*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-1

CHAPTER: 5 Emissions Impacts

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

RIA_20110722_Ch 05 Emissions Inventory.docx

5.1 Executive Summary

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

environment. According to the Intergovernmental Panel on Climate Change, anthropogenic 

emissions of greenhouse gases (GHG) are very likely (90 to 99 percent probability) the cause of 

most of the observed global warming over the last 50 years. The primary GHGs of concern are 

carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur 

hexafluoride.1 Mobile sources emitted 31 percent of all U.S. GHG in 2007 (transportation 

sources, which do not include certain off-highway sources, account for 28 percent) and have 

been the fastest-growing source of U.S. GHG since 1990.2 Mobile sources addressed in the 

recent endangerment finding under CAA section 202(a)--light-duty vehicles, heavy-duty trucks, 

buses, and motorcycles--accounted for 23 percent of all U.S. GHG in 2007.3 Heavy-duty

vehicles emit CO2, methane, nitrous oxide, and hydrofluorocarbons and are responsible for 

nearly 19 percent of all mobile source GHGs (nearly 6% of all U.S. GHGs) and about 25 percent 

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

represented more than 99 percent of all GHG emissions (including HFCs).

2

This final action estimates anticipated impacts from the EPA vehicle CO2 emission 

standards. The emissions from the GHGs carbon dioxide (CO2), methane (CH4), nitrous oxide 

(N2O) and hydrofluorocarbons (HFCs) were quantified. In addition to reducing the emissions of 

greenhouse gases, this program would also influence the emissions of “criteria” air pollutants, 

including carbon monoxide (CO), fine particulate matter (PM2.5) and sulfur dioxide (SOX) and 

the ozone precursors hydrocarbons (VOC) and oxides of nitrogen (NOX); and several air toxics 

(including benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and acrolein).

Downstream (tailpipe) emission impacts were developed using EPA’s Motor Vehicle 

Emission Simulator (MOVES2010). Upstream (fuel production and distribution) emission 

changes resulting from the decreased fuel consumption predicted by the downstream models 

were calculated using a spreadsheet model based on emission factors from GREET.4 Based on 

these analyses, this program would lead to 76 million metric tons (MMT) of CO2 equivalent 

(CO2EQ) of annual GHG reduction and 6.0 billion gallons of fuel savings in the year 2030.

The non-GHG impacts of the final rulemaking are driven by the increased use of auxiliary 

power units (APUs) and reduced emissions from upstream fuel production and distribution. 

Emissions of certain pollutants are further reduced through improved aerodynamics and tire 

rolling resistance. To a much smaller extent, rebound of vehicle miles traveled (VMT) increases 

emissions of all pollutants proportional to the VMT rebound amount. Table 5-1 summarizes 

these non-GHG emissions impacts from the heavy-duty sector.
Regulatory Impact Analysis 

5-2

Table 5-1 Impacts of Program on Heavy-Duty Non-GHG Emissions (Short Tons per year)

POLLUTANT

CALENDAR 

YEAR 2030

CHANGE VS. 

2030 BASELINE

Δ 1,3-Butadiene -0.5 -0.1%

Δ Acetaldehyde -1,912 -40.2%

Δ Acrolein -263 -40.0%

Δ Benzene -359 -15.0%

Δ Carbon Monoxide -55,579 -2.1%

Δ Formaldehyde -6,282 -46.2%

Δ Oxides of Nitrogen -245,129 -21.0%

Δ Particulate Matter 

(below 2.5 micrometers) 356 1.1%

Δ Oxides of Sulfur -6,888 -10.1%

Δ Volatile Organic Compounds -29,932 -16.0%

5.2 Introduction

5.2.1 Scope of Analysis

The standards affect both diesel- and gasoline-fueled heavy-duty vehicles. This analysis 

accounts for the direct downstream/tailpipe reduction of GHG as well upstream (fuel production 

and distribution) reductions of GHGs and non-GHGs. Total GHG impacts will also be 

determined by any VMT rebound effects, changes in fleet turnover, and changes in fuel 

consumption globally due to reduced petroleum prices. See Chapter 9 for a further discussion of 

these aspects of the analysis. The agencies also expect this program to impact downstream and 

upstream emissions of non-GHG air pollutants. 

Emissions estimates for the four greenhouse gases carbon dioxide (CO2), methane (CH4), 

nitrous oxide (N2O), and hydrofluorocarbons (HFC) are presented herein. Inventories for the 

non-GHG pollutants 1,3-butadiene, acetaldehyde, acrolein, benzene, carbon monoxide (CO), 

formaldehyde, oxides of nitrogen (NOX), particulate matter below 2.5 micrometers (PM2.5), 

oxides of sulfur (SOX), and volatile organic compounds (VOC) are also presented.

