **Increm ental**  **Costs in the 2021, 2024, and**  **20 27**  **Model Year a**  **,b**

**Preferred Alternative vs. the Less Dynamic Baseline (20**  **12 $**  **per vehicle )**  

### 2021 MY 2024 MY 2027 MY Engine c $314 $904 $1,698 

### Tires $81 $78 $75 

### Tire inflation system $180 $330 $314 

### Transmission $3,969 $5,883 $6,797 

### Axle & axle lubes $70 $128 $200 

### Air conditioning $45 $82 $117 

### Other vehicle technologies $174 $318 $302 

### Total $4,833 $7,723 $9,503 Notes: a Costs shown are for the specified mo del year and are incremental to the costs of a tractor meeting the phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts con sidered in this analysis and how it impacts technology costs for other years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12 in particular). c Engine costs are for a heavy HD diesel engine meant for a combination tractor.

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2 - 108 **Table 2**  **- 40**  **Class 7 and 8 Tractor Technology Increm**  **ental Costs in the 20**  **21 Model Year**  **a ,b** 

**Alternative 4 vs. the Less Dynamic Bas eline**  **(20 12**  **$ per vehicle** **)** 

### CLASS 7 CLASS 8 Day Cab Day

Cab Sleeper Cab Low/Mid Roof High

Roof Low/ Mid Roof High

Roof Low

Roof Mid

Roof High Roof Engine c $656 $656 $656 $656 $656 $656 $656 

### Aerodynamics $769 $632 $769 $632 $740 $740 $665 

### Tires $50 $11 $83 $18 $61 $61 $18 

### Tire inflation system $271 $271 $271 $271 $271 $271 $271 

### Transmission $6,794 $6,794 $6,794 $6,794 $6,794 $6,794 $6,794 

### Axle & axle lubes $56 $56 $75 $95 $75 $75 $115 

### Idle reduction with APU $0 $0 $0 $0 $2,449 $2,449 $2,449 

### Air conditioning $90 $90 $90 $90 $90 $90 $90 

### Other vehicle technologies $261 $261 $261 $261 $261 $261 $261 

### Total $8,946 $8,769 $8,999 $8,816 $11,397 $11,397 $11,318 Notes: a Costs shown are for the 20 21 mo del year and are incremental to the costs of a tractor meeting the phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to Chapter 2 of the draft RIA ( see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated tractor c lasses. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA (see draft RIA 2.12 in particular). c Engine costs are for a heavy HD diesel engine meant for a combination tractor.

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2 - 109 **Table 2**  **- 41**  **Class 7 and 8 Tractor Technology Increm**  **ental Costs in the 20**  **24 Model Year**  **a ,b** 

**Alternative 4 vs. the Less Dynamic Baseline (20**  **12 $**  **per vehicle )**  

### CLASS 7 CLASS 8 Day Cab Day

Cab Sleeper Cab Low/Mid Roof High

Roof Low/ Mid Roof High

Roof Low

Roof Mid

Roof High Roof Engine c $1,885 $1,885 $1,885 $1,885 $1,885 $1,885 $1,885 

### Aerodynamics $805 $935 $805 $935 $773 $773 $997 

### Tires $50 $14 $83 $23 $63 $63 $23 

### Tire inflation system $330 $330 $330 $330 $330 $330 $330 

### Transmission $7,143 $7,143 $7,143 $7,143 $7,143 $7,143 $7,143 

### Axle & axle lubes $102 $102 $138 $210 $138 $138 $210 

### Idle reduction with APU $0 $0 $0 $0 $2,687 $2,687 $2,687 

### Air conditioning $123 $123 $123 $123 $123 $123 $123 

### Other vehicle technologies $318 $318 $318 $318 $318 $318 $318 

### Total $10,757 $10,851 $10,826 $10,968 $13,461 $13,461 $13,717 Notes: a Costs shown are for the 20 24 mo del year and are incremental to the costs of a tractor meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to Chapter 2 of the draft RIA (see draft RIA 2.12). b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated tractor c lasses. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the draft RIA ( see draft RIA 2.12 in particular). c Engine costs are for a heavy HD diesel engine meant for a combination tractor. 

## 2.9 **Technology Application and Estimated Costs**  **– Vocational Vehicles**  The agencies are analyzing nine baseline vocational vehicle configurations: one for each of the nine proposed subcategories obtained with three weight class groups and the three proposed composite duty cycles. For each configuration, some of the attributes and parameters are proposed to be fixed by the agencies and would not be available as manufacturer inputs, while some are proposed to be available to manufacturers when identifying configurations to c ertify in the model years of the proposed HD Phase 2 program. 

## 2.9.1 **Vocational Engines** This section describes the engines the agencies selected to incorporate into the baseline vehicle configurations for the nine proposed subcategories of vocational vehicles, and how we used the GEM tool to establish performance levels of these baseline vehicles. The agencies have

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2 - 110 developed models for engines that represent performance of the technologies we expect would be installed in vocational vehicles in the baseline year of 2017. A description of the technologies applied to our 2017 diesel engine models can be found above in Chapter 2.7 of this draft RIA. A description of the GEM engine simulation can be found in draft RIA Chapter 4. 

## 2.9.1.1 Baseline Vocational Engines One of th e most significant changes in the HD Phase 2 version of GEM is the provision for manufacturers to enter their own engine fuel maps by following the test procedure described in the draft RIA Chapter 3. The GEM engine fuel map input file consists of three types of input. The first is the engine fueling map and includes: engine speed in rpm, engine torque in Nm, and engine fueling rate in g/s. Second is the engine full torque or lug curve b y engine speed in rpm and torque in NM. The third is the motoring torque curve . The agencies have developed the proposed vehicle standards using engine fuel maps derived as discussed above in Chapter 2.7 for all sub - categories, utilizing the same format that the OEMs would be required to provide. Four sets of diesel engine maps cover all nine vocational vehicle regulatory

categories, as listed in Table 2 - 42 . This means that some of the subcategories share the same engine fuel map. For example, all MHD vehicles use the same 7Lengine with 270 hp rating. The 15L engine was selected for the Regional HHD subcategory because these vocational vehicles often require a similar level of power as a day cab tractor. This is the same power and displacement of the engine simulated for HHD vocational vehicles in Phase 1, and is the engine powering the Kenworth T700 reference vehicle , as described in RIA Chapter 4 and summarized in Table 4 - 2 . An 11L - 345 hp engine was selected for the HHD Multi -purpose and Urban subcategories, and is the engine powering the New Fl yer refuse truck as the applicable reference vehicle, as described in RIA Chapter 4. For these two subcategories, the agencies selected this engine because this is a more ty pical power rating for vehicles that are not long haul. For example, Volvo manufactures many vehicles that would likely be certified in these subcategories, and one product brochure describes an 11Lengine as being fitted in all their TerraPro refuse trucks and other weight - sensitive applications. 114 

### Although the displacement and horsepower rating of this engine are similar to those of the MHD engine described above in Chapter 2.8 for Class 7 tractors, the HHD vocational engine described here is very different from that MHD tractor engine, both in terms of technology and its engine certification cycle. The engine displacements and power ratings for the MHD and LHD vocational subcategories are the same as those simulated in GEM for Phase 1. The specifications for the Kenworth T270 truck and F650 tow truck that serve as reference vehicles for all MHD and LHD are shown in Table 4 - 2 of draft RIA Chapter 4.

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2 - 111 **Table 2**  **- 42**  **GEM CI Engines for Vocational Vehicles**  REGULATORY SUBCATEGO RY AND DUTY CYCLE ENGINE FUEL MAP Heavy Heavy - Duty (Class 8) Regional Duty Cycle 15L - 455 HP Heavy Heavy - Duty (Class 8) Multi - Purpose and Urban Duty Cycles 11L - 345 HP Medium Heavy - Duty (Class 6 - 7) Regional, Multi - Purpose, and Urban Duty Cycles 7L - 270 HP Light Heavy - Duty (Class 2b - 5) Regional, Multi - Purpose, and Urban Duty Cycles 7L - 200 HP 

### The 2017 baseline maps in the HD Phase 2 version of GEM are different than those used for simulating engines that would meet the MY2017 vehicle standards in the HD Phase 1 rul emaking . The baseline map in the HD Phase 2 version takes two major factors into consideration. The first is the likelihood of engine down speeding beyond the 2020 model year and the second is to make the gradient of brake specific fuel consumption rate (BSFC) around the fuel consumption sweet spot less radical when compared to the HD P hase 1 version’s engine fuel map. Figure 2 - 15 gi ves an example of an engine fuel map for a 455 hp rated CI engine, for the baseline ye ar.

18 3 18

3 18 3

1

8 3 18 4 18

4 18

4 18

4

1

8 4 1 8 6 18

6 18 6 18 6

1

8 6 19 0 19 0 1

9 0 19

0

1

9 0 19 3 19 3 1

9 3 19

3

1

9 3 19 6 19 6 1

9 6 1

9 6

20 3 20 3 20 3 20

3

20 3 21 8 21 8 21 8 2

1 8

23 9 23 9 23 9 18 3 

### 455 **HP / 1**  **5 L**  **: 2018**  **Ba sel**  **in e**  **BSFC (g**  **/k W-**  **hr )** 

**Engi ne**  **Speed (R**  **PM )** **T o** **r q** **u e** **( N** **m )** 



### 600 800 1000 1200 1400 1600 1800 2000 0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200

**Figure 2**  **- 15**  **Engine fuel m ap**  **for 455hp**  **rated CI engine used in H**  **HD Phase 2 Baseline** 

### The agencies do not have baseline fuel maps for SI engines intended for vocational vehicles. We have not obtained sufficient manufacturer data to construct a valid set of inputs that would reasonabl y represent a gasoline engine that will comply with the appl icable MY 2016 engine standard. In lieu of a SI engine map , we have approximated the performance of a

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2 - 112 baseline gasoline engine over the vocational vehicle GEM duty cycles b y applying a correction factor to the results of simulating identical vocational vehicles fitted with CIengines. This correction factor is derived using coefficients from the MY 2018 HD pickup and van Phase 1 standards for HD gasoline pickup trucks. It is appropriate to do this, because the difference in performance of chassis - certifi ed SI complete vehicles and similarly- sized CIcomplete vehicles would likely

be proportional to the difference between SI -powered and CI -powered GEM certified vocational vehicles. Using the HD pickup and van stringency curves and coefficients for the MY 2018 targets from Phase 1, the ratio of CO 2 

### performance of gasoline powered vehicles to diesel powered vehicles calculates to 1.05 8. This was derived using the equations and coefficients found at 40 CFR 1037.104(a)(2), where a work factor of 9,000 was ass umed, and the resulting calculated target value for SI vehicles was divided b y the similarly calculated target value for CI vehicles. The correction factor approach is not the agencies’ preferred approach to establishing SIvocational vehicle baseline performance, as it has many drawbacks. One key drawback with this approach is that it does not account for the fact that SIengines operate very

differentl y than CIengines at idle. Our current model includes information on CI engine idle performance, and a ssumes transmissions and torque converters appropriate for CI engines. We expect these driveline parameters would be very different for SIpowered vehicles, which would affect performance over all the GEM duty cycles . 

## 2.9.1.2 Improved Vocational Engines for Phase 2 Standard - Setting Four model ye ar versions of these engine maps have been developed for each of these four diesel engines: one set for MY 2017 as the baseline, a set of maps for MY2021, a set for MY2024, and a set for MY 2027 , as improved over the 2017 b aseline engine maps. Because the agencies are proposing to retain the Phase 1 SI separate engine standard for all implementation years of Phase 2, we developed the proposed Phase 2 standards for vocational vehicles powered b y S I engines using the same analys is described above for development of the SIbaseline engine, without further improvement. When developing improvement levels for the stringency

of the MY 2027 proposed vehicle standards (and the MY 2024 Alternative 4 standards), the agencies analyzed adoption rates, effectiveness, and cost of SIengine technologies that reduce friction. Consistent with our projection of adoption rates of advanced engine friction reduction on HD gasoline pickup trucks, the agencies projected that about 40 percent of SI engines intended for vocational vehicles would already have technologies applied that achieve performance equivalent to Level 2 engine friction reduction, making the available population that could upgrade to Level 2 about 60 percent for MY 2027. In term s of effectiveness, the agencies relied on the data presented in the Joint Technical Support Document (TSD) published in support of the LD GHG final rulemaking. 115 

### In Chapter 3 of that document, the agencies present effectiveness values for upgrading from b aseline levels of engine friction reducti on to Level 2 (EFR2) as ranging from 3.4 percent to 4.8 percent , for a range of LD vehicle ty pes , and with large trucks falling in the middle of this range . The TSD describes example technologies as including low - tension piston rings, piston skirt design, roller cam followers, improved crankshaft design and bearings, material coatings, material substitution, more optimal thermal management, and piston and cylinder surface treatments . For this Phase 2 HD rulemaking, the agencies derived incremental EFR2 effectiveness values from the combined EFR1+EFR2 values that were relative to baseline - level friction reduction. We were able to do this because the TSD also presented incremental improvements for upgrading from EFR1 to

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2 - 113 EFR2 as ranging from 0.83 to 1.37. The agencies then calculated a mid- range effectiveness value representing large trucks of about one percent. In terms of costs, the agencies have presented the costs of upgrading from EFR1 to EFR2, as shown in Chapter 2.12 below. Specificall y, the tables in Chapter 2.12.2.17 present the incremental and total costs over the model years of the proposed Phase 2 standards for low friction lubricants and engine friction reduction. By

appl ying our market adoption rate of a pproximately

60 percent to the incremental costs of upgrading to EFR2 from EFR1, we estimate a vocational vehicle package cost of approximately

$70 for this technology . 

## 2.9.2 **Defining the Baseline Vocational Vehicles** Nine baseline vocational vehicle configurations have been developed. Vocational vehicle attributes that would be set by the agencies not only

in the baseline but also in the executable version of the GEM include: transmission gear efficiencies, transmission inertia, engine inertia, axle efficiency, number of axles, axle inertia, axle efficiency , electrical and mechanical accessory power demand, vehicle mass and payload, and aerody namic cross - section and drag coefficient. Other vehicle attributes that would be available as user inputs for compliance purposes and for which we have established baseline values include: engine power and displacement (and multi - point fuel map), axle ratio, transmission ty pe and gear ratios, and tire loaded radius. In each of these proposed baseline configurations, the ag encies have not applied any vehicle - level fuel saving or emission reduction technology beyond what is required to meet the Phase 1 standards. NHTSA and EPA reviewed available information regarding the likelihood that manufacturers of vocational vehicles would apply technology

beyond what is required for Phase 1, and we concluded that the best approach was to anal yz e a reference case that maintains technology

performance at the Phase 1 level. Thus, the nine GEM - simulated baseline vocational vehicle configurations as well as the programmatic vocational vehicle reference case anal yz ed in this proposal represent what is referred to as a nominally flat baseline. Tables 4 - 8, 4 - 9, and 4 - 10 in the draft RIA Chapter 4 present the non -user- adjustable modeling param eters for HHD, MHD and LHD vocational vehicles, respectively . In addition to those parameters, to completely define the proposed baseline vehicles, the agencies also selected parameters shown in Table 2 - 43 , Table 2 - 44 , and Table 2 - 45 . These attributes and parameters were selected to represent a range of performance across this diverse segment, and are intended to represent a reasonable range of vocational chassis configurations likely

to be manufactured in the implementation years of the Phase 2 program. The tire radii and axle ratios were selected based on market research of publically available manufacturer product specifications, as well as some confidential manufacturer information about configurations sold in prior model years. The transmission gear ratios were selected based on the transmissions for which models have been validated in GEM. Using the reference vehicles noted above, the agencies were able to better determine an appropriate ty pe of transmission and its gear ratios, for all vocational vehicles. Tire radii and axle ratios were selected using good engineering judgment and stakeholder input, to reflect reasonable final drive ratios to match with our mode led transmissions. In general, the trend is that vehicles with higher

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2 - 114 final drive ratios have been selected for the subcategories with less weighting of the highway test cycles. The proposed Phase 2 weighting of steer tire CRR and drive tire CRR is different than in Phase 1. In Phase 1 , the agencies weighted drive and steer tire CRR values as if 50 percent of the vehicle load was on the front axle and 50 percent on the rear axle(s). The agencies reviewed the Vehicle Valuation Services quick reference guide to obtain ty pical axle load ratings for a variety of vocational vehicle types. 116 

### According to that guide, the examples of vocational vehicles with two axles had a rear axle designed to carry between 1.8 and three times the weight of the front axle. Examples of vehicles with three axles had combined weights of the rear axles designed to carry

loads ranging from 2.4 to 3.7 times the weight rating of the front axle. Based on this, the agencies propose a Phase 2 weighting of 0.3 times the steer tire CRR and 0.7 times the drive tire CRR , representing a weight distribution of the rear axle(s) carrying 2.3 times the weight of the front axle. The proposed allocation of 50 percent of reduced weight back to payload is described below in Section 2.9.3.5 . **Table 2**  **- 43**  **Heavy Heavy -**  **Duty User -**  **Enterable Modeling**  **Param eters**  **for Vocational Baseline**  

### GEM INPUT HHD (CLASS 8) HHD (CLASS 8) HHD (CLASS 8) Regional Duty Cycle Multi - Purpose

Duty Cycle Urban Duty Cycle Transmission Number of Forward Gears 10 5 5 Gear Ratio for Each Gear 12.8, 9.25, 6.76, 4.9, 3.58, 2.61, 1.89, 1.38, 1, 0.73 4.6957, 2.213,

1.5291, 1, 0.7643 4.6957, 2.213,

1.5291, 1, 0.7643 Architecture Type Manual Automatic Automatic Axle Axle Ratio 3.76 4.33 5.29 Advanced Axle Lubrication No No No 6 x 2 Axle No No No Idle Reduction Neutral Idle No No No Stop - Start No No No Tires Steer Tire CRR 7.7 7.7 7.7 Drive Tire CRR 7.7 7.7 7.7 Tire Loaded Radius 0.483 0.483 0.483 Weight Reduction (lbs) No No No

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2 - 115 **Table 2**  **- 44**  **Medium Heavy** **- Duty User**  **- Enterable**  **Modeling Param**  **eters for**  **Vocational Baseline**  

### GEM INPUT MHD (CLASS 6 - 7) MHD (CLASS 6 -

7) MHD (CLASS 6 - 7) Regional Duty Cycle Multi - Purpose

Duty Cycle Urban Duty Cycle Transmission Number of Forward Gears 5 5 5 Gear Ratio for Each Gear 3.102, 1.8107, 1.4063, 1, 0.7117 3.102, 1.8107,

1.4063, 1, 0.7117 3.102, 1.8107,

1.4063, 1, 0.7117 Architecture Type Automatic Automatic Automatic Axle Axle Ratio 4.33 4.88 4.88 Advanced Axle Lubrication No No No 6 x 2 Axle No No No Idle Reduction Neutral Idle No No No Stop - Start No No No Tires Steer Tire CRR 7.7 7.7 7.7 Drive Tire CRR 7.7 7.7 7.7 Tire Loaded Radius 0.462 0.462 0.426 Weight Reduction (lbs) No No No

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2 - 116 **Table 2**  **- 45**  **Light Heavy -**  **Duty User -**  **Enterable Modeling**  **Param eters**  **for Vocational Baseline** 

### GEM INPUT LHD (CLASS 2B 5) LHD (CLASS 2B 5) LHD (CLASS 2B 5) Regional Duty Cycle Multi - Purpose

Duty Cycle Urban Duty Cycle Transmission Number of Forward Gears 5 5 5 Gear Ratio for Each Gear 3.102, 1.8107, 1.4063, 1, 0.7117 3.102, 1.8107,

1.4063, 1, 0.7117 3.102, 1.8107,

1.4063, 1, 0.7117 Architecture Type Automatic Automatic Automatic Axle Axle Ratio 4.1 4.56 4.56 Advanced Axle Lubrication No No No 6 x 2 Axle No No No Idle Reduction Neutral Idle No No No Stop - Start No No No Tires Steer Tire CRR 7.7 7.7 7.7 Drive Tire CRR 7.7 7.7 7.7 Tire Loaded Radius 0.378 0.378 0.378 Weight Reduction (lbs) No No No 

## 2.9.2.1 Setting Normalized V ocational V ehicle Baselines The agencies developed adjusted, normalized vocational vehicle GEM numerical baselines, from which the improvements due to the technology packages would be set. This process began with simulating the performance of each of the nine baseline vehicles define d above. In this simulation, the emissions for curb idle transmission torque were calculated for each vehicle over the idle cycle. Next, the best performing vehicle in each weight class was identified. For the HHD weight class, this was the Regional vehi cle. For the MHD and LHD weight classes, these were the Urban vehicles. Next, we calculated a normalization factor for each of the nine subcategories by dividing each GEM result of the best vehicle by the fleet weighted average result per weight class of the best vehicle. For each weight class, we assumed that 25 percent of the vehicles would use the Regional cycle, 50 percent would use the Multipurpose cycle, and 25 percent would use the Urban cycle. Then, we calculated a population - weighted result of the actual baseline GEM results in each weight class group using a presumed population distribution (25 - 50 - 25). Finall y, we calculated the normalized baseline values for each of nine subcategories by multiplying the weighted baseline GEM result in each wei ght class by each respective normalization factor for that subcategory . This process is summarized in Table 2 - 46 .

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2 - 117 **Table 2**  **- 46**  **Vocational Baseline Norm alizing**  CLASS 2B - 5 CLASS 6 - 7 CLASS 8 Urban Multi Purpose Rural,

Regional Urban Multi Purpose Rural,

Regional Urban Multi Purpose Rural,

Regional **Straight GEM Baseline Performance** 318 328 331 200 204 199 223 216 187 **Normalization Factor** 0.97 1.0 0 1.0 4 1.00 1.0 1 0.99 1.0 1 1.0 2 0.96 **Population Weighted Best Vehicle**  **Result** 32 8.8 202.4 193.9

**Population Weighted Baseline Result**  3 2 6. 3 201.8 2 10.5 **Normalized Baseline** 31 6 32 5 3 39 201 20 3 19 9 2 12 21 4 20 3 

## 2.9.2.2 Assigning Vocational Vehicles to Subcategories To determine appropriate engine speed cut-points for subcategory assignments, the agencies conducted GEM simulations for each of the nine defined baseline vocational vehicles using a sweep of axle ratios ranging from 2.47:1 to 12:1. We then compared the C O 2 

### emission rates of the composite cycle to assess the sensitivity of the results to axle ratio, and identified the axle ratio for which the emission rate was lowest, and thus most optimized for that vehicle and duty cycle . Next the agencies compared the engine speeds attained during the 55 mph and 65 mph cruise cycles for the optimized axle ratio simulation to the maximum engine test speed of the engine in each simulated vehicle. The diesel engines in each simulated vehicle are described above in Chapter 2.9.1. The agencies used two gasoline engine models for this analysis, which were not used for derivation of the proposed standards. We noted considerable variability in the ratio of attained engine speed at 55 mph vs . maximum test speed, but we reasoned that if an engine was rotating close to the engine’s rated speed (represented b y a high percent of maximum test speed) while the vehicle is at 55 mph then it would logicall y be best certified using the Urban Duty C ycle. Based on our observations and goo d engineering judgment, we selected a cutpoint for the Urban Duty C yc le where a vehicle at 55 mph would have an engine working above 90 percent of maximum engine test speed for vocational vehicles powered b y diesel engines and above 50 percent for vocational vehicles powered b y gasoline engines. We similarly noted considerable variability in the ratio of attained engine speed at 65 mph vs . maximum test speed, but we reasoned that if an engine was rotating slowly (represented b y a low percent of maximum tes t speed) while the vehicle is at 65 mph then it would logicall y be best certified using the Regional Duty C ycle. Based on our observations and good engineering judgment, we selected a cutpoint for the Regional Duty C ycle where a vehicle at 65 mph would have an engine working below 75 percent of maximum engine test speed for vocational vehicles powered b y diesel engines and below 45 percent for vocational vehicles powered b y gasoline engines. The proposed regulations describe this subcategory assignment process at 40 CFR 1037.510.

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2 - 118 

## 2.9.3 **Costs and Effectiveness of Vocational Vehicle Technologies** The following paragraphs describe the vehicle - level technologies on which the proposed vocational vehicle standards are predicated, and their projected effectiveness over the proposed test cycles. The methodology for estimating costs, including indirect cost estimates and learning effects, is described in draft RIA Chapter 2.12.1. Certain elements of the cost estimating methodology

are the same as for the Phase 1 program, but as described in that section, certain elements are different, including how the agencies apply the markups, how the markups change with time, and which cost elements are influenced by learning effects. As a result of different technology

complexities , learning effects, and different short - term and long - term warranty and non - warranty- related indirect costs, some technology costs identified below may appear higher in MY 2021 than in MY 202 7 . These differences are not due to changes in adoption rates, s ince the costs in Chapter 2.12 and below in Chapter 2.9.3 to 2.9.4 are for appl ying a given technology to a single vehicle. Throughout this Chapter, where a dollar cost is given for a technology, note that these are adjusted to be valued as ye ar 2012 doll ars. Average costs for vocational vehicle technology

packages , including adoption rates, are presented below in Chapter 2.9.5. Detailed descriptions of technology packages for SI engines can be found in the draft RIA Chapter 2.6. Detailed descriptions o f technology packages and costs for CI engines can be found in the draft RIA Chapter 2.7. 

## 2.9.3.1 Transmissions Transmission improvements present a significant opportunity for reducing fuel consumption and CO 2 

### emissions from vocational vehicles. Transmission eff iciency is important for many vocational vehicles as their duty c ycl es involve high percentages of driving under transient operation. The three categories of transmission improvements the agencies considered for Phase 2 are driveline optimization, archite ctural improvements, and hybrid powertrain systems. Of the technologies described above in Chapter 2.4, the agencies are predicating the proposed vocational vehicle standards on performance improvements achieved by use of advanced transmissions as describe d in Table 2 - 47 , below. The projected market adoption rates that inform the technology packages are described in Chapter 2.9.5 .

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2 - 119 **Table 2**  **- 47**  **Projected Vocational Transmission Improvements over GEM**  **Baseline** 

### TRANSMI SSI ON TECHNOLOGY PROJECTED

IMPROVEMENT OVER TEST CYCLE A 

### REG IONAL

COMPOSITE CYCLE MULTI - PURPOSE

COMPOSITE CYCLE URBAN

COMPOSITE CYCLE Two More Gears (over 5 - speed) ARB Transient 2% 1 . 1 1. 7 1.9

55 mph Cruise 0% 65 mph Cruise 0% DCT or AMT (over automatic) ARB Transient 4 % 2 . 1 3 . 4 3 .8

55 mph Cruise 0 % 65 mph Cruise 0 % HHD DCT or AMT (over manual) b 

### ARB Transient 4 % 2. 3 (2.95) N/A N/A

55 mph Cruise 1.5 % 65 mph Cruise 1.5 % Strong Hy

brid ARB Transient 27% 1 4.7 22. 9 25. 6

55 mph Cruise 0% 65 mph Cruise 0% Deep Driveline Integration ARB Transient 7 % 4 . 7 6. 2 6.7

55 mph Cruise 2% 65 mph Cruise 2% Note s : a Improvement is relative to a 5 - speed automatic transmission in GEM, except where noted. T echnology im provement s wo uld either be mo deled in GEM or would be measured over the p owertrain test , except as noted . b Fixed im

provement for HHD AMT or DCT vs . manual transmission in GEM wo uld be 2.3 percent as shown, in addition to the GEM - modeled improvement of one percent over the ARB Transient and zero over the cruise cycles . Com bined these wo uld be 2.95 percent. 

## 2.9.3.1.1 **Deep Integration -**  **Conventional** The agencies believe an effective way to derive efficiency

improvements from a transmission is by

optimizing it with the engine and other driveline components to balance both performance needs and fuel savings. However, many vocational vehicles today are not operating with such optimized systems. Due to the fact that customers are able to specify their preferred components in a highl y customized build process, many vocational vehicles are assembled with components that were designed more for compatibility than for optimization. To some extent, verticall y integrated manufacturers are able to optimize their drivelines. However, this is not widespread in the vocational vehicle sector, resulting, primaril y, from the multi - stage manufacture process. The agenc ies thus project that transmission and driveline optimization would yi eld a substantial proportion of vocational vehicle fuel efficiency improvements for Phase 2. On average, we anticipate that efficiency improvements of about five percent can be achieved from optimization, sometimes called deep integration , of drivelines . However, we are not assigning a fixed level of improvement; rather we have developed a test procedure, the powertrain test, for manufacturers to use to obtain improvement factors representative of their systems. See the draft RIA Chapter 3 for a discuss ion of this test procedure. Depending on the test cycle and level of integration, the agencies believe improvement factors greater than ten percent above the baseline vehicle performance could be achieved. To obtain such benefits

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2 - 120 across more of the vocational vehicle fleet, the agencies believe there is opportunity for manufacturers to form strategic partnerships and explore commercial pathways to deploy deeper driveline integration. For example, one partnership of an engine manufacturer and a transmissi on manufacturer has led to development of driveline components that deliver improved fuel efficiency

based on optimization that could not be realized without sharing of critical data. 117 

### The agencies project other related transmission technologies would be recognized over the powertrain test along with driveline optimization. These include improved mechanical gear efficiency , more sophisticated shift strategies, more aggressive torque converter lockups, transmission friction reduction, and reduced parasitic losses. 118 

### Each of these attributes would be simulated in GEM using default values, unless the powertrain test were employed . The expected benefits of improved gear efficiency , shift logic, and torque converter lockup are included in the total projected e ffectiveness of optimized conventional transmissions using the powertrain test. For conventional powertrains, the agencies are projecting effectiveness of deep integration from 3.5 to 4.8 percent, as shown in Table 2 - 47 above . The agencies estimate the total cost to apply a high efficiency

gearbox, aggressive shift logic, and earl y torque converter lockup to a vocational vehicle at $372 in MY 2021 and $3 15 in MY 202 7 , a s described in draft RIA 2.12.3.5. The agencies describe the capital and operational expenses of conducting powertrain testing in the draft RIA Chapter 7.1 . 

## 2.9.3.1.2 **Architectural Transmission Improvements** One ty pe of architectural improvement the agencies project can reasonabl y be developed by manufacturers of all transmission architectures is increased number of gears. The benefit of adding more gears varies depending on whether the gears are added in the range where most operation occurs. The TIAX 2009 report p rojected that 8 - speed transmissions could incrementall y reduce fuel co nsumption by 2 to 3 percent over a 6 - speed automatic transmission , for Class 3 - 6 box and bucket trucks, refuse haulers, and transit buses. 119 

### Although the agencies estimate the improvement could on average be about two percent for the adding of two gears in the range where significant vehicle operation occurs, we are not assigning a fixed improvement based solel y on number of transmission gears. Manufacturers would enter the number of gears and gear ratios into GEM and the model would simulate the efficiency benefit over the applicable test cycle. The agencies estimate the total cost to add two gears to a vocational vehicle transmission at $49 5 in MY 2021 and $4 5 7 in MY 202 7 , as described in draft RIA 2.12.3.1. Transmission efficiency

could also be improved in the time frame of the proposed rules by changes in the architecture of conventional transmissions. Most vocational vehicles currentl y u se torque converter automatic transmissions (AT), especiall y in Classes 2b - 6. According to the 2009 TIAX report, approximately 70 percent of Class 3 - 6 box and bucket trucks use AT, and all refuse trucks, urban buses, and motor coaches use AT. 118 

### AT’s offer acceleration benefits over drive cycles with frequent stops, which can enhance productivity. However, with the diversity of vocational vehicles and drive c ycles, other kinds of transmission architectures can meet customer needs, including automated manual transmissions (AMT) and even some manual transmissions (MT). 120

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2 - 121 Other architectural changes that the agencies project would offer efficiency improvements include improved a utomated m anual transmissions (AMT) and introduction of dual clutch transmissions (DCT). Newer versions of AMT are showing significant improvements in reliability, such that the current generation of transmissions with this architecture is more likely to retain resale value and win customer acceptance than early models . 121 

### The agencies believe AMT generall y compare favorabl y to manual transmissions in fuel efficiency, and while the degree of improvement is highly driver- dependent, it can be two percent or greater, depending on the drive cycle. See Chapter 2.4.4 for additional discussion of AMT. The agencies are not assigning fixed average performance levels to compare an AMT with a traditional automatic transmission. Although the lack of a torque converter offers AMT an efficiency advantage in one respect, the lag in power during shifts is a disadvantage. For Phase 2, the agencies have developed validated models of both AMT and AT, as described in the draft RIA Chapter 4. Manufacturers installing AMT or AT would enter the relevant inputs to GEM and the simulation would calculate the performance. Dual clutch transmissions (DCT) are already in production for light - duty

vehicles, and are expected to become available in the vocational vehi cle market prior to the proposed beginning of Phase 2 in MY 2021. 122 

### Based on supplier conversations, manufacturers intend to match varying DCT designs with the diverse needs of the heavy- duty market. The agencies do not yet have a validated DCT model in GEM, and we are not assigning a fixed performance level for DCT, though we expect the per- vehicle fuel efficiency improvement due to switching from automatic to DCT to be in the range of three percent over the GEM vocational vehicle test cycles. Selection of transmission architecture ty pe (Manual, AMT, AT, DCT) would be made b y m anufacturers at the time of certification, and GEM would either use this input information to simulate that transmission using algorithms as described in the draft RIA Chapter 4, or fixed improvements may be assigned. The agencies are proposing to assign fixed levels of improvement that vary by test cycle in GEM for AMT when replacing a manual, which for vocational vehicles would be in the HHD Regional subcategory . If a manufacturer elected not to conduct powertrain testing to obtain specific improvements for use of a DCT, GEM would simulate a DCT as if it were an AMT, with no fixed assigned benefit. According to EPA’s light - duty teardown report, the direct incremental cost to build a six speed wet dual clutch transmission was determined to be roughly $100 less than the cost of a six speed automatic transmission. 123 

### We estimate the components and engineering to design a heavy- duty torque converter automatic transmission are at least a s costl y and complex as those to design a dual clutch transmission. Therefore, the agencies estimate switching from AT to DCT would have zero incremental cost for vocational vehicles. The agencies have estimated the costs of upgrading from HHD manual transmissions to AT, AMT, and DCT, as summarized in Table 2 - 48 , and described in detail below in 2.12.3.

**Table 2**  **- 48**  **Incre me**  **ntal Costs for HHD Transmissions Relative**  **to Manual Transmissions**  **a**



### TECHNOLOGY 2021 COST 202 7 COST Manual to AMT $4,472 $3, 7 9 5 Manual to AT $ 3,764 $ 3,470 Manual to DCT $4,472 $3, 7 9 5 Note: a Costs include markups (2012$)

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2 - 122 

## 2.9.3.1.3 **Deep Integration -**  **Hybrid** The agencies are including hy brid powertrains as a technology on which the proposed vocational vehicle standards are predicated. We project a variety of mild and strong hybrid systems, with a wide range of effectiveness. Mild hy brid s ys tems that offer an engine stop - start feature are discussed below under workday idle reduction. For hyb rid powertrains, we are estimating a 22 to 25 percent fuel efficiency improvement over the powertrain test, depending on the duty cycle in GEM for the applicable subcategory. The agencies obtained these estimates by projecting a 27 percent effectiveness over the ARB Transient cycle, and zero percent over the highway cruise cycles. With the proposed cycle weightings, depending on the subcategory , this is projected to yi eld a 25 to 26 percent improvement over the Urban cycle, and 22 to 23 percent improvement over the Multi - Purpose cycle. According to the NREL Final Evaluation of UPS Diesel Hy

brid- Electric Delivery

Vans, the improvement of a hybrid over a conventional diesel in gallons per ton - mile on a chassis dy namometer over the NYC Composite test cycle was 28 percent. 124 

### NREL characterizes the NYC Composite cycle as more aggressive than most of the observed field data points from the study, and may represent an ideal hybrid cycle in terms of low average speed, high stops per mile, and high kinetic intensity (KI). NREL noted that most of the observed field data points were reasonably represented by the HTUF4 cycle, over which the chassis dy namometer results showed a 31 percent improvement 

### in gallons per ton - mile . In units of grams 

### CO 2 

### per mile, NREL reported these test results as 22 percent improvement over the NYC Composite cycle and 26 percent improvement over the HTUF4 cycle. Based on these results, and the fact that any improvement from strong hybrids in Phase 2 would not be simulated in GEM, rather evaluated using the powertrain test, the agencies deemed it reasonable to estimate a conservative 27 percent effectiveness over the ARB Transient in setting the stringency of the standards. 

### Hy brid powertrain systems are included under transmission technologies because, depending on the design and degree of hyb ridization, they may either replace a conventional transmission or be deeply integrated with a conventional transmiss ion. Further, these s ys tems are often manufactured b y companies that also manufacture conventional transmissions. The Phase 1 standards were not predicated on any adoption of hybrid powertrains in the vocational vehicle sector. Because the first implementation year of Phase 1 came just three years after promulgation, it did not offer an opportunity to provide the lead time for development of technology . The agencies believe the Phase 2 rulemaking would offer sufficient lead time to develop, demonstrate, and conduct reliability testing for technologies that are still maturing. Several types of vocational vehicle s are well suited for hy brid powertrains , and tend to be earl y adopters of this technology . Vehicles such as utility or bucket trucks, delivery vehicles, refuse haulers, and buses have operational usage patterns with either a significant amount of stop - and- go activity

or spend a large portion of their operating hours idling the main engine to operate a PTO unit. The industry

is currentl y developing many variations of hy

brid powertrain systems. There are a few hybrid systems in the heavy- duty market today and several more under development. In addition, energy storage s ys tems are getting better. 125 

### Heavy- duty customers are getting used to these systems with the number of demonstration products on the road. Even so, manufacturers are uncertain how much investment to make in this technology without clear

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2 - 123 signals from regulators. A list of hy brid manufacturers and their products intended for the vocati onal market is provided in Table 2 - 49 . **Table 2**  **- 49**  **Examples of Hybrid Manufacturers** 

### MANUFACTURER PRODUCT EXAMPLE APPLICATION Hino Class 5 cab - over- engine batteryelectric hybrid Delivery Trucks Allison HHD parallel hybrid Transit Bus BAE HHD series or parallel hybrid Transit Bus XL Class 3 -4 mild electric hybrid Shuttle Bus Crosspoint Kinetics Class 3 - 7 mild electric hybrid Delivery trucks, shuttle buses Lightning Hybrids Class 2 - 5 hydraulic hybrid Delivery trucks Parker Hannifin MHD hydraulic hybrid Delivery trucks Freightliner Custom Chassis MHD hydraulic hybrid Delivery trucks Morgan Olson MHD hydraulic hybrid Delivery trucks Autocar- Parker Runwise hydraulic hybrid Refuse Trucks Eaton a 

### HHD parallel electric hybrid Trucks and Buses Odyne Plug - in electric hybrid, E - PTO Utility Trucks Note: a Currently selling in markets outside the U.S. 

### Some low cost products on the simple end of the hy brid spectrum are available th at minimize battery

demand through the use of ultra - capacitors or only provide power assist at low speeds. Our regulations define a hyb rid system as one that has the capacity for energy storage. M 

### Unofficiall y, some s ys tems are commonl y known as mild hy brids, where some accessories are electrified, the engine is not downsized and there may or may not be capacity

for regenerative braking. Strong hy

brids are typicall y referred to as those that have larger energy storage capacity such that the engine may

be downsized in some cases. Depending on the drive cycle and units of measurement, strong hyb rids developed to date have seen fuel consumption and CO 2 

### emissions reductions between 20 and 50 percent in the field. 126 

### The agencies estimate the total cost of a hybrid powertrain s ys tem for a LHD vocational vehicle at $15,207 in MY 2021 and $1 1,791 in MY 2027. For a MHD vocational vehicle, the total cost is estimated at $23,904 in MY 2021 and $18,534 in MY 2027. For a HHD vocational vehicle, the total cost is estimated at $39,919 in MY 2021 and $30,952 in MY 2027 , as described in draft RIA 2.12.7. The estimated higher costs for heavier vehicles are related to higher power demands and greater energy storag e needs. The se estimates assume no engine downsizing in the design of hyb rid packages. This is in part to be conservative in our cost estimates, and in part because in some applications a smaller engine may not be acceptable if it would risk that perform ance could be sacrificed during some portion of a work day .

M NHTSA’s and EPA’s regulations define a hybrid vehicle as one that “includes energy storage features ... in addition to an internal combustion engine or other engine using consumable chemical fuel....” 49 CFR 535.4 and 40 CFR 1037.801.

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2 - 124 

## 2.9.3.2 Axles The agencies are considering two axle technologies for the vocational sector. The first is advanced low friction axle lubricants. SwRI tested improved driveline lubrication and found measurable improvements by switching from current mainstream products to top - tier formulation s focusing on modified viscometric effects . 127 

### The agencies believe that a 0.5 percent improvement in vocational vehicle efficiency (as for tractors) is achievable through the application of low friction axle lubricants, and have included that value as a fixed technology improvement value in GEM. If a manufacturer wishes to demonstrate a greater benefit, an axle efficiency test could be performed to support an applic ation for an innovative technology credit. See draft RIA Chapter 3 for a description of a test procedure for axle efficiency . We are estimating the axle lubricating costs for HHD to be the same as for tractors since those vehicles likewise ty

pically have three axles. However, for LHD and MHD vocational vehicles, we scaled down the cost of this technology to reflect the presence of a single rear axle. The agencies estimate the total cost of low friction axle lubricants on a LHD or MHD vocational vehicle (with 2 axles) at $132 in MY 2021 and $11 4 in MY 202 7 . For HHD vocational vehicles (with 3 axles), the agencies estimate the cost at $197 in MY 2021 and $1 72 in MY 202 7 , as described in draft RIA 2.12.5.4. The second axle technology the agencies are considering is a design that enables one of the tandem axles to temporaril y disconnect or permanently be a non - driven axle, on vehicles with two rear (drive) axle s, commonly referred to as a 6x2 configuration. The agencies have considered two types of 6x2 configurations for vocational vehicles: those that are engaged full time on a vehicle, and those that may be engaged only

during some types of vehicle operation, such as only

when operating at highway cruise speeds . In prior ye ars, manufacturers offered versions of this technology that were not accepted by vehicle owners. When the second drive axle is no longer powered, traction may be sacrificed in some cases. Vehicles with earlier versions of this technology have seen reduced residual values in the se condary market. 128 

### Over the model years covered by the Phase 2 rule s , the agencies expect the market to offer significantl y improved versions of this technology, with traction control maintained at lower speeds and efficiency

gains at highway

cruise spe eds. 129 

### Mechanisms to automatically disconnect or reconnect drive axles would likely function in a similar manner as with two axle vehicles that can seamlessly switch from four- wheel drive to two - wheel drive and back. Further information about 6x2 axle technology is provided in the feasibility of the tractor standards, preamble Section III, as well as in draft RIA Chapter 2.4. The efficiency

benefit of a 6x2 axle configuration is highly duty- cycle dependent. In many instances, vocational vehicles need to operate off - highway , such as at a construction site delivering materials or dumping at a refuse collection facility . Under these conditions, vehicles with two drive axles may need the full tractive benefit of both drive axles. The 6x2 axle disconnect technology

is not expected to measurably improve a vehicle’s efficiency for vehicles whose normal duty c ycl e is performing off - highway work, but the agencies do expect this technology

to be recognized on a cycle with a significant weighting of highway cruise. The agencies estimate the total cost of full time 6x2 at $197 in MY 2021 and $172 in MY 2027. The agencies estimate the total cost of part time 6x2 on a vocational vehicle at $120 in MY 2021 and $116 in MY 2027 , as described in draft RIA 2.12.5.2.

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2 - 125 Some vocational vehicles in the HHD Regional subcategory may see a 6x2 axle disconnect technology

as a reasonable option for improving fuel efficiency . As in Phase 1, our vehicle simulation model assumes that only HHD vehicles have two rear axles, so only thes e could be recognized for adopting this technology . Further, the agencies don’t believe vehicles in the Multipurpose and Urban subcategories operate with a significant enough highway time to make this technology

worthwhile. While the agencies project thi s can achieve over 2 percent benefit at highway

cruise, we propose to assign a fixed 2.5 percent value in GEM for part time 6x2 over the highway

cruise cycles and zero over the ARB Transient cycle, where the specific benefit would be calculated according to the composite weighting of the applicable vocational vehicle test cycle. 130 

## 2.9.3.3 Lower Rolling Resistance Tires T ires are the second largest contributor to energy losses of vocational vehicle s, as found in the energy

audit conducted by

Argonne National Lab. 131 

### There is a wide range of rolling resistance of tires used on vocational vehicle s today . This is in part due to the fact that the competitive pressure to improve rolling resistance of vocational vehicle tires has been less than that found in the line haul tire market. In addition, the drive cycles ty pical for these applications often lead vocational vehicle buyers to value tire traction and durability more heavil y than rolling resistance. The agencies acknowledge there can be tradeoffs when designing a tire for reduced rolling resistance. These tradeoffs can include characteristics such as wear resistance, cost and scuff resistance. NHTSA, EPA, and ARB met with stakeholders from the tire industry (Bridgestone, Continental, Cooper, Goodyear, and Michelin) to discuss the next generation of lower rolling resistance (LRR) tires for the Phase 2 timeframe for all segments of Class 2b - 8 vehicles, including trailers. Manufacturers discussed forecasts for rolling resistance levels and production availability

in the Phase 2 timeframe, as well as their plans for improving rolling resistance performance while maintaining other performance parameters such as traction, handling, wear, mass reduction, retreadability , and structural durability. The meetings included sp ecific discussions of the impacts of the current generation of LRR tires on vehicle stopping distance and handling. Manufacturers indicated no known safety disbenefit in the current on - road fleet from use of LRR tires. While the next generation of tires may require some tradeoffs in wear performance and costs over the next 10 years to achieve better tire rolling resistance performance, manufacturers said they will not trade off safety for performance. They

also emphasized that keeping tires inflated (through proper maintenance or automatic systems) was the best way to assure long term fuel efficiency and safety during vehicle operation . According to the 201 5 NHTSA Technology Study , vocational vehicles are likely to see the most benefits from reduced tire rolling resistance when they are driving at 55 mph. 132 

### This report also found an influence of vehicle weight on the benefits of LRR tires. The study found that both vocational vehicles tested had greater benefits of LRR tires at 100 percent payload than when empty. Also, the T270 delivery box truck that was 4,000 pounds heavier when full y loaded saw slightly

greater efficiency

gains from LRR tires than the F650 flatbed tow truck over the same cycles. At higher speeds, aerodyn amic drag grows , which reduces the rolling resistance share of total vehicle power demand. In highly transient cycles, the power required to accelerate the vehicle inertia overshadows the rolling resistance power demand. In simulation, GEM

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2 - 126 represents vocational vehicle s with fixed vehicle weights, payloads and aerody namic coefficients. Thus, the benefit of LRR tires would be reflected in GEM differently for vehicles of different weight classes. There will also be further differences arising from the different test cycles. Based on preliminary simulations, it appears the vehicles in GEM most likely to see the greatest fuel efficiency

gains from use of LRR tires are those in the MHD weight classes tested over the Regional or Multipurpose duty cycles, where one percent efficiency improvement could be achieved b y reducing CRR by four to five percent. Those seeing the least benefit from LRR tires would likely

be Class 8 vocational vehicles tested over the Urban or Multipurpose cycles, where one percent efficiency impro vement could be achieved by reducing CRR by

seven to eight percent. As shown in draft RIA Chapter 2.12.8, the agencies estimate the total cost to apply LRR tires that have five percent lower CRR than baseline to be the same as the cost to apply baseline level LRR tires. The agencies estimate the cost to apply LRR tires that have 10 percent lower CRR than baseline to be about $4 more than the cost of baseline tires. The agencies estimate the cost to apply

LRR tires that have 15 percent lower CRR than baseline to be about $6 more than the cost of baseline tires. Based on these costs, some illustrations of the costs associated with LRR tires are provided. To fit a LHD or MHD vocational vehicle with two steer tires improved by 10 percent and 4 drive tires imp roved by 5 percent would be roughl y $9 to $10 in MY 2021 as well as in MY 2024. Based on the estimated zero - cost to upgrade the drive tires by five percent, we estimate the cost to fit a HHD vocational vehicle (with 10 tires) with the same CRR upgrades w ould be roughly the same, $9 to $10. As another example, to fit a LHD or MHD vocational vehicle with two steer tires improved by

15 percent and 4 drive tires improved by 10 percent, it is estimated to cost $33 in MY 2024. For a HHD vehicle (with 8 drive tires) to make the same CRR upgrades, we estimate the cost to be $54 in MY 2024. Detailed tables of LRR tire costs in each ye ar are provided in draft RIA Chapter 2.12.8. The agencies propose to continue the light truck (LT) tire CRR adjustment factor that was adopted in Phase 1 . See generall y 76 FR 57172 - 74. In Phase 1, the agencies developed this adjustment factor by dividing the overall vocational test average CRR of 7.7 by the LT vocational average CRR of 8.9. This yielded an adjustment factor of 0.87. After promulgation of the Phase 1 rules, the agencies conducted additional tire CRR testing on a variety of LT tires, most of which were designated as all -position tires. In addition, manufacturers have submitted to the agencies pre - certification data that include CRR values provided by tire suppliers. For the small subset of newer test tires that were designated as steer tires, the average CRR was 7.8 kg/ton. For the subset of newer test tires that were designated as driv e tires, the average CRR was 8.6 kg/ton. However all -position tires had an average CRR of 8.9 kg/ton. 133 

### Therefore, f or LT vocational vehicle tires, we propose to continue allowing the measured CRR values to be multiplied by

the 0.87 adjustment factor before entering the values in the GEM for compliance , b ecause this additional testing has not revealed compelling information that a change is needed . 

## 2.9.3.4 Workday Idle Reduction The Phase 2 idle reduction technologies considered for vocational vehicle s are thos e that reduce workday idling, unlike the overnight idling of combination tractors. There are many

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2 - 127 potential such technologies. The agencies in particular evaluated neutral idle and stop - start technologies, and the proposed standards are predicated on pro jected amounts of penetrations of these technologies. While neutral idle is necessarily a transmission technology , stop - start could range from an engine technology to one that would be installed by a secondary

manufacturer under a delegated assembly agreement. The agencies are aware that for a vocational vehicle’s engine to turn off during workday driving conditions, there must be a reserve source of energy to maintain functions such as power steering, cabin heat, and transmission pressure, among others. Stop - start systems can be viewed as having a place on the low - cost end of the hy bridization continuum. The agencies are including the cost of energy storage sufficient to maintain critical onboard systems and restart the engine as part of the cost of voc ational vehicle stop - start packages. The technologies to capture this energy

could include a system of photovoltaic cells on the roof of a box truck, or regenerative braking. The technologies to store the captured energy could include a battery

or a hydraulic pressure bladder. According to CAL START’s report to the NAFA 2014 Institute and Expo , examples of suppliers of on - vehicle energy storage s ys tems that can enable idle reduction include Altec, Terex, and Time. More discussion of stop - start technologie s is found in the draft RIA Chapter 2.4. The agencies are also proposing a certification test cycle, as described in draft RIA Chapter 3.4.2, which measures the amount of fuel saved and CO 2 

### reduced by these two primary ty pes of technologies: neutral idle and stop - start. Vocational vehicles frequently also idl e while cargo is loaded or unloaded, and while operating a PTO such as compacting garbage or operating a bucket. In these rules, the agencies are proposing that the Regional duty cycle have ten percent idle, the Multi -purpose cycle have 15 percent idle, and the Urban cycle have 20 percent idle. These estimates are based on some publically available data published by NREL . 134 

### Figure 2 - 16 depicts a chart that illustrates the ty pe of data on zero - speed operation data from delivery trucks available from NRELon its Fleet DNA web site. However, because engine parameters were not captured during the data- logging of this vehicle activity, these data cannot distinguish between zero speed conditions with the engine o ff and zero speed conditions with the engine idling.

