Proposed Phase 2 Fuel Efficiency 

and GHG Emission Standards for 

Heavy-Duty Vehicles

APRIL 07, 2015

1
Overview

Phase 1 standards began in 2014 – fully phased-in by 2018

Proposing more ambitious and longer-term Phase 2 standards

Very cost-effective

Builds upon Phase 1 structure

NPRM invites comment on both proposed standards and 

alternative standards that achieve 2027 stringency levels in 

2024/2025

Other issues including natural gas and small businesses

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Heavy-Duty

Large Pickups & Vans

14% of HD Fuel Consumption

and GHG Inventory

Standards in g/mile

and gallons/100 miles

Vocational Vehicles

21% of HD Fuel Consumption 

and GHG Inventory

Standards in g/ton-mile

and gallons/1000 ton-miles

Line-Haul Tractors

65% of HD Fuel Consumption and 

GHG Inventory (together)

Standards in g/ton-mile

and gallons/1000 ton-miles

Heavy-Duty Truck Categories

Line-Haul Trailers

(currently unregulated 

Federally)
4

60%

20%

9%

3%

2%

6%

Light-Duty Vehicles

Heavy-Duty Trucks and Buses

Aircraft

Ships and Boats

Rail

Other (Motorcycles,

Pipelines, Lubricants)

Heavy-Duty

U.S. Transportation Sector Energy Use

Source: 

U.S. Energy Information Administration

Annual Energy Outlook 2014

 Heavy-duty vehicles 

responsible for about one 

fifth of the energy use and 

GHG emissions from 

transportation sources

 In terms of energy use, 

heavy-duty vehicles are also 

the fastest growing 

transportation sector in the 

U.S. and globally

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Key Differences from Light-Duty Vehicles

Heavy-duty vehicles used almost exclusively for commercial use

 Transporting freight is the most significant heavy-duty application category with respect to 

fuel consumption and GHG emissions

Heavy-duty vehicles are more expensive

 Many cost more than $100,000

 Up to $500,000 for specialty vehicles

Different manufacturers for most heavy-duty vehicles

 Some light-duty manufacturers also make heavy-duty pickups and vans

 One heavy-duty manufacturer makes only engines 

Most heavy-duty vehicles are built to custom specifications

 Few are sold as a standard configuration off of a dealer’s lot

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Phase 1 Highlights

Phase 1 standards began in 2014

 Fully phased-in by 2018

 Manufacturers expected to comply primarily with “off-the-shelf” technologies

 Very cost-effective technologies lead to fuel-savings greater than the technology cost

Phase 1 program for heavy-duty pickups and vans is similar to light-duty program

 Vehicle certification based on testing complete vehicle

Phase 1 program for other heavy-duty vehicles include:

 Engine certification based on EPA’s existing criteria pollutant test procedures

 Computer simulation certification of vehicle performance (without engine, transmission and axle) – instead of actual vehicle 

testing

Computer simulation is used to certify heavy-duty vehicle performance because:

 Heavy-duty vehicle size makes complete vehicle testing more difficult and expensive

 Custom-build aspect of heavy-duty market means thousands of different vehicle configurations – too many to actually test

 Vehicle simulation brings together the results from a smaller number of vehicle component tests (tires, aerodynamics, etc.)

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Early Input from the Market for Phase 1

7

“Class 8 Registrations Rise in 2014 to Highest Level in Eight Years”

Transport Topics, 2/20/15

“Daimler expects to sell more than 500,000 trucks this year [2015], mainly thanks to

growing demand in the United States, trucks chief Wolfgang Bernhard said ...” Reuters, 

2/23/2015

“.... consultancy FTR said that North American heavy-duty truck "net orders"—the 

number of new orders minus order cancellations—hit 45,795 units in October [2014] , 

the second-highest month of orders ever recorded. Added incentives to buy now, 

according to Larkin, include the soaring resale value of used trucks with three to four 

years of road time and the superior fuel efficiency of the newer engines, which can get 

as much as nine miles per gallon.” DC Velocity, 11/21/2014

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Proposed Phase 2 Program

Proposed Phase 2 standards would begin:

 In 2018 for EPA trailer standards, which were not regulated in Phase 1

 In 2021 for NHTSA trailer standards, and all other categories

(EISA requires NHTSA to issue standards with 4 years lead time)

Standards would be fully phased in by 2027

Proposed standards’ levels are based on:

 Nearly full use of most Phase 1 technologies – with additional optimization

 Significant use of emerging and advanced technologies by 2027

Also proposing improvements to computer simulation compliance procedures to better reflect 

new technologies, and inclusion of the engine and transmission in the vehicle standards 

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9

Phase 2 Proposed Flexibilities

Trailers One year delay in implementation for small businesses.