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2 - 128 **Figure 2**  **- 16**  **Example Fleet DNA Vehicle Activity**  **Dat a from** **NREL** 

### Combining the publically available zero - speed frequency charts from NREL on delivery trucks, service vans, delivery vans, and bucket trucks, the agencies observed that roughl y half of the logged operating days had less than 10 percent time at z ero speed, roughly 30 percent of the logged operating days had between 10 and 15 percent time at zero speed, roughl y 20 percent of the logged operating days had between 15 and 20 percent time at zero speed, and roughl y 6 percent of the logged operating days had over 20 percent time at zero speed. School buses were excluded from this average, because the given distribution had two modes: over 40 percent of the school bus operating days logged had less than five percent time at zero speed , while nearly half of the logged operating days for those buses had roughl y 40 percent time at zero speed . Without actual engine information, if we assume all the zero speed time is idling, then based on these rough estimates , it appears that 94 percent of these vehicles (excluding school buses) idle at frequencies of less than 20 percent on a daily basis . Thus , the agencies designed composite test cycles where the maximum weighting of idle was 20 percent. We assigned that value to the Urban cycle, where we expect a high incidence of traffic - related idling and city delivery routes involving frequent stops. The 15 percent and 10 percent idle weightings for the Multi - Purpose and Regional cycles, respectivel y, were selected as reasonably lesser values, given the distribution s observed in the NREL charts. Table 2 - 50 presents a summary of this anal ys is.

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2 - 129 **Table 2**  **- 50**  **Daily Z ero Speed Percentage D**  **istribution by Vehicle Type**



### LESS THAN 10 10 TO 14 15 TO 20 OVER 20 Service Vans 59% 18% 23% 0% Delivery Trucks 76% 16% 9% 0% Delivery Vans 38% 35% 2% 25% Bucket Trucks 18% 45% 37% 0% School Buses 41% 3% 7% 48% Average 47% 23% 16% 15% Average Without Buses 48% 28% 18% 6% 

### Because these data are not representative of the national vocational vehicle fleet, EPA has entered into an interagency agreement with NREL to further characterize workday idle among vocational vehicles. One task of this agre ement is to estimate the nationally representative fraction of idle operation for vocational vehicles for each proposed regulatory subcategory . The preliminary

range of daily idle operation per vehicle indicated b y this work is about 1 8 to 33 percent when combining the data from all available vehicles. An anal ys is of possible vocational vehicle standards derived from alternate characterizations of idle operation has been prepared b y the agencies, and is available for review in the public docket for this rulemaking. 135 

### Based on GEM simulations using the currentl y proposed vocational vehicle test cycles, the agencies estimate neutral idle for automatic transmissions to provide fuel efficiency improvements ranging from one percent to four percent, depending on the regulatory subcategory . The agencies estimate stop - start to provide fuel efficiency improvements ranging from 0.8 percent to seven percent, depending on the regulatory subcategory . Because of the higher idle weighting factor in the Urban test cyc le, vehicles certified in these subcategories would derive the greatest benefit from appl ying idle reduction technologies. This presumes there is a correlation between amount of urban driving and amount of idle time . Although the primary

program would not simulate vocational vehicles over a test cycle that includes PTO operation, the agencies are proposing to continue, with revisions, the hy bridPTO test option that was in Phase 1. See 40 CFR 1037.525 and 76 FR 57247. Recall that we are proposing to regulate vocational vehicles at the incomplete stage when a chassis manufacturer may not know at the time of certification whether a PTO will be installed or how the vehicle will be used. Although chassis manufacturers wil l certainly know whether a vehicle’s transmission is PTO - enabled, that is very different from knowing whether a PTO will actually be installed and how it will be used. Chassis manufacturers may rarel y know whether the PTO - enabled vehicle will use this cap ability

to maneuver a lift gate on a delivery vehicle, to operate a utility boom, or merel y as a reserve item to add value in the secondary market. In cases where a manufacturer can certify

that a PTO with an idle - reduction technology will be installed either by the chassis manufacturer or b y a second stage manufacturer, the hy brid- PTO test cycle may

be utilized by the certifying manufacturer to measure an improvement factor over the GEM duty cycle that would otherwise appl y to that vehicle. In addition, the delegated assembl y provisions would apply . See preamble Section V.E for a description of the delegated assembly provisions. See draft RIA Chapter 3 for a discussion of the proposed revisions to the hy brid PTO test cycle. In

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2 - 130 cases where a chassis manuf acturer does not know whether a powertrain that is PTO - enabled will actually

have a PTO -using tool installed, and whether there will be an energy storage s ys tem installed to save fuel during PTO operation, then the agencies do not see a way for the Phase 2 program to recognize hybrid PTO technology . Our estimates are that applying neutral idle to a vocational vehicle with an automatic transmission would cost $9 in MY 2021, decreasing to $8 in MT 202 7 , as shown in draft RIA 2.12.6. Th ese cost s are based on a small amount of engineering development and testing costs, with no hardware required . Our estimates are that the cost of appl ying stop - start to a vocational vehicle would vary

by vehicle weight class. For LHD vocational vehicles, we estimate the total c ost would range from $855 in MY 2021 to $7 09 in MY 2027. For MHD vocational vehicles, we estimate the total cost would range from $902 in MY 2021 to $748 in MY 2027. For HHD vocational vehicles, we estimate the total cost would range from $1,657 in MY 202 1 to $1,374 in MY 2027 . Th ese cost s, presented in draft RIA Chapter 2.12.6, are derived from costs reported by Tetra T ech for stop - start, along with costs for electrified accessories used in the light - duty GHG program, and scaled up for heavier vehicles . With either a stop - start engine feature or with a neutral idle transmission calibration, less fuel is burned at idle. Furthermore, it is expected that SCR catalyst function could be better managed when an engine shuts off than when it idles, because SCR s ys tems are well insulated and can maintain temperature when an engine is shut off, however idling causes relativel y cool air to flow through a catalyst. Therefore, the agencies have reason to believe there may be a NO X 

### co -benefit to stop - start idle reducti on technologies, and possibly also to neutral idle. This would be true if the NO X 

### reductions from reduced fuel consumption and retained aftertreatment temperature were greater than any ex cess NO X 

### emissions due to engine re - starts. 

## 2.9.3.5 Weight Reduction The ag encies believe there is opportunity for weight reduction in some vocational vehicles. The 201 5 NHTSA Technology Study found that weight reduction provides a greater fuel efficiency

benefit for vehicles driving under transient conditions than for those operating under constant speeds. In simulation, the study found that the two Class 6 trucks improved fuel efficiency by over two percent on the ARB transient cycle by removing 1,100 lbs. Further, SwRIobserved that the improvements due to weight reduction behaved linearl y. 136 

### The proposed menu of components available for a vocational vehicle weight credit in GEM is presente d in Table 2 - 52 . It includes fewer options than for tractors, but the agencies believe there are a number of feasible material substitution choices at the chassis level, which could add up to weight savings on the order of a few hundred pounds. The agencies estimate the total cost to reduce the weight of a vocational vehicle b y 200 pounds to be $683 in MY 2021 and $ 578 in MY 202 7 , as described in draft RIA 2.12.10.3. This is in the range of $3 to $4 per pound, as reported b y T IAX 2009. 137 

### To assess the projected effectiveness of weight reduction of the proposed package of 200 pounds, the agencies simulated a HHD, MHD and LHD vocational vehicle in GEM over each of the s eparate test cycles. Based on the results of this simulation, the agencies project a reduction of 200 pounds may

yield a fuel efficiency

improvement ranging from 0.8 percent to 2 percent over the ARB Transient cycle, depending on vehicle weight class. Th e results of this example

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2 - 131 simulation are presented in Table 2 - 51 . Consistent with the results of SwRI study mentioned above, these GEM results show a slightl y greater benefit over transient operation than highway cruise. **Table 2**  **- 51**  **Projected Effectiveness of Vocational Weight Reduction** 

### HHD MHD LHD Weight Reduction 200 0 200 0 200 0 Static Test Weight (kg) 19,006 19,051 11,363 11,408 7,212 7,257 Dy namic Test Weight (kg) 19,573 19,618 11,703 11,748 7,552 7,597 Payload (ton) 7.55 7.5 5.65 5.6 2.9 2.85 Transient CO 2 

### Emission (g CO 2 

### ptm) 240 242 224 227 351 358 55mph CO 2 

### Emission (g CO 2 

### ptm) 181 182 182 184 332 338 65mph CO 2 

### Emission (g CO 2 

### ptm) 216 217 230 232 394 401 Effectiveness over Transient - 0.8% - 1.1% - 2.0% Effectiveness over 55 mph - 0.7% - 1.0% - 1.8% Effectiveness over 65 mph - 0.7% - 1.0% - 1.8% Urban C ycle Effectiv en ess (94% Transient, 6% 55 mph) - 0.8% - 1.1% - 2.0% Multi - Purpose Cycle Effectiv en ess (82 % Transient, 15 % 55 mp h, 3% 65 mph) - 0.8% - 1.1% - 1 . 9 % Regional C ycle Effectiv en ess (50 % Transient, 28% 55 mp h, 22% 65 mph) - 0.8% - 1.0 % - 1.9 % Without more specific data on which to base our assumptions, the agencies are proposing to allocate 50 percent of any mass reduction to increased payload, and 50 percent to reduce the chassis weight. We considered the data on which the tractor weight allo cation (1/3:2/3) is based, but determined this would not be valid for vocational vehicles, as the underlying data pertained only to long haul tractor- trailers. The agencies propose that 50 percent of weight removed from vocational vehicle chassis would be added back as additional payload in GEM. This suggests an equal likelihood that a vehicle would be reducing weight for benefits of being lighter, or reducing weight to carry

more payload. One reason why this effectiveness appears greater than would be expected based on the SwRIresults is the change in payload. As shown in Table 2 - 51 , this payload attribute has a stronger influence on the effectiveness than the duty cycle. For the LHD vehicles, reducing 200 pounds would decrease the test weight by 0.6 percent and increas e the payload by 1.8 percent. The agencies project the effectiveness of weight reduction for Phase 2 would be one percent or less for HHD and MHD vocational vehicles, and the effectiveness would be close to two percent for LHD vehicles over any of the voc ational vehicle composite cycles.

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2 - 132 **Table 2**  **- 52**  **Proposed Vocational Weight Reduction**  **Technologies** COMPONENT MATERIAL VOCATIONAL VEHICLE CLASS Class 2b - 5 Class 6 - 7 Class 8 Axle Hubs - Non - Drive Aluminum 40 40 Axle Hubs - Non - Drive High Strength Steel 5 5 Axle - Non - Drive Aluminum 60 60 Axle - Non - Drive High Strength Steel 15 15 Brake Drums - Non - Drive Aluminum 60 60 Brake Drums - Non - Drive High Strength Steel 8 8 Axle Hubs - Drive Aluminum 40 80 Axle Hubs - Drive High Strength Steel 10 20 Brake Drums - Drive Aluminum 70 140 Brake Drums - Drive High Strength Steel 5.5 11 Clutch Housing Aluminum 34 40 Clutch Housing High Strength Steel 9 10 Suspension Brackets, Hangers Aluminum 67 100 Suspension Brackets, Hangers High Strength Steel 20 30 Transmission Case Aluminum 45 50 Transmission Case High Strength Steel 11 12 Crossmember

– Cab Aluminum 10 14 15 Crossmember

– Cab High Strength Steel 2 4 5 Crossmember - Non Suspension Aluminum 15 18 21 Crossmember - Non Suspension High Strength Steel 5 6 7 Crossmember - Suspension Aluminum 15 20 25 Crossmember - Suspension High Strength Steel 4 5 6 Driveshaft Aluminum 12 40 50 Driveshaft High Strength Steel 5 10 12 Frame Rails Aluminum 120 300 440 Frame Rails High Strength Steel 24 40 87 Wheels - Dual Aluminum 126 126 210 Wheels - Dual High Strength Steel 48 48 80 Wheels - Dual Lightweight Aluminum 180 180 300 Wheels - Wide Base Single Aluminum 278 278 556

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2 - 133 COMPONENT MATERIAL VOCATIONAL VEHICLE CLASS Class 2b - 5 Class 6 - 7 Class 8 Wheels - Wide Base Single High Strength Steel 168 168 336 Wheels - Wide Base Single Lightweight Aluminum 294 294 588 Permanent 6x2 Axle Configuration Multi N/A N/A 300 

## 2.9.3.6 HFC Leakage EPA believes the capacity of vocational vehicle air conditioning s ys tems are sufficientl y similar to those of other HD vehicles to appl y a similar leakage standard as was applied in the HD Phase 1 program for tractors and HD pickup trucks and vans. Emissi ons due to direct refrigerant leakage are significant in all vehicle types. EPA is proposing a1.50 percent refrigerant leakage per year standard, to assure that high - quality , low - leakage components are used in the design of each air conditioning s ys tem with a refrigerant capacity greater than 733 grams . Since refrigerant leakage past the compressor shaft seal is the dominant source of leakage in belt - driven air conditioning systems, the agency recognizes that this 1.50 percent leakage standard would not b e feasible for s ys tems with a refrigerant capacity of 733 grams or lower, as the minimum feasible leakage rate does not continue to drop as the capacity or size of the air conditioning s ys tem is reduced. The fixed leakage from the compressor seal and other system devices results in a minimum feasible yearly leakage rate, and further reductions in refrigerant capacity

(the ‘denominator’ in the percent refrigerant leakage calculation) would result in a system which could not meet the 1.50 percent leakage per ye ar standard. EPA does not believe that leakage reducing technologies will be available in MY 2021 to enable lower capacity s ys tems to meet the percent per ye ar standard, so we are proposing a maximum gram per year leakage standard of 11.0 grams per ye ar for vocational vehicle air conditioning systems with a refrigerant capacity of 733 grams or lower, as was adopted in the HD Phase 1 program for tractors and HD pickup trucks and vans. The proposed standard is derived from the vehicles with the largest system refrigerant capacity based on the Minnesota GHG Reporting database. 138 

### Th ese are the same data on which the HD Phase 1 HFC leakage standard was based. 139 

### By requiring that all vocational vehicles achieve the leakage level of 1.50 percent per ye ar, roughl y half of the vehicles in the 2010 data sample would need to reduce their leakage rates, and an emissions reduction roughly comparable to that necessary to generate direct emission credits under the light - duty vehicle program would result. See 75 FR at 25426 - 247. However, no credits or trading flexibilities are proposed under this standard for heavy- duty vocational vehicles. We believe that a ye arl y s ys tem leakage approach would assure that high quality , low - leakage, components are used in each A/C system design, and we expect that manufacturers would reduce A/C leakage emissions by utilizing improved, leak- tight components. Some of the improved components available to manufacturers are low -permeation flexible hoses, multiple o - ring or seal washer connections, and multiple - lip compressor shaft seals. The availability

of low leakage components in the market is being driven by the air

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2 - 134 conditioning credit program in the light - duty GHG rulemaking (which applies to 2012 model ye ar and later vehicles). EPA believes that reducing A/C s ys tem leakage is both highly cost effective and technologically feasible. The cooperative industry and government Improved Mobile Air Conditioning (IMAC) program has demonstrated that new - vehicle leakage emissions can be reduced b y 50 percent b y reducing the number and improving the quality of the components, fittings, seals, and hoses of the A/C system. 140 

### All of these technologies are already in commercial use and exist on some of today ’s A/C systems in other heavy- duty vehicles. EPA is proposing to adopt the same compliance method for control of leakage from A/C systems in vocational vehicles as was adopted for the HD Phase 1 HFC le akage standard. Under this approach, manufacturers would choose from a menu of A/C equipment and components used in their vehicles in order to establish leakage scores, which would characterize their A/C system leakage performance and calculate the percent leakage per year as this score divided by the system refrigerant capacity . The agencies estimate the total cost to apply low leakage A/C components to a vocational vehicle to be $22 in MY 2021 and $ 19 in MY 2027 , as described in draft RIA 2.12.4.1. Cons istent with the Light - Duty Vehicle Greenhouse Gas Emissions rulemaking, a manufacturer would compare the components of its A/C system with a set of leakage reduction technologies and actions that is based closel y on that being developed through IMAC and the Society of Automotive Engineers (as SAE Surface Vehicle Standard J2727, August 2008 version). 141 

### See generally 75 FR at 25426. The SAE J2727 approach was developed from laboratory

testing of a variety

of A/C related components, and EPA believes that the J2727 leakage scoring s ys tem generall y represents a reasonable correlation with average real - world leakage in new vehicles. Like the IMAC approach, our proposed approach would associate each component with a specific leakage rate in grams per year identic al to the values in J2727 and then sum together the component leakage values to develop the total A/C system leakage. As is currentl y done for other HD vehicles, for vocational vehicles, the total A/C leakage score would then be divided b y the total refrig erant s ys tem capacity to develop a percent leakage per year value. 

## 2.9.4 **Other Vocational Vehicle Technologies Considered** 2.9.4.1 Vocational Aerody namics The agencies are not predicating the proposed standards on improved aerody namics of vocational vehicles. However, the agencies are proposing to offer an option for manufacturers to receive recognition for a few specific aerodynamic technologies on vehicles where the criteria would be met to qualify

for this credit, should a manufacturer decide to utilize the technology . We are partnering with CARB to incorporate into GEM some data from testing that is being conducted b y CARB through NREL. A test plan is in place to assess the fuel efficiency benefit of three different devices to improve the aerody namic performance of a Class 6 box truck, as well as two devices on a cutaway van. We propose that, if a manufacturer can certify that a final vehicle configuration will closely match one of the configurations on which testing was conducted, then an option may be selected to improve that vehicle’s GEM score based on installation of the applicable aerodyn amic devices. The amount of improvement would be set by

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2 - 135 EPA based on NREL’s test results. This credit provision would apply onl y to vocational vehicles certified over the Region al duty cycle. Manufacturers wishing to receive credit for other aerodynamic technologies or on other vehicle configurations would be able to appl y for innovative credits using the established procedures. Table 2 - 53 shows the vocational aerody namic technologies that are being tested, for which credit could be available through GEM. The agencies have not estimated manufacturing costs for these technologies on vocational vehicles. We project that a manufacturer would onl y apply these where it was found to be cost - effective for the specific application. For a description of the costs estimated for applying aerody namic technologies to tractors, see the draft RIA at Chap ter 2.12.9, where the estimated cost for a Bin2 package on a low roof day cab tractor is shown to be roughly

$1,000. **Table 2**  **- 53**  **Vocational Aerodynamic Technologies Being Assessed** 

### VEHICLE SKIRTS FRONT FAIRING (NOSE CONE ) REAR

FAIRING (TAIL) WHEELCOVERS Class 6 Box Truck X X X Class 4 Box Truck X The vehicles eligible for this GEM -based credit would be those for which the chassis manufacturer can certify

that, through a delegated assembly agreement, the final built configuration would be reasonabl y similar to the dimensions of one of the test vehic les. A description of vehicles and aerodynamic technologies that c ould be eligible for this option , as well as a description of the testing conducted to obtain the assigned GEM improvements due to these technologies , are presented in a memorandum to the docket. 142 

## 2.9.4.2 Electric Vehicles Some heavy- duty vehicles can be powered exclusively b y e lectric motors . Electric motors are efficient and able to produce high torque, giving e - trucks strong driving characteristics, particularly in stop - and- go or urban driving situations, and are wel l - suited for moving heavy loads . Electric motors also offer the ability to operate with very

low noise, an advantage in certain applications . Currently , e - trucks have some disadvantages over conventional vehicles, primarily in cost , weight and range. C omponents are relativel y expensive, and storing electricity using currentl y available technology is expensive, bulky, and heavy. The West Coast Collaborative, a public -private partnership, has estimated the incremental costs for electric Class 3 - 6 trucks in the Los Angeles, CA, area. 143 

### Compared to a conventional diesel, the WCC estimates a battery- electric vehicle system would cost between $70,000 and $90,000 more than a conventional diesel system. The CalHEAT Technology Roadmap includes an estimate that the incremental cost for a fully- electric medium - or heavy- duty vehicle would be between $50,000 and $100,000. Indraft RIA Chapter 2.12.7.6, the agencies estimate the cost

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2 - 136 of a full electric LHD or MHD vocational vehicle at $55,216 in MY 2021 and $52,128 in MY 2024. Th e CalHEAT roadmap report also presents several actions that must be taken by manufacturers and others, before heavy- duty e - trucks can reach what they call Stage 3 Deploy ment. 144 

### Earl y adopters of electric drivetrain te chnology are medium - heavy- duty

vocational vehicles that are not weight - limited and have drive cycles where they don’t need to go far from a central garage. According to CAL START’s report to the NAFA 2014 Institute and Expo , there is an emerging market of MHD all - electric vocational vehicles, including models from Smith, EVI, Boulder, AMP, and others . 126 

### CalHEAT has published results of a comprehensive performance evaluation of three battery electric truck models using information and data from in -use data collection, on road testing and chassis dy namometer testing. 145 

### G iven the high costs and the developing nature of this technology , the agencies do not project full y electric vocational vehicles to be widely commerciall y available in the time frame of the proposed rules. For this reason, the agencies have not based the proposed Phase 2 standards on adoption of full - electric vocational vehicles . Howev er, in the more stringent alternatives discussed in detail in draft RIA Chapter 9, the agencies do project three percent adoption of full electric LHD and MHD vocational vehicles (onl y applicable for MY 2024 for Alternative 5). To the extent this technolo gy is able to be brought to market in the time frame of the Phase 2 program, there is currently a certification path for these chassis from Phase 1, as described in the Preamble Section V and in the regulations at 40 CFR 1037.150 and 49 CFR 535.8. 

## 2.9.5 **Derivati on**  **of the Proposed Vocational Vehicle Technology Packages** The agencies are proposing standards for vocational vehicles predicated on the same suite of technologies in both the 2021 and 2024 MY implementation years. The change in stringency between those years would be a result of different adoption rates of those technologies. Package costs for each model ye ar are presented following each respective adoption rate discussion. 

## 2.9.5.1 Projected Technology Adoption Rates for Vocational Vehicles The agencies have estimated the extent to which technologies may be adopted by manufacturers to meet the proposed 2021 vocational vehicle standards. 

## 2.9.5.1.1 **Transm issions**  The agencies project a compliance path whereb y 30 percent of vocational vehicles would have one or more of the transmission technol ogies identified above in this chapter applied b y MY 2021 , increasing to nearl y 60 percent by MY 2024 and over 80 percent by MY 2027 . Most of this increase is due to a projected increase in adoption of technologies that represent deep driveline integration. The agencies project an adoption rate of 15 percent in MY 2021 and 30 percent in MY 2024 for of various non - hardware technologies that enable driveline optimization, including gear efficiencies, shift strategies, and torque converter l ockups . Manufacturers would use the powertrain test to certify these technology

improvements . Due to the relativel y high efficiency gains available from driveline optimization for relativel y low costs, the agencies are

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2 - 137 projecting a 70 percent application rate of driveline optimization (including the non - hardware enabling technologies) by MY 2027 across all subcategories . W e do not have information about the extent to which integration may be deterred by barriers to information - sharing between component suppliers. Therefore we are projecting that major manufacturers would work to overcome these barriers , integrate and optimize their drivelines , and use the powertrain test on all eligible configurations, while smaller manufacturers may not adopt th ese technologies at all , or not to a degree that they

would find value in this optional test procedure . For the technology

of adding two gears, w e are predicating the proposed MY 2021 standard on a five percent adoption rate, except for zero in the HHD Regional subcategory , which is modeled with a 10 - speed transmission. This adoption rate is projected to essentiall y remain at this level throughout the program, with an increase to ten percent only for two subcatego ries (Regional LHD and MHD) in MY 2027. This is because the manufacturers most likely to develop 8 - speed transmissions are those that are also developing transmissions for HD pickups and vans, and the GEM - certified vocational market share among those manu facturers is relativel y small. The HHD Regional subcategory is the onl y one where we assume a manual transmission in the baseline configuration. For these vehicles, the agencies project upgrade s to electronic transmissions such as either AMT, DCT, or automatic , at collective adoption rates of 51 percent in MY 2021, 68 percent in MY 2024, and five percent in MY 2027. The decrease in MY 2027 reflects a projection that a greater number of deeply integrated HHD powertrains would be used by MY 2027 (one cons equence being that fewer HHD powertrains would be directl y simulated in GEM in that year). The larger numbers in the phase - in years reflect powertrains that have been automated or electrified but not deepl y integrated. The agencies have been careful to account for the cost of both electrifying and deeply integrating the MY 2027 powertrains. In draft RIA Chapter 11, the technology adoption rates for the HHD Regional subcategory presented in Table 11 - 42, Table 11 - 45, and Table 11 - 48 account for the assumption that a manual transmission cannot be deepl y integrated, so there must also be an automation upgrade. These tables are inputs to the agencies’ cost analysis, thus the costs of both upgrading and integrating HHD powertrains are included. The adoption rates of the upgraded but not integrated transmission architectures represent a projection of three percent of all vocational vehicles in MY 2021 and four percent in MY 2024. This is based on an estimate that seven percent of the vocational vehicles would be in the HHD Regional subcategory . For more information about the assumptions that were made about the populations of vehicles in different subcategories, see the agencies’ inventory

estimates in draft RIA Chapter 5. In the eight subcategories in which automatic transmissions are the base technology , the agencies project that five percent would upgrade to a dual clutch transmission in MY 2021. This projection increases to 15 percent in MY 2024 and decreases in MY 2027 to ten percent for two subcategorie s (Regional LHD and MHD) and five percent for the remaining 6 subcategories. The low projected adoption rate s of DCT reflect the fact that this is a relatively new technology for the heavy- duty sector, and it is likely that broader market acceptance would be achieved once fleets have gained experience with the technology . Similar to the pattern described for the HHD Regional subcategory, the decrease in MY 2027 reflects a projection of greater use of deepl y integrated powertrains.

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2 - 138 In determining the proposed standard stringency , we have projected that hy brids on vehicles certified in the Multipurpose subcategories would achieve on average 22 percent improvement, and those in the Urban subcategories would see a 25 percent improvement. We have also projected zero hy brid adoption rate by

vehicles in the Regional subcategories , expecting that the benefit of hy brids for those vehicles would be too low to merit use of that ty pe of technology . However, there is no fixed hy brid value assigned in GEM and the actual improvement over the applicable test cycle would be determined b y powertrain testing. By the full implementation year of MY 2027, the agencies are projecting an overall vocational vehicle adoption rate of ten percent hy brids, which we estimate would be 18 percent of vehicles certified in the Multi - Purpose and Urban subcategories . We are projecting a low adoption rate in the earl y ye ars of the Phase 2 program, just four percent in these subcategories in MY 2021, and seven percent in MY 2024 for vehicles certified in the Multi - Purpose and Urban subcategories. Based on our assumptions ab out the populations of vehicles in different subcategories , these hy brid adop tion rates are about two percent overall in MY 2021 and four percent overall in MY 2024. Considering the combination of the above technologies and adoption rates, we project the CO 2 

### and fuel efficiency

improvements for all transmission upgrades to be appro ximately seven percent on a fleet basis by MY 202 7 . One subcategory in which we are projecting a very large advanced transmission adoption rate is the HHD Regional subcategory , in which we are projecting 75 percent of the transmissions would be either automated or automatic (upgraded from a manual) with 70 percent of those also being deepl y integrated b y M Y 2027. By comparison, the agencies are projecting that HHD day cab tractors would have 90 percent adoption of automated or automatic transmissions by MY 2027. Although we are not prepared to predict what fraction of these would be upgraded in the absence of Phase 2, as noted above in Chapter 2. 9.3 , the agencies are confident that durable transmissions will be widely available in the Phase 2 time frame to support manufacture of HHD vocational vehicles. If the above technologies do not reach the expected level of market adoption, the vocational vehicle Phase 2 program has several other technology options that manufacturers could choose to meet the proposed standards. 

## 2.9.5.1.2 **Axles** The agencies project that 75 percent of vocational vehicles in all subcategories would adopt advanced axle lubricant formulations in all implementation years of the Phase 2 program. Fuel efficient lubricant formulations are widespread across the heavy- duty market, though advanced sy

nthetic formulations are currentl y less popular. N 

### Axle lubricants with improved viscosity and efficiency- enhancing performance are projected to be widel y adopted b y manufacturers in the time frame of Phase 2. Such formulations are commercially available and the agencies see no reason why they could not be feasible for most vehicles. Nonetheless, we have refrained from projecting full adoption of this technology . The agencies do not have specific information regarding reasons why axle manufacturers may specify a specific ty

pe of

N Based on conversations with axle s uppliers.

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2 - 139 lubricant over another, and whether advanced lubricant formulations may not be recommended in all cases. The agencies estimate that 45 percent of HHD Regional vocational vehicles would adopt either full time or part time 6x2 axle technology in MY 2021. This technology is most likely

to be applied to Class 8 vocational vehicles (with 2 rear axles) that are designed for frequent highway trips. The agencies project a slightl y higher adoption rate of 60 percent combined for both full and part time 6x2 axle technologies in MY 2024 and MY 2027 . Based on our estimates of vehicle populations, this is about four percent of all vocational vehicles . 

## 2.9.5.1.3 **Lower Rolling Resistance Tires** The agencies estimate that the per- vehicle average level of rolling resistance from vocational vehicle tires could be reduced b y 1 1 percent by full implementation of the Phase 2 program in MY 2027 , based on the tire development achievements expected over the next decade. This is estimated by weighting the projected improvements of steer tires and drive tires using an assumed axle load distribution of 30 percent on the steer tires and 70 percent on the drive tires, as explained in the draft RIA Chapter 2.9. By appl ying the assumed axle load distribution, the average vehicle CRR improvements projected for the proposed MY 2021 standards would be four percent, which we project would achieve up to one percent reduction in fuel use and CO 2 

### emissions , depending o n the vehicle subcategory . Using that same method, the agencies estimate th e average vehicle CRR in MY 2024 would be seven percent , yielding reduction s in fuel use and CO 2 

### emissions of between one and two percent, depending on the vehicle subcategory . The agencies understand that the vocational vehicle segment has access to a large variety of tires, including some that are designed for tractors, some that are designed for HD pickups and vans, and some with multiple use designations. In spite of the like ly availability

of LRR tires during the Phase 2 program, the projected adoption rates are intended to be conservative. The agencies believe that these tire packages recognize the variety of tire purposes and performance levels in the vocational vehicle ma rket, and maintain choices for manufacturers to use the most efficient tires (i.e. those with least rolling resistance) onl y where it makes sense given these vehicles’ differing purposes and applications. The projected adoption rates and expected improvements in CRR are presented in Table 2 - 54 . **Table 2**  **- 54**  **Projected LRR Tire Adoption Rates** 

### TIRE POSITION LEVEL OF ROLLING

RESISTANCE MY 2021 ADOPTION RATE MY 2024

ADOPTION RATE MY 2027

ADOPTION RATE Drive Baseline CRR (7.7) 50 20 10 Steer Baseline CRR (7.7) 20 10 0 Drive 5% Lower CRR (7.3) 50 50 25 Steer 10% Lower CRR (6.9) 80 30 20 Drive 10% Lower CRR (6.9) 0 30 50 Steer 15% Lower CRR (6.5) 0 60 30 Drive 15% Lower CRR (6.5) 0 0 15 Steer 20% Lower CRR (6.2) 0 0 50

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2 - 140 Drive Average Improvement

in CRR 3% 6% 9% Steer Average Improvement

in CRR 8% 12% 17% 

### For comparison purposes, the reader may note that these levels of tire CRR generall y correspond with levels of tire CRR projected for tractors built for the Phase 1 standards. For example, the baseline level CRR for vocational tires is very similar to the baseline tractor steer tire CRR. Vocational vehicle tires with 10 percent better CRR have a similar CRR level as tractor tires of Drive Level 1. Vocational vehicle tires with 15 percent better CRR have a similar CRR level as tractor tires of Steer Level 1. Vocational vehicle tires with 20 percent better CRR have a similar CRR level as tractor tires of Drive Level 2 , as described in preamble Section III.D.2 . 

## 2.9.5.1.4 **Workday Idle Reduction** In this proposal, we are projecting a progression of idle reduction technology development that begins with 70 percent adoption rate of neutral idle for the MY 2021 standards , which by MY 2027 is replaced by

a 70 percent adoption rate of stop - start idle reduction technology . Although it is possible that a vehicle could have both neutral idle and stop - start, we are onl y considering emissions reductions for vehicles with one or the other of these technologies. Also, as the program phases in, we do not see a reduction in the projected adoption rate of neutral idle to be a concern in terms of stranded investment, because it is a very low cost technology

that could be an enabler for stop - start systems in some cases. We are not projecting any adoption of neutral idle for the HHD Regional subcategory , b ecause any vehicle with a manual transmission must shift to neutral when stopped to avoid stalling the engine, vehicles in the HHD Regional subcategory would already

essentially

be idling in neutral, and no additional technology would be needed to achieve this. A similar case can be made for any vocational vehicle with an automated manual transmission, since these share inherently

similar architectures with manual transmission s. The agencies are not projecting an adoption rate of 85 percent neutral idle until MY 2024, because it may take some additio nal development time to apply this technology

to high - torque automatic transmissions designed for the largest vocational vehicles. Based on stakeholder input, the designs needed to avoid an uncomfortable re - engagement bump when returning to drive from neutral may require some engineering development time as well as some work to enable two - way communication between engines and transmissions. We are projecting a five percent adoption rate of stop - start in the six MHD and LHD subcategories for MY 2021 and zero for the HHD vehicles , because this technology is still developing for vocational vehicles and is most likely to be feasible in the early years of Phase 2 for vehicles with lower power demands and lower engine inertia. Stopping a heavy- duty engine is not challenging. The real challenge is designing a robust system that can deliver multiple smooth restarts daily

without loss of function while the engine is off. Many current light - duty products offer this feature, and some heavy- duty manufacturers are exp loring this. 146 

### The agencies are projecting an adoption rate of 15 percent stop - start across all subcategories in the intermediate ye ar of MY 2024 . The agencies are projecting this technology to have a relativel y

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2 - 141 high adoption rate (70 percent as stated above) b y MY 2027 because we see it being technically feasible on the majority of vocational vehicles, and especiall y effective on those with the most time at idle in their workday operation. Although we are not prepared to predict what fraction of vehicl es would adopt stop - start in the absence of Phase 2, above in draft RIA Chapter 2.9.3 the agencies explain why

we are confident that this technology , which is on the entry- level side of the hy brid and electrification spectrum, will be widely available in the Phase 2 time frame. Based on these projected adoption rates and the effectiveness values described above in this section, we expect overall GHG and fuel consumption reductions from workday idle on vocational vehicles to be approximately three percent in MY 2027 . 

## 2.9.5.1.5 **Weight Reduction** As described in the draft RIA Chapter 2. 12 , weight reduction is a relativel y costly technology , at approximately $3 to $4 per pound for a 200 - lb package . Even so, for vehicles in service classes where dense, heavy loads are frequently carried, weight reduction can translate directly to additional payload. The agencies project weight reduction would most likely be used for vocational vehicles in the refu se and construction service classes, as well as some regional delivery vehicles. The agencies are predicating the proposed standards on an adoption rate of five to eight percent , depending on the subcategory , in MY 202 7, with slightly lower adoption rates in MY 2021 and MY 2024. For this technology

package, NHTSA and EPA project manufacturers would use material substitution in the amount of 200 pounds . An example of how this weight could be reduced would be a complete set of aluminum wheels for a Class 8 vocational vehicle, or an aluminum transmission case plus high strength steel wheels, frame rails, and suspension brackets on a MHD or LHD vocational vehicle. The agencies have limited information about how popular the use of aluminum components is in the vocational vehicle sector . 

## 2.9.5.1.6 **HFC Leakage** We project 100 percent adoption rate in all implementation years of the Phase 2 program for use of low leakage air conditioning system components to reduce direct emissions of HFC compounds from vocational vehicles. 

## 2.9.5.2 Proposed Vocational Vehicle Standards The agencies applied the technology adoption rates shown in Table 2 - 55 through Table 2 - 57 as GEM inputs, but have not directl y transferred the GEM results from these inputs as the proposed standards. Rather, the proposed standards are th e result of the normalizing process described in Chapter 2.9.2.1. The proposed standards are presented in Table 2 - 58 through Table 2 - 63 .

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2 - 142 **Table 2**  **- 55**  **GEM Inputs**  **Used to Derive Proposed**  **MY 2021 Vocational Vehicle Standard**  **s** CLASS 2B - 5 CLASS 6 - 7 CLASS 8 Urban Multi Purpose Regional Urban Multi Purpose Regional Urban Multi Purpose Regional **CI Engine a**  202 1 MY 7L, 200 hp Engine 202 1 MY 7L, 270 hp Engine 202 1 MY 11L, 345 hp Engine 202 1 MY

15L 455hp Engine **Transmission (improvement factor)**  0.023 0.021 0.008 0.023 0.021 0.009 0.023 0.022 0.022 **Axle (improvement factor)**  0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.012 **Stop -**  **Start (adoption rate)**  5% 5% 5% 5% 5% 5% 0% 0% 0% **Neutral Idle (adoption rate)**  70% 70% 70% 70% 70% 70% 70% 70% 0% **Steer Tires (CRR kg/metric ton)** 7.1 7.1 7.1 7.1 7.1 7.1 7.1 7.1 7.1 **Drive Tires (CRR kg/metric ton)** 7. 5 7. 5 7. 5 7. 5 7. 5 7. 5 7. 5 7. 5 7. 5 **Weight Reduction (lb)** 8 8 14 8 8 12 8 8 1 0 Note: a SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results

**Table 2**  **- 56**  **GEM Inputs**  **Used to Derive Proposed**  **MY 2024 Vocational Vehicle Standard**  **s** CLASS 2B - 5 CLASS 6 - 7 CLASS 8 Urban Multi Purpose Regional Urban Multi Purpose Regional Urban Multi Purpose Regional **CI Engine a**  2024 MY 7L, 200 hp Engine 2024 MY 7L, 270 hp Engine 2024 MY 11L, 345 hp Engine 2024 MY

15L 455hp Engine **Transmission (improvement factor)**  0.045 0.04 0.017 0.045 0.041 0.018 0.045 0.042 0.035 **Axle (improvement factor)**  0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.014 **Stop -**  **Start (adoption rate)**  15% 15% 15% 15% 15% 15% 15% 15% 15% **Neutral Idle (adoption rate)**  85% 85% 85% 85% 85% 85% 85% 85% 0% **Steer Tires (CRR kg/metric ton)** 6.8 6.8 6.8 6.8 6.8 6.8 6.8 6.8 6.8 **Drive Tires (CRR kg/metric ton)** 7. 3 7. 3 7. 3 7. 3 7. 3 7. 3 7. 3 7. 3 7. 3 **Weight Reduction (lb)**

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2 - 143 8 8 14 8 8 12 8 8 1 0 Note: a SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results

**Table 2**  **- 57**  **GEM Inputs**  **Used to Derive Proposed**  **MY 202 7**  **Vocational Vehicle Standard**  **s** CLASS 2B - 5 CLASS 6 - 7 CLASS 8 Urban Multi Purpose Regional Urban Multi Purpose Regional Urban Multi Purpose Regional **CI Engine a**  202 7 MY 7L, 200 hp Engine 202 7 MY 7L, 270 hp Engine 202 7 MY 11L, 345 hp Engine 202 7 MY

15L 455hp Engine **Transmission (improvement factor)**  0.096 0.085 0.034 0.096 0.088 0.037 0.097 0.089 0.036 **Axle (improvement factor)**  0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.004 0.014 **Stop -**  **Start (adoption rate)**  75% 70% 70% 75% 70% 70% 70% 70% 70% **Neutral Idle (adoption rate)**  25% 30% 30% 25% 30% 30% 30% 30% 0% **Steer Tires (CRR kg/metric ton)** 6.4 6.4 6.4 6.4 6.4 6.4 6.4 6.4 6.4 **Drive Tires (CRR kg/metric ton)** 7. 0 7. 0 7. 0 7. 0 7. 0 7. 0 7. 0 7. 0 7. 0 **Weight Reduction (lb)** 10 1 0 16 10 10 14 10 1 0 12 Note: a SI engines were not simulated in GEM, rather a gas/diesel adjustment factor was applied to the results 

### Table 2 - 58 and Table 2 - 59 present EPA’s proposed CO 2 

### standards and NHTSA’s proposed fuel consumption standards, respectively, for chassis manufacturers of Class 2b through Class 8 vocational vehicles for the beginning model year of the program, MY 2021 . As in Phase 1, the standards would be in the form of the mass of emissions , or gallons of fuel, associated with carrying a ton of cargo over a fixed distance . The EPA standards would be measured in units of grams CO 2 

### per ton - mile and the NHTSA standards would be in gallons of fuel per 1,000 ton - miles. With the mass of freight in the denominator of this term, the program is designed to measure improved efficiency in terms of freight efficiency . As in Phase 1, the Phase 2 program would assign a fixed default payload in GEM for each vehicle weight class group (heavy heavy- duty, medium heavy- duty, and light heavy- duty) . Even though this simplification does not allow individual vehicle freight effi ciencies to be recognized, the general capacity for larger vehicles to carry more payload is represented in the numerical values of the proposed standards for each weight class group.

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2 - 144 **Table 2**  **- 58**  **Proposed EPA CO**  **2 Standards for MY2021 Class 2b**  **- 8 Vocational Vehicles**  

### EPA Standard f

or Vehicle with C I Engine Effective MY2021 ( gram C O 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 29 6 18 8 19 8 Multi - Purpose 30 5 1 90 200 Regional 3 18 18 6 1 89 EPA Standard for Vehicle with SIEngine Effective MY2021 (gram CO 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 320 203 214 Multi - Purpose 329 20 5 216 Regional 343 201 204

**Table 2**  **- 59**  **Proposed NHTSA Fuel Consumption Standards for MY2021 Class 2b -**  **8 Vocational Vehicles** 

### NHTSA Standard f

or Vehicle with C I Engine Effective MY 2021 (Fuel Consumption g allon p er 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 29.0766 18.4676 19.4499 Multi - Purpose 29.9607 18.6640 19.6464 Regional 31.2377 18.2711 18.5658 NHTSA Standard for Vehicle with SIEngine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 36.0077 22.8424 24.0801 Multi - Purpose 37.0204 23.0674 24.3052 Regional 38.5957 22.6173 22.9549 EPA’s proposed vocational vehicle CO 2 

### standards and NHTSA’s proposed fuel consumption standards for the MY 2024 stage of the program are presented in Table 2 - 60 and Table 2 - 61 , respectivel y . These reflect broader adoption rates of vehicle technol ogies already considered in the technology basis for the MY 2021 standards. The standards for vehicles powered b y CI engine s also reflect that in MY 2024, the separate engine standard would be more stringent, so the vehicle standard keeps pace with the engine standard.

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2 - 145 **Table 2**  **- 60**  **Proposed EPA CO 2**  **Standards for MY2024 Class 2b -**  **8 Vocational Vehicles** 

### EPA Standard f

or Vehicle with C I Engine Effective MY2024 (gram C O 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 28 4 1 79 1 90 Multi - Purpose 29 2 1 81 1 92 Regional 3 04 17 8 1 82 EPA Standard for Vehicle with SIEngine Effective MY2024 (gram CO 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 3 12 1 97 208 Multi - Purpose 3 21 19 9 210 Regional 3 34 196 199

**Table 2**  **- 61**  **Proposed NHTSA Fuel Consumption Standards for MY2024 Class 2b -**  **8 Vocational Vehicles** 

### NHTSA Standard f

or Vehicle with CI Engine Effective MY 2024 (Fuel Consumption g allon p er 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 27. 8978 17. 5835 18. 6640 Multi - Purpose 28. 6837 17.7800 18. 8605 Regional 29. 8625 17. 4853 17. 8782 NHTSA Standard for Vehicle with SIEngine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 35.1075 22.1672 23.4050 Multi - Purpose 36.1202 22.3923 23.6300 Regional 37.5830 22.0547 22.3923 EPA’s proposed vocational vehicle CO 2 

### standards and NHTSA’s proposed fuel consumption standards for the full implementation year of MY 2027 are presented in Table 2 - 62 and Table 2 - 63 , respectively . These reflect even greater adoption rates of the same vehicle technologies considered in the basis for the previous stages of the Phase 2 standards. The proposed MY 2027 standards for vocational vehicles powered b y CI engine s reflect additional engine technologies consistent with those on which the separate proposed MY 2027 CIengine standard is based. The proposed MY 2027 standards for v ocational vehicles powered b y S I engine s reflect improvements due to additional engine friction reduction technology , which is not among the technologies on which the separate SIengine standard is based.

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2 - 146 **Table 2**  **- 62**  **Proposed EPA CO 2**  **Standards for MY202 7**  **Class 2b -**  **8 Vocational Vehicles** 

### EPA Standard f

or Vehicle With CI Engine Effective MY202 7 (gram CO 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 272 172 182 Multi - Purpose 280 174 183 Regional 292 170 174 EPA Standard for Vehicle with SIEngine Effective MY202 7 (gram CO 2

### /ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 299 189 196 Multi - Purpose 308 191 198 Regional 321 187 188

**Table 2**  **- 63**  **Proposed NHTSA Fuel Consumption Standards for MY2027**  **Class 2b -**  **8 Vocational Vehicles** 

### NHTSA Standard For Vehicle With C I Engine Effective MY 202 7 (Fuel Consumption Gallon p er 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 26.7191 16.8959 17.8782 Multi - Purpose 27.5049 17.0923 17.9764 Regional 28.6837 16.6994 17.0923 NHTSA Standard for Vehicle with SIEngine Effective MY 202 7 (Fuel Consumption gallon per 1,000 ton - mile) Duty C ycle Li ght Heavy- Duty

Class 2b - 5 Medium Heavy- Duty

Class 6 - 7 Heavy Heavy- Duty

Class 8 Urban 33.6446 21.2670 22.0547 Multi - Purpose 34.6574 21.4921 22.2797 Regional 36.1202 21.0420 21.1545 

## 2.9.5.3 Summary of Vocational Vehicle Package Costs The agencies have estimated the costs of the technologies expected to be used to comply with the proposed standards. Table 2 - 64 presents estimated incremental c osts for MY2021 for light, medium and heavy HD vocational vehicles in each duty- cycle -based subcategory

– Urban, Multi - Purpose, and Regional. As shown, in MY 2021 these range from approximately $600 for MHD and LHD Regional vehicles, up to $3,400 for HHD Regional vehicles. Those two lowercost packages reflect zero hy brids, and the higher - cost package reflects significant adoption of automated transmissions. Inthe draft RIA Chapter 2.13, the agencies present vocational vehicle

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2 - 147 technology

package costs differentiated by MOVES vehicle ty

pe. For example, in Table 2 - 231, intercity buses are estimated to have an average package cost of $2,900 and gasoline motor homes are estimated to have an average package cost of $450 in MY 2021. These costs do not indicate the per - vehicle cost that may be incurred for any individual technology . Chapter 2.12.7 describes why a complex technology such as hy

bridization is estimated to range between $15,000 and $40,000 per vehicle for vocational vehicles in MY 2021. The engine costs listed represent the cost of an average package of diesel engine technologies. Individual technology adoption rates for engine packages are describe d above in Chapter 2.7. The details behind these costs are presented in draft RIA Chapter 2.12 , including the markups and learning effects applied and how the costs shown here are weighted to generate an overall cost for the vocational se ctor. **Table 2**  **- 64**  **Technology Package Incre**  **mental Costs for Vocational Vehicles for MY 20**  **21 a,b**  **(2012 $)** 

LIGHT HD MEDIUM HD HEAVY HD Urban Multi purpose Regional Urban Multi purpose Regional Urban Multi purpose Regional Engine c $293 $293 $293 $270 $270 $270 $270 $270 $270 Tires $7 $7 $7 $7 $7 $7 $7 $7 $7 Transmission $81 $81 $81 $81 $81 $81 $81 $81 $2,852 Axle related $99 $99 $99 $99 $99 $99 $148 $148 $219 Weight Reduction $27 $27 $48 $27 $27 $41 $27 $27 $34 Idle reduction $49 $49 $49 $51 $51 $51 $6 $6 $0 Electrification & hybridization $547 $547 $0 $861 $861 $0 $1,437 $1,437 $0 Air Conditioning $22 $22 $22 $22 $22 $22 $22 $22 $22 Total $1,125 $1,125 $598 $1,418 $1,418 $571 $1,998 $1,998 $3,404 Notes: a Costs shown are for the 2021 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to draft RIA Chapter 2.12. b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated vehicle subcategories. c Engine costs shown are for a light HD, medium HD or heavy HD diesel engine s . For gasoline -powered vocational vehicles we are projecting no additional engine -based costs beyond Phase 1. 

### Table 2 - 65 presents estimated incremental c osts for MY202 4 for light, medium and heavy HD vocational vehicles in each duty- cycle - based subcategory

– Urban, Multi - Purpose, and Regional. As shown, these range from approximately $800 for MHD and LHD Regional vehicles, up to $4,800 for HHD Regional vehicles. The increased costs above the MY 2021 values reflect increased adoption rates of individual technologies, while the individual technology

costs are generall y expected to remain the same or decrease, as explained in the draft RIA Chapter 2.12. For example, Chapter 2.12.7 presents MY 2024 hy bridization costs that range from $13,000 to $33,000 per vehicle for vocational vehicles.

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2 - 148 **Table 2**  **- 65**  **Technology Package Incre mental Costs for Vocational Vehicles for MY** **20 24**  **a,b (2012**  **$)** LIGHT HD MEDIUM HD HEAVY HD Urban Multi purpose Regional Urban Multi purpose Regional Urban Multi purpose Regional Engine c $437 $437 $437 $405 $405 $405 $405 $405 $405 Tires $17 $17 $17 $17 $17 $17 $23 $23 $23 Transmission $123 $123 $123 $123 $123 $123 $123 $123 $3,915 Axle related $90 $90 $90 $90 $90 $90 $136 $136 $224 Weight Reduction $24 $24 $43 $24 $24 $37 $24 $24 $30 Idle reduction $119 $119 $119 $125 $125 $125 $224 $224 $217 Electrification & hybridization $906 $906 $0 $1,423 $1,423 $0 $2,377 $2,377 $0 Air Conditioning $20 $20 $20 $20 $20 $20 $20 $20 $20 Total $1,737 $1,737 $849 $2,228 $2,228 $817 $3,332 $3,332 $4,834 Notes: a Costs shown are for the 2024 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to draft RIA Chapter 2.12. b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated vehicle subcategories. c Engine costs shown are for a light HD, medium HD or heavy HD diesel engine s . For gasoline -powered vocational vehicles we are projecting no additional engine -based costs beyond Phase 1. 

### Table 2 - 66 presents estimated incremental c osts for MY202 7 for light, medium and heavy HD vocational vehicles in each duty- cycle - based subcategory

– Urban, Multi - Purpose, and Regional. As shown, these range from approximately $1,400 for MHD and LHD Regional vehicles, up to $7,400 for HHD Urban and Multipurpose vehicles. These two subcategories are projected to have the higher- cost packages in MY 2027 due to an estimated 18 percent adoption of HHD hy

brids, which are estimated to cost $31,000 per vehicle in MY 2027, as shown in Chapter 2.12.7 of the draft RIA. The engine costs shown represent the average costs associated with the proposed MY 2027 vocational diesel engine standard described in Secti on II.D. For gasoline vocational vehicles, the agencies are projecting adoption of Level 2 engine friction reduction with an estimated $68 added to the average SI vocational vehicle package cost in MY 2027, which represents about 56 percent of those vehic les upgrading beyond Level 1 engine friction reduction. Further details on how these SI vocational vehicle costs were estimated are provided above in Chapter 2.9 .1 .