Trailer manufacturers may use pre-approved devices to avoid testing

Averaging program for manufacturers of dry and refrigerated box trailers

Flexibilities Carried Over from 

Phase 1 for Tractors, 

Vocational Vehicles and HD 

Pickups & Vans

ABT program which allows emissions and fuel consumption credits to be averaged, banked, or 

traded (five year credit life). Manufacturers allowed to carry-forward credit deficits for up to 

three model years.

Recognition of off-cycle technologies not accounted for by test procedures.

Tractors Same as Phase 1, except no extra credits for advanced technologies.

Vocational Vehicles

Same as Phase 1, except no advanced technology incentives. 

Chassis intended for emergency vehicles have proposed Phase 2 standards based only on Phase 

1 technologies, and may continue to certify using a simplified Phase 1-style GEM tool.

HD Pick-ups and Vans Stringency increases on year-over-year basis. 

No extra credits for advanced technologies.

Adjustment factor of 1.25 proposed for credits carried forward from Phase 1 to Phase 2 to 

account for proposed change in useful life. 

Engines in Tractors and 

Vocational Vehicles Same as Phase 1, except no advanced technology incentives. 

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Projected Reductions

2027 CO2/Fuel Consumption Reductions

(per new vehicle)

Tractors (includes engine reductions) 18-24%

Trailers 7-8%

Vocational Vehicles(includes engine reductions) 12-16%

Pick-ups & Vans 16%

 Technology-advancing standards that phase in through model year (MY) 2027

 Standards set in earlier MYs to ensure steady progress toward 2027 standards

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Summary* of Phase 2 Proposal GHG and Fuel 

Reductions, Costs and Benefits

11

Proposed Phase 2

MY 2018-2029

(in addition to Phase 1)*

Phase 1

MY 2014-2018

Fuel reductions (Billion Gallons) 70-77 22

GHG reductions (MMT CO2eq) 932-1036 270

Billions of 2012$ Billions of 2012$ 

Vehicle costs -$25 -$8

Fuel savings (pre-tax) $159-175 $50

GHG, non-GHG & other benefits $58-61 $10

Net benefits $192-211 $52

* Values shown in this table are representative values for 3% discount rate

Preamble and Draft Regulatory Impact Analysis present a range of estimates of costs and benefits to reflect different baselines, discount rates, and analytical methods.

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Per Vehicle Costs

12

Projected Average Cost Increase for 

MY 2027 Vehicle

(Relative to 2018 vehicles)

Tractors

$11,700

<12% cost increase

Trailers

$1,200

<5% cost increase

Vocational Vehicles $3,400

<5% cost increase

Pick-ups/Vans $1,300

<3% cost increase

Per Vehicle Cost and % Increase in Typical Vehicle Price*

*Assumed vehicle prices: $100,000+ for tractors, $25,000+ for trailers, $70,000+ for vocational 

vehicles and $40,000+ for HD pickups/vans

 Cost increase shown represents 

average 2027 vehicle vs. average

Phase 1 vehicle

 Because standards are essentially fleetaverage standards, vehicle market would 

still include a wide range of technology 

levels and cost impacts

 Phase-in standards for 2021 and 2024 

would lead to gradual introduction of new 

technology and gradual increase in costs

 Costs shown include engine costs

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Vehicle Payback for Proposed Standards

13

Tractors/Trailers 2

nd year

Vocational Vehicles 6

th year

Pick-ups/Vans 3

rd year

Payback Period for MY 2027 Vehicles

 Favorable paybacks 

 Purchasers will generally get what they pay for – bigger fuel 

savings for purchasers opting for more technology

 Customers that finance vehicles may see immediate payback 

where monthly fuel savings exceed increase in monthly 

payment

 Very quick paybacks for tractors, pick-ups and vans

 Vocational Vehicles

 Paybacks longer because of fewer miles travelled each year

 But vocational owners keep trucks longer – typically more 

accepting of longer payback periods

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Annual GHG Reductions, Phase 1 and 

Phase 2 Proposal

14

 600

 700

 800

 900

 1,000

 1,100

 1,200

2014 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

G

H

G (M

M

T

C

O

2

e

q)

Pre-Phase 1 Phase 1 Phase 2 - the Proposal

Phase 1 

Reduction

Phase 2 

Proposal 

Reduction

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Annual Fuel Reductions for the Phase 2 Proposal*

15

Phase 2 

Proposal 

Reduction

 30

 35

 40

 45

 50

 55

 60

 65

 70

 75

2014 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

Billio

n

G

allo

n

s (die

s

el e

q

uiv

ale

n

t)

Phase 1 Rule Phase 2 Proposal

* Based on the dynamic baseline and Method A

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Alternative Phase-In Schedule That Would Achieve 

Greater Reductions Sooner (Alternative 4)

 NPRM extensively highlights for comment an alternative phase-in of the 

proposed standards, two to three years earlier

 The agencies emphasize that if additional information becomes available 

supporting the alternative phase-in, the agencies may finalize some or all 

aspects of the alternative standards

 These alternative standards would achieve significant additional fuel 

consumption and GHG reductions, with associated incremental costs, 

shown on the next slides

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Summary* of Alternative Phase-In Schedule GHG 

and Fuel Reductions, Costs and Benefits

17

Proposed Phase 2

MY 2018-2029

Alternative 4

MY 2018-2029

Fuel reductions (Billion Gallons) 70-77 80-87

GHG reductions (MMT CO2eq) 932-1036 1056-1163

Billions of 2012$ Billions of 2012$ 

Vehicle costs -$25 -$33

Fuel savings (pre-tax) $159-175 $181-198

GHG, non-GHG & other benefits $58-61 $63-67

Net benefits $192-211 $211-232

* Values shown in this table are representative values for 3% discount rate

Preamble and Draft Regulatory Impact Analysis present a range of estimates of costs and benefits to reflect different baselines, discount rates, and analytical methods.

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Alternative Phase-In Schedule: 

Per Vehicle Costs and Vehicle Payback

18

Average 

Incremental 

Per Vehicle Cost ($)

Proposed

in MY2027

Alternative 4 

in MY2024/25 

*

Tractors $11,700 $12,400

Trailers $1,170 $1,230

Vocational $3,400 $3,600

Pickups/Vans $1,300 $1,700

Payback Period

Proposed

in MY2027

Alternative 4

in MY2024/25

Tractors/Trailers 2

nd year 2nd year

Vocational 6

th year 6th year

Pickups/Vans 3

rd year 4th year

Average Incremental Per Vehicle Cost ($) Payback Period

* The average incremental vehicle cost for Alternative 4 in MY 2027 would be more similar to the proposed 

alternative in MY 2027. 

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Other Issues

 Treatment of natural gas fueled vehicles (see Section XI of Preamble)

 Natural gas is a low-carbon and domestic fuel that has potential for increased use in heavy-duty vehicles

 High global warming potential of methane creates some risk of adverse climate consequences

 Largely proposing to maintain the neutral Phase 1 approach

 EPA is also proposing to require additional on-vehicle evaporative and refueling controls

 Regulatory technical amendments (see Sections XIII and XIV of Preamble)

 EPA and NHTSA are proposing minor technical amendments to motor vehicle programs – including minor clarifications to Phase 1 regulations

 EPA is also proposing minor technical amendments to nonroad engine regulations

 NHTSA is proposing to amend it’s reporting requirements for light-duty corporate average fuel economy to require only one electronic submission for 

pre-model, mid-model and supplemental reports 

 Small business impacts (see Section XV of Preamble)

 Affected small businesses include trailer manufacturers, alternative fuel converters, and specialty vehicle manufacturers

 Agencies proposing flexibility consistent with SBREFA Panel report

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Appendix

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Phase 1 Program

Alternative 3 - 2027 

(proposed standard)

Alternative 4 – 2024 (also 

under consideration)

Covered in this category Tractors that are designed to pull trailers and move freight.

Share of HDV fuel 

consumption and GHG 

emissions

Combination tractors and their engines account for approximately two thirds of fuel use and GHG emissions in the 

medium and heavy duty truck sector.