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2 - 149 **Table 2**  **- 66**  **Technology Package Incre mental**  **Costs for Vocational Vehicles for MY 20**  **27 a,b**  **(2012 $)**  LIGHT HD MEDIUM HD HEAVY HD Urban Multi purpose Regional Urban Multi purpose Regional Urban Multi purpose Regional Engine c $471 $471 $471 $437 $437 $437 $437 $437 $437 Tires $20 $20 $20 $20 $20 $20 $29 $29 $29 Transmission $244 $244 $267 $244 $244 $267 $244 $244 $2,986 Axle related $86 $86 $86 $86 $86 $86 $129 $129 $215 Weight Reduction $29 $29 $46 $29 $29 $40 $29 $29 $35 Idle reduction $498 $499 $499 $526 $526 $526 $964 $964 $962 Electrification & hybridization $2,122 $2,122 $0 $3,336 $3,336 $0 $5,571 $5,571 $0 Air Conditioning $19 $19 $19 $19 $19 $19 $19 $19 $19 Total $3,489 $3,490 $1,407 $4,696 $4,696 $1,395 $7,422 $7,422 $4,682 Notes: a Costs shown are for the 2024 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to draft RIA Chapter 2.12. b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated vehicle subcategories. c Engine costs shown are for a light HD, medium HD or heavy HD diesel engine s . For gasoline -powered vocational vehicles we are projecting $ 68 of additional engine -based costs beyond Phase 1. 

## 2.9.6 **Technologies and Costs of Alternati** **ve 4**  2.9.6.1 Derivation of Alternative 4 Standards 2.9.6.1.1 **Adoption Rates** In developing the Alternative 4 standards, the agencies are projecting a set of technology packages in MY 2024 that is identical to those projected for the final phase - in year of the preferred alternative. In the package descriptions below, the agencies outline technologyspecific adoption rates in MY 2021 for Alternative 4 and offer insights on what market conditions could enable reaching adoption rates that would achieve the full implementation levels of stringency

with less lead time. For transmissions including hybrids, the agencies project for Alternative 4 that 50 percent of vocational vehicles would have one or more of the transmission technologies identified above in this Section applied by MY 2021. This includes 25 percent deepl y integrated conventional transmissions that would be recognized over the powertrain test, 10 percent DCT, 11 percent adding two gears (except zero for HHD Regional), and nine percent hybrids for vehicles certified in the Multi - Purpose and Urban subcategories, which we estimate would be five percent overall. In this alternative, the agencies project 21 percent of the vocational vehicles with manual transmissions in the HHD Regional subcategory would upgrade to either an AMT, DCT, or automatic transmission. The increased projection of driveline integration would mean that more manufacturers would need to overcome data- sharing barriers. In this alternative, we project that manufacturers would need to conduct additional research and development to achieve overall application of five percent hy brids. In the draft RIA Chapter 7.1, the agencies have estimated

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2 - 150 costs for this additional accelerated research. In the preamble at Section V, the agencies request c omment on the expected costs to accelerate hyb rid development to meet the projected adoption rates of this alternative. For advanced axle lubricants, the agencies are projecting the same 75 percent adoption rate in MY 2021 as in the proposed program. For part time or full time 6x2 axles, the agencies pro ject the HHD Regional vocational vehicles could apply this at the 60 percent adoption rate in MY 2021, where this level wouldn’t be reached until MY 2024 in the proposed program. One action that could enable this to be achieved is if information on the rel iability of these s ys tems were to be disseminated to more fleet owners b y trustworthy sources. For lower rolling resistance tires in this alternative, the agencies project the same adoption rates of LRR tire s as in the proposed program for MY 2021, because we don’t expect tire suppliers would be able to make greater improvements for the models that are fitted on vocational vehicles in that time frame . The tire research that is being conducted currentl y is focused on models for tractors and trailers, and we project further improved LRR tires would not be commercially

available for vocational vehicles in the earl y implementation years of Phase 2. For the adoption rate of LRR tire s in MY 2024 to reach the level projected for MY 2027 in th e proposed program, tire suppliers could promote their most efficient products to vocational vehicle manufacturers to achieve equivalent improvements with less lead time. Depending on how tire manufacturers focus their research and product development, it is possible that more of the LRR tire advancements being applied for tractors and trailers could be a pplied to vocational vehicles. To see the specific projected adoption rates of different levels of LRR tires for Alternative 4, see columns three and five of Table 2 - 54 above . For workday

idle technologies, the agencies project an adoption rate of 12 percent stop start in the six MHD and LHD subcategories for MY 2021 and zero for the HHD vehicles , on the expectation that manufacturers would have fewer challenges in the short term in bringing this technology

to market for v ehicles with lower power demands and lower engine inertia . In this alternative, the agencies proje ct the overall workday idle adoption rate would approach 100 percent, such that any vehicle without stop - start (except HHD Regional) would apply neutral idle in MY 202 1. These adoption raters consider a more aggressive investment by manufacturers in developing th e s e technologies . Estimates of research and development costs for this alternative are presented in the draft RIA Chapter 7.1. For weight reduction, in this alternative, the agencies project the same adoption rates of a 200 - lb lightweighting package as in the proposal for each subcategory in MY 2021, which is four to seven percent. 

## 2.9.6.1.2 **Costs Associated with Alternative 4**  **Standards** The agencies have estimated the costs of the technologies expected to be used to comply with the Alternative 4 standards , as shown in Table 2 - 67 for MY2021. Fleet average c osts are shown for light, medium and heavy HD vocational vehicles in each duty- cycle -based subcategory

– Urban, Multi - Purpose, and Regional. As shown, in MY 2021 these range from approximately

$800 for MHD and LHD Regional vehicles, to $4,300 for HHD Urban and

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2 - 151 Multipurpose vehicles . Those two subcategories are projected to have the higher- cost packages in MY 2021 due to an estimated 9 percent adoption of HHD hybrids, which are estimated to cost $40,000 per vehicle in MY 2021, as shown in Chapter 2.12.7 of the draft RIA . The engine cos ts listed represent the cost of an average package of diesel engine technologies with Alternative 4 adoption rates described in the preamble at Section II.D.2(e) . **Table 2**  **- 67**  **Vocational Vehicle Technology Incremental Costs for Alternative 4**  **Standards in the 2021 Model Year**  **a,b (2012$)**  LIGHT HD MEDIUM HD HEAVY HD Urban Multi purpose Regional Urban Multi purpose Regional Urban Multi purpose Regional Engine c $372 $372 $372 $345 $345 $345 $345 $345 $345 Tires $7 $7 $7 $7 $7 $7 $7 $7 $7 Transmission $148 $148 $148 $148 $148 $148 $148 $148 $2,042 Axle related $99 $99 $99 $99 $99 $99 $148 $148 $243 Weight Reduction $27 $27 $48 $27 $27 $41 $27 $27 $34 Idle reduction $110 $110 $110 $116 $116 $116 $8 $8 $0 Electrification & hybridization $1,384 $1,384 $0 $2,175 $2,175 $0 $3,633 $3,633 $0 Air Conditioning $22 $22 $22 $22 $22 $22 $22 $22 $22 Total $2,169 $2,169 $805 $2,938 $2,938 $777 $4,337 $4,337 $2,693 Notes: a Costs shown are for the 2021 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to draft RIA Chapter 2.12. b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated vehicle classes. c Engine costs are for a light HD, medium HD or heavy HD diesel engine. We are projecting no additional costs beyond Phase 1 for gasoline vocational engines in MY2021 under this alternative . 

### The estimated costs of the technologies expected to be used to comply with the Alternative 4 standards for MY202 4 are shown in Table 2 - 68 . Fleet average c osts are shown for light, medium and heavy HD vocational vehicles in each duty- cycle -based subcategory

– Urban, Multi - Purpose, and Regional. As shown, these range from appro ximately $1,500 for MHD and LHD Regional vehicles to $7,900 for HHD Urban and Multipurpose vehicles. These two subcategories are projected to have the higher- cost packages in MY 2024 due to an estimated 18 percent adoption of HHD hy brids, which are estimated to cost $33,000 per vehicle in MY 2024, as shown in Chapter 2.12.7 of the draft RIA. The engine costs listed represent the cost of an average package of diesel engine technologies with Alternative 4 adoption rates described in the preamble at Section II.D.2(e). For gasoline vocational vehicles, the agencies are projecting adoption of Level 2 engine friction reduction with an estimated $74 added to the average SI vocational vehicle package cost in MY 2024, which represents about 56 percent of those vehicles upgrading beyond Level 1 engine friction reduction. Further details on how these SI vocational vehicle costs were estimated are provided above in Chapter 2.9.1. The details behind all these costs are presented in draft RIA Chapter 2 .12 , including the markups and learning effects applied

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2 - 152 and how the costs shown here are weighted to generate an overall cost for the vocational vehicle segment . **Table 2**  **- 68**  **Vocational Vehicle Technology Incremental Costs for Alternative 4**  **Standards in the 2024 Model Year**  **a,b (2012$)**  LIGHT HD MEDIUM HD HEAVY HD Urban Multi purpose Regional Urban Multi purpose Regional Urban Multi purpose Regional Engine c $493 $493 $493 $457 $457 $457 $457 $457 $457 Tires $26 $26 $26 $26 $26 $26 $40 $40 $40 Transmission $256 $256 $280 $256 $256 $280 $256 $256 $3,123 Axle related $90 $90 $90 $90 $90 $90 $136 $136 $224 Weight Reduction $30 $30 $49 $30 $30 $43 $30 $30 $37 Idle reduction $561 $524 $524 $592 $553 $553 $1,014 $1,014 $1,011 Electrification & hybridization $2,264 $2,264 $0 $3,559 $3,559 $0 $5,943 $5,943 $0 Air Conditioning $20 $20 $20 $20 $20 $20 $20 $20 $20 Total $3,741 $3,704 $1,482 $5,030 $4,992 $1,469 $7,895 $7,895 $4,912 Notes: a Costs shown are for the 2024 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it im pacts technology costs for other years, refer to draft RIA Chapter 2.12. b Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the indicated vehicle subcategories. Estimated technology costs exclusive of adoption rates are discussed in RIA 2.12. c Engine costs shown are for a light HD, medium HD or heavy HD diesel engine s . For gasoline -powered vocational vehicles we are projecting $ 74 of additional engine -based costs beyond Phase 1 in MY2024 . 

## 2.10 **Technology Application and Estimated Costs –**  **Trailers** The agencies are proposing standards for trailers specificall y designed to be pulled by Class 7 and 8 tractors . These proposed standards are expressed as CO 2 

### and fuel consumption standards, and would apply to each trailer with respect to the emissions and fuel consumption that would be expected for a specific standard typ e of tractor pulling such a trailer . EPA and NHTSA believe it is appropriate to establish standards for trailers separately from tractors because they

are separately

manufactured by

distinct companies; the agencies are not aware of any manufacturers that currentl y assemble both the finished tractor and the trailer. This section of the draft RIA describes the anal ys es performed by the agencies as we developed the proposed trailer program. 

## 2.10.1 **Trailer Subcategories Evaluated** The agencies evaluated several trailer subcategories for this proposal. Though many of the same technologies are available for dry and refrigerated vans, the agencies evaluated these trailer types separatel y. The transport refrigeration unit (TRU) commonly located at the front of refrigerated trailers adds weight, has the potential to impact the aerodyn amic characteristics of the trailer, and may

limit the ty

pe of aerody

namic devices that can be applied. Additionally , “long box” trailers in lengths 50 feet or longer and “short box” trailers less than 50 feet in length were evaluated separately due to differences in both weight and use patterns.

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2 - 153 The agencies identified a list of work-performing devices that are sometimes added to standard box trailers, which may inhibit the use of some aerodyn amic devices. The agencies are proposing to recognize box trailers that are restricted from using aerodyn amic devices in one location on the trailer as “partial - aero ” box trailers. We believe these trailers have the ability to adopt some aerodyn amic technologies, but do not expect them to be able to meet the same stringencies as the standard box vans. Additionally , we propose to consider box trailers that have work -performing devices in two locations such that they inhibit the use of all practical aerodyn amic devices to be “non - aero ” box trailers that would be not be expected to adopt aerodynamic technologies at any point in the program. The agencies are proposing that the non - aero box trailer subcategory include box trailers with more than three axles, since they are designed to be u sed in heavy- haul applications where aerodyn amic devices are not generall y practical. The agencies evaluated all non -box highway trailers (e.g., tankers, platforms, and car haulers) as a single representative trailer assuming a single stringency level fo r all trailers within the subcategory . These stringency levels did not include the use of aerodynamic technologies. In summary , the agencies are proposing ten trailer subcategories:

– Long box (longer than 50 feet) dry vans

– Long box (longer than 50 fe et) refrigerated vans

– Short box (50 feet and shorter) dry vans

– Short box (50 feet and shorter) refrigerated vans

– Partial - aero l ong box dry vans

– Partial - aero l ong box refrigerated vans

– Partial - aero s hort box dry vans

– Partial - aero sh ort box refrigerated vans

– Non - aero box vans (all lengths of dry and refrigerated vans)

– Non -box highway

(tanker, platform, container chassis, and all other ty pes of highway trailers that are not box trailers). The partial - aero box trailers would have similar stringencies as the ir corresponding full - aero trailers in the earl y phase - in years, but would have separate, reduced standards as the program becomes full y implemented . The an al ys is in the following sections describes our evaluation of two alternative stringencies with similar technologies . In the first anal ys is we projected adoption rates that were used to develop the proposed standards in MY 2027 . The second anal ys is considers the same technologies with less lead time to achieve similar adoption rates. The agencies did consider an alternative that differentiated tanker trailers, platform trailers, and container chassis from the other non - box highway trailers to include aerodynamic technologies on a fraction of these trailer ty pes. However, an evaluation of this alternative is not included here. As discussed in Section IV of the preamble for this proposal, a majority of the

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2 - 154 non -box trailer manufacturers meet the definition o f small business . O 

### EPA convened and the agencies are proposing to follow the reco mmendations of the Small Business Advocacy Review panel required b y the Small Business Regulatory Enforcement Fairness Act (SBREFA). This panel concluded that aerody namic requirements for non -box trailer manufacturers would disproportionately

burden small manufacturers and they recommended that no aerody namic requirements be proposed. 

## 2.10.2 **Defining the Proposed Trailer Technology Packages** The impact of a trailer on the overall fuel efficiency and CO 2 

### emissions of a tractor- trailer vehicle varies depending on three main characteristics of the trailer: aerodynamic drag, rolling resistance, and weight. In this section, we outline the technologies that the agencies evaluated for the proposed standards. 

## 2.10.2.1 Aerody

namic Drag Reduction The rigid, rectangular shape of b ox trailers creates significant aerodyn amic drag and makes them ideal candidates for aerodyn amic technologies that can reduce drag and improve fuel consumption and CO 2 

### emissions. Current aerodynamic technologies for box trailers have shown significant drag reductions, as discussed below. These technologies are designed to create a smooth transition of airflow from the tractor, around the trailer, and beyond the trailer. Box trailers provide opportunities to address drag at the front, rear, and underside of the trailer, and the agencies considered several types of aerodynamic devices designed to address drag at all of these points. Table 2 - 69 lists general aerodynamic technologies that the EPA SmartWay program has evaluated for use on box trailers and a description of their intended impact. Several versions of each of these technologies are commercially available and have seen increased adoption over the past decade. Performance of these devices varies based on their design, their location and orientation on the trailer, and the vehicle speed. **Table 2**  **- 69**  **Aerodynam ic Technologies for Box Trailers**  LOCATION ON TRAILER EXAMPLE TECHNOLOGIES INTENDED IMPACT ON AERODYNAMICS Front Front fairings and gap -reducing

fairings Reduce cross - flow through gap and smoothly transition airflow from tractor to the trailer Rear Rear fairings, boat tails and flow

diffusers Reduce pressure drag induced by the trailer wake Underside Side fairings and skirts, and

underbody devices Manage flow of air underneath the trailer to reduce turbulence, eddies and wake 

## 2.10.2.1.1 **Performance of Aerodynamic Technologies**  SmartWay- verified technologies are evaluated on 53 - foot dry vans . The verified technologies are grouped into bins that represent one percent, four percent, or five percent fuel

O The Regulatory Flexibility Act defines small entities as including “small businesses,” “small governments,” and “small organizations” (5 USC 601) and references the Small Business Act for the definition of “small businesses” using size standard s based on the North American Industry Classification System (NAICS) (13 CFR 121.201).

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2 - 155 savings relative to a typical long - haul tractor - trailer at 65 - mph cruise conditions. Use of verified aerodynamic devices totaling at least five percent fuel savings, along with verified tires, qualifies a 53 - foot dry

van trailer for the “SmartWay Trailer” designation. In 2014, EPA expanded the program to include refrigerated vans and provided a “SmartWay Elite” des ignation if fleets adopt verified tires and aerodynamic equipment providing nine percent or greater fuel savings. To date, nine aerodynamic technology packages from five manufacturers have received the SmartWay

Elite designation. We may refer to SmartWay verification levels in this analysis, since the trailer industry

is most familiar with these values as a measure of trailer performance. It is important to note that the cruise speed results presented in SmartWay do not necessarily

represent performance that would be observed in real world operatio n. Additionally , EPA’s Greenhouse gas Emissions Model ( GEM ) , which is the tool the agencies are proposing to use for trailer compliance, uses a weighte d average of thre e drive cycles in its vehicle simulation . The CO 2 

### and fuel consumption reductions calculated in GEM may differ from those measured in SmartWay ’s performance tests . Figure 2 - 17 s hows a comparison of the CO 2 

### reductions observed for the three individual drive cycles simulated in GEM and the reductions using a combination of the three GEM cycles with the cycle weighting s assigned to long - haul tractor- trailers in this prop osed rulemaking (i.e., 86 percent 65 - mph cruise, 9 percent 55 - mph cruise, and 5 percent transient). These results could be used to estimate the difference in performance when comparing a constant, 65 - mph cruise test similar to SmartWay ’s performance tests or the results from GEM simulations used for compliance to other driving conditions. These results suggest that the SmartW ay

Elite target improvement of nine percent would be closer to eight percent using GEM’s long - haul simulation. Itcan also be seen that very little benefit is seen for tractortrailers driving under highly transient conditions. These results are for illustrative purposes onl y and do not provide an exact correlation between test results , real - world results, and results from GEM.

**0% 2%**  **4% 6%**  **8% 10%**  **12% 14%**  **16%**

4.0 4. 5 5. 0 5.5 6.0 6.5**C O** **2 R** **e d** **u c** **t i** **o n** **s (** **% )** 

**Aer odynami**  **c Dr**  **ag Ar**  **ea, C**  **dA (**  **m2)** 

### CO2 **Reductions for Simulated Long -**  **Haul Dry**  **V an**  **(Compare G EM**  **Cy cl**  **es)**

**65 -**  **MP H**  **Cr ui**  **se Long**  **- Haul**  **Weighted 55**  **- MP**  **H Cr** **ui se**  **Tr ansient**  **SmartWay Verified**  **Sm artWay**  **Elite**

**Figure 2**  **- 17**  **Com parison of Weighted and 65**  **- mph Cruise Results using EPA's GEM for a Long Dry Van** 

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2 - 156 In this analysis, the aerody namic performance of a tractor- trailer vehicle is quantified by the aerodyn amic drag area, CdA (coefficient of drag multiplied by frontal area), which is a function of both tractor and trailer aerodynamic characteristics. EPA’s aerody namic testing of Class 8 high roof sleeper cab tractors pulling standard 53 - foot dry vans with zero aerody namic technologies produced an average CdA value of 6.2 m2 

### in coastdown testing and an average zero - yaw CdA value of 5.5 m2 

### in wind tunnel testing (see Chapter 3.2.4.1). EPA also performed wind tunnel tests on a Class 7 high roof day cab pulling several configurations of a solo 28 - foot dry van trailer and two tandem 28 - foot dry van trailers . The average zero - yaw CdA value for the solo 28 - foot trailer configuration with zero aerodynamic technologies was 5.4 m2 

### (a two percent difference compared the corresponding test of the 53 - foot trailer). For this anal ys is, EPA grouped the se common aerody namic devices into packages of individual or combined technologies. Front fairings and gap reducers provide the smallest benefit of the aerodyn amic technologies considered. Skirts and boat tails come in ranges of sizes and vary in effectiveness. For the purpose of this anal ys is, the agencies grouped these two technologies into “basic” and “advanced”. Basic boat tails and skirts achieve SmartWay ’ s verification threshold of four percent at cruise speeds. Advanced tails and skirts achieve SmartWay ’s five percent verification. These technologies can be used individually , or in combination. The overall performance of a combination of devices could be nearl y additive in terms of the effectiveness of its individual devices. Some devices may work sy nergistically

to achieve greater reductions or counteract and provide less reduction. The trailer aerody namics industry continues to evolve and the agenci es anticipate further optimization of these devices in the future. In addition to these bolt - on technologies, some manufacturers are experimenting with physical changes to the trailer design such that the overall construction of the trailer is more aerody namic. EPA collected aerodynamic test data for many of the technologies mentioned previousl y on several tractor- trailer configurations, including 53 - foot dry vans and 28 - foot dry

van pup trailers. As described in Chapter 3, EPA’s aerodynamic testing included four tractor models, three trailer models, and several aerodyn amic technologies. The wind tunnel results shown in Figure 2 - 18 indicate there is very little difference in performance between trailer manufacturers for their basic trailer models.

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2 - 157**5 .** **6 5** **. 5** **5 .** **5 5** **. 3** **5 .** **2 5** **. 2** **5 .** **1 5** **. 0** **5 .** **1 5** **. 0** **4 .** **9 5** **. 0** **4 .** **6 4** **. 5** **4 .** **4**

0.0 1.0 2.0 3.0 4.0 5.0 6.0

Trailer 1 Trailer 2 Trailer 3**C d** **A (** **m 2** **) Wi**  **nd Tu**  **nnel Test** **s: Averag**  **e CdA** 

**(A verag**  **e of**  **Four Tractors)**  Baseline Ta il Skirt 1 Sk irt 2 Sk irt 2 + T ail

**Figure 2**  **- 18**  **Variation in Perform ance of Trailer Devices due to**  **Trailer Manufacturer** 

### However, the results showed some variation in aerody namic performance depending on the tractor type , device manufacturer, and test method . Figure 2 - 19 illustrates these variations for a single trailer. While there is some variability in the numerical CdA values of the baseline (zero technology) tractor - trailers tested, there is less variation in the effect of adding devices. For example, the wind tunnel CdA result for adding a skirt and tail to Tractor 1 (orange bar in the first column of Figure 2 - 19 ) is 4.5 m2 

### and the coastdown CdA result for adding the same skirt and tail to Tractor 3 (orange bar in the last column of Figure 2 - 19 ) is 5.8 m2 

### . However, when we compare the effect of adding the devices by taking into account the change from the baseline result, we get a change in CdA (delta CdA) of 0.9 m2 

### for Tractor 1 and 0.8 m2 

### for Tractor 3. This reduced variation is one of the motivating factors in our decision to use a delta CdA approach for trailers in lieu of requiring an absolute CdA test. P

P Additional considerations include the fact that an absolute test would require a specific standard tractor for testing to ensure an apples - to - apples comparison of all trailer test results and a delta CdA approach makes it possible to allow device manufacturers to perform tests on their devices and have them pre - approved for any trailer manufacturer to apply on their trailers.

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2 - 158**5 .** **4 5** **. 6** **5 .** **6 5** **. 6** **6 .** **1 5** **. 9** **6 .** **6 5** **. 5** **5 .** **7 5** **. 6** **5 .** **1 5** **. 2** **5 .** **4 5** **. 3** **5 .** **0 5** **. 2** **5 .** **1 4** **. 9** **5 .** **0 5** **. 1** **5 .** **0 5** **. 6** **5 .** **5 4** **. 5** **4 .** **6 4** **. 6** **4 .** **5 5** **. 0** **5 .** **8**

0. 0 1. 0 2. 0 3. 0 4. 0 5. 0 6. 0 7. 0

Win d Tunnel,

Tractor 1 Win d Tunnel,

Tractor 2 Wind Tunnel,

Tractor 3 Wind Tunnel,

Tractor 4 Coastdown,

Tractor 1' Coastdown,

Tractor 2 Coastdown,

Tractor 3'**C d** **A (** **m 2** **) Ef**  **fe ct**  **on Absolute**  **CdA (M**  **ul tip**  **le Tra**  **ct or** 

**s, Mul tip**  **le T** **est**

**M et**  **hods, Singl**  **e Tra**  **ile r)**  Ba seline Gap Ta il Ski rt 1 Skir t 2 Sk ir

t 2+T ai l

**Figure 2**  **- 19**  **Variation in Aerodynam ic Perform**  **a nce of Trailer Devices due to Tractor**  **Manufacturer and**  **Test Method** 

## 2.10.2.1.2 **Performance Bins for Aerodynamic Technologies** The agencies developed bins based on changes in CdA (or “delta CdA”) to encompass technologies that are expected to provide similar improvements in drag (e.g., most skirts would fall into the same bin) and cover the variability due to tractor model , test method, device manufacturer, and trailer manufacturer. Figure 2 - 20 summarizes the trailer aerodynamic test results that were used to establish the trailer certification bins. These results show the average delta CdA o ver four tractor ty pes, and two test methods ( i.e., wind tunnel and coastdown) using a single trailer.

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2 - 159 **Figure 2**  **- 20**  **Aerodynam ic Trailer Testing Results used to Establish Bins for Trailer Certification**  

### As seen in Figure 2 - 21 , results from EPA’s testing of solo 28 - foot trailers show that a basic skirt would fall into Bin II and the addition of a gap reducer improves the aerodyn amic performance to Bin III or Bin IV levels of drag reduction. Itshould be noted that while the agencies have chosen to test and regulate 28 - foot box trailers individually, they are often pulled in a tandem configuration , which restricts the ty pe of aerody

namic devices that can be applied on the rear of the trailers. We expect rear devices such as boat tails would not be practical for 28 - foot box trailers, since those devices are onl y deployable when the trailer is in the rear position. Howev er, we recognize that other trailer lengths within the short box trailer subcategory (e.g., 40 - foot and 48 - foot) would be able to use rear aerody namic devices and achieve the improvements observed in the higher bins.

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2 - 160 **Figure 2**  **- 21**  **Aerodynam ic Trailer Testing Results for a Solo 28**  **- Foot Dry Van Relative to Proposed Bins**  

### Table 2 - 70 below illustrates the bin structure that the agencies are proposing as the basis for compliance. The table summarizes example technology packages that might be included in each bin for two example trailers .

**Table 2**  **- 70**  **Aerodynam ic**  **Technology Bins used to Evaluate Trailer Benefits and Costs**  BIN DELTA CDA AVERAGE DELTA CDA EXAMPLE TECHNOLOGIES

53 - FOOT DRY VAN 28 - FOOT DRY VAN Bin I < 0. 09 0.0 No Aero Devices No Aero Devices Bin II 0.1 0 - 0. 19 0.1 Gap Reducer Skirt Bin III 0.2 0 - 0. 39 0.3 Basic Skirt or Basic Tail Skirt + Gap Reducer Bin IV 0.4 0 - 0. 59 0.5 Advanced Skirt or Tail Adv. Skirt + Gap Reducer Bin V 0.6 0 - 0. 79 0.7 Basic Combinations Bin VI 0.8 0 - 1. 19 1.0 Advanced Combinations (including SmartWay Elite) Bin VII 1.2 0 - 1. 59 1.4 Optimized Combinations Bin VIII > 1.6 0 1.8 Changes to Trailer Construction 

### Within GEM, the aerodynamic performance of each trailer subcategory is evaluated by comparing the delta CdA from Table 2 - 70 to a CdA value representative of a tractor - trailer vehicle with zero aerodynamic trailer technologies (i.e., Bin I) . The agencies chose to model the zero - technology

long box dry

van using a CdA value of 6.2 m2 

### (the average CdA from EPA’s coastdown testing). For long box refrigerated vans, a two percent reduction in CdA was assumed to account for the aerodyn amic benefit of the TRU at the front of thos e trailers . A s hort box dry van also rece ived a two percent lower CdA value compared to its 53 - foot counterpart,

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2 - 161 consistent with the reduction observed in EPA’s wind tunnel testing. The CdA value assigned to a refrigerated short box van was an additional two percent lower than the short box dry van. Special purpose trailers of all lengths are modeled as a short dry van trailer in GEM and have the same Bin I CdA value of 6.1 m2



### . Since there are no aerodynamic requirements for special purpose trailers, the rest of the bins are unnecessary . Non -b ox highway trailers, which are modeled as flatbed trailers, were assigned a drag area of 5.0 m2 

### , as was done in the Phase 1 tractor program for low roof day cabs. Table 2 - 71 illustrates the absolute drag areas (CdA) associated with each aerody namic bin for each trailer subcategory . **Table 2**  **- 71**  **Baseline CdA Values Associated with Aerodynam** **ic Bin I (**  **Zero Trailer Technologi es)**  **within GEM**  TRAILER SUBCATEGORY DRY VAN Long Dry Van 6.2 Short Dry Van 6.1 Long Ref. Van 6.1 Short Ref. Van 6.0 Special Purpose Box 6.1 Non - Box Highway 4. 9 

## 2.10.2.1.3 **Effect of Wind -**  **Averaged Drag** The agencies recognize that the benefits of aerodynamic devices for trailers can be better seen when measured considering multiple yaw angles. To evaluate the effect of wind, we compared the zero yaw and wind- averaged results from EPA’s wind tunnel tests. The windaverage results were calculated at 55 mph vehicle speeds , consistent with the procedures in 40 CFR 1037.810 . The results for three trailers, each an average of tests performed on four tractors, are shown in Figure 2 - 22 . The wind- averaged analysis consistently results in a larger improvement (i.e., delta CdA). The gap reducer technology shows minimal benefit under a zero yaw anal ys is, but a measurable bene fit when yaw angles are considered. The performance bins and the resulting proposed standards were developed using zero yaw drag results. The agencies are not proposing to accept wind averaged drag results, in order to maintain consistency

between test methods, as was shown in Figure 2 - 19. The use of windaveraged drag data would result in larger benefits for trailers tested using a wind tunnel or CFD compared to same trailer s tested using coastdown procedures. The tractor program, which is proposing to use wind- averaged drag results, has a reference test method and a correction factor to maintain consistency

between methods. The trailer program is not proposing to require a reference test, in order to reduce the test burden for manufacturers and allow them to choose an appropriate test method for their needs and resources.

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2 - 162 **Figure 2**  **- 22**  **Com parison of Zero Yaw and Wind** **- Averaged Drag Results**  

## 2.10.2.2 Tire Rolling Resistance 2.10.2.2.1 **Lowe r Rolling Resistance Tires**  On a ty pical Class 8 long - haul tractor - trailer, over 40 percent of the total energy loss from tires is attributed to rolling resistance from the trailer tires. 147 

### Trailer tire rolling resistance values collected b y the agencies fo r Phase 1 indicate that the average coefficient of rolling resistance (CRR) for new trailer tires was 6.0 kg/ton. This value was applied for the standard trailer used for tractor compliance in the Phase 1 tractor program. For Phase 2, the agencies consid er all trailer tires with CRR values below 6.0 kg/ton to be “lower rolling resistance” (LRR) tires. For reference, a trailer tire that qualifies as a SmartWay - verified tire must meet a CRR value of 5.1 kg/ton, a 15 percent CRR reduction from the trailer t ire identified in Phase 1 . Our research of rolling resistance indicates an additional CRR reduction of 15 percent or more from the SmartWay

verification threshold is possible with tires that are available in the commercial market today . For this proposal, the agencies are proposing to use the same rolling resistance baseline value of 6.0 kg/ton for all trailer subcategories. In the preamble at Section IV, the agencies request comment s including information on current adoption rates of and CRR values for models of LRR tires in use b y the various trailer ty pes today . Similar to the case of tractor tires, LRR tires are available as either dual or as single wide based tires for trailers. Single w ide -based tires achieve CRR values that are similar to their dual

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2 - 163 counterparts, but have an added benefit of weight reduction, which can be an attractive option for trailers that frequentl y maximize cargo weight. 

## 2.10.2.2.2 **Performance Levels for LRR Tires** Similar to the proposed Phase 2 tractor and vocational vehicle programs, the agencies are proposing a tire program based on adoption of lower rolling resistance tires. Feedback from several box trailer manufacturers indicates that the standard tires offered on their new trailers are SmartWay- verified tires (i.e., CRR of 5.1 kg/ton or better). An informal survey of members from the Truck Trailer Manufacturers Association (TTMA) indicates about 35 percent of box trailers sold today

have SmartWay

tires. 148 

### While some trailers continue to be sold with tires of higher rolling resistances, the agencies believe most box trailer tires currently achieve the Phas e 1 trailer tire CRR of 6.0 kg/ton or better. The agencies evaluated two levels of tire performance for this proposal beyond the baseline trailer tire with a CRR of 6.0 kg/ton. The first performance level was set at the criteria for SmartWay- verification for trailer tires, 5.1 kg/ton, which is a 15 percent reduction in CRR from the baseline . As mentioned previousl y, several tire models available today achieve rolling resistance values well below the present SmartWay threshold. Given the multiple year pha se - in of the standards, the agencies expect that tire manufacturers will continue to respond to demand for more efficient tires and will offer increasing numbers of tire models with rolling resistance values significantly

better than today ’s typical LRR tires. In this context, we believe it is reasonable to expect a large fraction of the trailer industry could adopt tires with rolling resistances at a second performance level that would achieve an additional eight percent reduction in rolling resistance (a 22 percent reduction from the Level 1 tire), especiall y in the later stages of the program. The agencies project the CRR for this second level of performance to be a value of 4.7 kg/ton. The agencies evaluated these three tire rolling resistance levels, summarized in Table 2 - 72 , in the feasibility analysis of the following sections. GEM simulations that apply Level 1 and 2 tires result in CO 2 

### and fuel consumption reduction s of two and three percent from the Level 1 tire, respectively .

**Table 2**  **- 72**  **Summ ary of Trailer Tire Rolling Resistance Levels Evaluated** 

ROLLING RESISTANCE LEVEL CRR (KG/TON) Baseline 6.0 Level 1 5.1 Level 2 4.7 

## 2.10.2.3 Tire Pressure Systems The inflation pressure of tires also impacts the rolling resistance. Tractor- trailers operating with all tires under- inflated b y 10 psi have been shown to increase fuel consumed b y up to one percent. 149 

### Tires can gradually lose pressure from small puncture s, leaky valves or simply diffusion through the tire casing. Changes in ambient temperature can also affect tire pressure. Trailers that remain unused for long periods of time between hauls may experience any of these conditions. A 2003 FMCSA report found that nearl y one in five trailers had at least one tire under- inflated by

20 psi or more. If drivers or fleets are not diligent about checking and

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2 - 164 attending to under- inflated tires, the trailer may have much higher rolling resistance and much higher CO 2 

### emissions and fuel consumption. 

## 2.10.2.3.1 **Types of Tire Pressure Monitoring Systems** Tire pressure monitoring (TPM) and automatic tire inflation (ATI) s ys tems are designed to address under - inflated tires. Both s ys tems alert drivers if a tire’s pressure drops below its set point. TPM systems simply monitor the tires and require user- interaction to reinflate to the appropriate pressure. Today ’s ATI s ys tems take advantage of trailers’ air brake s ys tems to supply air back into the tires (continuousl y or on demand) until a selected pressure is achieved. In the event of a slow leak, ATI s ys tems have the added benefit of maintaining enough pressure to allow the driver to get to a safe stopping area. 150 

### The agencies believe TPM systems cannot sufficiently

guarantee the proper inflation of tires due to the inherent user- interaction required. Therefore, AT I s ys tems are the onl y pressure s ys tems the agencies are proposing to recognize in Phase 2. 

## 2.10.2.3.2 **Performance of ATI Systems** Estimates of the benefits of ATI s ys tems vary depending on the base level of maintenance already performed by the driver or fleet, as well as the number of miles the trailer travels. Trailers that are well maintained or that travel fewer miles would experience less benefits from ATI s ys tems compared to trailers that often drive with poorly inflated tires or log many miles. The agencies believe ATI s ys tems can provide a CO 2 

### and fuel consumption benefit to most trailers. With ATIuse, trailers that have lower annual vehicle miles traveled (VMT ) due to long periods between uses would be less susceptible to low tire pressures when they resume activity . Trailers with high annual VMT or frequent changes in ambient conditions would experience the fuel savings associated with consistent tire pressure s. Automatic tire inflation systems could provide a CO 2 

### and fuel consumption savings of 0.5 - 2.0 percent, depending on the degree of under - inflation in the trailer s ys tem. Maintaining tire pressure is important to fuel consumption. Tire manufacturers e stimate a tire pressure 10 psi below target results in a 0.9 percent increase in fuel consumption. Two studies have evaluated truck and trailer tire inflation including FMCSA (2003) and TMC (2002). 152 , 153 

### In the 2003 FMCSA study, tire inflation (psi) was mea sured in 3,200 tractors and 1,300 trailers. The TMC study measured tire inflation rates in two fleets and found that only 38 percent of sampled trailer tires were within +/- 5 psi of target pressure as prescribed by tire manufacturers. The study also found that more than 20 percent of tires were 20 psi or more underinflated and four percent of tires were 50 psi or more underinflated compared to the target. The FMCSA study found similar results. These figures suggest under inflation of tractor and trailer tires in the U.S. fleet could result in an increase in fuel consumption of approximately one to two percent. Most recentl y, FMCSA (2014) evaluated trailer ATI s ys tems in two test fleets. 154 

### The study

found ATI s ys tems improved fuel consumption 1.4 percent in test trucks as compared to control trucks in two fleets. NHTSA and EPA recognize the role of proper tire inflation in maintaining optimum tire rolling resistance during normal trailer operation. For this proposal, rather than require performance testing of ATIs ys tems, the agencies are proposing to recognize the benefits of ATI

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2 - 165 systems with a single default reduction for manufacturers that incorporate ATI s ys tems into their trailer designs. Based on information available today , we believe that there is a narrow range of performance among technologies available and among s ys tems in ty pical use. We propose to assign a 1.5 percent reduction in CO 2 

### and fuel consumption for all trailers that implement ATI systems, based on information available today . 155 

### W e believe the use of these systems can consistently

ensure that tire pressure and tire rolling resistance are maintained. We selected the levels of the proposed trailer standards with the expectation that a high rate of adoption of ATI systems would occur across all on - highway trailers and during all years of the phase - in of the program. For a target tire pressure of 100 psi, a 1.5 percent reduction could be achieved assuming 30 percent of trailer tires are at their target pressure, 30 percent are 10 psi below target, 20 percent are 20 psi low, 10 percent are 30 psi low, 5 percent are 40 psi low and 5 percent are 50 psi or more below target pressure. 

## 2.10.2.4 Weight Reduction Reduction in trailer tare (or empty) weight can lead to fuel consumption reductions in tw o ways. For applications where payload is not limited by weight restrictions, the overall weight of the tractor and trailer would be reduced and would lead to improved fuel efficiency . For applications where payload is limited by weight restrictions, the lower trailer weight would allow additional payload to be transported during the truck’s trip, so g/ton - mile emissions would decrease. Weight reduction opportunities in trailers exist in both the structural components and in the wheels and tires. Manufacturers commonly replace c omponents such as roof posts, bows, side posts, cross members, floor joists, and floor section s with lighter weight options. Major lower- weight options are not offered consistently by all trailer manufacturers across the industry. For example, some manufacturers have already marketed lower- weight major components for many years, while others to date have not done so. There is no clear “baseline” for current trailer weight against which lower- weight designs could be compared for regulatory

purposes. For this reason, the agencies do not believe it would be appropriate or fair across the industry

to apply overall weight reductions toward compliance. However, the agencies do believe it would be appropriate to allow a manufacturer to account for weight reductions that involve substituting very specific, traditionally

heavier components with lowerweight options that are not currentl y widel y adopted in the industry . The agencies recognize that when weight re duction is applied to a trailer, some operators will replace that saved weight with additional payload. To account for this in EPA’s GEM vehicle simulation tool, it is assumed that one - third of the weight reduction is applied to the payload. For tractor - trailers simulated in GEM, it takes a weight reduction of nearl y 1,000 pounds before a one percent fuel savings is achieved and about a 2,500 pound reduction to reach three percent savings. The component substitutions identified by the agencies result in weight reductions of less than 500 pounds, yet can cost over $1,000. The agencies believe that few trailer manufacturers would apply weight reduction solely

as a means of achieving reduced fuel consumption and CO 2 

### emissions, and we are proposing standards that can be met without reducing weight. However, we are proposing to offer weight reduction as an option for box trailer manufacturers who wish to apply it to some of their trailers as part of their emissions averaging strategy .

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2 - 166 

## 2.10.2.4.1 **Weight Reductio n Options Recognized in this Proposal**  The agencies are proposing compliance provisions that would limit the weight - reduction options to the substitution of specified components that can be clearl y isolated from the trailer as a whole. For this proposal , the agencies have identified several conventional components with available lighter- weight substitutes (e.g., substituting conventional dual tires with steel wheels with single wide -based tires and aluminum wheels). We are proposing values for the associated weight - related savings that would be applied with these substitutions for compliance. We believe that the initial cost of these component substitutions is currently substantial enough that only a relativel y small segment of the industry has adopted the se technologies today . In addition to weight reduction associated with replacing standard steel wheels with aluminum versions, and adopting single wide -based tires in place of dual tires, the agencies have identified 11 common trailer components that hav e lighter weight options available. 156 , 157 , 158 , 159 

### Some of the references include confidential data that outlined weight savings and costs associated with these material substitutions. Table 2 - 73 lists the components, and estimates of weight savings and costs obtained by the agencies. Manufacturers that adopt these technologies would sum the associated weight reductions and apply those values in GEM. Steel wheels can be replaced with aluminum wheels and two dual tires can be replaced with single wide -based tires on aluminum wheels . Relatively large weight savings are possible by replacing steel upper coupler assemblies or suspension sub - frames with aluminum versi ons, but these substitutions are more expensive and more labor- intensive to install. **Table 2**  **- 73**  **Weight Reduction Options for Trailers COMPONENT**  **MATERIAL SUBSTITUTION**  **WEIGHT REDUCTION (LB)**  Hub and Drum (per axle) Cast Iron to Aluminum 80 Floor Hardwood to Aluminum 375 Floor Hardwood to Composite 245 Floor Crossmembers Steel to Aluminum 203 Landing Gear Steel to Aluminum 50 Rear Door Steel to Aluminum 187 Rear Door Surround Steel to Aluminum 150 Roof Bows Steel to Aluminum 100 Side Posts Steel to Aluminum 300 Slider Box Steel to Aluminum 150 Structure for Suspension Assembly Steel to Aluminum 280 Upper Coupler Assembly Steel to Aluminum 430 

## 2.10.2.5 Effectiveness of Technologies The agencies are proposing to recognize trailer improvements via four performance parameters: aerodynamic drag reduction, tire rolling resistance reduction, and the adoption of ATI and weight reduction . Table 2 - 74 summarizes the performance levels for each of these parameters based on the technology characteristics outlined in Section 2.10.2 .

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2 - 167 **Table 2**  **- 74**  **Perform ance Param**  **eters for the Proposed Trailer Program**

AE RODYNAMICS ( DELTA CDA, M 2 ) Bin I 0.0 Bin II 0.1 Bin III 0.3 Bin IV 0.5 Bin V 0.7 Bin VI 1.0 Bin VII 1.4 Bin VIII 1.8 Tire Rolling Resistance (CRR, kg/ton) Tire Baseline 6.0 Tire Level 1 5.1 Tire Level 2 4.7 Tire Inflation System (% reduction) AT I System 1.5 Weight Reduction (pounds) Weight 1/3 added to payload, remaining

reduces overall vehicle weight 

### These performance parameters have different effects on each trailer subcategory due to differences in the simulated trailer characteristics. Table 2 - 75 shows the agencies’ estimates of the effectiveness of each parameter for four box trailer ty pes. Each technology

was evaluated in GEM using the baseline parameter values for the other technology categories. For exampl e, each aerodynamic bin was evaluated using the Tire Level 1 (6.0 kg/ton) and the Base weight reduction option (zero pounds). The table shows that aerodynamic improvements offer the largest potential for CO 2 

### emissions and fuel consumption reductions, making them relativel y effective technologies.

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2 - 168 **Table 2**  **- 75**  **Effectiveness (Percent Change in CO**  **2 Emissions and Fuel Consumption)**  **of Technologies for the Proposed Trailer Program**  AE RODYNAMICS DELTA CDA (M 2 ) DRY VAN REFRIGERATED VAN Long Short Long Short Bin I 0.0 0% 0% 0% 0% Bin II 0.1 - 1% - 1% - 1% - 1% Bin III 0.3 - 2% - 2% - 2% - 2% Bin IV 0.5 - 3% - 4% - 3% - 3% Bin V 0.7 - 5% - 5% - 5% - 5% Bin VI 1.0 - 7% - 7% - 7% - 7% Bin VII 1.4 - 10% - 10% - 9% - 10% Bin VIII 1.8 - 13% - 13% - 12% - 12% Tire Rolling Resistance CRR (kg/ton) Dry Van Refrigerated Van Long Short Long Short Baseline 6.0 0% 0% 0% 0% Level 1 5.1 - 2% - 1% - 2% - 1% Level 2 4.7 - 3% - 2% - 3% - 2% Weight Reduction Weight (lb) Dry Van Refrigerated Van Long Short Long Short Base line 0.0 0.0% 0.0% 0.0% 0.0% Option 1 168 - 0.2% - 0.3% - 0.2% - 0.3% Option 2 280 - 0.3% - 1% - 0.3% - 1% Option 3 430 - 0.5% - 1% - 0.5% - 1% Option 4 556 - 1% - 1% - 1% - 1% 

## 2.10.3 **Defining the Baseline Trailers**  2.10.3.1 Baseline Tractor- Trailer Vehicles within GEM The regulatory

purpose of EPA’s heavy- duty vehicle compliance tool, GEM, is to combine the effects of trailer technologies through simulation so that they can be expressed as kg/ton - mile and gal/100 ton - mile and thus avoid the need for direct testing of each trailer model being certified. The proposed trailer program has separate standards for each trailer subcategory , and a unique tractor- trailer vehicle was chosen to represent each subcategory for compliance . In the Phase 2 update to GEM, each trailer subcategory is modeled as a particular trailer being pulled by a standard tractor depending on the physical characteristics and use pattern of the trailer. Table 2 - 76 highlights the relevant vehicle characteristics for the zero - technology baseline of each subcategory . Level 1 trailer tires are used, and the drag area, which is a function of the aerodynami c characteristics of both the tractor and trailer, is set to the Bin I values shown previously

in Table 2 - 71 . Weight reduction and ATIs ys tems are not applied in the se baselines. Chapter 2.10 of the draft RIA provides a detailed description of the development of these baseline tractor- trailers.

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2 - 169 **Table 2**  **- 76**  **Characteristics of the Z ero**  **- Technology Baseline Tractor**  **- Trailer**  **Vehicles** DRY VAN REFRIGERATED VAN AE RO EXCLUDED BOX NON - BOX

HIGHWAY Trailer Length Long Short Long Short All Lengths All Lengths Tractor Class Class 8 Class 8 Class 8 Class 8 Class 8 Class 8 Tractor Cab Type Sleeper Day Sleeper Day Day Day Tractor Roof Height High High High High High Lo w Engine 2018 MY 15L, 455 HP 2018 MY

15L, 455 HP 2018 MY

15L, 455 HP 2018 MY

15L, 455 HP 2018 MY

15L, 455 HP 2018 MY

15L, 455 HP Frontal Area (m

2 ) 10.4 10.4 10.4 10.4 10.4 6.9 Baseline Drag Area, CdA (m2 ) 6.2 6.1 6.1 6.0 6.1 4.9 Steer Tire RR (kg/ton) 6.54 6.54 6.54 6.54 6.54 6.54 Drive Tire RR (kg/ton) 6.92 6.92 6.92 6.92 6.92 6.92 Trailer Tire RR (kg/ton) 6.00 6.00 6.00 6.00 6.00 6.00 Total Weight (kg) 31978 21028 33778 22828 21028 29710 Payload (tons) 19 10 19 10 10 19 AT I System Use 0 0 0 0 0 0 Weight Reduction (lb) 0 0 0 0 0 0 Drive Cycle Weightings 65 - MPH Cruise 86% 64% 86% 64% 64% 64% 55 - MPH Cruise 9% 17% 9% 17% 17% 17% Transient Driving 5% 19% 5% 19% 19% 19% 

## 2.10.3.2 Reference Case Tractor - Trailer Vehicles to Evaluate Benefits and Costs In order to evaluate the benefits and costs of the proposed standards, it is necessary to establish a reference point for comparison . The technologies described in Section 2.10.2 exist in the market today, and their adoption is driven by available fuel savings as well as by the voluntary SmartWay

Partnership and California’s Heavy Duty Greenhouse Gas Emission Reduction Measure tractor- trailer requirements. For this proposal, the agencies identified reference case tractor- trailers for each trailer subcategory based on the technology

adoption rates we project would exist if this proposed trailer program was not implemented. The agencies believe research funded and conducted by the federal government, industry , academia and other organizations is likely to result in the adoption of some technologies beyond the levels req

uired to comply

with existing regulatory

and voluntary

programs. One example of such research is the Department of Energy Super Truck program 160 

### which has a goal of demonstrating cost - effective measures to improve the efficiency of Class 8 long - haul freight trucks by 50 percent by

2015. For purposes of our reference case, w e project that by 2018, absent further California regulation, EPA’s SmartWay program and these research programs will result in about 20 percent of 53 - foot dry and refrigerated vans adopting basic SmartWay- level aerodynamic technologies (meeting SmartWay ’s four percent verification level and Bin III from Table 2 - 74 ) , 161 , 162 , 163 

### 3 0 percent adopting more advanced aerodynamic technologies at the five percent SmartWay- verification level ( Bin IV) , and five percent adding combinations of technologies (Bin V) . In addition, we project half of these 53’ box trailers will be equipped with SmartWay- verified tires (i.e., 5.1 kg/ton) and ATI systems as well. The agencies project market forces will drive an additional one percent increase in adoption of the advanced Sma rtWay and

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2 - 170 tire technologies each ye ar through 2027. For analy tical purposes, the agencies assumed manufacturers of the shorter box trailers and other trailer subcategories would not adopt these technologies in the timeframe considered and a zero - technology baseline is assumed. We are not assuming any weight reduction for any of the trailer subcategories in the reference cases. Table 2 - 77 summarizes the reference case trailers for each trailer subcategory . **Table 2**  **- 77**  **Adoption Rates and Average Perform ance Param** **eters for the Reference Case Trailers** TECHNOLOGY LONG BOX DRY & REFRIGERATED

VANS SHORT BOX, NON - AE RO BOX, & NON - BOX TRAILERS Model Year 2018 2021 2024 2027 2018 - 2027 Aerodynamics Bin I 45% 41% 38% 35% 100% Bin II - - - - - Bin III 20% 20% 20% 20% - Bin IV 30% 34% 37% 40% - Bin V 5% 5% 5% 5% - Bin VI - - - - - Bin VII - - - - Bin VIII - - - - - Average Delta CdA (m 2

) a 0.2 0.3 0.3 0.3 0.0 Tire Rolling Resistance Baseline tires 50% 47% 43% 40% 100% Level 1 tires 50% 53% 57% 60% - Level 2 tires - - - - - Average CRR (kg/ton) a 5.55 5.52 5.49 5.46 6.0 Tire Inflation AT I 50% 53% 57% 60% 0% Average % Reduction a 0.8% 0.8% 0.9% 0.9% 0.0% Weight Reduction (pounds) We ight b 0 0 0 0 0 Notes: a Combines adoption rates with performance levels shown in Table 2 - 74 b Weight reduction was not projected for the reference case trailers 

### Also shown in Table 2 - 77 are average aerodynam ic performance (delta CdA), average tire rolling resistance (CRR), and average reductions due to use of ATI and weight reduction for each stage of the proposed program. These values indicate the performance of theoretical average tractor- trailers that the agencies project would be in use if no federal regulations were in place for trailer CO 2 

### and fuel consumption. The average tractor- trailer vehicles serve as reference cases for each trailer subcategory . In addition to the reference case described above, a second reference case was developed by the agencies. This alternative reflects the possibility that absent a Phase 2 regulation, there will be continuing adoptio n of technologies in the trailer market after 2027 that reduce fuel consumption and CO 2 

### emissions. This alternative assumes that b y 2040, 75 percent of new trailers will be equipped with SmartWay- verified aerody namic devices and low rolling resistance tires, and ATI. Table 2 - 78 shows the adoption rates of technologies in the alternative reference case.

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2 - 171 **Table 2**  **- 78**  **Adoption Rates and Average Perform ance Param** **eters for the Alternative Reference Case** TECHNOLOGY LONG BOX DRY & REFRIGERATED VANS SHORT BOX, NON - AE RO BOX, & NON - BOX TRAILERS Model Year 2018 2021 2024 2027 2040 2018 - 2027 Aerodynamics Bin I 45% 41% 38% 35% 20% 100% Bin II - - - - - - Bin III 20% 20% 20% 20% 20% - Bin IV 30% 34% 37% 40% 55% - Bin V 5% 5% 5% 5% 5% - Bin VI - - - - - - Bin VII - - - - - Bin VIII - - - - - - Average Delta CdA (m 2

) a 0.2 0.3 0.3 0.3 0.4 0.0 Tire Rolling Resistance Baseline tires 50% 47% 43% 40% 25% 100% Level 1 tires 50% 53% 57% 60% 75% - Level 2 tires - - - - - - Average CRR (kg/ton) a 5.6 5.5 5.5 5.5 5.3 6.0 Tire Inflation AT I 50% 53% 57% 60% 75% 0% Average % Reduction a 0.8% 0.8% 0.9% 0.9% 1.1% 0.0% Weight Reduction (pounds) We ight b 0 0 0 0 0 0 

### The agencies applied the vehicle attributes from Table 2 - 77 and the average performance values from Table 2 - 74 in the proposed Phase 2 GEM vehicle simulation to c alculate the CO 2 

### emissions and fuel consumption performance of the reference tractor- trailers. The results of these simulations are shown in Table 2 - 79 . We used these CO 2 

### and fuel consumption values to calculate the relative benefits of the proposed standards. Note that the large difference between the per ton - mile values for long and short trailers is due primarily to the large difference in assumed payload (19 tons compared to 10 tons) as seen in and discussed further in the Chapter 2.10.3. The alternative baseline in Table 2 - 78 impacts the long - term projections of benefits beyond 2027, which are anal yz ed in Chapters 5 through 7 of this draft RIA. The non -box trailers and non - aero box vans are not included in this reference case anal ys is, because we are proposing design standards for these trailers. As such, these trailers w oul d not have standards to meet. Instead, they

w oul d have minimum tire requirements. **Table 2**  **- 79**  **CO 2**  **Em issions and Fuel Consumption Results for the Reference Case Tractor**  **- Trailers**  DRY VAN REFRIGERATED VAN Length Long Short Long Short CO 2 Emissions (kg/ton - mile) 85 147 87 151 Fuel Consumption (gal/100 ton - miles) 8.3497 14.4401 8.5462 14.8330

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2 - 172 

## 2.10.4 **Effectiveness and Costs of the Proposed Standards** The agencies evaluated several alternatives for the proposed trailer program. The anal ys is below is for the alternative we believe reflects the agencies’ statutory authorities. This alternative is full y implemented in model year (MY) 2027. The agencies believe that a period of more than 10 years provides the industry sufficient lead time to meet the stringency requirements proposed. 

## 2.10.4.1 Projected Technology Adoption Rates for the Proposed Standards Table 2 - 80 and Table 2 - 81 provide a set of adoption rates that a manufacturer could appl y to meet the standards of this proposed rulemaking. These adoption rates begin with 60 percent of l ong box trailers achieving current SmartWay level aerodynamics (Bin IV) and progress to 90 percent achieving SmartWay Elite or better over the following nine ye ars. Short box trailers adopt single aero devices in 2021 MY and combinations of devices b y 202 7 MY . Both long and short refrigerated vans have less stringent aerodyn amic requirements in the later years to reflect the reduced number of aerody namic options they

have due to their TRUs. Similarly , we are proposing that partial - aero trailers of the various sizes would continue to be subject to the corresponding 2024 MY standards in 2027 and later model years to account for the workperforming devices that may inhibit the use of some technology combinations. The adoption rates for th e long box trailers include some technologies that meet SmartWay Elite verification levels. The short box trailers would also include some combinations of devices. The agencies expect these adoption rates could be feasible in the next decade. The agenci es believe trailer manufacturers and manufacturers of bolt - on aerody namic devices will have incentive to design single - components or trailer features that accommodate work-performing devices and achieve these levels of performance b y MY 2027. The agencies project that nearl y all box trailers would adopt tire technologies to comply with the standards and the agencies projected consistent adoption rates across all lengths of dry and refrigerated vans. As mentioned previously , the agencies did not include weight reduction in their technology

adoption projections, but manufacturers can use weight reduction as part of their compliance strategy . The adoption rates shown in the se table s are one set of many possible combinations that box trailer manufacturers could apply to achieve the same average stringency . If a manufacturer chose these adoption rates, a variety of technology options exist within the aerodynamic bins , and several models of LRR tires exist for the levels shown. Alternativel y, technologies from both higher and lower aero bins and tire levels could be used to comply . Itshould be noted that manufacturers are not limited to aerodynamic and tire technologies. Certain types of weight reduction, for example, may be used as a compli ance pathway . Similar to the reference cases, the agencies derived a single set of performance parameters for each subcategory by weighting the performance levels included in Table 2 - 74 by the corresponding adoption rates. These performance parameters represent an average compliant vehicle for each trailer subcategory .

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2 - 173 **Table 2**  **- 80**  **Adoption Rates and Average Perform ance**  **Param eters for the Long Box Trailers**  TECHNOLOGY LONG BOX DRY VANS LONG BOX REFRIGERATED VANS Model Year 2018 2021 2024 2027 2018 2021 2024 2027 Aerodynamic Technologies Bin I 5% - - - 5% - - - Bin II - - - - - - - - Bin III 30% 5% - - 30% 5% - - Bin IV 6 0 % 5 5% 2 5% - 6 0 % 5 5% 2 5% - Bin V 5% 10 % 10 % 10% 5% 10 % 10 % 20% Bin VI - 30% 65% 50% - 30% 65% 60% Bin VII - - - 40% - - - 20% Bin VIII - - - - - - - - Average Delta CdA (m 2

) a 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0 Trailer Tire Rolling Resistance Baseline tires 15% 5% 5% 5% 15% 5% 5% 5% Level 1 tires 85% 95% - - 85% 95% - - Level 2 tires - - 95% 95% - - 95% 95% Average CRR (kg/ton) a 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8 Tire Inflation System AT I 85% 95% 95% 95% 85% 95% 95% 95% Average ATI Reduction (%) a 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4% Weight Reduction (pounds) We ight b 0 0 0 0 0 0 0 0 Notes: a Combines adoption rates with performance levels shown in Table 2 - 74 b This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers

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2 - 174 **Table 2**  **- 81**  **Adoption Rates and Average Perform**  **ance Param eters for the Short Box Trailers**  TECHNOLOGY SHORT BOX DRY VANS SHORT BOX REFRIGERATED VANS Model Year 2018 2021 2024 2027 2018 2021 2024 2027 Aerodynamic Technologies a Bin I 100% 5% - - 100% 5% - - Bin II - 95% 70% 30% - 95% 70% 55% Bin III - - 30% 60% - - 30% 40% Bin IV - - - 10% - - - 5% Bin V - - - - - - - - Bin VI - - - - - - - - Bin VII - - - - - - - - Bin VII I - - - - - - - - Average Delta CdA (m 2

) b 0.4 0.7 0.8 1.1 0.4 0.7 0.8 1.0 Trailer Tire Rolling Resistance Baseline tires 15% 5% 5% 5% 15% 5% 5% 5% Level 1 tires 85% 95% - - 85% 95% - - Level 2 tires - - 95% 95% - - 95% 95% Average CRR (kg/ton) b 5.2 5.1 4.8 4.8 5.2 5.1 4.8 4.8 Tire Inflation System AT I 85% 95% 95% 95% 85% 95% 95% 95% Average ATI Reduction (%) c 1.3% 1.4% 1.4% 1.4% 1.3% 1.4% 1.4% 1.4% Weight Reduction (pounds) We ight b 0 0 0 0 0 0 0 0 Notes: a The majority of short box trailers are 28 feet in length. We recognize that they are often operated in tandem, which limits the technologies that can be applied (for example, boat tails). We established standards assuming these shorter trailers were run solo, but projected reduced aerodynamic improvements compared to the longer trailers with similar technologies to reflect their frequent tandem operation. b Com bines adoption rates with performance levels shown in Table 2 - 74 c This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers 

### Non -box and non - aero box trailers, with two or more work - related special components, are not shown in the tables above. These trailers are projected to adopt tire technologies with zero adoption of aerodyn amic technologies. As shown in Table 2 - 82 , we are projecting 100 percent adoption rates of these technologies at each stage of the program, which would significantl y reduce the compliance burden for manufacturers b y reducing the amount of tracking and eliminating the need to run GEM. The agencies are proposing these tire - only requirements in two stages. In 2018 MY , manufacturers would be required to use tires meeting a rolling resistance of Level 2 or better and appl y ATI s ys tem s on all non -box and non - aero box trailers. In 2024 MY , ATI and LRR tires at a Level 3 or better would be required. The agencies are proposing AT I at all stages of the program.

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2 - 175 **Table 2**  **- 82**  **Adoption Rates and Average Perform**  **ance Param eters for the**  **Non -** **Aero Box and Non**  **- Box**  **Trailers** TECHNOLOGY NON - AE RO BOX & NON - BOX TRAILERS Model Year 2018 2021 2024 + Aerodynamic Technologies Bin I 100% 100% 100% Bin II - - - Bin III - - - Bin IV - - - Bin V - - - Bin VI - - - Bin VII - - - Bin VII I - - - Average Delta CdA (m 2

) a 0.0 0.0 0.0 Trailer Tire Rolling Resistance Baseline tires **- -**  **-** Level 1 tires 100 % 100 % - Level 2 tires - - 100 % Average CRR (kg/ton) a 5.1 5.1 4.7 Tire Inflation System AT I 100 % 100 % 100 % Average ATI Reduction (%) a 1.5% 1.5% 1.5% Weight Reduction (pounds) We ight b 0 0 0 Notes: a Combines adoption rates with performance levels shown in Table 2 - 74 b This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers 

## 2.10.4.2 Derivation of the Proposed Standards The average performance parameters from Table 2 - 80 and Table 2 - 81 were applied as input values to the GEM vehicle simulation to derive the proposed HD Phase 2 fuel consumption and CO 2 

### emissions standards for each subcategory of box trailers. The proposed standards are shown in Table 2 - 83 . Over the four phases of the proposed rule s , box trailers longer than 50 feet would, on average, reduce their CO 2 

### emissions and fuel consumption by

three percent, five percent and seven percent compared to the ir reference case s for each ye ar in Table 2 - 79 . Box trailers 50 - foot and shorter would achieve reductions of two percent, four percent and five percent compared to the ir reference case s . The tire technologies used on non -box and special purpose box trailers would provide reductions of three percent in the first two stages and achieve four percent b y 2027.

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2 - 176 **Table 2**  **- 83**  **CO 2**  **Em issions and Fuel Consumption**  **Based on Projected Technology Adoption Rates for Proposed Standards**  MODEL YEAR SUBCATEGORY DRY VAN REFRIGERATED VAN Length Long Short Long Short 2018 - 2020 EPA Standard

(CO 2 Grams per Ton - Mile) 83 144 84 147 Voluntary NHTSA Standard (Gallons per 1,000 Ton Mile) 8.1532 14.1454 8.2515 14.4401 2021 - 2023 EPA Standard

(CO 2 Grams per Ton - Mile) 81 14 2 82 146 NHTSA Standard (Gallons per 1,000 Ton Mile) 7.9568 13.9489 8.0550 14.3418 2024 - 2026 EPA Standard

(CO 2 Grams per Ton - Mile) 79 141 81 144 NHTSA Standard (Gallons per 1,000 Ton Mile) 7.7603 13.8507 7.9568 14.1454 2027 + EPA Standard

(CO 2 Grams per Ton - Mile) 77 140 80 144 NHTSA Standard (Gallons per 1,000 Ton Mile) 7.5639 13. 7525 7.8585 14.1454 

## 2.10.4.3 Projected Cost of Proposed Trailer Standards The agencies evaluated technology costs for 53 - foot dry

and refrigerated vans and 28 - foot dry vans, which we believe are representative of the majority of trailers in the long and short box trailer categories, respectivel y. Similar tire technology costs were assumed for the non -box trailer subcategory . We identified costs for each technology package evaluated and projected out the costs for each ye ar of the program. A summary of the technology

costs is included in Table 2 - 84 through Table 2 - 86 for model year s 2018, 2021 and 2024, respectively , with additional details available in Chapter 2.12 . Costs shown in the following tables are for the specific model ye ar indicated and are incremental to the average reference case costs, which includes some level of adoption of these technologies as shown in Table 2 - 77 . Therefore, the technology costs in the following tables reflect the average cost expected for each of the indicated trailer subcategories . Note that these costs do not represent actual costs for the individual components , because some fraction of th e component costs ha s been sub tracted to reflect some use of these components in the referenc e case. These costs include indirect costs via markups along with learning impacts and also reflect estimated costs of the compliance process . For more on the estimated technology

costs exclusive of adoption rates, refer to Chapter 2.12 . **Table 2**  **- 84**  **Trailer Technology Increm ental Costs in the 2018 Model Year for the**  **Proposed Alternative**  **(2012 $)** 53 - FOOT DRY VAN 53 - FOOT

REF. VAN 28 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $285 $285 $0 $0 Tires $65 $65 $78 $185

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2 - 177 Tire inflation system $239 $239 $435 $683 Total $588 $588 $514 $868 **Table 2**  **- 85**  **Trailer Technology Increm ental Costs in the 20**  **21 Model Year for the Proposed**  **Alternative (2012 $)**  53 - FOOT DRY VAN 53 - FOOT

REF. VAN 28 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $602 $602 $468 $0 Tires $65 $65 $79 $175 Tire inflation system $234 $234 $426 $632 Total $901 $901 $974 $807

**Table 2**  **- 86**  **Trailer Technology Increm**  **ental Costs in the 20 24 Model Year for the**  **Proposed Alternative**  **(2012 $)** 53 - FOOT DRY VAN 53 - FOOT

REF. VAN 28 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $836 $836 $608 $0 Tires $61 $61 $76 $160 Tire inflation system $220 $220 $412 $578 Total $1,116 $1,116 $1,097 $739

**Table 2**  **- 87**  **Trailer Technology Increm ental Costs in the 20**  **24 Model Year for the Proposed**  **Alternative (2012 $)**  53 - FOOT DRY VAN 53 - FOOT

REF. VAN 28 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $1,163 $1,034 $788 $0 Tires $54 $54 $74 $155 Tire inflation system $192 $192 $391 $549 Total $1,409 $1,280 $1,253 $704 

## 2.10.5 **Effectiveness and Costs of a More Stringent Trailer Alternative**  The agencies also evaluated a more stringent alternative that considered the same technologies with less lead time. The reference cases from Section 2.10.3.2 apply for this alternative. Additionall y, the projected adoption rates for the non - aero box and non -box trailer subcategories remain unchanged in this alternative, so their results are not repeated in this section. 

## 2.10.5.1 Projected Adoption Rates for More Stringent Alternative From Table 2 - 88 and Table 2 - 89 , it can be seen that the 2018 MY aerodynamic technology

adoption rates and the tire technology adoption rates for all model years are identical to those presented previously for the proposed standards. The aerodyn amic projections for 2021 MY and 2024 MY in this more stringent alternative are the same as those projected for 2024 MY

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2 - 178 and 2027 MY of the proposed standards, but are applied three ye ars earlier. In this alternative, the 2021 MY adoption rates would continue to apply for the partial - aero box trailers in 2024 and later model years. **Table 2**  **- 88**  **Adoption Rates and Average Perform ance Param** **eters for the Long Box Trailers in the More Stringent Alternative**  TECHNOLOGY LONG BOX DRY VANS LONG BOX

REFRIGERATED VANS Model Year 2018 2021 2024 2018 2021 2024 Aerodynamic Technologies a Bin I 5% - - 5% - - Bin II - - - - - - Bin III 30% - - 30% - - Bin IV 6 0 % 2 5% - 6 0 % 2 5% - Bin V 5% 10 % 10% 5% 10 % 20% Bin VI - 65% 50% - 65% 60% Bin VII - - 40% - - 20% Bin VIII - - - - - - Average Delta CdA (m 2

) a 0.4 0.8 1.1 0.4 0.8 1.0 Trailer Tire Rolling Resistance Baseline tires 15% 5% 5% 15% 5% 5% Level 1 tires 85% 95% - 85% 95% - Level 2 tires - - 95% - - 95% Average CRR (kg/ton) a 5.2 5.1 4.8 5.2 5.1 4.8 Tire Inflation System AT I 85% 95% 95% 85% 95% 95% Average ATI Reduction (%) a 1.3% 1.4% 1.4% 1.3% 1.4% 1.4% Weight Reduction (pounds) We ight b 0 0 0 0 0 0 Notes: a Combines adoption rates with performance levels shown in Table 2 - 74 b This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers

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2 - 179 **Table 2**  **- 89**  **Adoption Rates and Average Perform ance Param** **eters for the Short Box Trailers in the More Stringent Alternative**  TECHNOLOGY SHORT BOX DRY VANS SHORT BOX

REFRIGERATED VANS Model Year 2018 2021 2024 2018 2021 2024 Aerodynamic Technologies a Bin I 100% - - 100% - - Bin II - 70% 30% - 70% 55% Bin III - 30% 60% - 30% 40% Bin IV - - 10% - - 5% Bin V - - - - - - Bin VI - - - - - - Bin VII - - - - - - Bin VII I - - - - - - Average Delta CdA (m 2

) b 0.4 0.8 1.1 0.4 0.8 1.0 Trailer Tire Rolling Resistance Baseline tires 15% 5% 5% 15% 5% 5% Level 1 tires 85% 95% - 85% 95% - Level 2 tires - - 95% - - 95% Average CRR (kg/ton) b 5.2 5.1 4.8 5.2 5.1 4.8 Tire Inflation System AT I 85% 95% 95% 85% 95% 95% Average ATI Reduction (%) b 1.3% 1.4% 1.4% 1.3% 1.4% 1.4% Weight Reduction (pounds) We ight c 0 0 0 0 0 0 Notes: a The majority of short box trailers are 28 feet in length. We recognize that they are often operated in tandem, which limits the technologies that can be applied (for example, boat tails). We established standards assuming these shorter trailers were run solo, but projected reduced aerodynamic improvements compared to the longer trailers with similar technologies to reflect their frequent tandem operation. b Com bines adoption rates with performance levels shown in Table 2 - 74 c This set of adoption rates did not apply weight reduction to meet the proposed standards for these trailers 

## 2.10.5.2 Derivation of the More Stringent Alternative Standards Similar to the proposed standards of Section 2.10.4.2 , the agencies applied the technology performance values from Table 2 - 88 and Table 2 - 89 as GEM inputs to derive the proposed standards for each subcategory . Table 2 - 90 shows the resulting standards for the more stringent alternative. Over the three phases of the alternative , box trailers longer than 50 feet would, on average, reduce their CO 2 

### emissions and fuel consumption by four percent, six percent and eight percent. Box trailers 50 - foot and shorter would achieve reductions of two percent, four percent, and five percent c ompared to the reference case. Partial - aero box trailers would continue to be subject to the 2021 MY standards for MY 2024 and later. The non - aero box and non -box trailers would meet the same standards and achieve the same three and four percent benefits as shown in the proposed alternative.

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2 - 180 **Table 2**  **- 90**  **Trailer CO**  **2 and Fuel Consumption Standards for Box Trailers in the More Stringent Alternative** 

MODEL YEAR SUBCATEGORY DRY VAN REFRIGERATED VAN Length Long Short Long Short 2018 - 2020 EPA Standard

(CO 2 Grams per Ton - Mile) 83 144 84 147 Voluntary NHTSA Standard (Gallons per 1,000 Ton - Mile) 8.1532 14.1454 8.2515 14.4401 2021 - 2023 EPA Standard

(CO 2 Grams per Ton - Mile) 80 142 81 145 NHTSA Standard (Gallons per 1,000 Ton - Mile) 7.8585 13.9489 7.9568 14.2436 2024 + EPA Standard

(CO 2 Grams per Ton - Mile) 77 140 80 144 NHTSA Standard (Gallons per 1,000 Ton - Mile) 7.5639 13.7525 7.8585 14.1454 

## 2.10.5.3 Projected Cost of the More Stringent Trailer Alternative A summary

of the technology

costs is included in Table 2 - 91 to Table 2 - 93 for MYs 2018, 2021 and 2024, with additional details availab le in Chapter 2.12 . Costs shown in the following tables are for the specific model year indicated and are incremental to the average reference case costs, which includes some level of adoption of these technologies as shown in Table 2 - 77 . Therefore, the technology costs in the following tables reflect the average cost expected for each of the indicated trailer classes. Note that these costs do not represent actual costs for the individual components because some fraction of the component costs ha s been subtracted to reflect some use of these components in the reference case. For more on the estimated technology

costs exclusive of adoption rates, refer to Chapter 2.12 of this draft RIA. These costs include indirect costs via markups along with learning impacts. Itcan be seen that, despite the similar stringencies for MY 2024 of this more stringent alternative and MY 2027 of the proposed alternative, the costs shown below are sl ightly higher. The lower cost in the proposed MY 2027 can be partiall y attributed to the reduced costs due to three ye ars of additional learning. For a description of the markups and learning impacts considered in this anal ys is and how it impacts technolo gy costs for other years, refer to the draft RIA Chapter 2.12 . **Table 2**  **- 91**  **Trailer Technology Increm ental Costs in the 2018**  **Model Year for the**  **More Stringent Alternative**  **(2012$)** >50 - FOOT DRY VAN >50 - FOOT

REF. VAN <35 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $285 $285 $0 $0 Tires $65 $65 $78 $185 Tire inflation system $239 $239 $435 $683 Total $588 $588 $514 $868

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2 - 181 **Table 2**  **- 92**  **Trailer Technology**  **Increm ental Costs in the 2021**  **Model Year for the**  **More Stringent Alternative**  **( 2012$)**  >50 - FOOT DRY VAN >50 - FOOT

REF. VAN <35 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $908 $908 $641 $0 Tires $65 $65 $79 $175 Tire inflation system $234 $234 $426 $632 Total $1,207 $1,207 $1,146 $807 **Table 2**  **- 93**  **Trailer Technolo gy Increm**  **ental Costs in the 2024 Model Year**  **for the More**  **Stringent Alternative (**  **2012$)** >50 - FOOT DRY VAN >50 - FOOT

REF. VAN <35 - FOOT

DRY VAN NON - BOX

HIGHWAY Aerodynamics $1,223 $1,090 $816 $0 Tires $61 $61 $76 $160 Tire inflation system $220 $220 $412 $578 Total $1,504 $1,371 $1,304 $739 

## 2.10.6 **Evaluation of Compliance Option using GEM**  **- Based Equation**  EPA created the Greenhouse gas Emissions Model (GEM) as a compliance tool for heavy- duty vehicles. Users provide specific performance parameters to the model and GEM calculates CO 2 

### emissions and fuel consumption results. As described previously , the proposed Phase 2 GEM is designed to accept four performance variables as trailer inputs : change in drag area (delta C D

### A), tire rolling resistance level (TRRL), automatic tire inflation (ATI) and weight reduction (WR) . The reduction applied when using an automatic tire inflation system is accounted for after th e vehicle simulation is complete. The other performance parameters directly impact the results of the vehicle simulation, by changing the drag, rolling resistance and weight of the simulated vehicle. We performed a sensitivity analysis for delta C D

### A, TRRLand WR to evaluate their effect on the model’s results. In the anal ys is to follow, all of the calculations are shown in terms of CO 2 

### emissions; use a conversion of 10,180 grams CO 2 

### per gallon of diesel fuel to calculate the corresponding fuel consumption values. Figure 2 - 23 through Figure 2 - 26 show GEM’s CO 2 

### results for a parameter sweep of a simulated Class 8 tractor pulling each of the four box van trailers. It can be seen that each of the three parameters has a linear impact on CO 2 

### emissions. A curve fit was applied to each data set and the equation is displayed on e ach plot. The intercept in each parameter sweep data set is the baseline CO 2 

### result considering a zero - technology trailer , and this value is consistent for all parameters for a given trailer . The coefficients indicate the relationship between the assesse d parameter and the model’s CO 2 

### result.

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2 - 182 (a)

(b)

(c) **Figure 2**  **- 23**  **Impact of (a) Delta C D** **A, (b) Delta C RR** **, and (c) Weight Reduction on CO 2**  **Results of a GEM**   ** Simulated Long Dry Van**

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2 - 183 (a)

(b)

(c) **Figure 2**  **- 24**  **Impact of (a) Delta C D** **A, (b) Delta C RR** **, and (c) Weight Reduction on CO 2**  **Results of a GEM**   ** Simulated** **Long Refrigerated Van**

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2 - 184 (a)

(b)

(c) **Figure 2**  **- 25**  **Impact of (a) Delta C D** **A, (b) Delta C RR** **, and (c) Weight Reduction on CO 2**  **Results of a GEM**   ** Simulated** **Short Dry Van**

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2 - 185 (a)

(b)

(c) **Figure 2**  **- 26**  **Impact of (a) Delta C D** **A, (b) Delta C RR** **, and (c) Weight Reduction on CO**  **2 Results of a GEM**  **** **Simulated Short Refrigerated Van** 

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2 - 186 Additional GEM simulations were performed for each of the four box trailer subcategories to assess the combined effect of these parameters. As seen in Figure 2 - 27 and Figure 2 - 28 for the long dry van simulation, the coefficients of the curve fit equations did not change, indicating that the combined impacts of these parameters on GEM’s CO 2 

### results were additive. Similar trends were seen with the simulations for the other trailer subcategories, though the results are not shown here.

**Figure 2**  **- 27**  **Com bined Impact of Drag Area and Tire Rolling Resistance Level on CO** **2 Results of a GEM**  **** **Simulated Long Dry Van with No Weight Reduction**

**Figure 2**  **- 28**  **Com bined Impact of Drag A** **rea and Weight Reduction on CO 2**  **Results of a GEM -**  **Sim ulated** 

**Long Dry Van at a Tire Rolling Resistance Level of 5.1 kg/ton** 

### The results presented Figure 2 - 27 and Figure 2 - 28 suggest that these parameters could be combined into a single equation to calculate CO 2 

### emissions. Equation 1 is the result of combining the curve fit equations for long box dry vans.

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2 - 187 = 87 . 6 − 6 . 1 ( ∆ ) − 1 . 7 ( ∆ ) − 0 . 001 ( ) (1) Our proposed regulations specify that TRRLbe an absolute measure of a tire’s coefficient of rolling resistance (not a change in rolling resistance). As a result, Equation 1 was modified such that the variables of the equation matched the trailer inputs required b y GEM. Equation 2 is the resulting equation.

= 77 . 4 − 6 . 1 ( ∆ ) + 1 . 7 ( ) − 0 . 001 ( ) (2) Each of the trailer subcategories follows the same general format and a generic equation is shown in Equation 3. Table 2 - 94 summarizes the corresponding constants for each of the trailer subcategories.

= + ( ∆ ) + ( ) + ( ) (3)

**Table 2**  **- 94**  **Constants for GEM**  **- Based CO**  **2 Equation**  **for Trailer Subcategories (See Equation 3)**  TRAILER SUBCATEGORY C 1 C 2 C 3 C 4 Long Dry Van 77.4 - 6.1 1.7 - 0.001 Long Refrigerated Van 78.3 - 6.0 1.8 - 0.001 Short Dry Van 134.0 - 10.5 2.2 - 0.003 Short Refrigerated Van 136.3 - 10.3 2.4 - 0.003 

### Over 100 GEM vehicle simulations were performed for a range of delta C D 

### A, TRRLand weight reduction values. The results of these simulations were compared to CO 2 

### results calculated using Equation 3 for each trailer subcategory . The following figures show the equation and GEM have nearl y identical CO 2 

### results.

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2 - 188 **Figure 2**  **- 29**  **Com parison of GEM and Calculated CO**  **2 Results for a Long Dry Van** 

**Figure 2**  **- 30**  **Com parison of GEM and Calculated CO**  **2 Results for a Long Refrigerated Van** 

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2 - 189 **Figure 2**  **- 31**  **Com parison of GEM and Calculated CO**  **2 Results for a**  **Short Dry Van**

**Figure 2**  **- 32**  **Com parison of GEM and Calculated**  **CO 2**  **Results for a Short Refrigerated Van** 

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2 - 190 The comparisons shown in Figure 2 - 29 through Figure 2 - 32 suggest that an equation may offer a simplified approach for trailer manufacturers to calculate CO 2 

### without the use of GEM. Equation 4 below is a slight modification to Equation 3. The constants shown in Table 2 - 94 and used in Equation 3 were rearranged slightl y to place the tire rolling resistance effect at the beginning of the equation, since we anticipate most trailers would adopt LRR tires. Equation 4 and the corresponding Table 2 - 95 illustrate the rearrangement. As mentioned previousl y, the proposed trailer program is also offering the use of automatic tire inflation (ATI) s ys tems as a me ans achieving the proposed standards. This parameter is not considered in Equation 3 . Equation 4 includes a constant , C 5 

### , to address the use of ATI. Constant C 5 

### is equal to unity for trailers that do not have ATI s ys tems installed and equal to 0.985 (accounting for the 1.5% reduction assigned to ATI) for trailers that do include ATI s ys tems. As mentioned previously , one can use a conversion factor of 10,180 gram s CO 2 

### per gallon of diesel fuel to calculate the corresponding fuel consumption values.

= [ + ∙ ( ) + ∙ ( ∆ ) + ∙ ( ) ] ∙ (4)

**Table 2**  **- 95**  **Constants for GEM -**  **Based CO 2**  **Equation for Trailer Subcategories (See Equation 4)** TRAILER SUBCATEGORY C 1 C 2 C 3 C 4 Long Dry Van 77.4 1.7 - 6.1 - 0.001 Long Refrigerated Van 78.3 1.8 - 6.0 - 0.001 Short Dry Van 134.0 2.2 - 10.5 - 0.003 Short Refrigerated Van 136.3 2.4 - 10.3 - 0.003 

## 2.11 **Natural Gas** 2.11.1 **Sealed Crankcase** EPA regulations allow venting to the atmosphere crankcase emissions from compression ignition engines, provided these vented crankcase emissions are measured and accounted for as part of an engine’s tailpipe emissions. This allowance has historically been in place to address the technical limitations related to recirculating diesel - fueled engines’ crankcase emissions, which have high PM emissions, back into the engine’s air intake. High PM emissions vented into the intake of an engine can foul turbocharger compressors and after- cooler heat exchangers. In contrast, historicall y EPA has mandated closed crankcase technology on all gasoline - fueled engines and all natural gas engines certified as spark- ignition. The inherently l ow PM emissions from these engines posed no technical barrier to a closed crankcase mandate. Because natural gas - fueled compression ignition engines also have inherently low PM emissions, there is no technological limitation that would prevent manufacturers from closing the crankcase and recirculating all crankcase gases into a natural gas - fueled compression ignition engine’s air intake. It is expected that costs for this requirement would be negligible .

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2 - 191 

## 2.11.2 **Require 5 Day Hold Time** Boil - off emissions from LNG vehicles were not addressed in the Phase 1 rulemaking. However, it is our understanding that the majority or all of the NG vehicles are already compliant with National Fire Protection Association standard NFPA 52 and the similar SAE standard SAE J2343 , which are recommended practices for 3 and 5 day hold times, respectivel y. These are very

similar to one another, but the SAE standards calls for more rigorous control. Although these standards were developed largel y t o address fire safety issues (boil - off emissions can lead to explosive mixtures in enclosed spaces) , it is clear that following the industry recommended practice spelled out in SAE J2343 for five day hold time would substantially limit boil - off emissions from LNG vehicles . Therefore, EPA is proposing to require compliance with SAE J2343 as part of certification for LNG vehicles. Since the majority or all of the NG vehicles are already compliant with the se requirements , there would be negligible costs associated with the requirement for 5 day hold time based on the SAE standard practice . 

## 2.12 **Technology Costs** 2.12.1 **Overview of Technology Cost Methodology Learning Effects on**  **Technology Costs** Section 2.12.1.2 presents the methods used to address indirect costs in this anal ys is. Section 2.12.1.3 presents the learning effects applied throughout this analysis. InSection 2.12.2 through 2.12.10 we present individual technology costs including: the direct manufacturing costs (DMC), their indirect costs (IC) and their total costs (TC, TC=DMC+IC). Note that we also present technology adoption rates for most technologies and the resultant total cost as applied to a technology

package (which we have denoted as TCp, where TCp=TC x Adoption Rate). The tables presented show the adoption rate for, generally , alternatives 1a and 3 where 1a represents the reference case (or the “no action” case) and 3 represents the preferred policy case. For TCp values under alternative 4, one would replace the alternative 3 adoption rates with the appropriate alternative 4 adoption rates to arrive at the TCp costs under alternative 4. Note also that some TCp values appear as negative values in some tables (notabl y the lower rolling resistance (LRR) tire tables). This is because certain LRR tires are expected in the reference case but are then expected to b e removed in the policy case and replaced b y more aggressive LRR tires. In such cases, the reference case tires show negative TCp costs since they are being removed and replaced. 

## 2.12.1.1 Direct Manufacturing Costs The direct manufacturing costs (DMCs) used throughout this anal ys is are derived from several sources. Many of the tractor, vocational and trailer DMCs can be sourced to the Phase 1 rule s which, in turn, were sourced largel y from a contracted study b y ICF International for EPA. 164 

### There was no s erious disagreement regarding these estimated costs in the public comments to the Phase 1 rule s . We have updated those costs by converting them to 2012 dollars, as described in Section IX. B .1.e of the Preamble , and by continuing the learning ef fects described in the Phase 1 rule s and in S ection IX. B .1.c of the Preamble . The new tractor, vocational and trailer costs can be sourced to a more recent study conducted by Southwest Research Institute (SwRI) under contract to NHTSA. 165 

### The cost methodology used by SwRI in

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2 - 1 92 that study was to estimate retail costs then work backward from there to derive a DMC for each technology . The agencies did not agree with the approach used b y Tetra Tech to move from retail cost to DMC. As such, the agencies have used an approach consistent with past GHG/CAFE/fuel consumption rules by dividing estimated retail prices by our estimated retail price equivalent markups to derive an a ppropriate DMC for each technology . We describe our RPEs in Section 2.12.1.2 . For HD pickups and vans, we have relied primarily on the Phase 1 rule s and the light duty 2017 - 2025 model year rule since most technologies expected on these vehicles are, in effect, the same as those used on light - duty pickups. Many of those technology

DMCs are based on cost teardown studies which the agencies consider to be the mo st robust method of cost estimation. However, many of the HD versions of those technologies would be expected to be more costly

than their light - duty

counterparts because of the heavier HD vehicles and/or the higher power and torque characteristics of the ir engines. Therefore, we have scaled upward where appropriate many of the light - duty DMCs for this analysis. We have also used some costs developed under contract to NHTSA by SwRI (the study mentioned above). 166 

### Importantly , in our methodology , all technologies are treated as being sourced from a supplier rather than being developed and produced in - house. As such, some portion of the total indirect costs of making a technology or s ys tem

—those costs incurred b y the supplier for research, development, transportation, marketing etc.

—are contained in the sales price to the engine and/or vehicle/trailer manufacturer (i.e., the original equipment manufacturer (OEM)). That sale price paid b y the OEM to the supplier is the DMC we estimate. 

## 2.12.1.2 Indirect Costs To produce a unit of output, engine and truck manufacturers incur direct and indirect costs. Direct costs include cost of materials and labor costs. Indirect costs are all the costs associated with producing the unit of output that are not direct costs

– for example, they may be related to production (such as research and development [R&D]), corporate operations (such as salaries, pensions, and health care costs for corporate staff), or selling (such as transportation, dealer support, and marketing). Indirect costs are generall y recovered b y allocating a share of the costs to each unit of good sold . Although it is possible to account for direct costs allocated to each unit of good sold, it is more challenging to account for indirect costs allocated to a unit of goods sold. To make a cost analysis process more feasible, markup factors, which relate total indirect costs to total direct costs, have been developed. These factors are often referred to as retail price equivalent (RPE) multipliers. Cost analysts and regulatory agencies ( including both EPA and NHTSA) have frequently used these multipliers to predict the resultant impact on costs associated with manufacturers’ responses to regulatory

requirem ents. The best approach, if it were possible, to determining the impact of changes in direct manufacturing costs on a manufacturer’s indirect costs would be to actuall y estimate th e cost impact on each indirect cost element. However, doing this within the constraints of an agency ’s time or budget is not always feasible, or the technical, financial, and accounting information to carry out such an analysis may simply be unavailable.

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2 - 193 RPE multipliers provide, at an aggregate level, the relative shares of revenues (Revenue = Direct Costs + Indirect Costs + Net Income ) to direct manufacturing costs. Using RPE multipliers implicitly

assumes that incremental changes in direct manufacturing costs produce common incremental changes in all indirect cost contributors as well as net income. However, a concern in using the RPE multiplier in cost analysis for new technologies added in response to regulatory

requirements is that the indirect cost s of vehicle modifications are not likely to be the same for different technologies. For example, less complex technologies could require fewer R&D efforts or less warranty coverage than more complex technologies. In addition, some simple technological adjustments may , for example, have no effect on the number of corporate personnel and the indirect costs attributable to those personnel . The use of RPEs, with their assumption that all technologies have the same proportion of indirect costs, is likely to overestimate the costs of less complex technologies and underestimate the costs of more complex technologies. Table 2 - 96 shows the RPE factors used in developing indirect costs in past, and this, agency

analyses. **Table 2**  **- 96**  **Industry Retail Price Equivalent (RPE) Factors**

INDUSTRY RPE Heavy engine manufacturers 1.28 Heavy truck manufacturers 1.36 Light- duty

vehicle manufacturers 1.50 

### To address this concern, modified multipliers have been developed by EPA, working with a contractor, for use in rulemakings . These multipliers are referred to as indirect cost multipliers (or IC Ms ). Incontrast to RPE multipliers, ICM s assign unique incremental changes to each indirect cost contributor as well as net income.

ICM = (direct cost + adjusted indirect cost)/(direct cost) Developing the ICMs from the RPE multipliers requires developing adjustment factors based on the complexity

of the technology

and the time frame under consideration : the less complex a technology , the lower its ICM, and the longer the time frame for applying the technology , the lower the ICM . This methodology w as used in the cost estimation for the recent l ight - d uty MYs 2012 - 2016 and MYs 2017 - 2025 rulemaking and for the heavy- duty MYs 2014 - 2018 rulemaking . There was no serious disagreement with this approach in the public comments to any of these rulemakings. The IC Ms for the light - duty context were deve loped in a peerreviewed report from RTI International and were subsequently discussed in a peer - reviewed journal article. 167 

### Importantly , since publication of that peer- reviewed journal article, the agencies have revised the methodology to include a return on capital (i.e., profits) based on the assumption implicit in ICMs (and RPEs) that capital costs are proportional to direct costs, and businesses need to be able to earn returns on their investments. For the heavy- duty pickup truck and van cost projecti ons in this proposal, the agencies have used ICM adjustment factors developed for light- duty vehicles, inclusive of a return on capital, primaril y because the manufacturers involved in this segment of the heavy- duty market are the same manufacturers that build light - duty trucks.

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2 - 194 For th e combination tractors, vocational vehicles, and heavy- duty engine cost projections in this proposal , the agencies are again using the ICMs used in the HD Phase 1 rule s . Those ICMs were developed b y RTIInternational under EPA contract to update EPA’s methodology for accounting for indirect costs associated with changes in direct manufacturing costs for heavyduty engine and truck manufacturers. 168 

### Inaddition to the indirect cost contributors varying by complexity

and time frame, there is no reason to expect that the contributors would be the same for engine manufacturers as for truck manufacturers. The resulting report from RTIprovides a description of the methodology , as well as calculations of th e indirect cost multipliers that are being used as the basis for the markups used in this proposal . These indirect cost multipliers were used, along with calculations of direct manufacturing costs, to provide estimates of the full additional costs associated with new technologies. As explained in the Phase 1 final rule s , and entirely consistent with the analysis supporting that program , the agencies have made some changes to both the ICMs factors and to the method of appl ying th ose factors relative to the factors developed b y RTIand presented in their reports. The first of these changes was done in response to continued thinking among the agencies about how past ICMs have been developed and what are the most appropriate data sources to rel y upon in determining the appropriate ICMs. The second change was done in response to both staff concerns and public feedback suggesting that the agencies were inappropriatel y appl ying learning effects to indirect costs via the multiplicative approach to applying the ICMs. Regarding the first change

– to the ICM factors themselves

– a little background must first be provided. In the original work done under contract to EPA b y RTI International, 169 

### EPA experts had undergone a consensus approach to determining the impact of specific technology changes on the indirect costs of a company. Subsequent to that effort, EPA experts underwent a blind survey

to make this determination on a different set of technology changes. This subsequent effort, referred to by EPA as a modified - Delphi approach, resulted in different ICM determinations. This effort is detailed in a memorandum contained in the docket for this rulemaking. 170 

### Upon completing this effort, EPA determined that the original RTIvalues should b e averaged with the modified- Delphi values to arrive at the final ICMs for low and medium complexity

technologies and that the original RTI values would be used for high complexity level 1 while the modified- Delphi values would be used for high complexity level 2. These final ICMs were used in the 2012 - 2016 light - duty GHG/CAFE rulemaking. Subsequent to that, EPA contracted RT I to update their light - duty report with an eye to the heavy- duty industry . In that effort, RTI determined the RPE of both the heavy- duty engine and heavy

truck industries, then applied the light - duty indirect cost factors

—those resulting from the averaging of the values from their original report with the modified- Delphi values

—to the heavy- duty RPEs to arrive at heavy- duty specific ICMs. That effort is described in their final heavy- duty I CM report mentioned above. 171 

### During development of the Phase 1 heavy- duty final rule s , the agencies decided that the original light - duty RTI values, given the technologies considered for low and medium complexity, should no longer be used and that we should rely solel y on the modified- Delphi values for these complexity levels. The original light - duty RTI study used low rolling resistance tires as a low complexity technology example and a dual clutch transmission as a medium complexity

technology . Upon further thought, the technologies considered for the modified

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2 - 195 Delphi values (passive aerody namic improvements for low complexity and turbocharging with downsizing for medium complexity were conside red to better represent the example technologies). As a result, the modified- Delphi values were to become the working IC Ms for low and medium complexity rather than averaging those values with the original RTI report values. The agencies have also re - examined the technology complexity

categories that were assigned to each light - duty technology

and modified these assignments to better reflect the technologies that are now used as proxies for each category . This decision impacted the low and medium complex ity

heavy- duty ICMs too because the modified- Delphi values alone were to be applied to the heavy- duty RPEs to arrive at heavy- duty I CMs rather than using the averaged values developed for the light - duty 2012 - 2016 rulemaking. A secondary- level change was also made as part of this ICM recalculation to the light duty I CMs and, therefore, to the ICMs used in the Phase 1 HD final rule s and again in this proposed anal ys is for HD pickups and vans . That change was to revise upward the RPE level reported in the original RTIreport from an original value of 1.46 to 1.5 to reflect the long term average RPE. The original RTIstudy was based on 2008 data. However, an anal ys is of historical RPE data indicates that, although there is year to year variation, the average RPE has remained roughl y 1.5. ICMs are applied to future year’s data and therefore the agencies believed and continue to believe that it is most appropriate to base ICMs on the historical average rather than a single ye ar’s result. Therefore, ICMs w ere adjusted to reflect this average level. As a result, the High 1 and High 2 ICMs used for HD pickups and vans were changed for the Phase 1 final rule s and we continue to use those changed values here . Table 2 - 97 shows the IC M values used in this proposal. Near term values are used in earl y ye ars, depending on the technology, and account for differences in the levels of R&D, tooling, and other indire ct costs that would be incurred. Once the program has been full y implemented, some of the indirect costs would no longer be attributable to the standards and, as such, a lower IC M factor is applied to direct costs in later years. **Table 2**  **- 97**  **Indirect Cost Multipliers Used in this Analysis a**  CLASS COMPLEXITY NEAR TERM LONG

TERM HD Pickup Trucks and Vans Lo w 1.24 1.19 Medium 1.39 1.29 High1 1.56 1.35 High2 1.77 1.50 Loose diesel engines Lo w 1.15 1.13 Medium 1.24 1.18 High1 1.28 1.19 High2 1.44 1.29 Loose gasoline engines Lo w 1.24 1.19 Medium 1.39 1.29 High1 1.56 1.35 High2 1.77 1.50 Vocational Vehicles, Com bination Tractors and Trailers Lo w 1.18 1.14 Medium 1.30 1.23 High1 1.43 1.27

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2 - 196 High2 1.57 1.37 Note: a Rogozhin, A., et. al., “Using indirect cost multipliers to estimate the total cost of adding new technology in the automobile industry,” International Journal of Production Economics (2009); “Documentation of the Development of Indirect Cost Multipliers f or Three Automotive Technologies,” Helfand, G., and Sherwood, T., Memorandum dated August 2009; “Heavy Duty Truck Retail Price Equivalent and Indirect Cost Multipliers,” Draft Report prepared by RTI International and Transportation Research Institute, Univ ersity of Michigan, July 2010. 

### The second change made to the ICMs during development of the Phase 1 final rule s had to do with the way

in which the ICMs were applied. Until that time, we had applied the ICMs, as done in any analysis that relied on RPEs, as a pure multiplicative factor. This way , a direct manufacturing cost of, say , $100 would have been multiplied by an ICM of 1.24 to arrive at a marked up technology

cost of $124. However, as learning effects (discussed below) are applied to the direct m anufacturing cost, the indirect costs are also reduced accordingl y. Therefore, in ye ar 2 the $100 direct manufacturing cost might reduce to $97 and the marked up cost would become $120 ($97 x 1.24). As a result, indirect costs have been reduced from $24 to $23. Given that indirect costs cover many things such as facility- related costs, electricity , etc., it is perhaps not appropriate to appl y the ICM to the learned direct costs, at least not for those indirect cost elements unlikely

to change with learning. The agencies decided that it was more appropriate only to allow warranty costs to decrease with learning since warranty costs are tied to direct manufacturing costs (since warranty typically involves replacement of actual parts which should be less co stly

with learning). Q 

### However, the remaining elements of the indirect costs should remain constant ye ar- over- year, at least until some of those indirect costs are no longer attributable to the rulemaking effort that imposed them (such as R&D). As a result , the ICM calculation became more complex with the analysis supporting the Phase 1 final rule s , and we continue to use that more complex calculation here. We first establish the year in which the direct manufacturing costs are considered “valid.” For example, a cost estimate might be considered valid today , or perhaps not until high volume production is reached in some future model year. That year is considered the base year for the estimated cost. That cost is the cost used to determine the “non - warranty”portion of the indirect costs. For example, the near term non - warranty portion of the loose diesel engine low complexity I CM is 0.149 (the warranty versus non - warranty portions of the ICMs are shown in Table 2 - 98 ). For the improved water pump technology we have estimated a direct manufacturing cost of $82.66 (2012$) in MY 2014. So the non - warranty portion of the indirect costs would be $12.32 ($82.66 x 0.149) . This value would be added to the learned direct manufacturing cost for each ye ar through 2022 since the near term markup is considered appropriate for that technology through 2022. Beginning in 2023, when long - term indirect costs begin, the additive factor would become $10.08 ($82.66 x 0.122). Additionally , the $82.66 cost in 2014 would become $80.18 in MY 2015 due to learning ($82.66 x (1 - 3 percent)). So, while the warranty portion of the indirect costs would be $0.49 ($82.66 x 0.006) in 2014, they w ould decrease to $0.48 ($80.18 x 0.006) in 2015 as warranty costs decrease with learning. The resultant indirect costs for the water pump Q We note that the labor portion of warranty repairs does not decrease due to learning. However, we do not have data to separate this portion and so we apply learning to the entire warranty cost. Because warranty costs are a small portion of overall indirect costs, this has only a minor im pact on the analysis.