Per vehicle fuel consumption 

and CO2improvement 

10%-23% improvement over MY 2010 baseline, 

depending on tractor category. Improvements are in 

addition to improvements from engine standards.

18%-24% improvement over MY 2017 standards

Form of the standard EPA: CO2 grams/ton payload mile and NHTSA: gallons of fuel/1,000 ton payload mile

Example technology options 

available to help 

manufacturers meet 

standards 

Aerodynamic drag improvements; low rolling resistance 

tires; high strength steel and aluminum weight reduction; 

extended idle reduction; and speed limiters

Further technology improvements and increased use of all 

Phase 1 technologies, plus engine improvements, improved 

and automated transmissions and axles, powertrain 

optimization, tire inflation systems, and predictive cruise 

control (depending on tractor type)

Flexibilities ABT program which allows emissions and fuel 

consumption credits to be averaged, banked, or traded 

(five year credit life). Manufacturers allowed to carryforward credit deficits for up to three model 

years. Interim incentives for advanced technologies, 

recognition of innovative (off-cycle) technologies not 

accounted for by the HD Phase 1 test procedures, and 

credits for certifying early.

Same as Phase 1, except no extra credits for advanced 

technologies.

Summary of Phase 1 and Proposed Phase 2 Requirements for Class 7 and Class 8 

Combination Tractors

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Summary of Phase 1 and Proposed Phase 2 Requirements for Trailers

Phase 1 Program Alternative 3 - 2027 (proposed standard) Alternative 4 – 2024 (also under 

consideration)

Covered in this category Trailers hauled by low, mid, and high roof day and sleeper cab tractors, except those qualified as logging, mining, 

stationary or heavy-haul.

Share of HDV fuel 

consumption and GHG 

emissions

Trailers are modeled together with combination tractors and their engines. Together, they account for 

approximately two thirds of fuel use and GHG emissions in the medium and heavy duty truck sector.

Per vehicle fuel consumption 

and CO2improvement N/A

Between 3% and 8% improvement over MY 2017 baseline, depending on the trailer 

type.

Form of the standard

N/A EPA: CO2grams/ton payload mile and NHTSA: gallons /1,000 ton payload mile

Example technology options 

available to help 

manufacturers meet 

standards N/A

Low rolling resistance tires, automatic tire inflation systems, weight reduction for most 

trailers, aerodynamic improvements such as side and rear fairings, gap closing devices, 

and undercarriage treatment for box-type trailers (e.g., dry and refrigerated vans) 

Flexibilities

N/A

One year delay in implementation for small businesses, trailer manufacturers may use 

pre-approved devices to avoid testing, averaging program for manufacturers of dry and 

refrigerated box trailers

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Summary of Phase 1 and Proposed Phase 2 Requirements for Vocational Vehicles

Phase 1 Program

Alternative 3 - 2027 (proposed 

standard)

Alternative 4 – 2024 (also 

under consideration)

Covered in this category Class 2b – 8 chassis that are intended for vocational services such as delivery vehicles, emergency vehicles, dump truck, 

tow trucks, cement mixer, refuse trucks, etc., except those qualified as off-highway vehicles.

Because of sector diversity, vocational vehicle chassis are segmented into Light, Medium and Heavy Duty vehicle 

categories and for Phase 2 each of these segments are further subdivided using three duty cycles: Regional, Multipurpose, and Urban.

Share of HDV fuel 

consumption and GHG 

emissions

Vocational vehicles account for approximately 20 percent of fuel use and GHG emissions in the medium and heavy duty 

truck sector categories 

Per vehicle fuel consumption 

and CO2improvement

2% improvement over MY 2010 baseline.

Improvements are in addition to improvements 

from engine standards.

Up to 16% improvement over MY 2017 standards

Form of the standard EPA: CO2 grams/ton payload mile and NHTSA: gallons of fuel/1,000 ton payload mile 

Example technology options 

available to help 

manufacturers meet standards Low rolling resistance tires 

Further technology improvements and increased use of Phase 1 

technologies, plus improved engines, transmissions and axles, 

powertrain optimization, weight reduction, hybrids, and workday 

idle reduction systems.

Flexibilities

ABT program which allows emissions and fuel 

consumption credits to be averaged, banked, or 

traded (five year credit life). Manufacturers 

allowed to carry-forward credit deficits for up to 

three model years. Interim incentives for advanced 

technologies, recognition of innovative (off-cycle) 

technologies not accounted for by the HD Phase 1 

test procedures, and credits for certifying early.