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2 - 197 would be $12.81 ($12.32+$0.49) in MY 2014 and $12.80 ($12.32+$0.48) in MY2015, and so on for subsequent ye ars. Import antly , since the bulk of the indirect costs calculated using this methodology are the non - warranty costs, and since those costs do not change over with learning, one cannot look at the ICMs shown in Table 2 - 97 and assume that our HD pickup and van total costs are, in general, 1.24 or 1.39 times the direct costs (since most technologies considered for application in HD pickups and vans are low and m edium technologies). This can be illustrated by building on the example presented above for a water pump on a heavy diesel engine. We already calculated the MY 2014 total cost as $95.46 (2012$, $82.66+$12.32+$0.49). This is an effective markup of 1.155 ($95.46/$82.66). This is expected since the cost is based in 2014 and the near term ICM is 1.155. In MY2022, the final year of near term markups for this technology, the total cost would be $80.21 since the learned direct cost has reduced to $67.50, the non - warranty indirect costs (calculated above) remain $12.32, and the warranty indirect costs have become $0.39 ($67.50x0.006). So, in MY2022, we now have an effective markup of 1.19 ($80.21/$67.50). **Table 2**  **- 98**  **Warranty and Non -** **Warranty Portions of ICMs**

SHORT - TERM LONG - TERM CLASS COMPLEXITY WARRANTY NON WARRANTY WARRANTY NON WARRANTY HD Pickup and Vans Lo w 0.012 0.230 0.005 0.187 Medium 0.045 0.343 0.031 0.259 High1 0.065 0.499 0.032 0.314 High2 0.074 0.696 0.049 0.448 Loose diesel engines Lo w 0.006 0.149 0.003 0.122 Medium 0.022 0.213 0.016 0.165 High1 0.032 0.249 0.016 0.176 High2 0.037 0.398 0.025 0.265 Loose gasoline engines Lo w 0.012 0.230 0.005 0.187 Medium 0.045 0.343 0.031 0.259 High1 0.065 0.499 0.032 0.314 High2 0.074 0.696 0.049 0.448 Vocational Vehicles, Com bination Tractors and Trailers Lo w 0.013 0.165 0.006 0.134 Medium 0.051 0.252 0.035 0.190 High1 0.073 0.352 0.037 0.233 High2 0.084 0.486 0.056 0.312 

### The complexity

levels and subsequent ICMs applied throughout this analysis for each technology

are shown in Table 2 - 99 . **Table 2**  **- 99**  **Indirect Cost Markups and Near Ter m/** **Long Term Cutoffs**  **Used in this Analysis**  TECHNOLOGY AP PLIED TO ICM COMPLEXITY NEAR TERM THRU Cylinder head improvements 1 LH/MH/HH Engines Low 2022 Cylinder head improvements 2 LH/MH/HH Engines Low 2027 Turbo efficiency improvements 1 LH/MH/HH, HD Pickup & Van Engines Low 2022 Turbo efficiency improvements 2 LH/MH/HH Engines Low 2027 EGR cooler efficiency improvements 1 LH/MH/HH Engines Low 2022

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2 - 198 EGR cooler efficiency improvements 2 LH/MH/HH Engines Low 2027 Water pump improvements 1 LH/MH/HH Engines Low 2022 Water pump improvements 2 LH/MH/HH Engines Low 2027 Oil pump improvements 1 LH/MH/HH Engines Low 2022 Oil pump improvements 2 LH/MH/HH Engines Low 2027 Fuel pump improvements 1 LH/MH/HH Engines Low 2022 Fuel pump improvements 2 LH/MH/HH Engines Low 2027 Fuel rail improvements 1 LH/MH/HH Engines Low 2022 Fuel rail improvements 2 LH/MH/HH Engines Low 2027 Fuel injector improvements 1 LH/MH/HH Engines Low 2022 Fuel injector improvements 2 LH/MH/HH Engines Low 2027 Piston improvements 1 LH/MH/HH Engines Low 2022 Piston improvements 2 LH/MH/HH Engines Low 2027 Valve train friction reductions 1 LH/MH/HH Engines Low 2022 Valve train friction reductions 2 LH/MH/HH Engines Low 2027 Turbo compounding 1 LH/MH/HH Engines Low 2022 Turbo compounding 2 LH/MH/HH Engines Low 2027 Aftertreatment improvements 1 LH/MH/HH Engines Low 2022 Aftertreatment improvements 2 LH/MH/HH Engines Low 2024 Model based control LH/MH/HH Engines Low 2022 Waste heat recovery HH Engines Medium 2025 Engine friction reduction 1 HD Pickup & Van Engines Low 2018 Engine friction reduction 2 HD Pickup & Van Engines Low 2024 Engine changes to accommodate low friction lubes HD Pickup & Van Engines Low 2018 Variable valve timing

– coupled HD Pickup & Van Engines Low 2018 Variable valve timing

– dual HD Pickup & Van Engines Medium 2018 Stoichiometric gasoline direct injection HD Pickup & Van Engines Medium 2018 Cylinder deactivation HD Pickup & Van Engines Medium 2018 Cooled EGR HD Pickup & Van Engines Medium 2024 Turbocharging & downsizing HD Pickup & Van Engines Medium 2018 “Right sized” diesel engine HD Pickup & Van vehicles, Tractors Low 2022 6 speed transmission HD Pickup & Van vehicles Medium 2018 8 speed transmission HD Pickup & Van vehicles, Vocational Medium 2018 Automated manual transmission (AMT) Vocational, Tractors Medium 2022 Auto transmission, power- shift Tractors Medium 2022 Conversion from manual to auto trans Vocational Medium 2018 Dual clutch transmission Vocational, Tractors Medium 2022 Improved transmission Vocational Low 2022 Lower RR tires 1 HD Pickup & Van vehicles Low 2018 Lower RR tires 2 HD Pickup & Van vehicles Low 2024 Low drag brakes HD Pickup & Van vehicles Low 2018 Electric power steering HD Pickup & Van vehicles Low 2018 High efficiency transmission HD Pickup & Van vehicles Low 2024 Driveline friction reduction HD Pickup & Van vehicles Low 2022 Improved accessories (electrification) HD Pickup & Van vehicles Low 2018 Improved accessories (electrification) Tractors Low 2022 Improved fan Tractors Low 2022 Lower RR tires 1 Vocational , Tractors, Trailers Low 2022 Lower RR tires 2 Vocational , Tractors, Trailers Low 2022 Lower RR tires 3 Vocational , Tractors, Trailers s Medium 2025 Lower RR tires 4 Vocational , Tractors, Trailers Medium 2028

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2 - 199 Automated Tire Inflation System (ATIS) Tractors, Trailers Low 2022 Aero 1 HD Pickup & Van vehicles Low 2018 Aero 2 HD Pickup & Van vehicles Medium 2024 Aero Bins 1 thru 4 Tractors Low 2022 Aero Bin 5 thru 7 Tractors Medium 2025 Aero Bins 1 thru 8 Trailers Low 2018 Weight reduction (via single wide tires and/or aluminum wheels) Tractors Low 2022 Weight reduction via material changes HD Pickup & Van vehicles Low 2018 Weight reduction via material changes

– 200 lbs, 400 lbs Vocational Low 2022 Weight reduction via material changes

– 1000 lbs Vocational Medium 2022 Weight reduction via material changes Tractors Low 2022 Auxiliary power unit Tractors Low 2022 Air conditioning leakage Vocational, Tractors Low 2022 Air conditioning efficiency Tractors Low 2022 Neutral idle Vocational Low 2022 Stop - start (no regeneration) HD Pickup & Van vehicles Medium 2018 Stop - start (no regeneration) Vocational Medium 2022 Mild hybrid HD Pickup & Van vehicles High1 2024 Mild hybrid Tractors High1 2025 Strong hybrid HD Pickup & Van vehicles High1 2024 Strong hybrid Vocational High1 2022 Full electric Vocational, Tractors High1 2028 

### There is some level of uncertainty surrounding both the ICM and RPE markup factors. The ICM estimates used in this proposal group all technologies into three broad categories and treat them as if individual technologies within each of the three categories (low, medium, and high complexity) would have the same ratio of indirect costs to direct costs. This simplification means it is likely

that the direct cost for some technologies within a category will be higher and some lower than the estimate for the category in general. More importantly , the ICM estimates have not been validated through a direct accounting of actual indirect costs for individual technologies. RPEs themselves are inherentl y difficult to estimate because the accounting statements of manufacturers do not neatl y categorize all cost elements as either direct or indirect costs. Hence, each researcher developing an RPE estimate must apply a certain amount of judgment to the allocation of the costs. Moreover, RPEs for heavy- and medium - duty trucks and for engine manufacturers are not as well studied as they are for the light - duty

automobile industry . Since empirical estimates of ICMs are ultimately derived from the same data used to measure RPEs, this affects both measures. However, the value of RPE has not been measured for specific technologies, or for groups of specific technologies. Thus, even if we assume that the examined technology accuratel y represents the average impact on all technologies in its representative category, applying a single average RPE to any given technology

by definition overstates costs for very

simple technologies, or understates them for more advanced technologies in that group. 

## 2.12.1.3 Learning Effects on Technology Costs For some of the technologies considered in thi s analysis, manufacturer learning effects would be expected to play a role in the actual end costs. The “learning curve” or “experience curve” describes the reduction in unit production costs as a function of accumulated production

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2 - 200 volume. In theory , the cost behavior it describes applies to cumulative production volume measured at the level of an individual manufacturer, although it is often assumed

—as both agencies have done in past regulatory anal ys es—to apply

at the industry- wide level, particularly in industries that utilize many common technologies and component supply sources. Both agencies believe there are indeed many factors that cause costs to decrease over time. Research in the costs of manufacturing has consistently shown that, as manufacturers gain experience in production, they

are able to apply

innovations to simplify

machining and assembly operations, use lower cost materials, and reduce the number or complexity of component parts. All of these factors allow manufacturers to lower the per-unit cost of production ( i.e. , the manufacturing learning curve). 172 

### The agencies have a detailed description of the learning effect in the light- duty 2012 - 2016 rulemaking. Most studies of the effect of experience or learning on production costs appear to assume that cost reductions begin only after some initial volume threshold has been reached, but not all of these studies specify this threshold volume. The rate at which costs decline beyond the initial threshold is usually expressed as the percent red uction in average unit cost that results from each successive doubling of cumulative production volume, sometimes referred to as the learning rate. Many estimates of experience curves do not specify a cumulative production volume beyond which cost reducti ons would no longer occur, instead depending on the asy mptotic behavior of the effect for learning rates below 100 percent to establish a floor on costs. In past rulemaking analyses, as noted above, both agencies have used a learning curve algorithm that applied a learning factor of 20 percent for each doubling of production volume. NHTSA has used this approach in analyses supporting recent CAFE rules. In its analyses, EPA has simplified the approach by using an “every

two years” based learning progress ion rather than a pure production volume progression ( i.e. , after two years of production it was assumed that production volumes would have doubled and, therefore, costs would be reduced by 20 percent). In the light - duty 2012 - 2016 rulemaking, the agencies employed an additional learning algorithm to reflect the volume -based learning cost reductions that occur further along on the learning curve. This additional learning algorithm was termed “time -based” learning simply as a means of distinguishing this algorithm from the volume -based algorithm mentioned above, although both of the algorithms reflect the volume -based learning curve supported in the literature. 173 

### To avoid confusion, we now refer to this learning algorithm as the “flat-portion” of the learning curve. This way , we maintain the clarity that all learning is, in fact, volume -based learning, and the level of cost reductions depend only on where on the learning curve a technology ’s learning progression is. We distinguish the flat -portion of the cur ve from the steep portion of the curve to indicate the level of learning taking place in the ye ars following implementation of the technology . The agencies have applied the steep -portion learning algorithm for those technologies considered to be newer technologies likely to experience rapid cost reductions through manufacturer learning and the flat-portion learning algorithm for those technologies considered to be mature technologies likely to experience minor cost reductions through manufacturer learning. As noted above, the steep -portion learning algorithm results in 20 percent lower costs after two full years of implementation ( i.e. , the 2016 MY costs are 20 percent lower than the 2014 and 2015 model year costs). Once the steep -portion learning steps h ave occurred (for technologies having the steep - portion learning algorithm applied), flat-portion

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2 - 201 learning at 3 percent per year becomes effective for 5 years. For technologies having the flat portion learning algorithm applied), flat-portion learning at 3 percent per year begins in year 2 and remains effective for 5 years. Beyond 5 years of learning at 3 percent per year, 5 ye ars of learning at 2 percent per year, then 5 at 1 percent per year become effective. There was no serious disagreement with this a pproach in the public comments to any of the GHG/fuel economy/ consumption rulemakings. Learning effects are applied to most but not all technologies because some of the expected technologies are already used rather widely

in the industry

and, presumabl y , learning impacts have already occurred. The steep -portion learning algorithm was applied for only a handful of technologies that are considered to be new or emerging technologies. Most technologies have been considered to be more established given their current use in the fleet and, hence, the lower flat -portion learning algorithm has been applied. The learning algorithms applied to each technology are summarized in Table 2 - 100 . **Table 2**  **- 100**  **Learning Effect Algorithms Applied to Technologies Used in this Analysis** TECHNOLOGY APPLIED TO LEARNING ALGORITHM LEARNING

FACTOR “CURVE” A Cylinder head im

provements 1 LH/MH/HH Engines Flat 2 Cylinder head improvements 2 LH/MH/HH Engines Flat 13 Turbo efficiency improvements 1 LH/MH/HH, HD Pickup & Van Engines Flat 2 Turbo efficiency improvements 2 LH/MH/HH Engines Flat 13 EGR cooler efficiency im provements 1 LH/MH/HH Engines Flat 2 EGR cooler efficiency improvements 2 LH/MH/HH Engines Flat 13 Water pump improvements 1 LH/MH/HH Engines Flat 2 Water pump improvements 2 LH/MH/HH Engines Flat 13 Oil pump improvements 1 LH/MH/HH Engines Flat 2 Oil pump improvements 2 LH/MH/HH Engines Flat 13 Fuel pump improvements 1 LH/MH/HH Engines Flat 2 Fuel pump improvements 2 LH/MH/HH Engines Flat 13 Fuel rail improvements 1 LH/MH/HH Engines Flat 2 Fuel rail improvements 2 LH/MH/HH Engines Flat 13 Fuel injector improvements 1 LH/MH/HH Engines Flat 2 Fuel injector improvements 2 LH/MH/HH Engines Flat 13 Piston improvements 1 LH/MH/HH Engines Flat 2 Piston improvements 2 LH/MH/HH Engines Flat 13 Valve train friction reductions 1 LH/MH/HH Engines Flat 2 Valve train friction reductions 2 LH/MH/HH Engines Flat 13 Turbo compounding 1 LH/MH/HH Engines Flat 2 Turbo compounding 2 LH/MH/HH Engines Flat 13 Aftertreatment improvements 1 & 2 LH/MH/HH Engines Flat 2 Model based control LH/MH/HH Engines Flat 13 Waste heat recovery HH Engines Flat 12 Engine friction reduction 1 & 2 HD Pickup & Van Engines None 1 Engine changes to accommodate low friction lubes HD Pickup & Van Engines None 1 Variable valve timing HD Pickup & Van Flat 8

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2 - 202 Engines Stoichiometric gasoline direct injection HD Pickup & Van Engines Flat 7 Cylinder deactivation HD Pickup & Van Engines Flat 8 Cooled EGR HD Pickup & Van Engines Flat 7 Turbocharging & downsizing HD Pickup & Van Engines Flat 7 “Right sized” diesel engine HD Pickup & Van vehicles, Tractors None 1 6 speed transmission HD Pickup & Van vehicles Flat 7 8 speed transmission HD Pickup & Van vehicles, Vocational Flat 7 Automated manual transmission (AMT) Vocational, Tractors Flat 12 Auto transmission, power - shift Tractors Flat 12 Conversion from manual to auto trans Vocational Flat 7 Dual clutch transmission Vocational, Tractors Flat 12 Im proved transmission Vocational Flat 13 Lo wer RR tires 1 HD Pickup & Van vehicles None 1 Lo wer RR tires 2 HD Pickup & Van vehicles Steep 11 Lo w drag brakes HD Pickup & Van vehicles None 1 Electric power steering HD Pickup & Van vehicles Flat 8 High efficiency transmission HD Pickup & Van vehicles Flat 6 Driveline friction reduction HD Pickup & Van vehicles Flat 3 Im proved accessories (electrification) HD Pickup & Van vehicles Flat 8 Im proved accessories Tractors Flat 12 Im proved fan Tractors Flat 12 Lo wer RR tires 1 Vocational , Tractors, Trailers Flat 2 Lo wer RR tires 2 Vocational , Tractors, Trailers Flat 2 Lo wer RR tires 3 Vocational , Tractors, Trailers Flat 12 Lo wer RR tires 4 Vocational , Tractors, Trailers Flat 13 Automated Tire Inflation System (ATIS) Tractors, Trailers Flat 12 Aero 1 & 2 HD Pickup & Van vehicles Flat 8 Aero Bins 1 & 2 Tractors None 1 Aero Bin 3 Tractors Flat 2 Aero Bins 4 thru 7 Tractors Steep 4 Aero Bins 1 thru 8 Trailers Flat 2 Weight reduction (via single wide tires and/or aluminum wheels) Tractors Flat 2

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2 - 203 Weight reduction via material changes HD Pickup & Van vehicles Flat 6 Weight reduction via material changes Vocational, Tractors Flat 13 Auxiliary power unit Tractors Flat 2 Air conditioning leakage Vocational, Tractors Flat 2 Air conditioning efficiency Tractors Flat 12 Neutral idle Vocational None 1 Stop - start (no regeneration) HD Pickup & Van vehicles Steep 9 Stop - start (no regeneration) Vocational Flat 13 Mild hybrid HD Pickup & Van vehicles Flat 6 Mild hybrid Tractors Flat 12 Strong hybrid HD Pickup & Van vehicles, Vocational Steep 11 Full electric Vocational, Tractors Steep 4 Note: a See table and figure below . 

### The actual ye ar -by- ye ar factors for the numbered curves shown in Table 2 - 100 are shown in Table 2 - 101 and are shown graphicall y in Figure 2 - 33 . **Table 2**  **- 101**  **Year -**  **by -** **year Learning Curve Factors for the Learning Curves Used**  **in this Analysis** CURVE A 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 1 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000 1.000 2 1.000 0.970 0.941 0.913 0.885 0.868 0.850 0.833 0.817 0.800 0.784 0.769 3 1.031 1.000 0.970 0.941 0.913 0.894 0.877 0.859 0.842 0.825 0.808 0.792 4 1.000 1.000 0.800 0.800 0.640 0.621 0.602 0.584 0.567 0.550 0.533 0.517 6 1.096 1.063 1.031 1.000 0.970 0.941 0.913 0.885 0.859 0.842 0.825 0.808 7 0.941 0.913 0.885 0.868 0.850 0.833 0.817 0.800 0.784 0.769 0.753 0.738 8 1.031 1.000 0.970 0.951 0.932 0.913 0.895 0.877 0.859 0.842 0.825 0.809 9 1.250 1.000 1.000 0.970 0.941 0.913 0.885 0.859 0.833 0.808 0.784 0.760 11 1.563 1.563 1.563 1.563 1.563 1.250 1.250 1.000 0.970 0.941 0.913 0.885 12 1.130 1.096 1.063 1.031 1.000 0.970 0.941 0.913 0.894 0.877 0.859 0.842 13 1.238 1.201 1.165 1.130 1.096 1.063 1.031 1.000 0.970 0.941 0.913 0.894 Note: a Curves 5 and 10 were generated but subsequently not used so are not included in the table.

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2 - 204 0.40 0.60 0.80 1.00 1.20 1.40 1.60

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 1 2 3 4 6 7 8 9 11 12 13

**Figure 2**  **- 33**  **Year -**  **by -** **year Learning Curve Factors for the Learning Curves used in this Analysis**  

### Importantly , where the factors shown in Table 2 - 101 and, therefore, the curves shown in Figure 2 - 33 equal “1.00” represents the year for which any particular technology ’s cost is based. In other words, for example, the cost estimate that we have for cylinder head improvements 2 is “based” in 2021 (curve 13). Therefore, its learning factor equals 1.00 in 2021 and then decreases going forward to represent lower costs due to learning effects. It s learning factors are greater than 1.00 in years before 2021 to repres ent “reverse” learning, i.e., higher costs than our 2021 estimate since production volumes have, presumably, not yet reached the point where our cost estimate can be considered valid. 

## 2.12.1.4 Technology

Adoption Rates and Package Costs Determining the stringency o f the proposed standards involves a balancing of relevant factors

– chiefl y technology feasibility and effectiveness, costs, and lead time. For vocational vehicles, tractors and trailers, the agencies have projected a technology path to achieve the propos ed standards reflecting an application rate of those technologies the agencies consider to be available at reasonable cost in the lead times provided. The agencies do not expect each of the technologies for which costs have been developed to be employed b y al l engines and vehicles across the board. Further, many of today ’s vehicles are already equipped with some of the technologies and/or are expected to adopt them by MY2018 to comply with the HD Phase 1 standards. Estimated adoption rates in both the re ference and control cases are necessary for each vehicle/trailer category . The adoption rates for many technologies are zero in the reference

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2 - 205 case; however, for some technologies

— notably aero and tire technologies

—the adoption rate is not always zero in the reference case. These reference and control case adoption rates are then applied to the technology costs with the result being a package cost for each vehicle/trailer category . As such, package costs are rarel y if ever a simple sum of all the technology costs since each technology

would be expected to be adopted at different rates. For HD pickups and vans, the CAFE model determines the technology adoption rates that most cost effectivel y meet the standards being proposed. Similar to vocational vehicles, tractors and trailers, package costs are rarel y if ever a simple sum of all the technology costs since each technology

would be expected to be adopted at different rates. The methods for estimating technology

adoption rates and resultant costs (and other impacts) for HD pickups and vans are discussed in Chapter 10 of this draft RIA . 

## 2.12.1.5 Conversion of Technology Costs to 2012 U . S . Dollars As noted above in Section IX.C.1, the agencies are using technology costs from many different sources. These sources, having been published in different years, present costs in different ye ar dollars (i.e., 2009 dollars or 2010 dollars). For this analysis, the agencies sought to have all costs in terms of 2012 dollars to be consistent with the dollars used by AEO in its 2014 Annual Energy

Outlook. 174 

### While the factors used to convert from 2009 dollars (or other) to 2012 dollars are small, the agencies prefer to be overly diligent in this regard to ensure consistency

across our benefit - cost anal ysis. The agencies have used the GDP Implicit Price Deflator for Gross Domestic Product as the converter, with the actual factors used as shown in Table 2 - 102 . 175

**Table 2**  **- 102**  **Im plicit Price Deflators and Conversion Factors for Conversion to 2012$**  CALENDAR YEAR 2005 2006 2007 2008 2009 2010 2011 2012 2013 Price index for GDP 91.991 94.818 97.335 99.236 100 101.211 103.199 105.002 106.588 Factor applied for 2012$ 1.141 1.107 1.079 1.058 1.050 1.037 1.017 1.000 0.985 

### The sections above describe the technologies expected to be used to enable compliance with the proposed standards and the adoption rates we estimate to be possible. Here we present the cost of each technology , the markups used for each, the learning effect applied, etc. The tables here present the direct manufacturing cost (DMC) we have estimated for each technology , the indirect costs (IC) associated with that technology , and the resultant total cost (TC) of each (where TC=DMC+IC). Each table also presents, where appropriate, the expected adoption rate of each technology

in both the reference case (i.e., alternative 1a or the “no new controls” case) and th e policy

case (the proposed standards). For most technologies, the reference case adoption rate will be shown as 0 percent (or blanks in the tables) since the Phase 2 technologies are expected to be in limited or no use in the regulatory timeframe. Howev er, for some technologies

—

notably tire and aero technologies

—there is expected to considerabl y adoption of Phase 2 technologies in the reference case. The final row(s) of the tables shown here include the adoption rates applied to the technology costs to arrive at a total cost of each technology as it is applied to the ultimate package (noted as TCp). In Chapter 2.13 of this draft RIA , we sum these costs (the TCp costs) into total cost applied to the packages presented later in Chapter 7 of this draft RIA. We also describe how we moved from the total cost applied to the packages developed for the regulatory classes (i.e., Class 8 Sleeper cab, LH vocational medium - speed,

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2 - 206 etc.) to the MOVES sourcetypes (i.e., transit bus, refuse truck, combination long haul, etc.) in order to develop program costs. This final step

— moving from regulatory

classes to MOVES sourcetypes, was necessary because MOVES populations, sales, inventory calculations, etc., are based on sourcetypes, not regulatory classes, and to allow for a more granular look at payback as presented in Chapter 7.4 of this draft RIA. Note that the text surrounding the tables presented here refer to low/medium/high complexity

I CMs and to learning curves used. We discuss both the ICMs and the learning effects used in this anal ysis in Chapter 2.12.1.2 and 2.12.1.3 of this draft RIA, respectively . 

## 2.12.2 **Costs of Engine Technologies** 2.12.2.1 Aftertreatment improvements We have estimated the cost of aftertreatment improvements based on the aftertreatment improvements technology discussed in the Phase 1 rule s . That technology was estimated at $25 (DMC, 2008$, in 2014) for each percentage improvement in fuel consumption, or $100 (DMC, 2008$, in 2014) for the 4 percent improvement expected as a result of that program . In Phase 2, we are expecting onl y a 0.6 percent improvement in fuel consumption resulting from aftertreatment improvements. Therefore, the cost in Phase 2 including updates to 2012$ is $16 (DMC, 2012$, in 2014). We consider this technology to be on the flat portion of the learning curve (curve 2) and have applied a low complexity ICM with short term markups through 2024. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 103 for vocational engines and in Table 2 - 104 for tractor engines . **Table 2**  **- 103**  **Costs of Aftertreatm ent Improvements**  **– Level**  **2 Light/Medium/Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aftertreatment improvements

– level 2 DMC $14 $14 $13 $13 $13 $13 $12 $12 $12 $12 Aftertreatment improvements

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Aftertreatment improvements

– level 2 TC $17 $16 $16 $16 $15 $15 $15 $14 $14 $14 Aftertreatment improvements

– level 2 Alt 1a Aftertreatment improvements

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Aftertreatment improvements

– level 2 TCp $0 $0 $0 $8 $8 $8 $13 $13 $13 $14 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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2 - 207 **Table 2**  **- 104**  **Costs of Aftertreatm ent Improvements**  **– Level 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aftertreatment improvements

– level 2 DMC $14 $14 $13 $13 $13 $13 $12 $12 $12 $12 Aftertreatment improvements

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Aftertreatment improvements

– level 2 TC $17 $16 $16 $16 $15 $15 $15 $14 $14 $14 Aftertreatment improvements

– level 2 Alt 1a Aftertreatment improvements

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Aftertreatment improvements

– level 2 TCp $0 $0 $0 $7 $7 $7 $14 $13 $13 $14 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.2 Cylinder head improvements We have estimated the cost of cylinder head improvements based on the cylinder head improv ements technology discussed in the Phase 1 rule s . That technology was estimated at $9 (DMC, 2008$, in 2014) for light HDD engines and at $5 (DMC, 2008$, in 2014) for medium and heavy HDD engines. In Phase 2, we are estimating equivalent costs for an additional level of cylinder head improvements. With updates to 2012$, we estimate the costs at $10 (DMC, 2012$, in 2021) for light HDD engines and at $6 (DMC, 2012$, in 2021) for medium and heavy HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2027. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 105 through Table 2 - 107 . **Table 2**  **- 105**  **Costs for Cylinder Head Improvements –**  **Level 2** 

**Light HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Cylinder head improvements

– level 2 DMC $11 $11 $10 $10 $10 $9 $9 $9 $9 $9 Cylinder head improvements

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Cylinder head improvements

– level 2 TC $12 $12 $12 $11 $11 $11 $11 $10 $10 $10 Cylinder head improvements

– level 2 Alt 1a Cylinder head improvements

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Cylinder head improvements

– level 2 TCp $0 $0 $0 $6 $6 $5 $10 $9 $10 $10 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 208 **Table 2**  **- 106**  **Costs for Cylinder Head Improvements –**  **Level 2**  **Medium /Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Cylinder head im

provements

– level 2 DMC $6 $6 $6 $6 $6 $5 $5 $5 $5 $5 Cylinder head improvements

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Cylinder head improvements

– level 2 TC $7 $7 $7 $7 $7 $6 $6 $6 $6 $6 Cylinder head improvements

– level 2 Alt 1a Cylinder head improvements

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Cylinder head improvements

– level 2 TCp $0 $0 $0 $3 $3 $3 $6 $5 $5 $6 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 107**  **Costs for Cylinder Head Improvements –**  **Level 2**

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Cylinder head improvements

– level 2 DMC $6 $6 $6 $6 $6 $5 $5 $5 $5 $5 Cylinder head improvements

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Cylinder head improvements

– level 2 TC $7 $7 $7 $7 $7 $6 $6 $6 $6 $6 Cylinder head im

provements

– level 2 Alt 1a Cylinder head improvements

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Cylinder head improvements

– level 2 TCp $0 $0 $0 $3 $3 $3 $6 $6 $6 $6 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.3 Turbocharger efficiency improvements We have estimated the cost of turbo efficiency improvements based on the turbo efficiency improvements technology discussed in the Phase 1 rule s . That technology was estimated at $16 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equivalent costs for an additional level of turbo efficiency improvements. With updates to 2012$, we estimate the costs at $17 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology

to be on the flat portion of the learning curve (curve 13) and have applied a low complexity

I CM with short term markups through 2027. The resultant technol ogy costs, adoption rates and total cost applied to the package are shown in Table 2 - 108 and Table 2 - 109 for vocational and tractor engines .

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2 - 209 **Table 2**  **- 108**  **Costs for Turbocharger Efficiency Improvements –**  **Level 2**  **Light/Medium/Heavy HDD Vocational Engi nes (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Turbo efficiency im provements

– level 2 DMC $18 $18 $17 $17 $16 $16 $15 $15 $14 $14 Turbo efficiency im provements

– level 2 IC $3 $3 $3 $3 $3 $3 $3 $3 $3 $3 Turbo efficiency im provements

– level 2 TC $21 $20 $20 $19 $19 $18 $18 $17 $17 $17 Turbo efficiency im provements

– level 2 Alt 1a Turbo efficiency im provements

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Turbo efficiency im provements

– level 2 TCp $0 $0 $0 $10 $9 $9 $16 $16 $15 $17 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 109**  **Costs for Turbocharger Efficiency Improvements –**  **Level 2**

**H DD**  **Tractor Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Turbo efficiency im provements

– level 2 DMC $18 $18 $17 $17 $16 $16 $15 $15 $14 $14 Turbo efficiency im provements

– level 2 IC $3 $3 $3 $3 $3 $3 $3 $3 $3 $3 Turbo efficiency im provements

– level 2 TC $21 $20 $20 $19 $19 $18 $18 $17 $17 $17 Turbo efficiency im provements

– level 2 Alt 1a Turbo efficiency im provements

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Turbo efficiency im provements

– level 2 TCp $0 $0 $0 $9 $8 $8 $17 $16 $16 $17 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For HD diesel pickups and vans, we are estimating use of the Phase 1 level of turbo efficiency improvements, or $17 (DMC, 2012$, in 2014). We consider this technology to be on the flat por

tion of the learning curve (curve 2) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs are shown in Table 2 - 110 . **Table 2**  **- 110**  **Costs for Turbocharger Efficiency Improvements –**  **Level 1** 

**HD Pickups & Vans (2012$)** TECHNOLOGY 2021 2022 2023 2024 2025 2026 2027 Turbo efficiency improvements

– level 1 DMC $14 $14 $13 $13 $13 $13 $13 Turbo efficiency improvements

– level 1 IC $3 $3 $2 $2 $2 $2 $2 Turbo efficiency improvements

– level 1 TC $16 $16 $15 $15 $15 $15 $15 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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2 - 210 

## 2.12.2.4 Turbo compounding We have estimated the cost of turbo compounding based on the turbo compounding technology

discussed in the Phase 1 rule s . That technology was estimated at $813 (DMC, 2008$, in 2014) for all HDD tractor engines. In Phase 2, we are estimating equivalent costs for an additional level of turbo compounding improvements. With updates to 2012$, we estimate the costs at $860 (DMC, 2012$, in 2021) for all HDD tractor engines. We consider this technology

to be on the flat portion of the learning curve (curve 1 3) and have applied a low complexity

I CM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 111 . **Table 2**  **- 111**  **Costs for Turbocharger Compounding**  **– Level**  **2**

**HDD Tractor Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Turbo compounding

– level 2 DMC $942 $914 $886 $860 $834 $809 $785 $769 $754 $738 Turbo compounding

– level 2 IC $134 $133 $133 $133 $133 $133 $133 $133 $132 $132 Turbo compounding

– level 2 TC $1,076 $1,047 $1,020 $993 $967 $942 $917 $902 $886 $871 Turbo compounding

– level 2 Alt 1a Turbo compounding

– level 2 Alt 3 5% 5% 5% 10% 10% 10% 10% Turbo compounding

– level 2 TCp $0 $0 $0 $50 $48 $47 $92 $90 $89 $87 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.5 Valve actuation We have estimated the cost of valve actuation based on the dual cam phasing cost estimate used in the 2017 - 2025 light - duty rule. In that anal ys is, we estimated costs at $151 (DMC, 2010$, in 2015) for a large V8 engine. In this HD Phase 2 program , we are estimating equivalent costs for this technology . With updates to 2012$, we estimate the costs at $157 (DMC, 2012$, in 2015) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 8) and have applied a medium complexity I CM with short term markups through 2018. The resultant technology costs, adoption rates and total cost applied to the package are s hown in Table 2 - 112 for vocational engines and in Table 2 - 113 for tractor engines .

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

2 - 211 **Table 2**  **- 112**  **Costs for Valve Actuation Light/Medium/Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Valve actuation DMC $146 $143 $141 $138 $135 $132 $130 $127 $126 $125 Valve actuation IC $60 $45 $45 $45 $45 $45 $45 $45 $45 $44 Valve actuation TC $207 $188 $186 $183 $180 $177 $174 $172 $170 $169 Valve actuation Alt

1a Valve actuation Alt 3 50% 50% 50% 90% 90% 90% 100% Valve actuation All $0 $0 $0 $91 $90 $89 $157 $154 $153 $169 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 113**  **Costs for Valve Actuation HDD**  **Tractor Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Valve actuation DMC $146 $143 $141 $138 $135 $132 $130 $127 $126 $125 Valve actuation IC $60 $45 $45 $45 $45 $45 $45 $45 $45 $44 Valve actuation TC $207 $188 $186 $183 $180 $177 $174 $172 $170 $169 Valve actuation Alt

1a Valve actuation Alt 3 45% 45% 45% 95% 95% 95% 100% Valve actuation All $0 $0 $0 $82 $81 $80 $166 $163 $162 $169 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For HD pickups and vans, we have estimated the costs of dual cam phasing based on the DMC, IC and TC presented above in Table 2 - 112 . For discrete variable valve lift (DVVL), we have again used the 2017 - 2025 light - duty FRM values updated to 2012$ to arrive at a cost of $259 (DMC, 2012$, in 2015). We consider this technology

to be on the flat portion of the learning curve (curve 8) and have applied medium complexity

mark ups with short term markups through 2024. The resultant costs are presented in Table 2 - 114 . **Table 2**  **- 114**  **Costs for Discrete Variable Valve Lift (DVVL)**  **Gasoline HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Discrete variable valve lift (DVVL) DMC $227 $223 $218 $214 $210 $207 $205 Discrete variable valve lift (DVVL) IC $74 $74 $74 $74 $74 $73 $73 Discrete variable valve lift (DVVL) TC $301 $297 $292 $288 $283 $281 $279 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.2.6 EGR We have estimated the cost of EGR cooler improvements based on the EGR cooler improvements technology discussed in the Phase 1 rule s . That technology was estimated at $3

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

2 - 212 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equival ent costs for an additional level of EGR cooler improvements. With updates to 2012$, we estimate the costs at $3 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 115 for vocational engines and in Table 2 - 116 for tractor engines . **Table 2**  **- 115**  **Costs for EGR Cooler Improvem ents**  **– Level**  **2 Light/Medium/Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 EGR cooler

– level 2 DMC $4 $4 $3 $3 $3 $3 $3 $3 $3 $3 EGR cooler

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 EGR cooler

– level 2 TC $4 $4 $4 $4 $4 $4 $4 $3 $3 $3 EGR cooler

– level 2 Alt 1a EGR cooler

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% EGR cooler

– level 2 TCp $0 $0 $0 $2 $2 $2 $3 $3 $3 $3 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 116**  **Costs for EGR Cooler Improvem ents**  **– Level 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 EGR cooler

– level 2 DMC $4 $4 $3 $3 $3 $3 $3 $3 $3 $3 EGR cooler

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 EGR cooler

– level 2 TC $4 $4 $4 $4 $4 $4 $4 $3 $3 $3 EGR cooler

– level 2 Alt 1a EGR cooler

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% EGR cooler

– level 2 TCp $0 $0 $0 $2 $2 $2 $3 $3 $3 $3 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For HD pickups and vans, we have estimated the costs of adding cooled EGR to a gasoline engine based on the values used in the 2017 - 2025 light - duty FRM. We have scaled upward the light - duty value by 25 percent and converted to 2012$ to arrive at a cost of $317 (DMC, 2012$, in 2012). We consider this technology to be on the flat portion of the learning curve (curve 7) and have applied medium complexity markups with near term markups through 2024. The resultant costs are presented in Table 2 - 117 . **Table 2**  **- 117**  **Costs for Cooled EGR Gasoline HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Cooled EGR DMC $253 $248 $243 $239 $234 $231 $229 Cooled EGR IC $120 $120 $119 $119 $89 $89 $89 Cooled EGR TC $373 $368 $363 $358 $323 $321 $318 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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2 - 213 

## 2.12.2.7 Water pump improvements We have estimated the cost of water pump improvements based on the water pump improvements technology discussed in the Phase 1 rule s . That technology was estimated at $78 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equival ent costs for an additional level of water pump improvements. With updates to 2012$, we estimate the costs at $83 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have a pplied a low complexity

I CM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 118 for vocational engines and in Table 2 - 119 for tractor engines . **Table 2**  **- 118**  **Costs for Water Pump Improvement s**  **– Level**  **2 Light/Medium/Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Water pump

– level 2 DMC $91 $88 $85 $83 $80 $78 $75 $74 $72 $71 Water pump

– level 2 IC $13 $13 $13 $13 $13 $13 $13 $13 $13 $13 Water pump

– level 2 TC $103 $101 $98 $95 $93 $91 $88 $87 $85 $84 Water pump

– level 2 Alt 1a Water pump

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Water pump

– level 2 TCp $0 $0 $0 $57 $56 $54 $79 $78 $77 $84 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 119**  **Costs for Water Pump Improvements –**  **L evel 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Water pump

– level 2 DMC $91 $88 $85 $83 $80 $78 $75 $74 $72 $71 Water pump

– level 2 IC $13 $13 $13 $13 $13 $13 $13 $13 $13 $13 Water pump

– level 2 TC $103 $101 $98 $95 $93 $91 $88 $87 $85 $84 Water pump

– level 2 Alt 1a Water pump

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Water pump

– level 2 TCp $0 $0 $0 $43 $42 $41 $84 $82 $81 $84 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.8 Oil pump improvements We have estimated the cost of oil pump improvements based on the oil pump improvements technology discusse d in the Phase 1 rule s . That technology was estimated at just under $4 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equivalent costs for an additional level of oil pump improvements. With updates to 2012$, we estimate the costs at just over $4 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2027. The resultant technology costs, adoption rates and total

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

2 - 214 cost applied to the package are shown in Table 2 - 120 for vocational engines and in Table 2 - 121 for tractor engines . **Table 2**  **- 120**  **Costs for Oil Pump Improvements –**  **Level 2**  **Light/Medium/Heavy HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Oil pump

– level 2 DMC $5 $4 $4 $4 $4 $4 $4 $4 $4 $4 Oil pump

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Oil pump

– level 2 TC $5 $5 $5 $5 $5 $5 $4 $4 $4 $4 Oil pump

– level 2 Alt 1a Oil pump

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Oil pump

– level 2 TCp $0 $0 $0 $3 $3 $3 $4 $4 $4 $4 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 121**  **Costs for Oil Pump Improvements –**  **Level 2**

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Oil pump

– level 2 DMC $5 $4 $4 $4 $4 $4 $4 $4 $4 $4 Oil pump

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Oil pump

– level 2 TC $5 $5 $5 $5 $5 $5 $4 $4 $4 $4 Oil pump

– level 2 Alt 1a Oil pump

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Oil pump

– level 2 TCp $0 $0 $0 $2 $2 $2 $4 $4 $4 $4 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.9 Fuel pump improvements We have estimated the cost of fuel pump improvements based on the fuel pump improvements technology discussed in the Phase 1 rule s . That technology was estimated at just under $4 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equivalent costs for an additional level of fuel pump improvements. With updates to 2012$, we estimate the costs at just over $4 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 122 for vocational engines and in Table 2 - 123 for tractor engines .

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

2 - 215 **Table 2**  **- 122**  **Costs for Fuel Pump Improvements –**  **Level 2**  **Light/Medium/Heavy HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel pump

– level 2 DMC $5 $4 $4 $4 $4 $4 $4 $4 $4 $4 Fuel pump

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Fuel pump

– level 2 TC $5 $5 $5 $5 $5 $5 $4 $4 $4 $4 Fuel pump

– level 2 Alt 1a Fuel pump

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Fuel pump

– level 2 TCp $0 $0 $0 $3 $3 $3 $4 $4 $4 $4 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 123**  **Costs for Fuel Pump Improvements –**  **Le vel 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel pump

– level 2 DMC $5 $4 $4 $4 $4 $4 $4 $4 $4 $4 Fuel pump

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Fuel pump

– level 2 TC $5 $5 $5 $5 $5 $5 $4 $4 $4 $4 Fuel pump

– level 2 Alt 1a Fuel pump

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Fuel pump

– level 2 TCp $0 $0 $0 $2 $2 $2 $4 $4 $4 $4 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.10 Fuel rail improvements We have estimated the cost of fuel rail improvements based on the fuel rail improvements technology

discussed in the Phase 1 rule s . That technology was estimated at $10 (DMC, 2008$, in 2014) for LHDD engines and just under $9 (DMC, 2008$, in 2014) for MHDD and HHDD engines. In Phase 2, we are estimating equivalent costs for an additional level of fuel rail improvements. With updates to 2012$, we estimate the costs at $11 (DMC, 2012$, in 2021) for LHDD and at just over $9 (DMC, 2012$, in 2021) for MHDD and HHDD engines. We consider this technology

to be on the flat portion of the learning curve (curve 13) and have applied a low complexity

I CM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 124 through Table 2 - 126 .

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

2 - 216 **Table 2**  **- 124**  **Costs for Fuel Rail Improvements –**  **Level 2**  **Light HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel rail

– level 2 DMC $12 $11 $11 $11 $10 $10 $10 $10 $9 $9 Fuel rail

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Fuel rail

– level 2 TC $13 $13 $13 $12 $12 $12 $11 $11 $11 $11 Fuel rail

– level 2 Alt 1a Fuel rail

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Fuel rail

– level 2 TCp $0 $0 $0 $7 $7 $7 $10 $10 $10 $11 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 125**  **Costs for Fuel Rail Improvements –**  **Level 2**  **Medium /Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel rail

– level 2 DMC $10 $10 $9 $9 $9 $9 $8 $8 $8 $8 Fuel rail

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Fuel rail

– level 2 TC $11 $11 $11 $11 $10 $10 $10 $10 $9 $9 Fuel rail

– level 2 Alt 1a Fuel rail

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Fuel rail

– level 2 TCp $0 $0 $0 $6 $6 $6 $9 $9 $8 $9 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 126**  **Costs for Fuel Rail Improvements –**  **Level 2**

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel rail

– level 2 DMC $10 $10 $9 $9 $9 $9 $8 $8 $8 $8 Fuel rail

– level 2 IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Fuel rail

– level 2 TC $11 $11 $11 $11 $10 $10 $10 $10 $9 $9 Fuel rail

– level 2 Alt 1a Fuel rail

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Fuel rail

– level 2 TCp $0 $0 $0 $5 $5 $4 $9 $9 $9 $9 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.11 Fuel injector improvements We have estimated the cost of fuel injector improvements based on the fuel injector improvements technology discussed in the Phase 1 rule s . That technology was estimated at $13 (DMC, 2008$, in 2014) for LHDD engines and $9 (DMC, 2008$, in 2014) for MHDD and HHDD engines. In Phase 2, we are estimating equivalent costs for an additional level of fuel injector improvements. With updates to 2012$, we estimate the costs at $13 (DMC, 2012$, in 2021) for LHDD and at $10 (DMC, 2012$, in 2021) for MHDD and HHDD engines. We consider this technology

to b e on the flat portion of the learning curve (curve 13) and have applied a low complexity ICM with short term markups through 2027. The resultant technology

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2 - 217 costs, adoption rates and total cost applied to the package are shown in Table 2 - 127 through Table 2 - 129 . **Table 2**  **- 127**  **Costs for Fuel Injec tor Improvem**  **ents –**  **Level 2**  **Light HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel injectors

– level 2 DMC $14 $14 $14 $13 $13 $12 $12 $12 $12 $11 Fuel injectors

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Fuel injectors

– level 2 TC $17 $16 $16 $15 $15 $14 $14 $14 $14 $13 Fuel injectors

– level 2 Alt 1a Fuel injectors

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Fuel injectors

– level 2 TCp $0 $0 $0 $8 $7 $7 $13 $12 $12 $13 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 128**  **C osts for Fuel Injector Improvem**  **ents –**  **Level 2**  **Medium /Heavy HDD**  **Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel injectors

– level 2 DMC $11 $11 $10 $10 $10 $9 $9 $9 $9 $9 Fuel injectors

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Fuel injectors

– level 2 TC $12 $12 $12 $11 $11 $11 $11 $10 $10 $10 Fuel injectors

– level 2 Alt 1a Fuel injectors

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Fuel injectors

– level 2 TCp $0 $0 $0 $6 $6 $5 $10 $9 $9 $10 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 129**  **Costs for Fuel Injector Improvem**  **ents –**  **Level 2**

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Fuel injectors

– level 2 DMC $11 $11 $10 $10 $10 $9 $9 $9 $9 $9 Fuel injectors

– level 2 IC $2 $2 $2 $2 $2 $2 $2 $2 $2 $2 Fuel injectors

– level 2 TC $12 $12 $12 $11 $11 $11 $11 $10 $10 $10 Fuel injectors

– level 2 Alt 1a Fuel injectors

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Fuel injectors

– level 2 TCp $0 $0 $0 $5 $5 $5 $10 $10 $10 $10 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.12 Piston improvements We have estimated the cost of piston improvements based on the piston improv ements technology

discussed in the Phase 1 rule s . That technology was estimated at just over $2 (DMC, 2008$, in 2014) for all HDD engines. In Phase 2, we are estimating equivalent costs for an additional level of fuel pump improvements. With updates to 2012$, we estimate the costs at over $2 (DMC, 2012$, in 2021) for all HDD engines. We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short

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

2 - 218 term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 130 for vocational engines and in Table 2 - 131 for tractor engines . **Table 2**  **- 130**  **Costs for Fuel Pump Improvements –**  **Level 2**  **Light/Medium/Heavy HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Piston improvements

– level 2 DMC $3 $3 $3 $2 $2 $2 $2 $2 $2 $2 Piston improvements

– level 2 IC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Piston improvements

– level 2 TC $3 $3 $3 $3 $3 $3 $3 $3 $3 $3 Piston im provements

– level 2 Alt 1a Piston improvements

– level 2 Alt 3 50% 50% 50% 90% 90% 90% 100% Piston improvements

– level 2 TCp $0 $0 $0 $1 $1 $1 $2 $2 $2 $3 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 131**  **Costs for Fuel Pump Improvements –**  **Level 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Piston improvements

– level 2 DMC $3 $3 $3 $2 $2 $2 $2 $2 $2 $2 Piston improvements

– level 2 IC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Piston improvements

– level 2 TC $3 $3 $3 $3 $3 $3 $3 $3 $3 $3 Piston improvements

– level 2 Alt 1a Piston improvements

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Piston improvements

– level 2 TCp $0 $0 $0 $1 $1 $1 $3 $2 $2 $3 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.13 Valvetrain friction reduction We have estimated the cost of valvetrain friction reduction based on the valvetrain friction reduction technology discussed in the Phase 1 rule s . That technology was estimated at $94 (DMC, 2008$, in 2014) for LHDD engines and $70 (DMC, 2008$, in 2014) for MHDD and HHDD engines. In Phase 2, we are estimating equivalent costs for an additional level of fuel injector improvements. With updates to 2 012$, we estimate the costs at $99 (DMC, 2012$, in 2021) for LHDD and at $74 (DMC, 2012$, in 2021) for MHDD and HHDD engines. We

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2 - 219 consider this technology

to be on the flat portion of the learning curve (curve 13) and have applied a low complexity ICM with short term markups through 2027. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 132 and Table 2 - 133 for vocational engines and in Table 2 - 134 for tractor engines .

**Table 2**  **- 132**  **Costs for Valvetrain Friction Improvem ents**  **– Level**  **2**

**Light HDD Vocational**  **Engines (201 2$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Valvetrain friction reduction

– level 2 DMC $109 $105 $102 $99 $96 $93 $91 $89 $87 $85 Valvetrain friction reduction

– level 2 IC $15 $15 $15 $15 $15 $15 $15 $15 $15 $15 Valvetrain friction reduction

– level 2 TC $124 $121 $118 $115 $112 $109 $106 $104 $102 $100 Valvetrain friction reduction

– level 2 Alt 1a Valvetrain friction reduction

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Valvetrain friction reduction

– level 2 TCp $0 $0 $0 $69 $67 $65 $95 $94 $92 $100 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 133**  **Costs for Valvetrain Friction Improvem ents**  **– Level**  **2 Medium** **/Heavy HDD Vocational**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Valvetrain friction reduction

– level 2 DMC $82 $79 $77 $74 $72 $70 $68 $67 $65 $64 Valvetrain friction reduction

– level 2 IC $12 $12 $12 $12 $12 $11 $11 $11 $11 $11 Valvetrain friction reduction

– level 2 TC $93 $91 $88 $86 $84 $81 $79 $78 $77 $75 Valvetrain friction reduction

– level 2 Alt 1a Valvetrain friction reduction

– level 2 Alt 3 60% 60% 60% 90% 90% 90% 100% Valvetrain friction reduction

– level 2 TCp $0 $0 $0 $52 $50 $49 $71 $70 $69 $75 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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2 - 220 **Table 2**  **- 134**  **Costs for Valvetrain Friction Improvem ents**  **– Level 2** 

**HDD Tractor**  **Engines (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Valvetrain friction reduction

– level 2 DMC $82 $79 $77 $74 $72 $70 $68 $67 $65 $64 Valvetrain friction reduction

– level 2 IC $12 $12 $12 $12 $12 $11 $11 $11 $11 $11 Valvetrain friction reduction

– level 2 TC $93 $91 $88 $86 $84 $81 $79 $78 $77 $75 Valvetrain friction reduction

– level 2 Alt 1a Valvetrain friction reduction

– level 2 Alt 3 45% 45% 45% 95% 95% 95% 100% Valvetrain friction reduction

– level 2 TCp $0 $0 $0 $39 $38 $37 $75 $74 $73 $75 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.14 “Right - sized” diesel engine We have estimated the cost of a slightly smaller diesel engine at a $500 savings (DMC, 2013$, in any

year) for all HDD tractor engines. We believe this represents an opportunity for lower costs because smaller diesel engines contain less materials and are , generall y, less costl y to produce than a larger diesel engine. In 2012$, we estimate the costs at $493 (DMC, 2012$, in any year) for all HDD tractor engines. As this cost is considered applicable in any year, we have applied not learning effects (curve 1). We have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 1 35 for tractor engines. For HD pickups and vans, we estimated the right - sized diesel engine cost as cost neutral to any reference case diesel engine and limited the technology to diesel vans. We have not included any costs associate d with lost utility of the smaller diesel engine. We believe that the smaller engine would be attractive to some buyers, but not all, and that those buyers would not be concerned by any possible lost utility . For that reason, we have used a limited applic ation rate for this technology since, as noted, not all buyers would be interested in this option due to the potential for lost utility . Note that, for HD pickups and vans, we have considered this technology to be cost neutral.

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2 - 221 **Table 2**  **- 1**  **35 Costs for “Right**  **- sized” HD**  **D Tractor Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Right - sized diesel engine DMC - $493 - $493 - $493 - $493 - $493 - $493 - $493 - $493 - $493 - $493 Right - sized diesel engine IC $88 $88 $88 $88 $88 $69 $69 $69 $69 $69 Right - sized diesel engine TC - $405 - $405 - $405 - $405 - $405 - $424 - $424 - $424 - $424 - $424 Right - sized diesel engine Alt 1a Right - sized diesel engine Alt 3 10% 10% 10% 20% 20% 20% 30% Right - sized diesel engine TCp $0 $0 $0 - $40 - $40 - $42 - $85 - $85 - $85 - $127 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.15 Waste heat recovery We have estimated the cost of waste heat recovery based on the estimate from Tetra Tech showing it at $12,000 (retail, 2013$). Using that $12,000 estimate and dividing b y a 1.36 RPE (see Chapter 2.12.1.2 of this draft RIA) and converting to 2012$, we arrive at our estimated DMC of $8,692 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) because although waste heat recovery is a new technology

and in the 2015 to 2017 timeframe remains, perhaps, on the steeper portion of the learning curve, applying such rapid learning effects to the cost estimate we have would result in costs too low in the MY2024 to 2027 timeframe. We have applied a medium complexity ICM with short term markups through 2025. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 136 for tractor engines.

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

2 - 222 **Table 2**  **- 136**  **Costs for Waste Heat Recovery HDD Tractor Engines (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Waste heat recovery DMC $8,692 $8,431 $8,179 $7,933 $7,775 $7,619 $7,467 $7,317 $7,171 $7,028 Waste heat recovery IC $2,628 $2,615 $2,602 $2,589 $2,581 $2,574 $2,566 $2,558 $1,908 $1,903 Waste heat recovery TC $11,320 $11,046 $10,780 $10,523 $10,356 $10,193 $10,032 $9,876 $9,079 $8,931 Waste heat recovery Alt

1a Waste heat recovery Alt 3 1% 1% 1% 5% 5% 5% 15% Waste heat recovery TCp $0 $0 $0 $105 $104 $102 $502 $494 $454 $1,340 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.16 Model - based control We have estimated the cost of model -based controls at $100 (DMC, 2013$). Using that estimate and converting to 2012$, we arrive at our estimated DMC of $99 (DMC, 2012$, in 2021). We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2022. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 137 for vocational engines. **Table 2**  **- 137**  **Costs for Model Based Controls Light/Medium/Heavy HDD Vocational Engines (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Model -based control DMC $108 $105 $102 $99 $96 $93 $90 $88 $86 $85 Model -based control IC $15 $15 $15 $15 $15 $12 $12 $12 $12 $12 Model -based control TC $123 $120 $117 $114 $111 $105 $102 $100 $99 $97 Model -based control Alt 1a Model -based control Alt 3 25% 25% 25% 30% 30% 30% 40% Model -based control TCp $0 $0 $0 $28 $28 $26 $31 $30 $30 $39 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.2.17 Engine friction reduction and accommodating low friction lubes We have based the costs for accommodating low friction lubes (LUB) on the costs used in the light - duty

2017 - 2025 FRM but have scaled upward that cost by 50 percent to account for the larger HD engines. Using that cost ($3 DMC, 2006$, in any year) and converting to 2012$

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

2 - 223 results in a cost of $5 (DMC, 2012$, in any year). We consider this technology to be beyond learning (curve 1) and have applied low complexity markups with near term markups through 2018. The resultant costs for HD pickups and vans are shown in are shown in Table 2 - 138 . **Table 2**  **- 138**  **Costs for Accommodating Low Friction Lubes**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Engine friction reduction - level 1 DMC $5 $5 $5 $5 $5 $5 $5 Engine friction reduction - level 1 IC $1 $1 $1 $1 $1 $1 $1 Engine friction reduction - level 1 TC $6 $6 $6 $6 $6 $6 $6 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### We have based the costs for engine friction reduction level 1 (EFR1) on the costs used in the light - duty 2017 - 2025 FRM. That cost is based on an original estimate of $11/cylinder (DMC, 2006$, in any

year). Using that cost for an 8 cylinder engine and converting to 2012$ results in a cost of $97 (DMC, 2012$, in any year). We consider this technology to be beyond learning (curve 1) and have applied low complexity markups with near term markups through 2018. The resultant costs for HD pickups and vans are shown in are shown in Table 2 - 139 . **Table 2**  **- 139**  **Costs for Engine Friction Reduction –**  **Level 1**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Engine friction reduction - level 1 DMC $97 $97 $97 $97 $97 $97 $97 Engine friction reduction - level 1 IC $19 $19 $19 $19 $19 $19 $19 Engine friction reduction - level 1 TC $116 $116 $116 $116 $116 $116 $116 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### For engine friction reduction level 2 (EFR2, which includes costs for accommodating low friction lubes) we have used the same approach as used in the light- duty 2017 - 2025 rule in that we have doubled the DMC associated with LUB and EFR1 . As with those technologies, we consider EFR2 to be beyond learning (curve 1) and have applied low complexity markups but have applied near term markups through 2024. The resultant costs for gasoline HD pickups and vans are shown in Table 2 - 140 .

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2 - 224 **Table 2**  **- 140**  **Costs for Engine Friction Reduction –**  **Level 2** 

**Gasoline HD Pickups and Vans (20 12$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Engine friction reduction - level 2 DMC $205 $205 $205 $205 $205 $205 $205 Engine friction reduction - level 2 IC $50 $50 $50 $50 $39 $39 $39 Engine friction reduction - level 2 TC $254 $254 $254 $254 $244 $244 $244 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### For diesel HD pickups and vans, we have used the above costs for EFR level 2 and added to that costs associated with improvements to other parasitic loads on the engine. For that latter portion of the cost, we have used the light HDD engine DMCs for improv ed water pump level 1, improved oil pump level 1, improved fuel pump level 1, improved fuel injectors level 1 and valvetrain friction reduction level 1, which together result in a cost of $193 (DMC, 2012$, in and ye ar). We consider this combined set of te chnologies to be beyond the effects of learning (curve 1) and have applied low complexity markups with near term markups through 2022. The resultant costs for diesel HD pickups and vans are shown in Table 2 - 141 .

**Table 2**  **- 141**  **Costs for Engine Friction Reduction & Improvem ents to**  **Other Parasitics**  **Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 202 4 2025 2026 2027 Engine friction reduction - diesel DMC $397 $397 $397 $397 $397 $397 $397 Engine friction reduction - diesel IC $96 $96 $87 $87 $77 $77 $77 Engine friction reduction - diesel TC $494 $494 $484 $484 $474 $474 $474 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.2.18 Cylinder deactivation For cylinder deactivation on HD pickups and vans, we have based the costs on values presented in the light - duty 2017 - 2025 FRM with updates to 2012$ to arrive at a cost of $169 (DMC, 2012$, in 2015). We consider this technology to be on the flat portion of the learning curve (curve 8) and have applied medium complexity markups with near term markups through 2018. The resultant costs are presented in Table 2 - 142 . **Table 2**  **- 142**  **Costs for Cylinder Deactivation Gasoline HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Cylinder deactivation DMC $148 $145 $142 $139 $137 $135 $134 Cylinder deactivation IC $48 $48 $48 $48 $48 $48 $48 Cylinder deactivation TC $196 $193 $190 $187 $185 $183 $182 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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2 - 225 

## 2.12.2.19 Stoichiometric gasoline direct injection (SGDI) For gasoline direct injection on HD pickups and vans, we have based the costs on values presented in the light - duty 2017 - 2025 FRM with updates to 2012$ to arrive at a cost of $417 (DMC, 2012$, in 2012). We consider this te chnology to be on the flat portion of the learning curve (curve 7) and have applied medium complexity markups with near term markups through 2018. The resultant costs are presented in Table 2 - 143 . **Table 2**  **- 143**  **Costs for Direct Injection Gasoline HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Gasoline direct injection DMC $333 $327 $320 $314 $307 $304 $301 Gasoline direct injection IC $118 $118 $118 $117 $117 $117 $117 Gasoline direct injection TC $451 $445 $438 $431 $425 $422 $418 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost. 

## 2.12.2.20 Turbocharging & downsizing For turbocharging and downsizing (TDS) on HD pickups and vans, we have based the costs on values presented in the light- duty 2017 - 2025 FRM with updates to 2012$. For the twin turbo configuration expected on a V6 engine (downsize d from a V8), we estimate the cost at $735 (DMC, 2012$, in 2012). We consider this technology to be on the flat portion of the learning curve (curve 7) and have applied medium complexity markups with near term markups through 2018. For downsizing from an overhead valve (OHV) V8 to an overhead cam (OHC) V6 valvetrain, we have estimated the cost at $340 (DMC, 2012$, in 2017). We consider this technology

to be on the flat portion of the learning curve (curve 6) and have applied medium complexity

markups with near term markups through 2018. For downsizing from an OHC V8 to an OHC V6, we have estimated the cost at - $295 (DMC, 2012$, in 2012). We consider this technology

to be on the flat portion of the learning curve to arrive at a cost of $417 (DMC, 2012$, in 2012). We consider this technology to be on the flat portion of the learning curve (curve 7) and have applied medium complexity markups with near term markups through 2024. The resultant costs for the turbocharging s ys tem are shown in Table 2 - 144 , for downsizing from an OHV V8 to an OHC V6 in Table 2 - 145 , and downsizing from an OHC V8 to an OHC V6 in Table 2 - 146 . **Table 2**  **- 144**  **Costs for Adding Twin Turbos Gasoline HD Pickups**  **and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Adding twin turbos DMC $588 $576 $565 $553 $542 $537 $531 Adding twin turbos IC $208 $208 $208 $207 $207 $207 $207 Adding twin turbos TC $796 $784 $772 $761 $749 $744 $738 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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2 - 226 **Table 2**  **- 145**  **Costs for Downsizing from an OHV V8 to an OHC V6** 

**Gasoline HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Downsizing from OHV V8 to OHC V6 DMC $301 $292 $286 $280 $275 $269 $264 Downsizing from OHV V8 to OHC V6 IC $97 $97 $97 $97 $96 $96 $96 Downsizing from OHV V8 to OHC V6 TC $398 $389 $383 $377 $371 $365 $360 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

**Table 2**  **- 146**  **Costs for Downsizing from an OHC V8 to an OHC V6** 

**Gasoline HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Downsizing from OHC V8 to OHC V6 DMC - $236 - $232 - $227 - $223 - $218 - $216 - $214 Downsizing from OHC V8 to OHC V6 IC $112 $112 $111 $111 $83 $83 $83 Downsizing from OHC V8 to OHC V6 TC - $125 - $120 - $116 - $111 - $135 - $133 - $131 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.3 **Transmissions** 2.12.3.1 Adding additional gears (vocational) We have estimated the cost of adding 2 additional gears for vocational vehicles (light/medium HD, heavy HD urban/multipurpose) based on the light- duty cost for an 8 speed automatic transmission relative to a 6 speed automatic of $78 (DMC, 2010$, in 2012). R 

### We have scaled that value b y typical torque values of 2000 foot -pounds for vocational and 332 for a lightduty truck. With updates to 2012$, this DMC for vocational vehicles becomes $486 (DMC, 2012$, in 2012). We consider this technology to be on the flat portion of the learning curve (curve 7) and have applied a medium complexity ICM with short term markups through 2018. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 147 and Table 2 - 148 for vocational vehicles.

R This cost was updated by FEV in early 2013. We are using the updated cost here, not the value used in the light duty 2017 - 2025 final rule.

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

2 - 227 **Table 2**  **- 147**  **Costs for Adding 2 Gears to an Autom atic Transmission**  **Vocational Light/Medium /Heavy**  **HD U**  **rban/ M**  **ultipurpose Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Adding additional gears DMC $413 $405 $397 $389 $381 $374 $366 $359 $355 $352 Adding additional gears IC $143 $107 $107 $106 $106 $106 $105 $105 $105 $105 Adding additional gears TC $557 $512 $504 $495 $487 $479 $472 $464 $460 $457 Adding additional gears Alt 1a Adding additional gears Alt 3 5% 5% 5% 5% 5% 5% 5% Adding additional gears TCp $0 $0 $0 $25 $24 $24 $24 $23 $23 $23 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 148**  **Costs for Adding 2 Gears to an Autom atic Transmission**  **Vocational Light/Medium HD R** **egional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Adding additional gears DMC $413 $405 $397 $389 $381 $374 $366 $359 $355 $352 Adding additional gears IC $143 $107 $107 $106 $106 $106 $105 $105 $105 $105 Adding additional gears TC $557 $512 $504 $495 $487 $479 $472 $464 $460 $457 Adding additional gears Alt 1a Adding additional gears Alt 3 5% 5% 5% 5% 5% 5% 10% Adding additional gears TCp $0 $0 $0 $25 $24 $24 $24 $23 $23 $46 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.3.2 Automated manual transmissions (AMT) We have estimated the cost of an AMT transmission, relative to a manual transmission, based on an estimate b y Tetra Tech of $5 , 100 (retail, 2013$). Using that estimate, we divided by an RPE of 1.36 and converted to 2012$ to arrive at an estimated cost of $3694 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a medium complex ity I CM with short term markups through 2022. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 149 for vocational vehicles and in Table 2 - 150 for tractors.

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

2 - 228 **Table 2**  **- 149**  **Costs for an AMT Transmission Vocational Heavy HD Regional**  **Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to AMT DMC $3,694 $3,583 $3,476 $3,372 $3,304 $3,238 $3,173 $3,110 $3,048 $2,987 Manual to AMT IC $1,117 $1,111 $1,106 $1,101 $1,097 $818 $815 $813 $811 $809 Manual to AMT TC $4,811 $4,695 $4,582 $4,472 $4,401 $4,056 $3,989 $3,923 $3,859 $3,795 Manual to AMT Alt

1a Manual to AMT Alt 3 22% 22% 22% 33% 33% 33% 25% Manual to AMT TCp $0 $0 $0 $984 $968 $892 $1,316 $1,295 $1,273 $949 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 150**  **Costs for an AMT Transmission**

**Tractor s (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to AMT DMC $3,694 $3,583 $3,476 $3,372 $3,304 $3,238 $3,173 $3,110 $3,048 $2,987 Manual to AMT IC $1,117 $1,111 $1,106 $1,101 $1,097 $818 $815 $813 $811 $809 Manual to AMT TC $4,811 $4,695 $4,582 $4,472 $4,401 $4,056 $3,989 $3,923 $3,859 $3,795 Manual to AMT Alt

1a Manual to AMT Alt 3 40% 40% 40% 50% 50% 50% 50% Manual to AMT TCp $0 $0 $0 $1,789 $1,761 $1,622 $1,994 $1,961 $1,929 $1,898 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.3.3 Automatic Transmission Powershift We have estimated the cost of a powershift automatic transmissi on, relative to a manual transmission, based on an estimate by Tetra Tech of $15000 (retail, 2013$). Using that estimate, we divided b y an RPE of 1.36 and converted to 2012$ to arrive at an estimated cost of $11670 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a medium complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 151 for tractors.

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

2 - 229 **Table 2**  **- 151**  **Costs for a Powershift Autom atic Transmission** 

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to AT powershift DMC $11,670 $11,320 $10,981 $10,651 $10,438 $10,229 $10,025 $9,824 $9,628 $9,435 Manual to AT powershift IC $3,528 $3,511 $3,493 $3,477 $3,466 $2,583 $2,576 $2,569 $2,562 $2,555 Manual to AT powershift TC $15,199 $14,831 $14,474 $14,128 $13,904 $12,812 $12,601 $12,393 $12,190 $11,990 Manual to AT powershift Alt

1a Manual to AT powershift Alt 3 10% 10% 10% 20% 20% 20% 30% Manual to AT powershift TCp $0 $0 $0 $1,413 $1,390 $1,281 $2,520 $2,479 $2,438 $3,597 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.3.4 Dual - clutch transmissions (DCT) For vocatio nal light/medium HD vehicles and for heavy HD urban and multipurpose vehicles , we estimate the cost of a move to a DCT from an automatic transmission to be cost neutral. For vocational heavy HD regional vehicles, we have estimated the cost of a DCT, relative to a manual transmission, as being equal to the move from a manual transmission to an AMT or $3694 (DMC, 2012$, in 2018, see 2.12.3.2 above). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a medium complexity I CM with short term markups through 2022. The resultant technolo gy costs, adoption rates and total cost applied to the package are shown in Table 2 - 154 . **Table 2**  **- 152**  **Costs for a Dual C lutch Transmission (DCT)**  **Vocational Light/Medium /Heavy**  **HD U**  **rban/ M**  **ultipurpose Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Auto trans to DCT DMC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT IC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT TC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT Alt 1a Auto trans to DCT Alt 3 5% 5% 5% 15% 15% 15% 5% Auto trans to DCT TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 230 **Table 2**  **- 153**  **Costs for a Dual Clutch Transmission (DCT) Vocational Light/Medium HD**  **Regional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Auto trans to DCT DMC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT IC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT TC $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Auto trans to DCT Alt 1a Auto trans to DCT Alt 3 5% 5% 5% 15% 15% 15% 10 % Auto trans to DCT TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 154**  **Costs for a Dual Clutch Transmission (DCT) Vocational Heavy HD Regional Vehicles (2012$)**  TECHNOLOGY 201 8 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to DCT DMC $3,694 $3,583 $3,476 $3,372 $3,304 $3,238 $3,173 $3,110 $3,048 $2,987 Manual to DCT IC $1,117 $1,111 $1,106 $1,101 $1,097 $818 $815 $813 $811 $809 Manual to DCT TC $4,811 $4,695 $4,582 $4,472 $4,401 $4,056 $3,989 $3,923 $3,859 $3,795 Manual to DCT Alt

1a Manual to DCT Alt 3 22% 22% 22% 33% 33% 33% 25% Manual to DCT TCp $0 $0 $0 $984 $968 $892 $1,316 $1,295 $1,273 $949 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For tractors, we have based our estimated cost of a DCT relative to a manual transmission on a Tetra Tech estimate of $17,500 (retail, 2013$). Using that estimate, we divided by an RPE of 1.36 and converted to 2012$ to arrive at an estimated cost of $12676 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a medium complexity I CM with short term markups through 2022. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 155 for tractors. **Table 2**  **- 155**  **Costs for a Dual Clutch Transmission (DCT) Tractors (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to DCT DMC $12,676 $12,296 $11,927 $11,569 $11,338 $11,111 $10,889 $10,671 $10,458 $10,248 Manual to DCT IC $3,832 $3,813 $3,794 $3,776 $3,765 $2,806 $2,798 $2,790 $2,783 $2,775 Manual to DCT TC $16,509 $16,109 $15,721 $15,346 $15,102 $13,917 $13,687 $13,461 $13,240 $13,024 Manual to DCT Alt

1a Manual to DCT Alt 3 5% 5% 5% 10% 10% 10% 10% Manual to DCT TCp $0 $0 $0 $767 $755 $696 $1,369 $1,346 $1,324 $1,302 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 231 

## 2.12.3.5 Improved transmissions

– vocational vehicles For this technology , we have relied on our light- duty technologies referred to as high efficiency gearbox (HEG), aggressive shift logic (ASL 1) and earl y torque converter lockup (TORQ). Each of those technologies was estimated at $202, $27 and $25 (all are DMC, in 2010$, in 2015 or 2017 (HEG)). For this anal ys is, we have used those estimates for ASL1 and TORQ, but have scaled upward the cost of HEG by 25 percent to account for differences between light - duty and HD. Converting to 2012$ results in costs for this technology of $316 (DMC, 2012$, in 2021). We consider this technology to be on the flat portion of the learning curve (curve 13) and have applied a low complexity I CM with short term markups through 2022. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 156 for vocational vehicles. **Table 2**  **- 156**  **Costs of Im proved**  **Transmissions All Vocational HD Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Im proved trans DMC $346 $336 $326 $316 $307 $297 $288 $283 $277 $271 Im proved trans IC $57 $57 $57 $56 $56 $44 $44 $44 $44 $44 Im proved trans TC $403 $393 $382 $372 $363 $342 $333 $327 $321 $315 Im proved trans Alt 1a Im proved trans Alt 3 15% 15% 15% 30% 30% 30% 70% Im proved trans TCp $0 $0 $0 $56 $54 $51 $100 $98 $96 $221 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.3.6 Manual to automatic transmission, vocational heavy HD regional vehicles For this technology , we have estimated the cost as equal to the cost for moving from a manual transmission to an AMT, as presented above, but have considered that cost to be applicable to MY2012, or $3694 (DMC, 2012$, in 2012). We consider this technology to be on the flat portion of the learning curve (curve 7) and have applied a medium complexity I CM with short term markups through 2018. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 157 .

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

2 - 232 **Table 2**  **- 157**  **Cost for an Autom atic Transmission**  **Vocational Heavy HD Regional Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Manual to auto trans DMC $3,141 $3,078 $3,017 $2,956 $2,897 $2,839 $2,782 $2,727 $2,699 $2,672 Manual to auto trans IC $1,089 $812 $810 $808 $806 $804 $802 $800 $799 $798 Manual to auto trans TC $4,230 $3,890 $3,826 $3,764 $3,703 $3,643 $3,584 $3,526 $3,498 $3,470 Manual to auto trans Alt

1a Manual to auto trans Alt 3 22% 22% 22% 33% 33% 33% 25% Manual to auto trans TCp $0 $0 $0 $828 $815 $801 $1,183 $1,164 $1,154 $868 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.3.7 8 speed transmission relative to a 6 speed, HD pickups & vans We have based the cost of this technology on several values used in the light - duty 2017 - 2025 final rule. In that rule, we presented costs for 6 to 8 speed automatic transmission, high efficiency gearbox (HEG) and aggressive shift logic (ASL 1) as separate technologies. Here we are treating these technologies as separate for costing (since some metrics differ for each) but considering them as being applied together as a complete group. As such, the cost for moving to an 8 speed transmission from the base 6 would always be the summation within any given ye ar of the total costs shown in the tables that follow. For adding 2 g ears, we have estimated the cost at $121 (DMC, 2012$, in 2012). We consider that technology to be on the flat portion of the learning curve (curve 7) and have applied medium complexity markups with near term markups through 2018. For HEG, we have estimate d the cost at $263 (DMC, 2012$, in 2017). We consider this technology

to be on the flat portion of the learning curve (curve 6) and have applied low complexity

markups with near term markups through 2024. For shift logic, we have estimated the cost at $2 8 (DMC, 2012$, in 2015). We consider this technology to be on the flat portion of the learning curve (curve 8) and have applied low complexity markups with near term markups through 2018. The resultant costs for adding 2 gears are shown in Table 2 - 158 , for HEG in Table 2 - 159 and for ASL1 in Table 2 - 160 . **Table 2**  **- 158**  **Costs to A**  **dd 2 Transmission Gears**  **HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Move from 6 to 8 gears DMC $97 $95 $93 $91 $89 $88 $88 Move from 6 to 8 gears IC $34 $34 $34 $34 $34 $34 $34 Move from 6 to 8 gears TC $131 $129 $127 $125 $123 $123 $122 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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

2 - 233 **Table 2**  **- 159**  **Costs for High Efficiency Gearbox (HEG)**

**HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 High efficiency gearbox DMC $232 $225 $221 $217 $212 $208 $204 High efficiency gearbox IC $63 $63 $63 $63 $50 $50 $50 High efficiency gearbox TC $296 $288 $284 $279 $262 $258 $254 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost **Table 2**  **- 160**  **Costs for Aggressive Shift Logic Level**  **1**

**HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Aggressive shift logic 1 DMC $25 $24 $24 $23 $23 $22 $22 Aggressive shift logic 1 IC $5 $5 $5 $5 $5 $5 $5 Aggressive shift logic 1 TC $30 $30 $29 $29 $28 $28 $28 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

**Table 2**  **- 161**  **Com plete Cost of Moving from** **the Base 6 Speed**  **to 8 Speed**  **Transmission 2**  **Gears +HEG+ASL1**  **HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Move from 6speed to 8speed Transmission TC $457 $447 $440 $433 $414 $409 $403 Notes: TC=total cost. 

## 2.12.4 **Air C**  **onditioning** 2.12.4.1 Direct AC controls

– vocational (all) We have estimated the cost of this technology based on an estimate from TetraTech of $30 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $22 (DMC, 2012$, in 2014). We consider this technology to be on the flat portion of the learning curve (curve 2) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 162 .

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

2 - 234 **Table 2**  **- 162**  **Costs for Direct Air Conditioning Controls**

**All Vocational HD Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 A/C direct DMC $19 $19 $18 $18 $18 $17 $17 $17 $17 $16 A/C direct IC $4 $4 $4 $4 $4 $3 $3 $3 $3 $3 A/C direct TC $23 $23 $22 $22 $22 $20 $20 $20 $20 $19 A/C direct Alt 1a A/C direct Alt 3 100% 100% 100% 100% 100% 100% 100% A/C direct TCp $0 $0 $0 $22 $22 $20 $20 $20 $20 $19 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.4.2 Indirect AC controls

– tractors (all) We have estimated the cost of this technology based on an estimate from TetraTech of $218 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $158 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 163 . **Table 2**  **- 163**  **Costs for Indirect AC Controls**

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 A/C indirect DMC $158 $153 $148 $144 $141 $138 $135 $133 $130 $127 A/C indirect IC $28 $28 $28 $28 $28 $22 $22 $22 $22 $22 A/C indirect TC $186 $181 $176 $172 $169 $160 $157 $155 $152 $149 A/C indirect Alt 1a A/C indirect Alt 3 10% 10% 10% 20% 20% 20% 30% A/C indirect TCp $0 $0 $0 $17 $17 $16 $31 $31 $30 $45 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.5 **Axles** 2.12.5.1 6x2 Axle We have estimated the cost of this technology based on an estimate from TetraTech of $250 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $181 (DMC, 2012$, in 2018). We c onsider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 164 for vocational heavy HD regional vehicles, in Table 2 - 165 for C lass 8 tractors (day

and sleeper cab) with low and mid roofs, and in Table 2 - 166 for Class 8 tractors (day

and sleeper cab) with high roofs.

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

2 - 235 **Table 2**  **- 164**  **Costs for 6x2 Axles Vocational Heavy HD Regional Vehicles**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle 6x2 DMC $181 $176 $170 $165 $162 $159 $156 $152 $149 $146 Axle 6x2 IC $32 $32 $32 $32 $32 $25 $25 $25 $25 $25 Axle 6x2 TC $213 $208 $203 $197 $194 $184 $181 $178 $175 $172 Axle 6x2 Alt 1a Axle 6x2 Alt 3 23% 23% 23% 30% 30% 30% 30% Axle 6x2 TCp $0 $0 $0 $44 $44 $41 $54 $53 $52 $51 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 165**  **Costs for 6x2 Axles Class 8**  **Day Cab Low and Sleeper Cab**  **Low/Mid Roof Tractors (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle 6x2 DMC $181 $176 $170 $165 $162 $159 $156 $152 $149 $146 Axle 6x2 IC $32 $32 $32 $32 $32 $25 $25 $25 $25 $25 Axle 6x2 TC $213 $208 $203 $197 $194 $184 $181 $178 $175 $172 Axle 6x2 Alt 1a Axle 6x2 Alt 3 10% 10% 10% 20% 20% 20% 20% Axle 6x2 TCp $0 $0 $0 $20 $19 $18 $36 $36 $35 $34 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 166**  **Costs for 6x2 Axles Class 8**  **Day Cab and Sleeper Cab High Roof Tractors**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle 6x2 DMC $181 $176 $170 $165 $162 $159 $156 $152 $149 $146 Axle 6x2 IC $32 $32 $32 $32 $32 $25 $25 $25 $25 $25 Axle 6x2 TC $213 $208 $203 $197 $194 $184 $181 $178 $175 $172 Axle 6x2 Alt 1a Axle 6x2 Alt 3 20% 20% 20% 60% 60% 60% 60% Axle 6x2 TCp $0 $0 $0 $39 $39 $37 $108 $107 $105 $103 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.5.2 Axle disconnect We have estimated the cost of this technology based on an estimate from TetraTech of $140 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $101 (DMC, 2012$, in all years). We consider this technology to be on the flat portion of the learning curve with no additional learning to occur (curve 1) and have applied a low complexity

I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 167 .

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

2 - 236 **Table 2**  **- 167**  **Costs for Axle Disconnect Vocational Heavy HD Region**  **al Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle disconnect DMC $101 $101 $101 $101 $101 $101 $101 $101 $101 $101 Axle disconnect IC $18 $18 $18 $18 $18 $14 $14 $14 $14 $14 Axle disconnect TC $120 $120 $120 $120 $120 $116 $116 $116 $116 $116 Axle disconnect Alt 1a Axle disconnect Alt 3 46% 46% 46% 61% 30% 30% 30% Axle disconnect TCp $0 $0 $0 $55 $55 $53 $71 $35 $35 $35 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.5.3 Axle downspeed We have estimated the cost of this technology based on engineering judgment at $50 (DMC, 2013$, in 2018). This DMC is expected to cover development and some testing and integration work since there is no real hardware required for this technology. Converting this DMC to 2012$ results in a $49 cost (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology co sts, adoption rates and total cost applied to the package are shown in Table 2 - 168 . **Table 2**  **- 168**  **Costs for Axle Downspe eding** 

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle downspeed DMC $49 $48 $46 $45 $44 $43 $42 $41 $41 $40 Axle downspeed IC $9 $9 $9 $9 $9 $7 $7 $7 $7 $7 Axle downspeed TC $58 $57 $55 $54 $53 $50 $49 $48 $47 $47 Axle downspeed Alt 1a Axle downspeed Alt 3 20% 20% 20% 40% 40% 40% 60% Axle downspeed TCp $0 $0 $0 $11 $11 $10 $20 $19 $19 $28 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.5.4 Low friction axle lubes We have estimated the cost of this technology based on an estimate from TetraTech of $250 (retail, 2013$), an estimate applicable to tractors having 3 axles. Using that estimate we divided by

a 1.36 RPE and converted to 2012$ to arrive at a cost of $181 (D MC, 2012$, in 2018). We consider this estimate to be applicable also to vocational HH vehicles since these generall y have 3 axles. For vocational light/medium HD vehicles, which generall y have 2 axles, we have estimated the DMC at 2/3 the vocational heavy HD/tractor cost, or $121 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology

costs, adoption rate s and total cost applied to the package are shown in Table 2 - 169 for vocational light and medium HD vehicles and in Table 2 - 170 for vocational heavy HD vehicles, and in Table 2 - 171 for tractors.

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

2 - 237 **Table 2**  **- 169**  **Costs for Low Friction Axle Lubes Vocational Light/Medium HD**  **Urban/Multipurpose/Regional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle low friction lubes DMC $121 $117 $114 $110 $108 $106 $104 $102 $100 $98 Axle low friction lubes IC $22 $22 $21 $21 $21 $17 $17 $17 $17 $17 Axle low friction lubes TC $142 $139 $135 $132 $129 $123 $121 $118 $116 $114 Axle low friction lubes Alt 1a Axle low friction lubes Alt 3 75% 75% 75% 75% 75% 75% 75% Axle low friction lubes TCp $0 $0 $0 $99 $97 $92 $90 $89 $87 $86 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 170**  **Costs for Low Friction Axle Lubes Vocational Heavy HD**  **Urban/Multipurpose/Regional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle low friction lubes DMC $181 $176 $170 $165 $162 $159 $156 $152 $149 $146 Axle low friction lubes IC $32 $32 $32 $32 $32 $25 $25 $25 $25 $25 Axle low friction lubes TC $213 $208 $203 $197 $194 $184 $181 $178 $175 $172 Axle low friction lubes Alt 1a Axle low friction lubes Alt 3 75% 75% 75% 75% 75% 75% 75% Axle low friction lubes TCp $0 $0 $0 $148 $146 $138 $136 $133 $131 $129 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 171**  **Costs for Low Friction Axle Lubes**

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Axle low friction lubes DMC $181 $176 $170 $165 $162 $159 $156 $152 $149 $146 Axle low friction lubes IC $32 $32 $32 $32 $32 $25 $25 $25 $25 $25 Axle low friction lubes TC $213 $208 $203 $197 $194 $184 $181 $178 $175 $172 Axle low friction lubes Alt 1a Axle low friction lubes Alt 3 20% 20% 20% 40% 40% 40% 40% Axle low friction lubes TCp $0 $0 $0 $39 $39 $37 $72 $71 $70 $69 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.6 **Idle R** **eduction** 2.12.6.1 Auxiliary power units (APU) We have estimated the cost of this technology based on the APU costs discussed in the Phase 1 rule. That technology was estimated at $4586 (DMC, 2008$, in 2014). With updates, that cost becomes $4853 (DMC, 2012$, in 2014) for Phase 2. We consider this technology to be on the flat portion of the learning curve (curve 2) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cos t applied to the package are shown in Table 2 - 172 .

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2 - 238 **Table 2**  **- 172**  **Costs for Auxiliary Power Units (APU)**

**Sleeper Cab Tractors**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 APU DMC $4,296 $4,210 $4,126 $4,043 $3,962 $3,883 $3,805 $3,729 $3,692 $3,655 APU IC $859 $857 $856 $855 $854 $674 $673 $673 $673 $672 APU TC $5,154 $5,067 $4,982 $4,899 $4,817 $4,557 $4,479 $4,402 $4,365 $4,327 APU Alt

1a 30% 30% 30% 30% 30% 30% 30% 30% 30% 30% APU Alt 3 30% 30% 30% 70% 70% 70% 80% 90% 90% 90% APU TCp $0 $0 $0 $1,959 $1,927 $1,823 $2,239 $2,641 $2,619 $2,596 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative 

## 2.12.6.2 Neutral idle We have estimated the cost of this technology based on engineering judgment at $10 (retail, 2013$). Using that estimate, we have divided by a 1.36 RPE and converted to 2012$ to arrive at a $7 cost (DMC, 2012$, in all years). This DMC is expected to cover development and some testing and integration work since there is no real hardware required for this technology . We consider this technology to be on the flat portion of the learning curve with no additional learning to occur (curve 1) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 173 and Table 2 - 174 for vocational vehicles . **Table 2**  **- 173**  **Costs for Neutral Idle Technology Vocational Light/Medium HD**  **U rban Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Neutral idle DMC $7 $7 $7 $7 $7 $7 $7 $7 $7 $7 Neutral idle IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Neutral idle TC $9 $9 $9 $9 $9 $8 $8 $8 $8 $8 Neutral idle Alt 1a Neutral idle Alt 3 70% 70% 70% 85% 85% 85% 25% Neutral idle TCp $0 $0 $0 $6 $6 $6 $7 $7 $7 $2 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 174**  **Costs for Neutral Idle Technology Vocational Light** **/M edium** **/Heavy HD**  **Multipurpose Vehicles**  **and Vocational Light/Medium HD Regional Vehicles**  **And Vocational Heavy HD Urban Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Neutral idle DMC $7 $7 $7 $7 $7 $7 $7 $7 $7 $7 Neutral idle IC $1 $1 $1 $1 $1 $1 $1 $1 $1 $1 Neutral idle TC $9 $9 $9 $9 $9 $8 $8 $8 $8 $8 Neutral idle Alt 1a Neutral idle Alt 3 70% 70% 70% 85% 85% 85% 30% Neutral idle TCp $0 $0 $0 $6 $6 $6 $7 $7 $7 $2 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 239 

## 2.12.6.3 Stop - start We have estimated the cost of this technology based on several cost estimates. First, an estimate from TetraTech of $700 (retail, 2013$) for gasoline HD pickups and vans and $1500 (retail, 2013$) for diesel HD pickups and vans. Using these values, we divided by a 1.36 RPE and converted to 2012$ to arrive at $507 (DMC, 2012$, in 2 021) and $1087 (DMC, 2012$, in 2021) which were considered appropriate for vocational MH and HH vehicles, respectively . To these estimates, we have added the costs for improved accessories used for HD pickups and vans of $124 (DMC, 2012$, in 2015) which i s based on values from the 2017 - 2025 light - duty FRM. However, to account for the heavier vocational vehicles relative to the HD pickup and vans, we have scaled upward the improved accessory value by 50 percent to arrive at a cost of $186 (DMC, 2012$, in 20 15). We have then added these values to arrive at costs of $693 (DMC, 2012$, in 2021) and $1272 (DMC, 2012$, in 2021) and have applied the lower cost to vocational medium HD vehicles and the higher cost to vocational heavy HD vehicles. For vocational light HD, we have used the stop - start cost for the 2017 - 2025 rule for LD pickups ($377 DMC, 2012$, in 2015) but have scaled upward that value b y 25 percent to account for the weight difference between the LD and vocational light HD vehicles. Doing this results in a cost of $471 (DMC, 2012$, in 2021). Adding to that the $186 value for improved accessories mentioned earlier gives the resultant vocational light HD cost of $656 (DMC, 2012$, in 2021). We consider all of these technologies to be on the flat portion of the learning curve (curve 13) and have applied a medium complexity

I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 175 for vocational light HD, Table 2 - 176 for vocational medium HD, and in Table 2 - 177 for vocational heavy HD vehicles. **Table 2**  **- 175**  **Costs for Stop -**  **start Vocational Light HD**  **Urban/Multipurpose/Regional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Stop - start DMC $719 $698 $677 $656 $637 $618 $599 $587 $575 $564 Stop - start IC $202 $201 $200 $198 $197 $147 $146 $146 $145 $145 Stop - start TC $921 $898 $876 $855 $834 $764 $745 $733 $721 $709 Stop - start Alt 1a Stop - start Alt 3 5% 5% 5% 15% 15% 15% 70% Stop - start TCp $0 $0 $0 $43 $42 $38 $112 $110 $108 $496 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 176**  **Costs for Stop -**  **start Vocational Medium** **HD Urban/Multipurpose/Regional**  **Vehicles (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Stop - start DMC $759 $736 $714 $693 $672 $652 $632 $620 $607 $595 Stop - start IC $213 $212 $211 $209 $208 $155 $154 $154 $153 $153 Stop - start TC $972 $948 $925 $902 $880 $807 $786 $773 $761 $748 Stop - start Alt 1a Stop - start Alt 3 5% 5% 5% 15% 15% 15% 70% Stop - start TCp $0 $0 $0 $45 $44 $40 $118 $116 $114 $524 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 240 **Table 2**  **- 177**  **Costs for Stop -**  **start Vocational Heavy HD**  **Urban/Multipurpose/Regional Vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Stop - start DMC $1,394 $1,352 $1,312 $1,272 $1,234 $1,197 $1,161 $1,138 $1,115 $1,093 Stop - start IC $391 $389 $387 $385 $383 $284 $283 $282 $282 $281 Stop - start TC $1,785 $1,741 $1,698 $1,657 $1,617 $1,482 $1,444 $1,420 $1,397 $1,374 Stop - start Alt

1a Stop - start Alt 3 15% 15% 15% 70% Stop - start TCp $0 $0 $0 $0 $0 $0 $217 $213 $210 $962 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For HD pickups and vans, we have based our costs for stop - start s ys tems on the values used in the light - duty 2017 - 2025 final rule, but have scaled upward those costs by 25 percent to account for the larger and harder starting HD engines. Using this approach and converting to 2012$ results in a cost of $471 (DMC, 2012$, in 2015). We consider this technology to be on the steep portion of the learning curve (curve 9, note the different year of cost - applicabil ity relative to the vocational cost discussed above) and have applied medium complexity markups with near term markups through 2018. The resultant costs for HD pickups and vans are shown in Table 2 - 178 . **Table 2**  **- 178**  **Costs of Stop -**  **start HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Stop - start DMC $404 $392 $380 $369 $358 $351 $344 Stop - start IC $134 $134 $134 $133 $133 $133 $132 Stop - start TC $539 $526 $514 $502 $491 $483 $476 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.7 **Electrifica tion (strong/mild HEV, full EV)**  2.12.7.1 Strong hyb rid electric vehicle (strong HEV) We have estimated the cost of this technology using the costs estimated in the 2017 - 2025 light - duty rule for a light - duty

pickup strong HEV. There we estimated the cost at $2729 (DMC, 2010$, in 2021) for a LD truck with a 5200 pound curb weight. We have then scaled upward that value using the ratio of test weights for HD pickups in our MY2014 market file (8739 pounds) to the test weight of the 5200 pound LD truck (5500 pounds). The resultant strong hy brid costs become $4335 (DM C, 2012$, in 2021) for HD pickups and vans. We consider this technology to be on the steep portion of the learning curve today but on the flat portion by 2021 (curve 11) and have applied high complexity level 1 with short term markups through 2024. The resultant technology

costs are shown in Table 2 - 179 for HD pickups and vans.

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2 - 241 **Table 2**  **- 179**  **Costs of Strong Hybrid HD**  **Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Strong HEV DMC $4,335 $4,205 $4,079 $3,957 $3,838 $3,723 $3,648 Strong HEV IC $2,443 $2,435 $2,427 $2,419 $1,482 $1,478 $1,476 Strong HEV TC $6,779 $6,640 $6,506 $6,376 $5,320 $5,201 $5,124 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### For vocational vehicle strong hybrids, we have scaled upward from the HD pickup and van values using best estimates of curb weights. For vocational vehicles, we have used curb we ights of 16,000 for light HD, 25,150 for medium HD and 42,000 for heavy HD relative to a 6500 pound value for HD pickups. Scaling based on curb weight here should provide an acceptable scaling of costs with battery and motor sizes since those are generall y directly correlated with the weight of the vehicle itself. Using these scaling factors results in costs for complete hybrid s ys tems for light, medium and heavy HD, respectivel y, of $10,672, $16,774 and $28,013 (DMC, 2012$, in 2021). We consider this technology to be on the steep portion of the learning curve today

but on the flat portion by 2021 (curve 11) and have applied high complexity level 1 with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown are shown in Table 2 - 180 for light HD, in Table 2 - 181 f or medium HD and in Table 2 - 182 for heavy HD vocational vehicles. **Table 2**  **- 180**  **Costs for Strong Hybrid Vocational Light HD**  **U rban/** **M ultipurpose Vehicles (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Strong HEV DMC $16,674 $13,340 $13,340 $10,672 $10,351 $10,041 $9,740 $9,448 $9,164 $8,981 Strong HEV IC $4,975 $4,731 $4,731 $4,536 $4,512 $2,849 $2,838 $2,827 $2,817 $2,810 Strong HEV TC $21,649 $18,070 $18,070 $15,207 $14,864 $12,890 $12,578 $12,275 $11,981 $11,791 Strong HEV Alt

1a Strong HEV Alt 3 4% 4% 4% 7% 7% 7% 18% Strong HEV TCp $0 $0 $0 $547 $535 $464 $906 $884 $863 $2,122 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 242 **Table 2**  **- 181**  **Costs for Strong Hybrid Vocational Medium** **HD U**  **rban/ M**  **ultipurpose Vehicles (2012$)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Strong HEV DMC $26,210 $20,968 $20,968 $16,774 $16,271 $15,783 $15,310 $14,850 $14,405 $14,117 Strong HEV IC $7,820 $7,436 $7,436 $7,129 $7,093 $4,478 $4,461 $4,444 $4,428 $4,418 Strong HEV TC $34,030 $28,404 $28,404 $23,904 $23,364 $20,262 $19,771 $19,295 $18,833 $18,534 Strong HEV Alt

1a Strong HEV Alt 3 4% 4% 4% 7% 7% 7% 18% Strong HEV TCp $0 $0 $0 $861 $841 $729 $1,424 $1,389 $1,356 $3,336 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 182**  **Costs for Strong Hybrid Vocational Heavy HD**  **U rban/** **M ultipurpose Vehicles (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Strong HEV DMC $43,770 $35,016 $35,016 $28,013 $27,173 $26,357 $25,567 $24,800 $24,056 $23,575 Strong HEV IC $13,059 $12,418 $12,418 $11,906 $11,844 $7,479 $7,450 $7,422 $7,395 $7,377 Strong HEV TC $56,829 $47,435 $47,435 $39,919 $39,017 $33,836 $33,017 $32,222 $31,451 $30,952 Strong HEV Alt

1a Strong HEV Alt 3 4% 4% 4% 7% 7% 7% 18% Strong HEV TCp $0 $0 $0 $1,437 $1,405 $1,218 $2,377 $2,320 $2,264 $5,571 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.7.2 Mild hybrid electric vehicle (mild HEV) We have estimated the cost of this technology using the costs estimated in the 2017 - 2025 light - duty rule for a light - duty

pickup mild HEV. There we estimated the cost at $983 (DMC, 2010$, in 2021) for a LD truck with a 3500 pound curb weight. We have then scaled upward that value using the ratio of curb weights for HD pickups of 6500 pounds to the 3500 pound curb weight. The resultant mild hy brid costs become $1894 (DMC, 2012$, in 2017) for HD pickups and vans. We consider this technology to be on the flat portion of the learning curve (curve 6) and have applied high complexity level 1 with short term markups through 2024. The resultant technology

costs are shown in Table 2 - 183 for HD pickups and vans.

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

2 - 243 **Table 2**  **- 183**  **Costs of Mild Hybrid HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Mild HEV DMC $1,677 $1,626 $1,594 $1,562 $1,531 $1,500 $1,470 Mild HEV IC $1,053 $1,050 $1,048 $1,046 $643 $642 $641 Mild HEV TC $2,730 $2,677 $2,642 $2,608 $2,173 $2,142 $2,111 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### For tractors, we have estimated the cost of this technology based on an estimate from TetraTech of $20,000 (retail, 2013$). Using that value, we divided b y a 1.36 RPE and converted to 2012$ to arrive at a cost of $ 14,487 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a high complexity level 1 markup with short term markups through 2025. The resultant technology costs are shown in Table 2 - 184 (note that this technology is not expected to be used so the application rate is 0%) . **Table 2**  **- 184**  **Costs for Mild Hybrid Tractors (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Mild HEV DMC $14,487 $14,052 $13,631 $13,222 $12,958 $12,698 $12,444 $12,196 $11,952 $11,713 Mild HEV IC $6,157 $6,125 $6,094 $6,065 $6,045 $6,026 $6,008 $5,989 $3,806 $3,798 Mild HEV TC $20,644 $20,178 $19,725 $19,287 $19,003 $18,725 $18,452 $18,185 $15,758 $15,510 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative 

## 2.12.7.3 Full electric vehicle (Full EV) For vocational vehicle full EVs, we have used an estimate of $77888 (retail, 2013$) based on an estimate from The West Coast Collaborative. 176 

### Using that value, we divided b y a 1.36 RPE and converted to 2012$ to arrive at a cost of $56,418 (DMC, 2012$, in 2014). We consider this technology

to be on the steep porti on of the learning curve (curve 4) and have applied a high complexity level 1 markup with short term markups through 2028. The resultant technology

costs are shown in Table 2 - 185 .

**Table 2**  **- 185**  **Costs of Full Electric Vehicle Vocational Light/Medium HD (** **Urban/Multipurpose/Regio nal) Vehicles (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Full EV DMC $36,108 $35,025 $33,974 $32,955 $31,966 $31,007 $30,077 $29,174 $28,591 $28,019 Full EV IC $22,492 $22,413 $22,336 $22,262 $22,189 $22,119 $22,051 $21,985 $21,942 $21,900 Full EV TC $58,600 $57,438 $56,310 $55,216 $54,155 $53,126 $52,128 $51,159 $50,533 $49,920 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

### For day cab tractor full EVs, we have used an estimate of $203,000 (retail, 2012$) based on an estimate from the California Energy Commission. Using that value, we divided by a 1.36

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

2 - 244 RPE to arrive at a cost of $149,265 (DMC, 2012$, in 2014). We consider thi s technology to be on the steep portion of the learning curve (curve 4) and have applied a high complexity level 1 markup with short term markups through 2028. The resultant technology costs are shown in Table 2 - 186 . **Table 2**  **- 186**  **Costs for Full Electric Vehicle Day**  **Cab Tractors (2012$)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Full EV DMC $95,529 $92,664 $89,884 $87,187 $84,572 $82,034 $79,573 $77,186 $75,642 $74,130 Full EV IC $59,507 $59,297 $59,094 $58,897 $58,705 $58,520 $58,340 $58,165 $58,052 $57,941 Full EV TC $155,036 $151,961 $148,978 $146,084 $143,277 $140,554 $137,913 $135,351 $133,694 $132,071 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.8 **Tires** 2.12.8.1 Lower rolling resistance tires ($/tire) We have estimated the cost of lower rolling resistance tires based on an estimate from TetraTech of $30 (retail, 2013$). Using that estimate we divided b y a 1.36 RPE and converted to 2012$ to arrive at a cost of $22 (DMC, 2012$) but consider that cost vali d in different years depending on the level of rolling resistance. For LRR tires level 1 and 2, we consider that $22 value valid in 2014, level 3 in 2018, and level 4 in 2021. We consider this technology to be on the flat portion of the curve with LRR tire s level 1 and 2 on curve 4, LRR tires level 3 on curve 12 and LRR tires level 4 on curve 13. We have applied a low complexity markup to LRR tires levels 1 and 3 with short term markups through 2022. For LRR tires level 3, we have applied a medium complexity markup with short term markups through 2025 and, for LRR tires level 4, we have applied a medium complexity markup with short term markups through 2028. As a result, despite using the same DMC for each level of rolling resistance, our tire costs can vary considerabl y ye ar- over- year for each of the 4 levels of rolling resistance considered. The resultant costs on a per - tire basis are shown in Table 2 - 187 . Table 2 - 188 through Table 2 - 202 show the costs per vehicle depending on the number of tires present on the vehicl e.