Same as Phase 1, except no advanced technology incentives. 

Chassis intended for emergency vehicles have proposed Phase 2 

standards based only on Phase 1 technologies, and may continue 

to certify using a simplified Phase 1-style GEM tool.

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Summary of Phase 1 and Proposed Phase 2 Requirements for 

HD Pick-up Trucks and Vans

Phase 1 Program

Alternative 3 - 2027 

(proposed standard)

Alternative 4 – 2025 (also 

under consideration)

Covered in this category Class 2b and 3 complete pickup trucks and vans, including all work vans and 15-passenger vans but excluding 12-

passenger vans which are subject to light-duty standards.

Share of HDV fuel consumption 

and GHG emissions

HD pickups and vans account for approximately 15% of fuel use and GHG emissions in the medium and heavy duty truck 

sector.

Per vehicle fuel consumption 

and CO2improvement 

15% improvement over MY 2010 baseline for diesel vehicles, 

and 10% improvement for gasoline vehicles 16% improvement over MY 2018-2020 standards

Form of the standard Phase 1 standards are based upon a “work factor” attribute that combines truck payload and towing capabilities, with an 

added adjustment for 4-wheel drive vehicles. There are separate target curves for diesel-powered and gasoline-powered 

vehicles. As proposed, the Phase 2 standards would be based on the same approach.

Example technology options 

available to help manufacturers 

meet standards 

Engine improvements, transmission improvements, 

aerodynamic drag improvements, low rolling resistance tires, 

weight reduction, and improved accessories.

Further technology improvements and increased use of all 

Phase 1 technologies, plus engine stop-start, and 

powertrain hybridization (mild and strong).

Flexibilities

Two optional phase-in schedules; ABT program which allows 

emissions and fuel consumption credits to be averaged, 

banked, or traded (five year credit life). Manufacturers 

allowed to carry-forward credit deficits for up to three model 

years. Interim incentives for advanced technologies, 

recognition of innovative (off-cycle) technologies not 

accounted for by the HD Phase 1 test procedures, and credits 

for certifying early.

Proposed to be same as Phase 1, with phase-in schedule 

based on year-over-year increase in stringency. 

Adjustment factor of 1.25 proposed for credits carried 

forward from Phase 1 to Phase 2 due to proposed change 

in useful life. Proposed cessation of advanced technology 

incentives in 2021 and continuation of off-cycle credits.

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Summary of Phase 1 and Proposed Phase 2 Requirements for 

Engines in Tractors and Vocational Vehicles

Phase 1 Program

Alternative 3 - 2027 (proposed 

standard)

Alternative 4 – 2024 (also under 

consideration)

Covered in this category Engines installed in tractors and vocational chassis.

Share of HDV fuel consumption 

and GHG emissions

Combination tractors and vocational vehicles account for approximately 85 percent of fuel use and GHG emissions in the 

medium and heavy duty truck sector.

Per vehicle fuel consumption 

and CO2improvement 

5%-9% improvement over MY 2010 baseline, 

depending vehicle application. Improvements are in 

addition to improvements from tractor and 

vocational vehicle standards.

4% improvement over MY 2017 for diesel engines. Note that 

improvements are captured in complete vehicle tractor and 

vocational vehicle standards, so that engine improvements and the 

vehicle improvement shown below are not additive.

Form of the standard EPA: CO2 grams/horsepower-hour and NHTSA: gallons of fuel/horsepower-hour

Example technology options 

available to help 

manufacturers meet standards 

Combustion, air handling, friction and emissions 

after-treatment technology improvements

Further technology improvements and increased use of all Phase 1 

technologies, plus waste heat recovery systems for tractor engines 

(e.g., turbo-compound and Rankine-cycle)

Flexibilities

ABT program which allows emissions and fuel 

consumption credits to be averaged, banked, or 

traded (five year credit life). Manufacturers allowed 

to carry-forward credit deficits for up to three model 

years. Interim incentives for advanced technologies, 

recognition of innovative (off-cycle) technologies not 

accounted for by the HD Phase 1 test procedures, 

and credits for certifying early.

Same as Phase 1, except no advanced technology incentives. 

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