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

2 - 245 **Table 2**  **- 187**  **Costs for Lower Rolling Resistance Tires**

**at each LRR level (2012$/tire)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 DMC $19 $19 $18 $18 $18 $17 $17 $17 $17 $16 LRR

– level 2 DMC $19 $19 $18 $18 $18 $17 $17 $17 $17 $16 LRR

– level 3 DMC $22 $21 $20 $20 $19 $19 $19 $18 $18 $18 LRR

– level 4 DMC $24 $23 $22 $22 $21 $20 $20 $19 $19 $19 LRR

– level 1 IC $4 $4 $4 $4 $4 $3 $3 $3 $3 $3 LRR

– level 2 IC $4 $4 $4 $4 $4 $3 $3 $3 $3 $3 LRR

– level 3 IC $7 $7 $7 $6 $6 $6 $6 $6 $5 $5 LRR

– level 4 IC $7 $7 $7 $7 $7 $7 $6 $6 $6 $6 LRR

– level 1 TC $23 $23 $22 $22 $22 $20 $20 $20 $20 $19 LRR

– level 2 TC $23 $23 $22 $22 $22 $20 $20 $20 $20 $19 LRR

– level 3 TC $28 $28 $27 $26 $26 $25 $25 $25 $23 $22 LRR

– level 4 TC $30 $30 $29 $28 $28 $27 $26 $26 $25 $25 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.8.2 Lower RR steer tires, All Vocational Vehicles

**Table 2**  **- 188**  **Costs for Lower Rolling Resistance Steer Tires**

**All Vocational Vehicles (2012$/vehicle @ 2 tires/vehicle)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 2 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 3 TC $57 $55 $54 $53 $52 $51 $50 $49 $45 $45 LRR

– level 4 TC $61 $59 $58 $57 $55 $54 $53 $52 $51 $50 LRR

– level 1 Alt

1a 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% LRR

– level 2 Alt

1a LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– Alt 3 100% 100% 100% 20% 20% 20% 10% 10% 10% 0%

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2 - 246 level 1 LRR

– level 2 Alt 3 LRR

– level 3 Alt 3 80% 80% 80% 30% 30% 30% 20% LRR

– level 4 Alt 3 60% 60% 60% 80% LRR

– level 1 TCp $0 $0 $0 - $35 - $35 - $33 - $36 - $35 - $35 - $39 LRR

– level 2 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 LRR

– level 3 TCp $0 $0 $0 $42 $41 $41 $15 $15 $14 $9 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $32 $31 $31 $40 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.3 Lower RR drive tires, All Vocational Light/Medium HD Vehicles

**Table 2**  **- 189**  **Costs for Lower Rolling Resistance Drive Tires** 

**Vocational Light/Medium HD Vehicles (2012$/vehicle @ 4 tires/vehicle)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 2 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 3 TC $113 $110 $108 $105 $104 $102 $100 $99 $91 $89 LRR

– level 4 TC $122 $119 $116 $113 $110 $108 $105 $104 $102 $100 LRR

– level 1 Alt

1a 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% LRR

– level 2 Alt

1a LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 100% 100% 100% 50% 50% 50% 20% 20% 20% 10% LRR

– level 2 Alt 3 50% 50% 50% 50% 50% 50% 25% LRR

– level 3 Alt 3 30% 30% 30% 50% LRR

– level 4 Alt 3 15% LRR

– level 1 TCp $0 $0 $0 - $44 - $43 - $41 - $64 - $63 - $63 - $70 LRR

– level 2 TCp $0 $0 $0 $44 $43 $41 $40 $39 $39 $19 LRR

– TCp $0 $0 $0 $0 $0 $0 $30 $30 $27 $45

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

2 - 247 level 3 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $15 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.4 Lower RR drive tires, Vocational Heavy HD Vehicles **Table 2**  **- 190**  **Costs for Lower Rolling Resistance Drive Tires**

**Vocational Heavy HD Vehicles**  **(2012$/vehicle @ 8 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 3 TC $226 $221 $216 $210 $207 $204 $201 $198 $182 $179 LRR

– level 4 TC $244 $238 $232 $226 $221 $216 $210 $207 $204 $201 LRR

– level 1 Alt

1a 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% LRR

– level 2 Alt

1a LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 100% 100% 100% 50% 50% 50% 20% 20% 20% 10% LRR

– level 2 Alt 3 50% 50% 50% 50% 50% 50% 25% LRR

– level 3 Alt 3 30% 30% 30% 50% LRR

– level 4 Alt 3 15% LRR

– level 1 TCp $0 $0 $0 - $88 - $86 - $82 - $128 - $126 - $125 - $140 LRR

– level 2 TCp $0 $0 $0 $88 $86 $82 $80 $79 $78 $39 LRR

– level 3 TCp $0 $0 $0 $0 $0 $0 $60 $59 $54 $89 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $30 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 248 

## 2.12.8.5 Lower RR steer tires, Day cab low roof tractors **Table 2**  **- 191**  **Costs for Lower Rolling Resistance Steer Tires**

**Day Cab Low Roof Tractors**  **(2012$/v ehicle @ 2 tires/vehicle)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 2 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 3 TC $57 $55 $54 $53 $52 $51 $50 $49 $45 $45 LRR

– level 4 TC $61 $59 $58 $57 $55 $54 $53 $52 $51 $50 LRR

– level 1 Alt

1a 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% LRR

– level 2 Alt

1a 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 50% 50% 50% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 10% 10% 10% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 $4 $4 $4 $0 $0 $0 - $12 LRR

– level 2 TCp $0 $0 $0 $7 $6 $6 $8 $8 $8 $16 LRR

– level 3 TCp $0 $0 $0 $5 $5 $5 $8 $7 $7 $11 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.6 Lower RR steer tires, Day cab high roof tractors **Table 2**  **- 192**  **Costs for Lower Rolling Resistance Steer Tires**

**Day Cab High Roof Tractors**  **(2012$/vehicle @ 2 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 2 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– TC $57 $55 $54 $53 $52 $51 $50 $49 $45 $45

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

2 - 249 level 3 LRR

– level 4 TC $61 $59 $58 $57 $55 $54 $53 $52 $51 $50 LRR

– level 1 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% LRR

– level 2 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 70% 70% 70% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 20% 20% 20% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 - $4 - $4 - $4 - $8 - $8 - $8 - $19 LRR

– level 2 TCp $0 $0 $0 $2 $2 $2 $4 $4 $4 $12 LRR

– level 3 TCp $0 $0 $0 $5 $5 $5 $8 $7 $7 $11 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.7 Lower RR steer tires, Sleeper cab low/mid roof tractors

**Table 2**  **- 193**  **Costs for Lower Rolling Resistance Steer Tires**

**Sleeper Cab Low/Mid Roof Tractors**  **(2012$/vehicle @ 2 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 2 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 3 TC $57 $55 $54 $53 $52 $51 $50 $49 $45 $45 LRR

– level 4 TC $61 $59 $58 $57 $55 $54 $53 $52 $51 $50 LRR

– level 1 Alt

1a 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% LRR

– level 2 Alt

1a 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– Alt 3 60% 60% 60% 60% 60% 60% 50% 50% 50% 20%

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

2 - 250 level 1 LRR

– level 2 Alt 3 10% 10% 10% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 $0 $0 $0 - $4 - $4 - $4 - $16 LRR

– level 2 TCp $0 $0 $0 $7 $6 $6 $8 $8 $8 $16 LRR

– level 3 TCp $0 $0 $0 $5 $5 $5 $8 $7 $7 $11 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.8 Lower RR steer tires, Sleeper cab high roof tractors

**Table 2**  **- 194**  **Costs for Lower Rolling Resistance Steer Tires**

**Sleeper Cab High Roof Tractors**  **(2012$/vehicle @ 2 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 2 TC $46 $45 $45 $44 $43 $41 $40 $39 $39 $39 LRR

– level 3 TC $57 $55 $54 $53 $52 $51 $50 $49 $45 $45 LRR

– level 4 TC $61 $59 $58 $57 $55 $54 $53 $52 $51 $50 LRR

– level 1 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% LRR

– level 2 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 70% 70% 70% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 20% 20% 20% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 - $4 - $4 - $4 - $8 - $8 - $8 - $19 LRR

– level 2 TCp $0 $0 $0 $2 $2 $2 $4 $4 $4 $12 LRR

– TCp $0 $0 $0 $5 $5 $5 $8 $7 $7 $11

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

2 - 251 level 3 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.9 Lower RR drive tires, Class 7 Day cab low roof tractors **Table 2**  **- 195**  **Costs for Lower Rolling Resistance Drive Tires**

**Class 7 Day Cab Low Roof Tractors**  **(2012$/vehicle @ 4 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 2 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 3 TC $113 $110 $108 $105 $104 $102 $100 $99 $91 $89 LRR

– level 4 TC $122 $119 $116 $113 $110 $108 $105 $104 $102 $100 LRR

– level 1 Alt

1a 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% LRR

– level 2 Alt

1a 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 50% 50% 50% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 10% 10% 10% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 $9 $9 $8 $0 $0 $0 - $23 LRR

– level 2 TCp $0 $0 $0 $13 $13 $12 $16 $16 $16 $31 LRR

– level 3 TCp $0 $0 $0 $11 $10 $10 $15 $15 $14 $22 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 252 

## 2.12.8.10 Lower RR drive tires, Class 8 Day cab low roof tractors **Table 2**  **- 196**  **Costs for Lower Rolling Resistance Drive Tires**

**Class 8 Day Cab Low Roof Tractors**  **(2012$/vehicle @ 8 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 3 TC $226 $221 $216 $210 $207 $204 $201 $198 $182 $179 LRR

– level 4 TC $244 $238 $232 $226 $221 $216 $210 $207 $204 $201 LRR

– level 1 Alt

1a 50% 50% 50% 50% 50% 50% 50% 50% 50% 50% LRR

– level 2 Alt

1a 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 50% 50% 50% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 10% 10% 10% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 $18 $17 $16 $0 $0 $0 - $47 LRR

– level 2 TCp $0 $0 $0 $26 $26 $24 $32 $32 $31 $62 LRR

– level 3 TCp $0 $0 $0 $21 $21 $20 $30 $30 $27 $45 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 253 

## 2.12.8.11 Lower RR drive tires, Class 7 Day cab high roof tractors **Table 2**  **- 197**  **Costs for Lower Rolling Resistance Drive Tires**

**Class 7 Day Cab High Roof Tractors**  **(2012$/vehicle @ 4 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 2 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

– level 3 TC $113 $110 $108 $105 $104 $102 $100 $99 $91 $89 LRR

– level 4 TC $122 $119 $116 $113 $110 $108 $105 $104 $102 $100 LRR

– level 1 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% LRR

– level 2 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 70% 70% 70% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 20% 20% 20% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 - $9 - $9 - $8 - $16 - $16 - $16 - $39 LRR

– level 2 TCp $0 $0 $0 $4 $4 $4 $8 $8 $8 $23 LRR

– level 3 TCp $0 $0 $0 $11 $10 $10 $15 $15 $14 $22 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 254 

## 2.12.8.12 Lower RR drive tires, Class 8 Day cab high roof tractors **Table 2**  **- 198**  **Costs for Lower Rolling Resistance Drive Tires**

**Class 8 Day Cab High Roof Tractors**  **(2012$/vehicle @ 8 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 3 TC $226 $221 $216 $210 $207 $204 $201 $198 $182 $179 LRR

– level 4 TC $244 $238 $232 $226 $221 $216 $210 $207 $204 $201 LRR

– level 1 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% LRR

– level 2 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 70% 70% 70% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 20% 20% 20% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 - $18 - $17 - $16 - $32 - $32 - $31 - $78 LRR

– level 2 TCp $0 $0 $0 $9 $9 $8 $16 $16 $16 $47 LRR

– level 3 TCp $0 $0 $0 $21 $21 $20 $30 $30 $27 $45 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 255 

## 2.12.8.13 Lower RR drive tires, Class 8 Sleeper cab low/mid roof tractors

**Table 2**  **- 199**  **Costs for Lower Rolling Resistance Drive Tires Class 8 Sleeper**  **Cab Low/Mid Roof Tractors (2012$/vehicle @ 8 tires/vehicle)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 3 TC $226 $221 $216 $210 $207 $204 $201 $198 $182 $179 LRR

– level 4 TC $244 $238 $232 $226 $221 $216 $210 $207 $204 $201 LRR

– level 1 Alt

1a 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% LRR

– level 2 Alt

1a 10% 10% 10% 10% 10% 10% 10% 10% 10% 10% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 60% 60% 60% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 10% 10% 10% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 $0 $0 $0 - $16 - $16 - $16 - $62 LRR

– level 2 TCp $0 $0 $0 $26 $26 $24 $32 $32 $31 $62 LRR

– level 3 TCp $0 $0 $0 $21 $21 $20 $30 $30 $27 $45 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 256 

## 2.12.8.14 Lower RR drive tires, Class 8 Sleeper cab high roof tractors

**Table 2**  **- 200**  **Costs for Lower Rolling Resistance Drive Tires**

**Class 8 Sleeper Cab High Roof Tractors**  **(2012$/vehicle @ 8 tires/vehicle)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

– level 3 TC $226 $221 $216 $210 $207 $204 $201 $198 $182 $179 LRR

– level 4 TC $244 $238 $232 $226 $221 $216 $210 $207 $204 $201 LRR

– level 1 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% LRR

– level 2 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% LRR

– level 3 Alt

1a LRR

– level 4 Alt

1a LRR

– level 1 Alt 3 70% 70% 70% 60% 60% 60% 50% 50% 50% 20% LRR

– level 2 Alt 3 20% 20% 20% 25% 25% 25% 30% 30% 30% 50% LRR

– level 3 Alt 3 10% 10% 10% 15% 15% 15% 25% LRR

– level 4 Alt 3 LRR

– level 1 TCp $0 $0 $0 - $18 - $17 - $16 - $32 - $32 - $31 - $78 LRR

– level 2 TCp $0 $0 $0 $9 $9 $8 $16 $16 $16 $47 LRR

– level 3 TCp $0 $0 $0 $21 $21 $20 $30 $30 $27 $45 LRR

– level 4 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 257 

## 2.12.8.15 Lower RR tires, 53 - foot dry van & reefer **Table 2**  **- 201**  **Costs for Lower Rolling Resistance Tires 53**  **- foot Dry**  **Van & Reefer**  **Highway Trailers (2012$/trailer @ 8**  **tires/trailer)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

–level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

–level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

–level 1 Alt 1a 50% 51% 52% 53% 54% 56% 57% 58% 59% 60% LRR

–level 2 Alt 1a LRR

–level 1 Alt 3 85% 85% 85% 90% 90% 90% LRR

–level 2 Alt 3 95% 95% 95% 95% LRR

–level 1 TCp $65 $62 $59 $65 $62 $56 - $91 - $91 - $92 - $93 LRR

–level 2 TCp $0 $0 $0 $0 $0 $0 $152 $150 $149 $147 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.16 Lower RR tires, 28 - foot dry van **Table 2**  **- 202**  **Costs for Lower Rolling Resistance Tires**

**28 -**  **foot Dry Van Trailers**  **(2012$/trailer @ 4 tires/trailer)** ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

–level 1 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

–level 2 TC $92 $91 $89 $88 $86 $82 $80 $79 $78 $78 LRR

–level 1 Alt 1a LRR

–level 2 Alt 1a LRR

–level 1 Alt 3 85% 85% 85% 90% 90% 90% LRR

–level 2 Alt 3 95% 95% 95% 95% LRR

–level 1 TCp $78 $77 $76 $79 $78 $73 $0 $0 $0 $0 LRR

–level 2 TCp $0 $0 $0 $0 $0 $0 $76 $75 $74 $74 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption 

## 2.12.8.17 Lower RR tires, Non - box highway trailers **Table 2**  **- 203**  **Costs for Lower Rolling Resistance Tires**

**Other Non -**  **Box Highway**  **Trailers (2012$/trailer @ 4 tires/trailer)**  ITEM 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 LRR

–level 1 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

–level 2 TC $185 $182 $178 $175 $173 $163 $160 $158 $156 $155 LRR

–level 1 Alt 1a LRR

–level 2 Alt 1a LRR

–level 1 Alt 3 100% 100% 100% 100% 100% 100% LRR

–level 2 Alt 3 100% 100% 100% 100% LRR

–level 1 TCp $185 $182 $178 $175 $173 $163 $0 $0 $0 $0 LRR

–level 2 TCp $0 $0 $0 $0 $0 $0 $160 $158 $156 $155 Notes: TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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

2 - 258 

## 2.12.8.18 Lower RR tires, HD pickup & van ($/tire) We have estimated the costs of lower rolling resistance tires for HD pickups and vans using the costs used in the 2017 - 2025 light - duty FRM. Inthat rule, we estimated the costs of lower rolling resistance tires level 1 at $5/vehicle including a spare (DMC, 2010$, in all years) and level 2 at $40/vehicle assuming no spare (DMC, 2010$, in 20 21). For HD pickups and vans, we have scaled upward both of those costs by 50 percent to account for the heavier and larger HD tires. We consider the level 1 tires to be learned out (curve 1) and the level 2 tires to be on the steep portion of the curve until 2021 after which it is on the flatter portion of the curve (curve 11). We have applied a low complexity markup to both with short term markups through 2018 for level 1 and through 2024 for level 2. With the exception of the 50 percent scaling facto r, all LRR tire costs for HD pickups and vans are identical to the 2017 - 2025 light - duty FRM. The resultant costs are presented in Table 2 - 204 . **Table 2**  **- 204**  **Costs for Lower Rolling Resistance Tires**

**HD Pickups & Vans (2012$ @ 4 tires/vehicle)**  ITEM 2021 2022 2023 2024 2025 2026 2027 LRR

– level 1 DMC $8 $8 $8 $8 $8 $8 $8 LRR

– level 2 DMC $63 $61 $59 $58 $56 $54 $53 LRR

– level 1 IC $2 $2 $2 $2 $2 $2 $2 LRR

– level 2 IC $15 $15 $15 $15 $12 $12 $12 LRR

– level 1 TC $10 $10 $10 $10 $10 $10 $10 LRR

– level 2 TC $78 $76 $74 $73 $68 $66 $65 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.8.19 Automatic Tire Inflation Systems (ATIS) For tractors, we have estimated the cost of this technology based on an estimate from TetraTech of $1143 (retail, 2013$). Using that esti mate we divided b y a 1.36 RPE and converted to 2012$ to arrive at a cost of $828 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 205 for tractors. **Table 2**  **- 205**  **Costs for Automatic Tire Inflation Systems**

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 AT IS DMC $828 $803 $779 $755 $740 $725 $711 $697 $683 $669 AT IS IC $148 $147 $147 $147 $147 $115 $115 $115 $115 $115 AT IS TC $975 $950 $926 $902 $887 $841 $826 $812 $798 $784 AT IS Alt 1a AT IS Alt 3 20% 20% 20% 40% 40% 40% 40% AT IS TCp $0 $0 $0 $180 $177 $168 $330 $325 $319 $314 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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2 - 259 For trailers, we have estimated the cost of this technology based on an estimate from TetraTech of $800 (retail, 2013$). We consider this estimate to be valid for all trailers except tandems. For tandems, we have used an estimate of $600 (retail, 2013$) s ince they have just one axle. Using these estimates we divided b y a 1.36 RPE and converted to 2012$ to arrive at a cost of $579 (DMC, 2012$, in 2018) for all but tandems and $435 (DMC, 2012$, in 2018) for tandems. We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 206 for 53 - foot dry

and reefer vans, in Table 2 - 207 for 28 - foot dry vans and in Table 2 - 208 for non box highway

trailers. **Table 2**  **- 206**  **Costs for Automatic Tire Inflation Systems**

**53 -**  **foot Dry and Reefer Van Trailers**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 AT IS DMC $579 $562 $545 $529 $518 $508 $498 $488 $478 $469 AT IS IC $103 $103 $103 $103 $103 $81 $81 $81 $81 $80 AT IS TC $683 $665 $648 $632 $621 $589 $578 $568 $559 $549 AT IS Alt 1a 50% 51% 52% 53% 54% 56% 57% 58% 59% 60% AT IS Alt 3 85% 85% 85% 90% 90% 90% 95% 95% 95% 95% AT IS TCp $239 $226 $214 $234 $224 $200 $220 $210 $201 $192 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative

**Table 2**  **- 207**  **Costs for Automatic Tire Inflation Systems**

**28 -**  **foot Dry Van Trailers**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 AT IS DMC $435 $422 $409 $397 $389 $381 $373 $366 $359 $351 AT IS IC $78 $77 $77 $77 $77 $61 $60 $60 $60 $60 AT IS TC $512 $499 $486 $474 $466 $441 $434 $426 $419 $412 AT IS Alt 1a AT IS Alt 3 85% 85% 85% 90% 90% 90% 95% 95% 95% 95% AT IS TCp $435 $424 $413 $426 $419 $397 $412 $405 $398 $391 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption **Table 2**  **- 208**  **Costs fo r Automatic Tire Inflation Systems** 

**Non -**  **box Highway Trailers**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 AT IS DMC $579 $562 $545 $529 $518 $508 $498 $488 $478 $469 AT IS IC $103 $103 $103 $103 $103 $81 $81 $81 $81 $80 AT IS TC $683 $665 $648 $632 $621 $589 $578 $568 $559 $549 AT IS Alt 1a AT IS Alt 3 100% 100% 100% 100% 100% 100% 100% 100% 100% 100% AT IS TCp $683 $665 $648 $632 $621 $589 $578 $568 $559 $549 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em pty cells for adoption rates denote 0% adoption

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2 - 260 

## 2.12.9 **Aerodynamic I**  **mprovements (aero)** The agencies’ estimates for cost of tractor aero features are based the work done by ICF in support of the Phase 1 HD rule s . For trailers, we have based our estimates on the work presented in the ICCT trailer technology report. 177 

## 2.12.9.1 Aero improvements, Day cab low roof tractors For low roof day

cab tractors, Aero Bin 2 costs are estimated at $1001, Bin 3 at $2022 and Bin 4 at $2578 (all are DMC, in 2012$, and applicable in 2014). We consider Bin 2 technologies to be beyond the effects of learning (curve 1), Bin 3 technologies to be on the flat portion of the curve (curve 2) and Bin 4 technologies to be on the steep portion of the curve (curve 4). We have applied a low complexity I CMs to each with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 209 . **Table 2**  **- 209**  **Costs of Aero Technologies Day**  **Cab Low Roof Tr actors**  **(2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin2 DMC $1,001 $1,001 $1,001 $1,001 $1,001 $1,001 $1,001 $1,001 $1,001 $1,001 Aero Bin3 DMC $1,790 $1,755 $1,719 $1,685 $1,651 $1,618 $1,586 $1,554 $1,539 $1,523 Aero Bin4 DMC $1,650 $1,601 $1,553 $1,506 $1,461 $1,417 $1,375 $1,333 $1,307 $1,281 Aero Bin2 IC $179 $179 $179 $179 $179 $140 $140 $140 $140 $140 Aero Bin3 IC $358 $357 $357 $356 $356 $281 $281 $280 $280 $280 Aero Bin4 IC $448 $447 $447 $446 $445 $354 $354 $353 $353 $353 Aero Bin2 TC $1,180 $1,180 $1,180 $1,180 $1,180 $1,141 $1,141 $1,141 $1,141 $1,141 Aero Bin3 TC $2,148 $2,112 $2,076 $2,041 $2,007 $1,899 $1,867 $1,835 $1,819 $1,803 Aero Bin4 TC $2,098 $2,048 $1,999 $1,952 $1,906 $1,771 $1,728 $1,687 $1,660 $1,634 Aero Bin2 Alt

1a 60% 60% 60% 60% 60% 60% 60% 60% 60% 60% Aero Bin3 Alt

1a Aero Bin4 Alt

1a Aero Bin2 Alt 3 60% 60% 60% 75% 75% 75% 60% 60% 60% 50% Aero Bin3 Alt 3 25% 25% 25% 38% 38% 38% 40% Aero Bin4 Alt 3 2% 2% 2% 10% Aero Bin2 TCp $0 $0 $0 $177 $177 $171 $0 $0 $0 - $114 Aero Bin3 TCp $0 $0 $0 $510 $502 $475 $709 $697 $691 $721 Aero Bin4 TCp $0 $0 $0 $0 $0 $0 $35 $34 $33 $163 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.9.2 Aero improvements, Day cab high roof tractors For high roof day

cab tractors, Aero Bin 3 costs are estimated at $1028, Bin 4 at $2049, Bin 5 at $2612, Bin 6 at $3176 and Bin 7 at $3739 (all are DMC, in 2012$, and applicable in 2014). We consider Bin 3 technologies to be on the flat portion of the curve (curve 2) and Bin 4 through 7 technologies to be on the steep portion of the curve (curve 4). We have applied a low

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2 - 261 complexity

I CMs to Bins 3 and 4 with short term markups through 2022. We have applied medium complexity

I CMs to Bins 5 through 7 with s hort term markups through 2025. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 210 . **Table 2**  **- 210**  **Costs of Aero Technologies Day**  **Cab High Roof Tractors (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin3 DMC $910 $892 $874 $856 $839 $822 $806 $790 $782 $774 Aero Bin4 DMC $1,311 $1,272 $1,234 $1,197 $1,161 $1,126 $1,092 $1,059 $1,038 $1,017 Aero Bin5 DMC $1,672 $1,622 $1,573 $1,526 $1,480 $1,436 $1,393 $1,351 $1,324 $1,297 Aero Bin6 DMC $2,032 $1,971 $1,912 $1,855 $1,799 $1,745 $1,693 $1,642 $1,609 $1,577 Aero Bin7 DMC $2,393 $2,321 $2,252 $2,184 $2,118 $2,055 $1,993 $1,933 $1,895 $1,857 Aero Bin3 IC $182 $182 $181 $181 $181 $143 $143 $142 $142 $142 Aero Bin4 IC $356 $355 $355 $354 $354 $281 $281 $281 $281 $281 Aero Bin5 IC $742 $740 $737 $735 $732 $730 $728 $726 $544 $543 Aero Bin6 IC $902 $899 $896 $893 $890 $888 $885 $882 $661 $660 Aero Bin7 IC $1,062 $1,059 $1,055 $1,052 $1,048 $1,045 $1,042 $1,039 $779 $777 Aero Bin3 TC $1,092 $1,073 $1,055 $1,037 $1,020 $965 $949 $932 $924 $916 Aero Bin4 TC $1,667 $1,627 $1,589 $1,551 $1,515 $1,407 $1,373 $1,340 $1,319 $1,298 Aero Bin5 TC $2,414 $2,361 $2,310 $2,260 $2,212 $2,166 $2,120 $2,077 $1,868 $1,840 Aero Bin6 TC $2,934 $2,870 $2,808 $2,748 $2,690 $2,633 $2,578 $2,524 $2,271 $2,237 Aero Bin7 TC $3,455 $3,380 $3,307 $3,236 $3,167 $3,100 $3,035 $2,972 $2,674 $2,634 Aero Bin3 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% Aero Bin4 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% Aero Bin5 Alt

1a Aero Bin6 Alt

1a Aero Bin7 Alt

1a Aero Bin3 Alt 3 70% 70% 70% 40% 40% 40% 30% 30% 30% 20% Aero Bin4 Alt 3 20% 20% 20% 35% 35% 35% 30% 30% 30% 20% Aero Bin5 Alt 3 20% 20% 20% 25% 25% 25% 35% Aero Bin6 Alt 3 5% 5% 5% 13% 13% 13% 20% Aero Bin7 Alt 3 2% 2% 2% 5% Aero Bin3 TCp $0 $0 $0 - $311 - $306 - $290 - $379 - $373 - $370 - $458 Aero Bin4 TCp $0 $0 $0 $233 $227 $211 $137 $134 $132 $0 Aero Bin5 TCp $0 $0 $0 $452 $442 $433 $530 $519 $467 $644 Aero Bin6 TCp $0 $0 $0 $137 $134 $132 $335 $328 $295 $447 Aero Bin7 TCp $0 $0 $0 $0 $0 $0 $61 $59 $53 $132 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.9.3 Aero improvements, Sleeper cab low/mid roof tractors For low and mid roof sleeper cab tractors, Aero Bin 2 costs are estimated at $1222, Bin 3 at $2313 and Bin 4 at $2949 (all are DMC, in 2012$, and applicable in 2014). We consider Bin 2 technologies to be beyond the effects of learning (curve 1), Bin 3 technologies to be on the flat

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

2 - 262 portion of the curve (curve 2) and Bin 4 technologies to be on the steep portion of the curve (curve 4). We have applied a low complexity I CMs to each with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 211 . **Table 2**  **- 211**  **Costs of Aero Technologies Sleeper**  **Cab Low/Mid Roof Tractors (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin2 DMC $1,222 $1,222 $1,222 $1,222 $1,222 $1,222 $1,222 $1,222 $1,222 $1,222 Aero Bin3 DMC $2,048 $2,007 $1,967 $1,928 $1,889 $1,851 $1,814 $1,778 $1,760 $1,742 Aero Bin4 DMC $1,888 $1,831 $1,776 $1,723 $1,671 $1,621 $1,572 $1,525 $1,495 $1,465 Aero Bin2 IC $218 $218 $218 $218 $218 $171 $171 $171 $171 $171 Aero Bin3 IC $409 $409 $408 $408 $407 $321 $321 $321 $321 $320 Aero Bin4 IC $512 $512 $511 $510 $509 $405 $405 $404 $404 $404 Aero Bin2 TC $1,440 $1,440 $1,440 $1,440 $1,440 $1,393 $1,393 $1,393 $1,393 $1,393 Aero Bin3 TC $2,457 $2,416 $2,375 $2,335 $2,296 $2,172 $2,135 $2,099 $2,081 $2,063 Aero Bin4 TC $2,400 $2,343 $2,287 $2,233 $2,181 $2,026 $1,977 $1,930 $1,899 $1,869 Aero Bin2 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% Aero Bin3 Alt

1a Aero Bin4 Alt

1a Aero Bin2 Alt 3 70% 70% 70% 75% 75% 75% 60% 60% 60% 50% Aero Bin3 Alt 3 25% 25% 25% 38% 38% 38% 40% Aero Bin4 Alt 3 2% 2% 2% 10% Aero Bin2 TCp $0 $0 $0 $72 $72 $70 - $139 - $139 - $139 - $279 Aero Bin3 TCp $0 $0 $0 $584 $574 $543 $811 $797 $791 $825 Aero Bin4 TCp $0 $0 $0 $0 $0 $0 $40 $39 $38 $187 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.9.4 Aero improvements, Sleeper cab high roof tractors For high roof sleeper cab tractors, Aero Bin 3 costs are estimated at $1387, Bin 4 at $2379, Bin 5 at $3034, Bin 6 at $3688 and Bin 7 at $4342 (all are DMC, in 2012$, and applicabl e in 2014). We consider Bin 3 technologies to be on the flat portion of the curve (curve 2) and Bin 4 through 7 technologies to be on the steep portion of the curve (curve 4). We have applied a low complexity ICMs to Bins 3 and 4 with short term markups through 2022. We have applied medium complexity I CMs to Bins 5 through 7 with short term markups through 2025. The resultant technology

costs, adoption rates and total cost applied to the package are shown in Table 2 - 212 .

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

2 - 263 **Table 2**  **- 212**  **Costs of Aero Technologies Sleeper**  **Cab High Roof Tractors (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin3 DMC $1,228 $1,204 $1,180 $1,156 $1,133 $1,110 $1,088 $1,066 $1,056 $1,045 Aero Bin4 DMC $1,523 $1,477 $1,433 $1,390 $1,348 $1,308 $1,268 $1,230 $1,206 $1,182 Aero Bin5 DMC $1,942 $1,883 $1,827 $1,772 $1,719 $1,667 $1,617 $1,569 $1,537 $1,507 Aero Bin6 DMC $2,360 $2,290 $2,221 $2,154 $2,090 $2,027 $1,966 $1,907 $1,869 $1,832 Aero Bin7 DMC $2,779 $2,696 $2,615 $2,536 $2,460 $2,387 $2,315 $2,246 $2,201 $2,157 Aero Bin3 IC $245 $245 $245 $245 $244 $193 $192 $192 $192 $192 Aero Bin4 IC $413 $413 $412 $412 $411 $327 $326 $326 $326 $326 Aero Bin5 IC $862 $859 $856 $853 $851 $848 $845 $843 $632 $631 Aero Bin6 IC $1,048 $1,044 $1,041 $1,037 $1,034 $1,031 $1,028 $1,025 $768 $767 Aero Bin7 IC $1,234 $1,229 $1,225 $1,221 $1,217 $1,214 $1,210 $1,207 $904 $903 Aero Bin3 TC $1,474 $1,449 $1,425 $1,401 $1,377 $1,303 $1,281 $1,259 $1,248 $1,237 Aero Bin4 TC $1,936 $1,890 $1,845 $1,801 $1,759 $1,634 $1,595 $1,557 $1,532 $1,508 Aero Bin5 TC $2,803 $2,742 $2,683 $2,625 $2,569 $2,515 $2,463 $2,412 $2,169 $2,137 Aero Bin6 TC $3,408 $3,334 $3,262 $3,192 $3,124 $3,058 $2,994 $2,932 $2,637 $2,598 Aero Bin7 TC $4,013 $3,925 $3,840 $3,758 $3,678 $3,600 $3,525 $3,452 $3,105 $3,060 Aero Bin3 Alt

1a 70% 70% 70% 70% 70% 70% 70% 70% 70% 70% Aero Bin4 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% Aero Bin5 Alt

1a Aero Bin6 Alt

1a Aero Bin7 Alt

1a Aero Bin3 Alt 3 70% 70% 70% 40% 40% 40% 30% 30% 30% 20% Aero Bin4 Alt 3 20% 20% 20% 35% 35% 35% 30% 30% 30% 20% Aero Bin5 Alt 3 20% 20% 20% 25% 25% 25% 35% Aero Bin6 Alt 3 5% 5% 5% 13% 13% 13% 20% Aero Bin7 Alt 3 2% 2% 2% 5% Aero Bin3 TCp $0 $0 $0 - $420 - $413 - $391 - $512 - $503 - $499 - $619 Aero Bin4 TCp $0 $0 $0 $270 $264 $245 $159 $156 $153 $0 Aero Bin5 TCp $0 $0 $0 $525 $514 $503 $616 $603 $542 $748 Aero Bin6 TCp $0 $0 $0 $160 $156 $153 $389 $381 $343 $520 Aero Bin7 TCp $0 $0 $0 $0 $0 $0 $71 $69 $62 $153 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.9.5 Aero improvements, trailers For dry and reefer van trailers , Aero Bin 3 costs are based on and ICCT estimate of $700 (retail, 2013$), Bin 4 costs are based on an ICCT estimate of $1000 (retail, 2013$), Bin 5 costs are based on an ICCT estimate of $1600 (retail, 2013$), Bin 6 costs are based on an ICCT estimate of $1900 (retail, 2013$), and Bin 7 costs are based on an ICCT estimate of $2200 (retail, 2013$). We have used these costs and divided by a 1.36 RPE and converted to 2012$ to arrive at direct manufacturing costs of $507, $724, $1159, $1376 and $1594 for Bins 3 through 7, respectiv el y (all are DMC, in 2012$, applicable in 2014). We consider each of these technologies to be on the flat portion of the learning curve (curve 2) and have applied low

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

2 - 264 complexity

I CMs with short term markups through 2018. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 213 and Table 2 - 214 for 53 - foot dry

and reefer van trailers , respectivel y, and in Table 2 - 215 for 28 - foot dry van trailers. **Table 2**  **- 213**  **Costs of Aero Technologies 53**  **- foot**  **Dry Van Trailers (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin3 DMC $449 $440 $431 $422 $414 $406 $398 $390 $386 $382 Aero Bin4 DMC $641 $628 $616 $604 $591 $580 $568 $557 $551 $546 Aero Bin5 DMC $1,026 $1,006 $985 $966 $946 $927 $909 $891 $882 $873 Aero Bin6 DMC $1,218 $1,194 $1,170 $1,147 $1,124 $1,101 $1,079 $1,058 $1,047 $1,037 Aero Bin7 DMC $1,411 $1,383 $1,355 $1,328 $1,301 $1,275 $1,250 $1,225 $1,212 $1,200 Aero Bin 8 DMC $1,860 $1,822 $1,786 $1,750 $1,715 $1,681 $1,647 $1,614 $1,598 $1,582 Aero Bin3 IC $90 $71 $71 $71 $70 $70 $70 $70 $70 $70 Aero Bin4 IC $128 $101 $101 $101 $101 $101 $100 $100 $100 $100 Aero Bin5 IC $205 $161 $161 $161 $161 $161 $161 $161 $161 $161 Aero Bin6 IC $244 $192 $191 $191 $191 $191 $191 $191 $191 $191 Aero Bin7 IC $282 $222 $222 $222 $221 $221 $221 $221 $221 $221 Aero Bin 8 IC $372 $293 $292 $292 $292 $292 $291 $291 $291 $291 Aero Bin3 TC $539 $511 $502 $493 $484 $476 $468 $460 $456 $452 Aero Bin4 TC $769 $729 $717 $704 $692 $680 $669 $657 $652 $646 Aero Bin5 TC $1,231 $1,167 $1,147 $1,127 $1,107 $1,088 $1,070 $1,051 $1,042 $1,034 Aero Bin6 TC $1,462 $1,386 $1,362 $1,338 $1,315 $1,292 $1,270 $1,249 $1,238 $1,227 Aero Bin7 TC $1,693 $1,604 $1,577 $1,549 $1,523 $1,496 $1,471 $1,446 $1,433 $1,421 Aero Bin 8 TC $2,231 $2,115 $2,078 $2,042 $2,007 $1,973 $1,939 $1,906 $1,889 $1,873 Aero Bin3 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% Aero Bin4 Alt

1a 30% 31% 32% 33% 34% 36% 37% 38% 39% 40% Aero Bin5 Alt

1a 5% 5% 5% 5% 5% 5% 5% 5% 5% 5% Aero Bin6 Alt

1a Aero Bin7 Alt

1a Aero Bin 8 Alt

1a Aero Bin3 Alt 3 30% 30% 30% 5% 5% 5% Aero Bin4 Alt 3 60% 60% 60% 55% 55% 55% 25% 25% 25% Aero Bin5 Alt 3 5% 5% 5% 10% 10% 10% 10% 10% 10% 10% Aero Bin6 Alt 3 Aero Bin7 Alt 3 30% 30% 30% 65% 65% 65% 50% Aero Bin 8 Alt 3 40% Aero Bin3 TCp $54 $51 $50 - $74 - $73 - $71 - $94 - $92 - $91 - $90 Aero Bin4 TCp $231 $212 $201 $155 $145 $129 - $80 - $85 - $91 - $258 Aero Bin5 TCp $0 $0 $0 $56 $55 $54 $53 $53 $52 $52 Aero Bin6 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Aero Bin7 TCp $0 $0 $0 $465 $457 $449 $956 $940 $932 $711 Aero Bin 8 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $749 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 265 **Table 2**  **- 214**  **Costs of Aero Technologies Reefer**  **Van Trailers (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin3 DMC $449 $440 $431 $422 $414 $406 $398 $390 $386 $382 Aero Bin4 DMC $641 $628 $616 $604 $591 $580 $568 $557 $551 $546 Aero Bin5 DMC $1,026 $1,006 $985 $966 $946 $927 $909 $891 $882 $873 Aero Bin6 DMC $1,218 $1,194 $1,170 $1,147 $1,124 $1,101 $1,079 $1,058 $1,047 $1,037 Aero Bin7 DMC $1,411 $1,383 $1,355 $1,328 $1,301 $1,275 $1,250 $1,225 $1,212 $1,200 Aero Bin 8 DMC $1,860 $1,822 $1,786 $1,750 $1,715 $1,681 $1,647 $1,614 $1,598 $1,582 Aero Bin3 IC $90 $71 $71 $71 $70 $70 $70 $70 $70 $70 Aero Bin4 IC $128 $101 $101 $101 $101 $101 $100 $100 $100 $100 Aero Bin5 IC $205 $161 $161 $161 $161 $161 $161 $161 $161 $161 Aero Bin6 IC $244 $192 $191 $191 $191 $191 $191 $191 $191 $191 Aero Bin7 IC $282 $222 $222 $222 $221 $221 $221 $221 $221 $221 Aero Bin 8 IC $372 $293 $292 $292 $292 $292 $291 $291 $291 $291 Aero Bin3 TC $539 $511 $502 $493 $484 $476 $468 $460 $456 $452 Aero Bin4 TC $769 $729 $717 $704 $692 $680 $669 $657 $652 $646 Aero Bin5 TC $1,231 $1,167 $1,147 $1,127 $1,107 $1,088 $1,070 $1,051 $1,042 $1,034 Aero Bin6 TC $1,462 $1,386 $1,362 $1,338 $1,315 $1,292 $1,270 $1,249 $1,238 $1,227 Aero Bin7 TC $1,693 $1,604 $1,577 $1,549 $1,523 $1,496 $1,471 $1,446 $1,433 $1,421 Aero Bin 8 TC $2,231 $2,115 $2,078 $2,042 $2,007 $1,973 $1,939 $1,906 $1,889 $1,873 Aero Bin3 Alt

1a 20% 20% 20% 20% 20% 20% 20% 20% 20% 20% Aero Bin4 Alt

1a 30% 31% 32% 33% 34% 36% 37% 38% 39% 40% Aero Bin5 Alt

1a 5% 5% 5% 5% 5% 5% 5% 5% 5% 5% Aero Bin6 Alt

1a Aero Bin7 Alt

1a Aero Bin 8 Alt

1a Aero Bin3 Alt 3 30% 30% 30% 5% 5% 5% Aero Bin4 Alt 3 60% 60% 60% 55% 55% 55% 25% 25% 25% Aero Bin5 Alt 3 5% 5% 5% 10% 10% 10% 10% 10% 10% 20% Aero Bin6 Alt 3 Aero Bin7 Alt 3 30% 30% 30% 65% 65% 65% 60% Aero Bin 8 Alt 3 20% Aero Bin3 TCp $54 $51 $50 - $74 - $73 - $71 - $94 - $92 - $91 - $90 Aero Bin4 TCp $231 $212 $201 $155 $145 $129 - $80 - $85 - $91 - $258 Aero Bin5 TCp $0 $0 $0 $56 $55 $54 $53 $53 $52 $155 Aero Bin6 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Aero Bin7 TCp $0 $0 $0 $465 $457 $449 $956 $940 $932 $853 Aero Bin 8 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $375 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 266 **Table 2**  **- 215**  **Costs of Aero Technologies 28**  **- foot**  **Dry Van Trailers (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Aero Bin3 DMC $449 $440 $431 $422 $414 $406 $398 $390 $386 $382 Aero Bin4 DMC $641 $628 $616 $604 $591 $580 $568 $557 $551 $546 Aero Bin5 DMC $1,090 $1,068 $1,047 $1,026 $1,006 $985 $966 $946 $937 $928 Aero Bin3 IC $90 $71 $71 $71 $70 $70 $70 $70 $70 $70 Aero Bin4 IC $128 $101 $101 $101 $101 $101 $100 $100 $100 $100 Aero Bin5 IC $218 $171 $171 $171 $171 $171 $171 $171 $171 $171 Aero Bin3 TC $539 $511 $502 $493 $484 $476 $468 $460 $456 $452 Aero Bin4 TC $769 $729 $717 $704 $692 $680 $669 $657 $652 $646 Aero Bin5 TC $1,308 $1,240 $1,218 $1,197 $1,177 $1,156 $1,137 $1,117 $1,108 $1,098 Aero Bin3 Alt

1a Aero Bin4 Alt

1a Aero Bin5 Alt

1a Aero Bin3 Alt 3 95% 95% 95% 70% 70% 70% 30% Aero Bin4 Alt 3 30% 30% 30% 60% Aero Bin5 Alt 3 10% Aero Bin3 TCp $0 $0 $0 $468 $460 $452 $328 $322 $319 $136 Aero Bin4 TCp $0 $0 $0 $0 $0 $0 $281 $276 $274 $543 Aero Bin5 TCp $0 $0 $0 $0 $0 $0 $0 $0 $0 $110 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.9.6 Aero improvements, HD pickups and vans For HD pickups and vans, we have based our aero improvement costs on values used in our light - duty 2017 - 2025 final rule. Using those values updated to 2012$ results in costs for aero 1 (passive aero treatments) and active aero treatments of $47 and $142 (both are DMC, in 2012$, in 2015). Note that the aero 2 costs are the passive aero 1 plus the active aero costs. We consider both of these technologies to be on the flat portion of the learning curve (curve 8) and, to aero 1, have applied low complexity markups with near term markups through 2018 and, to active aero, have applied medium complexity markups with near term markups through 2024. The resultant costs for HD pickups and vans are shown in Table 2 - 216 (aero 1) and in Table 2 - 217 (active aero) and in Table 2 - 218 (aero 2, passive+active aero). **Table 2**  **- 216**  **Costs for Passive Aero Treatm ents**  **– Aero 1**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Aero 1

– passive aero DMC $42 $41 $40 $39 $38 $38 $38 Aero 1

– passive aero IC $9 $9 $9 $9 $9 $9 $9 Aero 1

– passive aero TC $51 $50 $49 $48 $47 $47 $47 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

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

2 - 267 **Table 2**  **- 217**  **Costs for Active Aero Treatm ents**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Aero 2

– active aero DMC $125 $122 $120 $118 $115 $114 $113 Aero 2

– active aero IC $54 $54 $54 $54 $40 $40 $40 Aero 2

– active aero TC $179 $177 $174 $172 $156 $154 $153 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost

**Table 2**  **- 218**  **Costs for Aero 2 (passive plus active aero)**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Aero 2

– active aero DMC $166 $163 $160 $157 $154 $152 $151 Aero 2

– active aero IC $63 $63 $63 $63 $50 $49 $49 Aero 2

– active aero TC $230 $227 $223 $220 $203 $201 $200 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.10 **Other T**  **echnologies** 2.12.10.1 Advanced cruise controls, tractors We have estimated the cost of this technology based on an estimate from TetraTech of $1100 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $797 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 219 for tractors. **Table 2**  **- 219**  **Costs for Advanced Cruise Controls**

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Advanced cruise control DMC $797 $773 $750 $727 $713 $698 $684 $671 $657 $644 Advanced cruise control IC $142 $142 $142 $141 $141 $111 $111 $111 $111 $111 Advanced cruise control TC $939 $915 $891 $868 $854 $809 $795 $782 $768 $755 Advanced cruise control Alt 1a Advanced cruise control Alt 3 20% 20% 20% 40% 40% 40% 40% Advanced cruise control TCp $0 $0 $0 $174 $171 $162 $318 $313 $307 $302 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

## 2.12.10.2 Improved accessories We have estimated the cost of this technology based on an estimate from TetraTech of $350 (retail, 2013$). Using that estimate we divided by a 1.36 RPE and converted to 2012$ to arrive at a cost of $254 (DMC, 2012$, in 2018). We consider this technology to be on the flat portion of the learning curve (curve 12) and have applied a low complexity I CM with short term markups through 2022. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 220 for tractors.

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

2 - 268 **Table 2**  **- 220**  **Costs for Im proved Accessories** 

**Tractors (2012$)** TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Im proved accessories DMC $254 $246 $239 $231 $227 $222 $218 $213 $209 $205 Im proved accessories IC $45 $45 $45 $45 $45 $35 $35 $35 $35 $35 Im proved accessories TC $299 $291 $284 $276 $272 $258 $253 $249 $244 $240 Im proved accessories Alt 1a Im proved accessories Alt 3 10% 10% 10% 20% 20% 20% 30% Im proved accessories TCp $0 $0 $0 $28 $27 $26 $51 $50 $49 $72 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption 

### For HD pickups and vans, we have estimated the costs for two levels of improved accessories based on estimates presented in the light- duty 2017 - 2025 final rule. In that rule, we estimated the costs of IACC1 and IACC2 at $73 and $118, respectivel y (both are DMC, 2009$, in 2015). With updates to 2012$, these costs become $77 and $124, respectively (both are DMC, 2012$, in 2015). Note that IACC2 includes IACC1. We consider these technologies to be on the flat portion of the learning curve (curve 8) and have applied low complexity markups with near term markups through 2018. The resultant cost for both are shown in Table 2 - 221 . **Table 2**  **- 221**  **Costs for Im proved Accessories**  **Gasoline & Diesel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Im proved accessories 1 (IACC1) DMC $67 $66 $64 $63 $62 $61 $61 Im proved accessories 1 (IACC2) DMC $109 $106 $104 $102 $100 $99 $98 Im proved accessories 1 (IACC1) IC $15 $15 $15 $15 $15 $15 $15 Im proved accessories 1 (IACC2) IC $24 $24 $24 $24 $24 $24 $24 Im proved accessories 1 (IACC1) TC $82 $80 $79 $78 $77 $76 $75 Im proved accessories 1 (IACC2) TC $132 $130 $128 $126 $124 $123 $122 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.10.3 Weight reduction, vocational vehicles We have estimated the cost of a 200, 400 and 1000 pound weight reduction on vocational vehicles at $4/pound, $6/pound and $8/pound, respectivel y (all are retail, 2013$). Using those costs we have divided b y a 1.36 RPE and converted to 2012$ to arrive at c osts of $579, $1738 and $5795 for 200, 400 and 1000 pound reductions, respectivel y (all are DMC, in 2012$, applicable in 2021). We consider each of these weight reduction levels to be on the flat portion of the learning curve (curve 13) and have applied l ow complexity I CMs with short term markups through 2022 for 200 and 400 pound reductions, and medium complexity ICMs with short term markups through 2022 for a 1000 pound reduction. The resultant technology costs, adoption rates and total cost applied to the package are shown in Table 2 - 222 though Table 2 - 227 .

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

2 - 269 **Table 2**  **- 222**  **Costs for a 200 Pound Weight Reduction Vocational**  **Light/ Medium** **/Heavy HD**  **Urban/Multipurpose V ehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 200 lbs DMC $635 $616 $597 $579 $562 $545 $529 $518 $508 $498 Weight reduction, 200 lbs IC $104 $104 $104 $103 $103 $81 $81 $81 $81 $81 Weight reduction, 200 lbs TC $739 $720 $701 $683 $665 $626 $610 $599 $589 $578 Weight reduction, 200 lbs Alt 1a Weight reduction, 200 lbs Alt 3 4% 4% 4% 4% 4% 4% 5% Weight reduction, 200 lbs TCp $0 $0 $0 $27 $27 $25 $24 $24 $24 $29 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

**Table 2**  **- 223**  **Costs for a 200 Pound Weight Reduction Vocational**  **Light HD**  **Regional V ehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 200 lbs DMC $635 $616 $597 $579 $562 $545 $529 $518 $508 $498 Weight reduction, 200 lbs IC $104 $104 $104 $103 $103 $81 $81 $81 $81 $81 Weight reduction, 200 lbs TC $739 $720 $701 $683 $665 $626 $610 $599 $589 $578 Weight reduction, 200 lbs Alt 1a Weight reduction, 200 lbs Alt 3 7% 7% 7% 7% 7% 7% 8% Weight reduction, 200 lbs TCp $0 $0 $0 $48 $47 $44 $43 $42 $41 $46 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 224**  **Costs for a 200 Pound Weight Reduction Vocational**  **Medium HD**  **Regional V ehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 200 lbs DMC $635 $616 $597 $579 $562 $545 $529 $518 $508 $498 Weight reduction, 200 lbs IC $104 $104 $104 $103 $103 $81 $81 $81 $81 $81 Weight reduction, 200 lbs TC $739 $720 $701 $683 $665 $626 $610 $599 $589 $578 Weight reduction, 200 lbs Alt 1a Weight reduction, 200 lbs Alt 3 6% 6% 6% 6% 6% 6% 7% Weight reduction, 200 lbs TCp $0 $0 $0 $41 $40 $38 $37 $36 $35 $40 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption **Table 2**  **- 225**  **Costs for a 200 Pound Weight Reduction Vocational**  **Heavy HD**  **Regional V ehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 200 lbs DMC $635 $616 $597 $579 $562 $545 $529 $518 $508 $498 Weight reduction, 200 lbs IC $104 $104 $104 $103 $103 $81 $81 $81 $81 $81 Weight reduction, 200 lbs TC $739 $720 $701 $683 $665 $626 $610 $599 $589 $578 Weight reduction, 200 lbs Alt 1a Weight reduction, 200 lbs Alt 3 5% 5% 5% 5% 5% 5% 6% Weight reduction, 200 lbs TCp $0 $0 $0 $34 $33 $31 $30 $30 $29 $35 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative ; em

pty cells for adoption rates denote 0% adoption

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

2 - 270 **Table 2**  **- 226**  **Costs for a 400 Pound Weight Reduction**

**Vocational vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 400 lbs DMC $1,905 $1,848 $1,792 $1,738 $1,686 $1,636 $1,587 $1,555 $1,524 $1,493 Weight reduction, 400 lbs IC $312 $312 $311 $310 $310 $243 $243 $242 $242 $242 Weight reduction, 400 lbs TC $2,217 $2,159 $2,103 $2,049 $1,996 $1,879 $1,829 $1,797 $1,766 $1,735 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost; TCp=total cost applied to the package; alt=alternative **Table 2**  **- 227**  **Costs for a 1000 Pound Weight Reduction Vocational vehicles (2012$)**  TECHNOLOGY 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 Weight reduction, 1000 lbs DMC $6,349 $6,159 $5,974 $5,795 $5,621 $5,452 $5,289 $5,183 $5,079 $4,978 Weight reduction, 1000 lbs IC $1,780 $1,770 $1,761 $1,752 $1,743 $1,296 $1,290 $1,286 $1,283 $1,279 Weight reduction, 1000 lbs TC $8,129 $7,929 $7,735 $7,547 $7,364 $6,748 $6,579 $6,469 $6,362 $6,257 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.10.4 Weight reduction in HD pickups and vans For this proposal, we are estimating weight reduction costs for HD pickups and vans using the same cost curve used in support of the 2017 - 2025 light - duty GHG/CAFE FRM. That curve can be expressed as: Mass Reduction Direct Manufacturing Cost (DMC) ($/lb) = 4. 55 x Percentage of Mass Reduction (201 2 $) For example, this results in an estimated $80 (2012$) DMC increase for a 5 percent mass reduction of a 7,000 pound vehicle and $ 318 (2012$) DMC increase for a 10 percent mass reduction of a 7 ,000 pound vehicle , or $0.227 $/lb and $0.4 55 /lb , respectively (both in 2012$). Consistent with the 2017 - 2025 light - duty FRM, the agencies consider this DMC to be applicable to MY2017 and consider mass reduction technology to be on the flat portion of the learning curve in the 2017 - 2025MY timeframe. To estimate indirect costs for applied mass reduction of up to 1 0 percent , the agencies have applied a low complexity I CM with near term markups through 2018.

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

2 - 271 

## 2.12.10.5 Electric power steering, HD pickups and vans We have based the costs for electric power steering on the costs used in the light- duty 2017 - 2025 FRM but have scaled upward that cost by 50 percent to account for the larger HD vehicles. Using that cost and converting to 2012$ results in a cost of $141 (DMC, 2012$, in 2015). We consider this technology to be on the flat portion of the learning curve (curve 8) and have applied low complexity markups with near term markups through 2018. The resultant costs for HD pickups and vans are shown in are shown in Table 2 - 228 . **Table 2**  **- 228**  **Costs for Electric Power Steering Gasoline & Diesel HD Pickups and Vans (2012$)**  ITEM 2021 2022 2023 2024 2025 2026 2027 Electric power steering (EPS) DMC $124 $121 $119 $117 $114 $113 $112 Electric power steering (EPS) IC $27 $27 $27 $27 $27 $27 $27 Electric power steering (EPS) TC $151 $148 $146 $144 $141 $140 $139 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.10.6 Low drag brakes, HD pickups and vans We have based the costs for low drag brakes on the costs used in the light- duty 2017 - 2025 FRM but have scaled upward that cost by 50 percent to account for the larger HD vehicles. U sing that cost and converting to 2012$ results in a cost of $91 (DMC, 2012$, in any year). We consider this technology

to be beyond the learning curve (curve 1) and have applied low complexity

markups with near term markups through 2018. The resultant cos ts for HD pickups and vans are shown in are shown in Table 2 - 229 . **Table 2**  **- 229**  **Costs for Low Drag Brakes Gasoline & Die**  **sel HD Pickups and Vans (2012$)** ITEM 2021 2022 2023 2024 2025 2026 2027 Lo w drag brakes DMC $91 $91 $91 $91 $91 $91 $91 Lo w drag brakes IC $18 $18 $18 $18 $18 $18 $18 Lo w drag brakes TC $109 $109 $109 $109 $109 $109 $109 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.12.10.7 Driveline friction reduction, diesel HD pickups & vans We have estimated the cost of driveline friction reduction based on the cost of secondary axle disconnect in the light - duty 2017 - 2025 final rule. Using that cost of $80 (DMC, 2009$, in 2015), we have scaled upward b y 50 percent to account for the larger HD componentry to arrive at a cost of $126 (DMC, 2012$, in 2015). We consider this technology to be on the flat portion of the learning curve (curve 3) and have applied low complexity markups with near term markups through 2022. The resultant costs for driveline friction reduction (applied only to diesel HD pickups & vans) are shown in Table 2 - 230 .

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

2 - 272 **Table 2**  **- 230**  **Costs for Driveline Friction Reduction Diesel HD Pickups and Vans (2012$)**  IT EM 2021 2022 2023 2024 2025 2026 2027 Driveline friction reduction DMC $108 $106 $104 $102 $100 $99 $98 Driveline friction reduction IC $30 $30 $24 $24 $24 $24 $24 Driveline friction reduction TC $139 $136 $128 $126 $124 $123 $122 Notes: DMC=direct manufacturing cost; IC=indirect cost; TC=total cost 

## 2.13 **Pack age Costs**  Section 0presents detailed technology costs along with adoption rates to illustrate how each technology

is accounted for in the package costs. Here we present package costs by regulated sector (i.e., vocational heavy HD, urban vehicles) and package costs by MOVES sourcetype (i.e., diesel refuse trucks). We determine package costs by MOVES sourcetype so that we can calculate total program costs (i.e., package costs multiplied by vehicle sales) since sourcetypes are the sales figures that we can glean from MOVES. As a result, the sourcetype package costs presented here are the costs used in our program cost estimations. 

## 2.13.1 **Package Costs by Regulated Sector** 2.13.1.1 Vocational vehicles We have estimated costs for 9 vocational segments and 2 fuels. We present package costs in Table 2 - 231 through Table 2 - 238 for these for alternatives 3 and 4, both relative to alternatives 1a and 1b and separately for diesel and gasoline vehicles. **Table 2**  **- 231**  **Package Costs for Regulated Vocational Segment**

**Alternative 3 Increm**  **ental to Alternative 1a** 

**Diesel (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $1,125 $1,100 $1,008 $1,737 $1,701 $1,664 $3,489 $3,427 Light HD Multipurpose $1,125 $1,100 $1,008 $1,737 $1,701 $1,664 $3,490 $3,427 Light HD Regional $598 $585 $563 $849 $835 $819 $1,407 $1,378 Medium HD Urban $1,418 $1,386 $1,254 $2,228 $2,180 $2,132 $4,696 $4,616 Medium HD Multipurpose $1,418 $1,386 $1,254 $2,228 $2,180 $2,132 $4,696 $4,616 Medium HD Regional $571 $559 $537 $817 $803 $788 $1,395 $1,367 Heavy HD Urban $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 Heavy HD Multipurpose $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 Heavy HD Regional $3,404 $3,348 $3,160 $4,834 $4,755 $4,683 $4,682 $4,607

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

2 - 273 **Table 2**  **- 232**  **Package Costs for Regulated Vocational Segment** 

**Alternative 3 Increm**  **ental to Alternative 1a** 

**Gasoline (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $832 $814 $729 $1,299 $1,271 $1,240 $3,086 $3,037 Light HD Multipurpose $832 $814 $729 $1,299 $1,271 $1,240 $3,087 $3,038 Light HD Regional $305 $299 $284 $412 $405 $395 $1,004 $989 Medium HD Urban $1,147 $1,122 $996 $1,823 $1,782 $1,740 $4,327 $4,259 Medium HD Multipurpose $1,147 $1,122 $996 $1,823 $1,782 $1,740 $4,328 $4,259 Medium HD Regional $300 $294 $279 $412 $405 $395 $1,026 $1,010 Heavy HD Urban $1,728 $1,690 $1,491 $2,927 $2,860 $2,791 $7,053 $6,941 Heavy HD Multipurpose $1,728 $1,690 $1,491 $2,927 $2,860 $2,791 $7,053 $6,941 Heavy HD Regional $3,134 $3,083 $2,902 $4,429 $4,357 $4,290 $4,314 $4,251

**Table 2**  **- 233**  **Package Costs for Regulated Vocational Segment**

**Alternative 4 Increm**  **ental to Alternative 1a** 

**Diesel (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $2,169 $2,120 $1,911 $3,741 $3,661 $3,582 $3,525 $3,462 Light HD Multipurpose $2,169 $2,120 $1,911 $3,704 $3,625 $3,546 $3,490 $3,427 Light HD Regional $805 $788 $756 $1,482 $1,457 $1,430 $1,407 $1,378 Medium HD Urban $2,938 $2,873 $2,560 $5,030 $4,920 $4,810 $4,733 $4,652 Medium HD Multipurpose $2,938 $2,873 $2,560 $4,992 $4,882 $4,772 $4,696 $4,616 Medium HD Regional $777 $760 $729 $1,469 $1,444 $1,417 $1,395 $1,367 Heavy HD Urban $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 Heavy HD Multipurpose $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 Heavy HD Regional $2,693 $2,647 $2,504 $4,912 $4,831 $4,752 $4,682 $4,607

**Table 2**  **- 234**  **Package Costs for Regulated Vocational Segment**

**Alternative 4 Increm**  **ental to Alternative 1a** 

**Gasoline (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $1,796 $1,757 $1,556 $3,322 $3,245 $3,172 $3,122 $3,072 Light HD Multipurpose $1,796 $1,757 $1,556 $3,285 $3,209 $3,136 $3,087 $3,038 Light HD Regional $433 $424 $401 $1,063 $1,041 $1,020 $1,004 $989 Medium HD Urban $2,594 $2,536 $2,232 $4,648 $4,539 $4,435 $4,365 $4,296 Medium HD Multipurpose $2,594 $2,536 $2,232 $4,609 $4,501 $4,398 $4,328 $4,259 Medium HD Regional $432 $423 $400 $1,086 $1,063 $1,042 $1,026 $1,010 Heavy HD Urban $3,992 $3,903 $3,416 $7,512 $7,339 $7,168 $7,053 $6,941 Heavy HD Multipurpose $3,992 $3,903 $3,416 $7,512 $7,339 $7,168 $7,053 $6,941 Heavy HD Regional $2,348 $2,310 $2,175 $4,529 $4,450 $4,378 $4,314 $4,251

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

2 - 274 **Table 2**  **- 235**  **Package Costs for Regulated Vocational Segment**

**Alternative 3 Increm**  **ental to Alternative 1b** 

**Diesel (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $1,125 $1,100 $1,008 $1,737 $1,701 $1,664 $3,489 $3,427 Light HD Multipurpose $1,125 $1,100 $1,008 $1,737 $1,701 $1,664 $3,490 $3,427 Light HD Regional $598 $585 $563 $849 $835 $819 $1,407 $1,378 Medium HD Urban $1,418 $1,386 $1,254 $2,228 $2,180 $2,132 $4,696 $4,616 Medium HD Multipurpose $1,418 $1,386 $1,254 $2,228 $2,180 $2,132 $4,696 $4,616 Medium HD Regional $571 $559 $537 $817 $803 $788 $1,395 $1,367 Heavy HD Urban $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 Heavy HD Multipurpose $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 Heavy HD Regional $3,404 $3,348 $3,160 $4,834 $4,755 $4,683 $4,682 $4,607

**Table 2**  **- 236**  **Package Costs for Regulated Vocational Segment**

**Alternative 3 Increm**  **ental to Alternative 1b** 

**Gasoline (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $843 $825 $740 $1,311 $1,282 $1,251 $3,097 $3,048 Light HD Multipurpose $843 $825 $740 $1,311 $1,282 $1,251 $3,097 $3,049 Light HD Regional $316 $310 $295 $423 $416 $406 $1,015 $999 Medium HD Urban $1,159 $1,134 $1,008 $1,835 $1,793 $1,750 $4,338 $4,270 Medium HD Multipurpose $1,159 $1,134 $1,008 $1,835 $1,793 $1,750 $4,339 $4,270 Medium HD Regional $312 $306 $291 $424 $416 $406 $1,037 $1,021 Heavy HD Urban $1,740 $1,702 $1,502 $2,938 $2,871 $2,802 $7,064 $6,952 Heavy HD Multipurpose $1,740 $1,702 $1,502 $2,938 $2,871 $2,802 $7,064 $6,952 Heavy HD Regional $3,146 $3,095 $2,914 $4,441 $4,368 $4,301 $4,324 $4,262

**Table 2**  **- 237**  **Package Costs for Regulated Vocational Segment**

**Alternative 4 Increm**  **ental to Alternative 1b** 

**Diesel (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $2,169 $2,120 $1,911 $3,741 $3,661 $3,582 $3,525 $3,462 Light HD Multipurpose $2,169 $2,120 $1,911 $3,704 $3,625 $3,546 $3,490 $3,427 Light HD Regional $805 $788 $756 $1,482 $1,457 $1,430 $1,407 $1,378 Medium HD Urban $2,938 $2,873 $2,560 $5,030 $4,920 $4,810 $4,733 $4,652 Medium HD Multipurpose $2,938 $2,873 $2,560 $4,992 $4,882 $4,772 $4,696 $4,616 Medium HD Regional $777 $760 $729 $1,469 $1,444 $1,417 $1,395 $1,367 Heavy HD Urban $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 Heavy HD Multipurpose $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 Heavy HD Regional $2,693 $2,647 $2,504 $4,912 $4,831 $4,752 $4,682 $4,607

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

2 - 275 **Table 2**  **- 238**  **Package Costs for Regulated Vocational Segment**

**Alternative 4 Increm**  **ental to Alternative 1b** 

**Gasoline (2012$)** WEIGHT CLASS SPEED 2021 2022 2023 2024 2025 2026 2027 2028 Light HD Urban $1,808 $1,768 $1,567 $3,334 $3,256 $3,183 $3,132 $3,083 Light HD Multipurpose $1,808 $1,768 $1,567 $3,297 $3,220 $3,147 $3,097 $3,049 Light HD Regional $445 $436 $413 $1,075 $1,052 $1,031 $1,015 $999 Medium HD Urban $2,605 $2,547 $2,243 $4,659 $4,550 $4,446 $4,375 $4,306 Medium HD Multipurpose $2,605 $2,547 $2,243 $4,620 $4,512 $4,408 $4,339 $4,270 Medium HD Regional $444 $435 $412 $1,097 $1,074 $1,053 $1,037 $1,021 Heavy HD Urban $4,004 $3,915 $3,428 $7,524 $7,350 $7,178 $7,064 $6,952 Heavy HD Multipurpose $4,004 $3,915 $3,428 $7,524 $7,350 $7,178 $7,064 $6,952 Heavy HD Regional $2,360 $2,321 $2,187 $4,540 $4,461 $4,389 $4,324 $4,262 

## 2.13.1.2 Tractors We have estimated costs for 7 tractor segments and 1 fuel. We present package costs in Table 2 - 239 through Table 2 - 242 for these for alternatives 3 and 4, both relative to alternatives 1a and 1b. **Table 2**  **- 239**  **Package Costs for Regulated Tractor Segm ent**  **Alternative 3 Increm**  **ental to Alternative 1a** 

**Diesel (2012$)** CLASS TYPE 2021 2022 2023 2024 2025 2026 2027 2028 7 Day

cab, low roof $5,468 $5,381 $5,008 $8,400 $8,259 $8,095 $10,140 $9,968 7 Day

cab, high roof $5,252 $5,161 $4,811 $8,304 $8,160 $7,913 $10,099 $9,923 8 Day

cab, low roof $5,520 $5,432 $5,057 $8,467 $8,325 $8,159 $10,204 $10,031 8 Day

cab, high roof $5,298 $5,206 $4,854 $8,419 $8,274 $8,024 $10,209 $10,030 8 Sleeper cab,

low roof $7,916 $7,786 $7,281 $11,102 $10,912 $10,723 $12,744 $12,548 8 Sleeper cab,

mid roof $7,916 $7,786 $7,281 $11,102 $10,912 $10,723 $12,744 $12,548 8 Sleeper cab,

high roof $7,771 $7,637 $7,156 $11,145 $10,952 $10,666 $12,842 $12,640

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

2 - 276 **Table 2**  **- 240**  **Package Costs for Regulated Tractor Segm**  **ent Alternative 4**  **Increm ental**  **to Alternative 1a**

**Diesel (2012$)** CLASS TYPE 2021 2022 2023 2024 2025 2026 2027 2028 7 Day

cab, low roof $8,946 $8,799 $8,180 $10,757 $10,574 $10,306 $10,140 $9,968 7 Day

cab, high roof $8,769 $8,621 $8,035 $10,851 $10,664 $10,270 $10,099 $9,923 8 Day

cab, low roof $8,999 $8,852 $8,230 $10,826 $10,642 $10,371 $10,204 $10,031 8 Day

cab, high roof $8,816 $8,666 $8,079 $10,968 $10,780 $10,382 $10,209 $10,030 8 Sleeper cab,

low roof $11,397 $11,208 $10,456 $13,461 $13,229 $12,934 $12,744 $12,548 8 Sleeper cab,

mid roof $11,397 $11,208 $10,456 $13,461 $13,229 $12,934 $12,744 $12,548 8 Sleeper cab,

high roof $11,318 $11,126 $10,411 $13,717 $13,481 $13,039 $12,842 $12,640

**Table 2**  **- 241**  **Package Costs for Regulated Tractor Segm ent**  **Alternative 3 Increm**  **ental to Alternative 1b** 

**Diesel (2012$)** CLASS TYPE 2021 2022 2023 2024 2025 2026 2027 2028 7 Day

cab, low roof $5,244 $5,086 $4,642 $7,966 $7,765 $7,564 $9,504 $9,337 7 Day

cab, high roof $5,159 $5,040 $4,681 $8,156 $7,995 $7,726 $9,885 $9,710 8 Day

cab, low roof $5,296 $5,137 $4,691 $8,033 $7,831 $7,628 $9,569 $9,400 8 Day

cab, high roof $5,205 $5,085 $4,724 $8,271 $8,108 $7,836 $9,995 $9,818 8 Sleeper cab,

low roof $7,642 $7,426 $6,863 $10,610 $10,381 $10,140 $12,078 $11,882 8 Sleeper cab,

mid roof $7,556 $7,332 $6,770 $10,528 $10,283 $10,044 $11,944 $11,758 8 Sleeper cab,

high roof $7,653 $7,497 $7,019 $10,996 $10,788 $10,497 $12,640 $12,443

**Table 2**  **- 242**  **Package Costs for Regulated Tractor Segm ent**  **Alternative 4 Increm**  **ental to Alternative 1b** 

**Diesel (2012$)** CLASS TYPE 2021 2022 2023 2024 2025 2026 2027 2028 7 Day

cab, low roof $8,721 $8,505 $7,815 $10,323 $10,080 $9,774 $9,504 $9,337 7 Day

cab, high roof $8,676 $8,499 $7,905 $10,703 $10,499 $10,083 $9,885 $9,710 8 Day

cab, low roof $8,775 $8,557 $7,865 $10,392 $10,148 $9,840 $9,569 $9,400 8 Day

cab, high roof $8,722 $8,545 $7,949 $10,820 $10,614 $10,195 $9,995 $9,818 8 Sleeper cab,

low roof $11,124 $10,848 $10,038 $12,969 $12,698 $12,351 $12,078 $11,882 8 Sleeper cab,

mid roof $11,037 $10,753 $9,944 $12,887 $12,599 $12,255 $11,944 $11,758 8 Sleeper cab,

high roof $11,200 $10,985 $10,273 $13,567 $13,317 $12,870 $12,640 $12,443

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

2 - 277 

## 2.13.1.3 Trailers We have estimated costs for 7 trailer typ es. We present package costs in Table 2 - 243 and Table 2 - 244 for these for alternatives 3 and 4 relative to alternative 1a. We present package co sts in Table 2 - 245 and Table 2 - 246 for alternative 3 and 4 relative to alter native 1b. **Table 2**  **- 243**  **Costs for Trailers Alternative 3**  **Increm ental**  **to Alternative 1a (2012$)** TYPE 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 53 - foot dry van $588 $550 $524 $901 $870 $817 $1,116 $1,083 $1,059 $1,409 $1,396 53 - foot reefer van $588 $550 $524 $901 $870 $817 $1,116 $1,083 $1,059 $1,280 $1,267 Container chassis $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28 - foot dry van $514 $501 $489 $974 $957 $923 $1,097 $1,078 $1,065 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other highway $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693

**Table 2**  **- 244**  **Costs for Trailers Alternative 4**  **Increm ental**  **to Alternative 1a (2012$)** TYPE 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 53 - foot dry van $588 $550 $524 $1,207 $1,172 $1,113 $1,504 $1,465 $1,437 $1,409 $1,396 53 - foot reefer van $588 $550 $524 $1,207 $1,172 $1,113 $1,371 $1,333 $1,306 $1,280 $1,267 Container chassis $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28 - foot dry van $514 $501 $489 $1,146 $1,127 $1,090 $1,304 $1,282 $1,267 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other highway $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693

**Table 2**  **- 245**  **Costs for Trailers Alternative 3**  **Increm ental**  **to Alternative 1b (2012$)** TYPE 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 53 - foot dry van $588 $550 $524 $901 $856 $817 $1,116 $1,083 $1,059 $1,409 $1,382 53 - foot reefer van $588 $550 $524 $901 $856 $817 $1,116 $1,083 $1,059 $1,280 $1,254 Container chassis $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28 - foot dry van $514 $501 $489 $974 $957 $923 $1,097 $1,078 $1,065 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other highway $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693

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

2 - 278 **Table 2**  **- 246**  **Costs for Trailers Alternative 4**  **Increm ental**  **to Alternative 1b (2012$)**  TYPE 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 53 - foot dry van $588 $550 $524 $1,207 $1,157 $1,113 $1,504 $1,465 $1,437 $1,409 $1,382 53 - foot reefer van $588 $550 $524 $1,207 $1,157 $1,113 $1,371 $1,333 $1,306 $1,280 $1,254 Container chassis $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28 - foot dry van $514 $501 $489 $1,146 $1,127 $1,090 $1,304 $1,282 $1,267 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other highway $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 

## 2.13.1.4 HD Pickups and Vans The costs presented in Table 2 - 247 are CAFE model outputs used in this analysis. We describe the CAFE model and how these costs were generated in Chapter 11 of this draft RIA. The costs presented here spread evenl y over MYs 2 021 through 2026 the costs estimated by the CAFE model for MYs 2017 - 2020. **Table 2**  **- 247**  **Package Costs for HD Pickups and Vans (2012$)** ALTERNATIVE BASELINE CASE 2021 2022 2023 2024 2025 2026 2027 3 1a $516 $508 $791 $948 $1,161 $1,224 $1,342 4 1a $1,050 $1,033 $1,621 $1,734 $1,825 $1,808 $1,841 3 1b $493 $485 $766 $896 $1,149 $1,248 $1,366 4 1b $909 $894 $1,415 $1,532 $1,627 $1,649 $1,684 

## 2.13.2 **Package Costs by MOVES Sourcetype** The package costs b y segment can then be used to calculate package costs by MOVES sourcetype. To do this, we need the percentage of the MOVES sourcety pe fleet comprised of each regulated sector. Table 2 - 248 shows this breakout for the vocational sector and Table 2 - 249 shows it for tractors.

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

2 - 279 **Table 2**  **- 248**  **Fleet Mix**  **by MOVES Sourcetype and Regulated Sector --**  **Vocational a**  ENGINE FUEL SPEED INTERCITY BUS TRANSIT

BUS SCHOOL

BUS REFUSE

TRUCKS SINGLE

UNIT SHORT HAUL SINGLE

UNIT LONG HAUL MOTOR

HOMES Light HD Gasoline Urban 0% 7% 0% 0% 4% 0% 0% Light HD Gasoline Multipurpose 0% 20% 1% 0% 49% 0% 0% Light HD Gasoline Regional 0% 0% 0% 0% 28% 0% 54% Medium HD Gasoline Urban 0% 2% 0% 0% 1% 0% 0% Medium HD Gasoline Multipurpose 0% 7% 95% 0% 11% 0% 0% Medium HD Gasoline Regional 0% 0% 0% 0% 7% 0% 41% Heavy HD Gasoline Urban 0% 16% 0% 0% 0% 0% 0% Heavy HD Gasoline Multipurpose 0% 48% 4% 0% 0% 0% 0% Heavy HD Gasoline Regional 0% 0% 0% 0% 0% 0% 5% Light HD Diesel Urban 0% 0% 0% 0% 2% 0% 0% Light HD Diesel Multipurpose 0% 0% 1% 0% 25% 0% 0% Light HD Diesel Regional 2% 0% 0% 0% 14% 25% 54% Medium HD Diesel Urban 0% 0% 0% 3% 2% 0% 0% Medium HD Diesel Multipurpose 0% 0% 95% 0% 20% 0% 0% Medium HD Diesel Regional 15% 0% 0% 0% 12% 37% 41% Heavy HD Diesel Urban 0% 25% 0% 97% 1% 0% 0% Heavy HD Diesel Multipurpose 0% 75% 5% 0% 15% 0% 0% Heavy HD Diesel Regional 83% 0% 0% 0% 9% 37% 5% Note: a Columns add to 100% or 0% for gasoline rows and 100% for diesel rows.

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

2 - 280 **Table 2**  **- 249**  **F leet**  **Mix by**  **MOVES Sourcetype and Regulated Sector –**  **Tractors a**  ENGINE MOVES

SOURCETYPE CLASS

7 DAY CAB LOW ROOF CLASS

7 DAY CAB HIGH ROOF CLASS

8 DAY CAB LOW ROOF CLASS

8 DAY CAB HIGH ROOF CLASS 8

SLEEPER CAB LOW ROOF CLASS 8

SLEEPER CAB MID ROOF CLASS 8

SLEEPER CAB HIGH ROOF Medium HD Com

bination Short haul 11% 11% Heavy HD Com

bination Short haul 39% 39% Heavy HD Com

bination Long haul 5% 15% 80% Note: a Com bination short haul adds to 100% and long haul to 100% ; em pty cells denote 0% . 

### Using the fleet mix information shown in Table 2 - 248 and Table 2 - 249 , along with the package costs shown in Table 2 - 231 through Table 2 - 246 , we can generate the package costs by MOVES sourcetype (note that package costs b y MOVES sourcetype differ from package costs by regulated sector onl y for vocational vehicles and tractors; trailer and HD pickup and van costs do not change). These costs are shown in Table 2 - 250 through Table 2 - 253 .

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

2 - 281 **Table 2**  **- 250**  **Package Costs by MOVES Sourcetype Alternative 3**  **Increm ental**  **to Alternative 1a (2012$)**  SOURCETYPE FUEL 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Intercity Bus Diesel $0 $0 $0 $2,913 $2,864 $2,705 $4,138 $4,070 $4,008 $4,112 $4,045 Transit Bus Diesel $0 $0 $0 $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 School Bus Diesel $0 $0 $0 $1,442 $1,410 $1,275 $2,275 $2,226 $2,177 $4,813 $4,730 Refuse Truck Diesel $0 $0 $0 $1,983 $1,939 $1,735 $3,302 $3,230 $3,156 $7,350 $7,226 SingleUnit ShortHaul Diesel $0 $0 $0 $1,400 $1,371 $1,261 $2,155 $2,112 $2,069 $3,975 $3,905 SingleUnit LongHaul Diesel $0 $0 $0 $1,637 $1,608 $1,525 $2,327 $2,289 $2,252 $2,627 $2,581 MotorHome Diesel $0 $0 $0 $736 $721 $690 $1,047 $1,030 $1,011 $1,576 $1,545 Intercity Bus Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Transit Bus Gasoline $0 $0 $0 $1,434 $1,402 $1,240 $2,388 $2,334 $2,277 $5,736 $5,645 School Bus Gasoline $0 $0 $0 $1,170 $1,145 $1,016 $1,868 $1,826 $1,782 $4,439 $4,368 Refuse Truck Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SingleUnit ShortHaul Gasoline $0 $0 $0 $686 $671 $606 $1,053 $1,031 $1,006 $2,512 $2,472 SingleUnit LongHaul Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MotorHome Gasoline $0 $0 $0 $453 $444 $421 $625 $615 $602 $1,189 $1,170 Com b ShortHaul Diesel $0 $0 $0 $5,398 $5,309 $4,945 $8,423 $8,279 $8,072 $10,187 $10,012 Com b LongHaul Diesel $0 $0 $0 $7,800 $7,667 $7,181 $11,137 $10,944 $10,677 $12,823 $12,622 53’ dry van $588 $550 $524 $901 $870 $817 $1,116 $1,083 $1,059 $1,409 $1,396 53’ rfr van $588 $550 $524 $901 $870 $817 $1,116 $1,083 $1,059 $1,280 $1,267 Container ch $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28’ dry van $514 $501 $489 $974 $957 $923 $1,097 $1,078 $1,065 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other trailer $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Vocational Diesel $0 $0 $0 $1,366 $1,337 $1,230 $2,102 $2,060 $2,018 $3,892 $3,824 Vocational Gasoline $0 $0 $0 $612 $599 $547 $916 $898 $877 $2,086 $2,053 Vocational Weighted

Avg $0 $0 $0 $1,152 $1,128 $1,037 $1,766 $1,731 $1,695 $3,381 $3,323 Tractor Weighted

Avg $0 $0 $0 $6,708 $6,605 $6,184 $9,935 $9,774 $9,542 $11,684 $11,503 Trailer Weighted

Avg $639 $613 $592 $898 $877 $832 $1,012 $989 $971 $1,165 $1,152 Tractor/Trailer Weighted

Avg $639 $613 $592 $7,606 $7,482 $7,016 $10,947 $10,763 $10,513 $12,849 $12,655

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

2 - 282 **Table 2**  **- 251**  **Package Costs by MOVES Sourcetype Alternative 4**  **Increm ental**  **to Alternative 1a (2012$)** SOURCETYPE FUEL 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Intercity Bus Diesel $0 $0 $0 $2,361 $2,320 $2,197 $4,314 $4,243 $4,174 $4,112 $4,045 Transit Bus Diesel $0 $0 $0 $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 School Bus Diesel $0 $0 $0 $2,997 $2,930 $2,610 $5,115 $5,002 $4,890 $4,813 $4,730 Refuse Truck Diesel $0 $0 $0 $4,300 $4,204 $3,714 $7,819 $7,645 $7,470 $7,350 $7,227 SingleUnit ShortHaul Diesel $0 $0 $0 $2,388 $2,336 $2,109 $4,216 $4,128 $4,040 $3,976 $3,907 SingleUnit LongHaul Diesel $0 $0 $0 $1,500 $1,473 $1,400 $2,760 $2,714 $2,668 $2,627 $2,581 MotorHome Diesel $0 $0 $0 $894 $875 $838 $1,658 $1,630 $1,601 $1,576 $1,545 Intercity Bus Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Transit Bus Gasoline $0 $0 $0 $3,273 $3,201 $2,807 $6,112 $5,971 $5,832 $5,739 $5,648 School Bus Gasoline $0 $0 $0 $2,649 $2,590 $2,279 $4,727 $4,616 $4,510 $4,439 $4,368 Refuse Truck Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SingleUnit ShortHaul Gasoline $0 $0 $0 $1,417 $1,386 $1,235 $2,673 $2,612 $2,554 $2,513 $2,474 SingleUnit LongHaul Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MotorHome Gasoline $0 $0 $0 $534 $524 $495 $1,256 $1,231 $1,207 $1,189 $1,170 Com b ShortHaul Diesel $0 $0 $0 $8,896 $8,748 $8,144 $10,877 $10,691 $10,357 $10,187 $10,012 Com b LongHaul Diesel $0 $0 $0 $11,334 $11,142 $10,420 $13,666 $13,430 $13,018 $12,823 $12,622 53’ dry van $588 $550 $524 $1,207 $1,172 $1,113 $1,504 $1,465 $1,437 $1,409 $1,396 53’ rfr van $588 $550 $524 $1,207 $1,172 $1,113 $1,371 $1,333 $1,306 $1,280 $1,267 Container ch $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28’ dry van $514 $501 $489 $1,146 $1,127 $1,090 $1,304 $1,282 $1,267 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other trailer $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Vocational Diesel $0 $0 $0 $2,333 $2,282 $2,061 $4,126 $4,041 $3,955 $3,892 $3,825 Vocational Gasoline $0 $0 $0 $1,134 $1,109 $997 $2,218 $2,168 $2,121 $2,087 $2,054 Vocational Weighted

Avg $0 $0 $0 $1,994 $1,950 $1,760 $3,586 $3,511 $3,436 $3,382 $3,324 Tractor Weighted

Avg $0 $0 $0 $10,225 $10,065 $9,404 $12,431 $12,227 $11,859 $11,684 $11,503 Trailer Weighted

Avg $639 $613 $592 $1,084 $1,059 $1,012 $1,231 $1,204 $1,184 $1,165 $1,152 Tractor/Trailer Weighted

Avg $639 $613 $592 $11,310 $11,124 $10,416 $13,662 $13,431 $13,043 $12,849 $12,655

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

2 - 283 **Table 2**  **- 252**  **Package Costs by MOVES Sourcetype Alternative 3**  **Increm ental**  **to Alternative 1b (2012$)** SOURCETYPE FUEL 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Intercity Bus Diesel $0 $0 $0 $2,913 $2,864 $2,705 $4,138 $4,070 $4,008 $4,112 $4,045 Transit Bus Diesel $0 $0 $0 $1,998 $1,954 $1,748 $3,332 $3,258 $3,183 $7,422 $7,298 School Bus Diesel $0 $0 $0 $1,442 $1,410 $1,275 $2,275 $2,226 $2,177 $4,813 $4,730 Refuse Truck Diesel $0 $0 $0 $1,983 $1,939 $1,735 $3,302 $3,230 $3,156 $7,350 $7,226 SingleUnit ShortHaul Diesel $0 $0 $0 $1,400 $1,371 $1,261 $2,155 $2,112 $2,069 $3,975 $3,905 SingleUnit LongHaul Diesel $0 $0 $0 $1,637 $1,608 $1,525 $2,327 $2,289 $2,252 $2,627 $2,581 MotorHome Diesel $0 $0 $0 $736 $721 $690 $1,047 $1,030 $1,011 $1,576 $1,545 Intercity Bus Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Transit Bus Gasoline $11 $12 $12 $1,445 $1,414 $1,252 $2,399 $2,345 $2,288 $5,747 $5,655 School Bus Gasoline $11 $12 $12 $1,182 $1,156 $1,028 $1,880 $1,837 $1,793 $4,449 $4,379 Refuse Truck Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SingleUnit ShortHaul Gasoline $11 $12 $12 $697 $683 $617 $1,065 $1,041 $1,017 $2,522 $2,483 SingleUnit LongHaul Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MotorHome Gasoline $11 $12 $12 $465 $456 $432 $636 $625 $613 $1,199 $1,181 Com b ShortHaul Diesel $0 - $59 - $114 $5,240 $5,101 $4,698 $8,132 $7,950 $7,713 $9,763 $9,590 Com b LongHaul Diesel $0 - $70 - $115 $7,638 $7,468 $6,974 $10,906 $10,692 $10,411 $12,508 $12,312 53’ dry van $588 $550 $524 $901 $856 $817 $1,116 $1,083 $1,059 $1,409 $1,382 53’ rfr van $588 $550 $524 $901 $856 $817 $1,116 $1,083 $1,059 $1,280 $1,254 Container ch $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28’ dry van $514 $501 $489 $974 $957 $923 $1,097 $1,078 $1,065 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other trailer $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Vocational Diesel $0 $0 $0 $1,366 $1,337 $1,230 $2,102 $2,060 $2,018 $3,892 $3,824 Vocational Gasoline $11 $12 $12 $624 $611 $558 $928 $909 $888 $2,096 $2,063 Vocational Weighted

Avg $3 $3 $3 $1,156 $1,132 $1,040 $1,770 $1,734 $1,698 $3,384 $3,326 Tractor Weighted

Avg $0 - $65 - $114 $6,547 $6,402 $5,958 $9,678 $9,488 $9,235 $11,321 $11,145 Trailer Weighted

Avg $639 $613 $592 $898 $870 $832 $1,012 $989 $971 $1,165 $1,146 Tractor/Trailer Weighted

Avg $639 $548 $478 $7,445 $7,273 $6,790 $10,690 $10,476 $10,206 $12,487 $12,292

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

2 - 284 **Table 2**  **- 253**  **Package Costs by MOVES Sourcetype Alternative 4**  **Increm ental**  **to Alternative 1b (2012$)** SOURCETYPE FUEL 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 Intercity Bus Diesel $0 $0 $0 $2,361 $2,320 $2,197 $4,314 $4,243 $4,174 $4,112 $4,045 Transit Bus Diesel $0 $0 $0 $4,337 $4,240 $3,745 $7,895 $7,719 $7,542 $7,422 $7,298 School Bus Diesel $0 $0 $0 $2,997 $2,930 $2,610 $5,115 $5,002 $4,890 $4,813 $4,730 Refuse Truck Diesel $0 $0 $0 $4,300 $4,204 $3,714 $7,819 $7,645 $7,470 $7,350 $7,227 SingleUnit ShortHaul Diesel $0 $0 $0 $2,388 $2,336 $2,109 $4,216 $4,128 $4,040 $3,976 $3,907 SingleUnit LongHaul Diesel $0 $0 $0 $1,500 $1,473 $1,400 $2,760 $2,714 $2,668 $2,627 $2,581 MotorHome Diesel $0 $0 $0 $894 $875 $838 $1,658 $1,630 $1,601 $1,576 $1,545 Intercity Bus Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Transit Bus Gasoline $11 $12 $12 $3,285 $3,212 $2,819 $6,124 $5,981 $5,843 $5,750 $5,659 School Bus Gasoline $11 $12 $12 $2,661 $2,602 $2,290 $4,738 $4,627 $4,521 $4,449 $4,379 Refuse Truck Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 SingleUnit ShortHaul Gasoline $11 $12 $12 $1,429 $1,397 $1,246 $2,685 $2,623 $2,565 $2,524 $2,484 SingleUnit LongHaul Gasoline $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 MotorHome Gasoline $11 $12 $12 $546 $535 $507 $1,268 $1,241 $1,218 $1,199 $1,181 Com b ShortHaul Diesel $0 - $59 - $114 $8,737 $8,540 $7,897 $10,586 $10,361 $9,998 $9,763 $9,590 Com b LongHaul Diesel $0 - $70 - $115 $11,172 $10,944 $10,212 $13,435 $13,178 $12,752 $12,508 $12,312 53’ dry van $588 $550 $524 $1,207 $1,157 $1,113 $1,504 $1,465 $1,437 $1,409 $1,382 53’ rfr van $588 $550 $524 $1,207 $1,157 $1,113 $1,371 $1,333 $1,306 $1,280 $1,254 Container ch $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 28’ dry van $514 $501 $489 $1,146 $1,127 $1,090 $1,304 $1,282 $1,267 $1,253 $1,239 Platform $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Tanker $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Other trailer $868 $847 $827 $807 $793 $752 $739 $726 $715 $704 $693 Vocational Diesel $0 $0 $0 $2,333 $2,282 $2,061 $4,126 $4,041 $3,955 $3,892 $3,825 Vocational Gasoline $11 $12 $12 $1,146 $1,121 $1,009 $2,230 $2,179 $2,132 $2,098 $2,065 Vocational Weighted

Avg $3 $3 $3 $1,997 $1,954 $1,763 $3,589 $3,514 $3,439 $3,385 $3,327 Tractor Weighted

Avg $0 - $65 - $114 $10,065 $9,862 $9,179 $12,174 $11,941 $11,552 $11,321 $11,145 Trailer Weighted

Avg $639 $613 $592 $1,084 $1,053 $1,012 $1,231 $1,204 $1,184 $1,165 $1,146 Tractor/Trailer Weighted

Avg $639 $548 $478 $11,149 $10,915 $10,191 $13,404 $13,144 $12,736 $12,487 $12,292

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2 - 285 

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2 - 289 91 Vincent, R., Cleary, K. , Ayala, A., Corey, R. 2004. “Emissions of HFC - 134a from Light - Duty Vehicles in California.” SAE 2004 - 01 - 2256 92 Society of Automotive Engineers, “IMAC Team 1

– Refrigerant Leakage Reduction, Final Report to Sponsors,” 2006 93 California Air Resources Board. Letter from Michael Carter to Matthew Spears dated December 3, 2014. Solar Control: Heavy - Duty Vehicles White Paper. Docket EPA - HA - OAR - 2014 - 0827. 94 National Renewal Energy Laboratory. Reducing Long - Haul Truck Idle Load s and Resulting Fuel Use. Presented by Jason A. Lustbader to EPA on July 29, 2014. See Docket EPA - HA - OAR - 2014 - 0827. 95 See NHTSA Technology Report # 1 ( 201 5), Note 6 . 96 U.S. EPA and NHTSA, “Final Rulemaking to Establish Light - Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards

– Joint Technical Support Document,” 2010. Last viewed on June 3, 2010 at http://www.epa.gov/otaq/cl imate/regulations/420r10901.pdf 97 “Light - Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 - 2014”, EPA 420 - R- 14 - 023, October 2014. Available at http://www.epa.gov/otaq/fetrends.htm (last accessed October 31, 2014). 98 “De velopment and Optimization of the Ford 3.5L V6 EcoBoost Combustion System,” Yi,J., Wooldridge, S., Coulson, G., Hilditch, J. Iyer, C.O., Moilanen, P., Papaioannou, G., Reiche, D. Shelby, M., VanDerWege, B., Weaver, C. Xu, Z., Davis, G., Hinds, B. Schamel, A. SAE Technical Paper No. 2009 - 01 - 1494, 2009, Docket EPA HQ - OAR - 2009 - 0472 - 2860. 99 David Woldring and Tilo Landenfeld of Bosch, and Mark J. Christie of Ricardo, “DI Boost: Application of a High Performance Gasoline Direct Injection Concept,” SAE 2007 - 01 - 1 410. Available at http://www.sae.org/technical/papers/2007 - 01 - 1410 (last accessed Nov. 9, 2008) 100 Yves Boccadoro, Loïc Kermanac’h, Laurent Siauve, and Jean - Michel Vincent, Renault Powertrain Division, “T he New Renault TCE 1.2L Turbocharged Gasoline Engine ,” 28th Vienna Motor Symposium, April 2007. 101 Tobias Heiter, Matthias Philipp, Robert Bosch, “Gasoline Direct Injection: Is There a Simplified, Cost - Optimal System A pproach for an Attractive Future of Gasoline Engines?” AVL Engine & Environment Conferenc e, September 2005 . 102 U.S. EPA and NHTSA, “Final Rulemaking to Establish Light - Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards

– Joint Technical Support Document,” 2010. Last viewed on June 3, 2010 at http://www. epa.gov/otaq/climate/regulations/420r10901.pdf 103 “All - new- Ford - engineered, Ford - tested, Ford -built diesel maximizes 2011 Super Duty productivity,” Ford press release, August 3, 2010. Available at: http://www.medi a.ford.com (last accessed June 27, 2011). 104 Stanton, Donald. “Enabling High Efficiency Clean Combustion.” 2009 Semi - Mega Merit Revie w of the Department of Energy. May 21, 2009. Last accessed on August 25, 2010 at http://www1.eere.energy.gov/vehiclesandfuels/pdfs/merit_review_2009/advanced_combustion/ace_40_stanton.pdf. 105 Committee on the Assessment of Technologies for Improving Light - Duty Vehicle Fuel Economy; National Research Council, “Assessment of Fuel Economy Technologies for Light - Duty Vehicles”, 2011. Available at http://www.nap.edu/catalog.php?record_id=12924 (las t accessed Jun 27, 2012) 106 SAE World Congress, “Focus B -pillar ‘tailor rolled’ to 8 different thicknesses,” Feb. 24, 2010. Available at http://www.sae.org/mags/AEI/7695 (last accessed Jun. 10, 2012) 107 “2008/9 Blueprint for Sustainability,” Ford Motor Company. Available at: http:// www.ford.com/go/sustainability (last accessed February 8, 2010). 108 “2015 North American Light Vehicle Aluminum Content Study

– Executive Summary”, June 2014, http://www. drivealuminum .org/research -resources/PDF/Research/2014/2014 - ducker-report (last accessed February 26, 2015) 109 Fox News September 2014, “Ford confirms increased aluminum use on next - gen Super Duty pickups,” http://www.foxnews.com/leisure/2014/09/30/ford - confirms - increased - aluminum- use - on - next - gen - super - duty pickups/ (last accessed February 2015) 110 “Mass Reduction and Cost Analysis

– Light - Duty Pickup Trucks Model Years 2020 - 2025”, FEV, North America, Inc., April 2015, Document no. EPA - 420 - R- 15 - 006 111 Michelin. SAE Presentation. 112 U.S. Department of Energy. Transportation Energy Data Book, Edition 28 - 2009. Table 5.7. 113 Gaines, L., A. Vyas, J. Anderson. Estimation of Fuel Use by Idling Commercial Trucks. January 2006. 114 Mack 2010 Powertrain Brochure

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2 - 290 115 Joint Technical Support Document: Final Rulemaking for 2017 - 2025 Light - Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, August 2012, available at http://www.epa.gov/otaq/climate/documents/420r12901.pdf 116 Vehicle Valuation Services, Inc, 200 0, available at http://www.vvsi.com/training/TrainingGuide.pdf (accessed June 2014) 117 See Cummins - Eaton partnership at http://smartadvantag epowertrain.com/ 118 See TIAX 2009 , Note 2 at 4.5.2 119 See TIAX 2009, Note 2 , Table 4 - 48 120 Heavy Duty Trucking October 2014, “2015 Medium - Duty Truck Trends,” http://www. truckinginfo.com /channel/equipment/article/story/2014/10/2015 - medium- duty - trucks - the - vehicles - and trends - to - look - for/page/3.aspx (downloaded November 2014) 121 See NACFE Confidence Report: Electronically Controlled Transmissions, at http://www.truckingefficiency.org/powertrain/automated - manual - transmissions (January 2015). See also http://www.overdriveonline.com/auto - vs - manual - transmission- autos - finding - solid - ground -by - sharing - data - with engines/ (accessed November 2014) 122 See Eaton Announcement September 2014, available at http://www.ttne ws.com/articles/lmtbase.aspx?storyid=2969&t=Eaton -Unveils - Medium- Duty - Procision Transmission 123 Light - Duty Technology Cost Analysis, Report on Additional Case Studies, Revised final Report, EPA - 420 - R - 13 - 008, page 2 - 16, April 2013, available at http://www.epa.gov/otaq/climate/documents/420r13008.pdf 124 Lammert, M., Walkowivz, K., NREL, Eighteen - Month Final Evaluation of UPS Second Generation Diesel Hy brid - Electric Delivery Vans, September 2012, NREL/TP - 5400 - 55658 125 Green Fleet Magazine, The Latest Developments in EV Battery Technology, November 2013, available at http://www.greenfleetmagazine.com/article/story/2013/12/the - latest- developments - in - ev -battery- technology grn/page/1.aspx 126 Van Amburg, Bill, CALSTART, Status Report: Alternative Fuels and High - Efficiency Vehicles, P resentation to National Association of Fleet Administrators (NAFA) 2014 Institute and Expo, April 8, 2014 127 See NHTSA Technology Report #1 (201 5 ) , Note 6 . See T - 270 Delivery Truck Vehicle Technology Results 128 Heavy Duty Trucking, “Rise of the 6x2”, May 2013, accessed from http://www.truckinginfo.com/article/story/2013/05/rise - of - the - 6x2.aspx 129 NACFE, Confidence Findings on the Potential of 6x2 Axles, available at http://nacfe.org/wp content/uploads/2014/01/Trucking - Efficiency - 6x2 - Confidence - Report - FINAL - 011314.pdf , January 2014 (downloaded November 2014). 130 See NHTSA Technology Report #1 ( 201 5), Note 6 . 131 Argonne National Laboratory. “Evaluation of Fuel Consumption Potential of Medium and Heavy Duty Vehicles through Modeling and Simulation.” October 2009. Page 91. 132 See S wRI Technology Report 1 ( 2 014 ), Note 6 . See Section 3.3.4.3 T270 Delivery Truck Vehicle Technology Results. 133 See memorandum dated May 2015 on Vocational Vehicle Tire Rolling Resistance Test Data Evaluation. 134 See NREL data at http://www.nrel.gov/vehiclesandfuels/fleettest/rese arch_fleet_dna.html 135 See memorandum dated May 2015 on Analysis of Possible Vocational Vehicle Standards Based on Alternative Idle Cycle Weightings 136 See NHTSA Technology Report #1 (2015 ) Note 6 , T - 270 and F - 650 weight reduction results 137 See TIAX 2009 , Note 2 . 138 The Minnesota refrigerant leakage data can be found at http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata 139 See Phase 1 RIA, Chapter 2.7 140 Society of Automotive Engineers, “I MAC Team 1

– Refrigerant Leakage Reduction, Final Report to Sponsors,” 2006 141 Society of Automotive Engineers Surface Vehicle Standard J2727, issued August 2008, http://www.sae.org 142 EPA Docket memo on Vocational Aerodynamics, May 2015 143 See http://westcoastcollaborative.org/files/sector - fleets/WCC - LA - BEVBusinessCase2011 - 08 - 15.pdf

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2 - 291 144 Silver, Fred, and Brotherton, Tom. (CalHEAT) Research and Market Tran sformation Roadmap to 2020 for Medium- and Heavy - Duty Trucks. California Energy Commission, June 2013. 145 Gallo, Jean- Baptiste, and Jasna Tomic (CalHEAT). 2013. Battery Electric Parcel Delivery Truck Testing and Demonstration. California Energy Commission. 146 See Ford announcement December 2013, https://media.ford.com/content/fordmedia/fna/us/en/news/2013/12/12/70 -percent - of - ford - lineup - to - have - auto - start stop -by - 2017 -- fuel - .html . See also Allison - Cummins announcement July 2014, http://www.oemoffhighway.com/press_release/12000208/alli son - stop start?utm_source=OOH+Industry+News+eNL&utm_medium=email&utm_campaign=RCL140723006 147 “T ires & Truck Fuel Economy: A New Perspective”, The Tire Topic Magazine, Special Edition Four, 2008, Bridgestone Firestone, North American Tire, LLC. Availabl e online: http://www.trucktires.com/bridgestone/us_eng/brochures/pdf/08 - Tires_and_Truck_Fuel_Economy.pdf 148 Truck Trailer Manufacturers Associati on letter to EPA. October 16, 2014. Docket EPA - HQ - OAR - 2014 - 0827 149 “T ire Pressure Systems - Confidence Report”. North American Council for Freight Efficiency. 2013. Available online: http://nacfe.org/wp - content/uploads/2014/01/TPS - Detailed - Confidence - Report1.pdf 150 ”A Day in the Life of a Tire”, Pressure Systems International , Presented to EPA on August 20, 2014. 152 Federal Motor Carriers Safety Administration, “Commercial Vehicle Tire Condition Sensors,” conducted by Booz - Allen - Hamilton, Inc. November, 2003. 153 TMC Technol ogy & Maintenance Council, “TMC Tire Air Pressure Study,” May 2002 154 FMCSA “Advanced Sensors and Applications: Commercial Motor Vehicle Tire Pressure Monitoring and Maintenance,” February 2014 155 “Underinflated Commercial Low Rolling Resistanc e Truck Tires & It’s Impact on Fuel Economy”, October 2010. Pressure Systems International , Presentation Material shared with EPA on May 21, 2014 . 156 Scarcelli, Jamie. "Fuel Efficiency for Trailers" Presented at ACEEE/ICCT Workshop: Emerging Technologie s for Heavy - Duty Vehicle Fuel Efficiency, Wabash National Corporation. July 22, 2014 157 "Weight Reduction: A Glance at Clean Freight Strategies", EPA SmartWay. EPA420F09 - 043. Available at: http://permanent.access.gpo.gov/gpo38937/EPA420F09 - 043.pdf 158 Memo to docket regarding confidential weight reduction information obtained during SBREFA Panel , June 4, 2015 159 Randall Scheps, Aluminum Association, “The Aluminum Advantage: Exploring Commercial Vehicles Applications,” presented in Ann Arbor, Michigan, June 18, 2009 160 http://energy.gov/eere/articles/supertruck- making - leaps - fuel - efficiency 161 Truck Trailer Manufacturers Association letter to EPA. October 16, 2014. Docket EPA - HQ - OAR - 2014 - 0827 162 Ben Sharpe (ICCT) and Mike Roeth (North American Council for Freight Efficiency), “Costs and Adoption Rates of Fuel - Saving Technologies for Trailer in the North American On - Road Freight Sector”, Feb 2014 163 Frost & Sullivan, “Strategic Analysis of North American Semi - trailer Advanced Technology Market”, Feb 2013 164 ICF International. Investigation of Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy - Duty On - Road Vehicles. July 2010. See also, TIAX, LLC. “Assessment of Fuel Economy Technologies for Medium and Heavy - Duty Vehicles,” Final Report to the National Academy of Sciences, November 19, 2009. 165 Schubert, R., Chan, M., Law, K. (2015). Commercial Medium - and Heavy - Duty (MD/HD) Truck Fuel Efficiency Cost Study. Washington, DC: National Highway Traffic Safety Administration , Tetra Tech Technology Cost Report (201 5 ) , Note 8 . 166 Schubert, R ., Chan, M., Law, K. (2015 ). Commercial Medium- and Heavy - Duty Truck Fuel Efficiency Technology Cost Study . Washington, DC: National Highway Traffic Safety Administratio n . 167 A. Rogozhin et al., Int. J. Production Economics 124 (2010) 360

–368. 168 RTI International. Heavy Duty Truck Retail Price Equivalent and Indirect Cost Multipliers. July 2010. 169 Rogozhin, A., et al., “Using indirect cost multipliers to estimate the total cost of adding new technology in the automobile industry,” International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031. 170 Helfand, Gloria, and Todd Sherwood, “Documentation of the Development of Indirect Cost Multipliers for Three Automotive Technologies,” August 2009. 171 RTI International. Heavy Duty Truck Retail Price Equivalent and Indirect Cost Multipliers. July 2010. 172 See “Learning Curves in Manufacturing”, L. Argote and D. Epple, Science, Volume 247; “Toward Cost Buy dow n Via Learning -by - Doing for Environmental Energy Technologies, R. Williams, Princeton University,

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2 - 292 Workshop on Learning -by - Doing in Energy Technologies, June 2003; “Industry Learning Environmental and the Heterogeneity of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA Anderson School of Management, December 2006, Discu ssion Papers, Center for Economic Studies, Washington DC. 173 See “Learning Curves in Manufacturing”, L. Argote and D. Epple, Science, Volume 247; “Toward Cost Buy dow n Via Learning -by - Doing for Environmental Energy Technologies, R. Williams, Princeton University, Workshop on Learning -by - Doing in Energy Technologies, June 2003; “Industry Learning Environments and the Heterogeneity of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA Anderson School of Management, December 2006, Discussion Papers, Center for Economic Studies, Washington DC. 174 U.S. Energy Information Administration, Annual Energy Outlook 2014, Early Release; Report Number DOE/EIA - 0383ER (2014), December 16, 2013. 175 Bureau of Economic Analysis, Table 1.1.9 Implicit Price Deflators for Gross Domestic Product; as revised on March 27, 2014. 176 Business Case for Battery - Electric Trucks in Los Angeles, California, at http://westcoastcollaborative.org/files/sector- fleets/WCC - LA - BEVBusinessCase2011 - 08 - 15.pdf , last accessed on 12/8/2014. 177 Ben Sharpe (ICCT) and Mike Roeth (North American Council for Freight Efficiency), “Costs and Adoption Rates of Fuel - Saving Technologies for Trailer in the North American On - Road Freight Sector”, Feb 2014.