5.2.2 Downstream Contributions

The largest source of GHG and other air pollutant reductions from this program is from 

tailpipe emissions produced during vehicle operation. Absolute reductions from tailpipe 

emissions are projected to grow over time as the fleet turns over to vehicles affected by the 

standards, meaning the benefit of the program will continue to grow as long as the older vehicles 

in the fleet are replaced by newer, lower CO2-emitting vehicles.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-3

As described herein, the downstream reductions in emissions due to the program are 

anticipated to be achieved through improvements in engine efficiency, road load reduction, and 

APU use during extended idling.

Changes in downstream GHG and other emissions at the fleet level will be affected by 

whether the regulations affect the timing of fleet turnover and total VMT, as discussed in Section 

VIII of the preamble. If the regulations spur firms to increase their purchase of new vehicles 

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

standards are in place to avoid higher costs, then there will be a delay in achieving the full GHG 

and other emission reductions from improved fuel economy across the fleet. If the lower permile costs associated with higher fuel economy lead to an increase in VMT (the “rebound 

effect”), then total emission reductions will also be reduced. Chapter 9 of this RIA provides 

more detail on how the rebound effect is calculated in EPA’s analysis. The analysis discussed in 

this chapter incorporates the rebound effect into the estimates, though fleet turnover impacts are 

not estimated. 

In addition, the agencies also recognize that this regulation would lower the world price 

of oil (the “monopsony” effect, further discussed in Chapter 9 of the RIA). Lowering oil prices 

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

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

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

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

and GHG emissions in this RIA. 

5.2.3 Upstream Contributions

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

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

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

Changes are anticipated in upstream emissions due to the expected reduction in the volume of 

fuel consumed. Less fuel consumed means less fuel transported, less fuel refined, and less crude 

oil extracted and transported to refineries. Thus, there should be reductions in the emissions 

associated with each of these steps in the fuel production and distribution process. Any changes 

in downstream reductions associated with changes in fleet turnover, VMT, and global petroleum 

consumption should be reflected in a corresponding change in upstream emissions associated 

with petroleum processing and distribution.

5.2.4 Global Warming Potentials

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

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

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

abilities into a single inventory (Table 5-2). When expressed in CO2 EQ terms, each gas is 

weighted by its heat trapping ability relative to that of carbon dioxide. The GWPs used in this 
Regulatory Impact Analysis 

5-4

chapter are drawn from publications by the Intergovernmental Panel on Climate Change 

(IPCC).5

The global warming potentials (GWP) used in this analysis are consistent with the 2007 

Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (AR4). At this 

time, the 1996 IPCC Second Assessment Report (SAR) global warming potential values have 

been agreed upon as the official U.S. framework for addressing climate change and are used in

the official U.S. greenhouse gas inventory submission to the United Nations climate change 

framework. This is consistent with the use of the SAR global warming potential values in 

current international agreements. 

Table 5-2 Global Warming Potentials for the Inventory GHGs

GAS GLOBAL WARMING 

POTENTIAL

(CO2 Equivalent)

CO2 1

CH4 25

N2O 298

HFC 1,430

5.3 Program Analysis and Modeling Methods

5.3.1 Models Used

The Motor Vehicle Emissions Simulator, more commonly called MOVES, EPA’s official 

mobile source emission inventory model, was the primary tool used to calculate downstream 

emissions inventories.

6

 The MOVES2010a version was used along with an internal 2010-

October-6 default database. Some post-processing was done to MOVES output to ensure proper 

calculation of emissions inventories for each alternative.

This program affects heavy-duty vehicles. In MOVES, which categorizes vehicle types 

by their use, these vehicle types are represented by combination tractors, single unit tractors, 

refuse trucks, motor homes, transit buses, intercity buses, school buses, and light commercial 

trucks. Changes made to the default MOVES data for the baseline and the control case are 

described below in Section 5.3.2. All the input data and MOVES run spec files can be found in 

the docket.7

Upstream emissions were calculated using the same tools as were used for the Renewable 

Fuel Standard 2 (RFS2) rule analysis.

8

The estimate of emissions associated with production of 

gasoline and diesel from crude oil is based on emission factors in the “Greenhouse Gases, 

Regulated Emissions, and Energy Use in Transportation” model (GREET) developed by DOE's 

Argonne National Lab, and are consistent with those used for the Light-Duty Greenhouse Gas 

rulemaking.

4,9

The actual calculation of the emission inventory impacts of the decreased 

gasoline production is done in EPA's spreadsheet model for upstream emission impacts. This 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-5

model uses the decreased volumes of the crude based fuels and the various crude production and

transport emission factors from GREET to estimate the net emissions impact of fuel use changes. 

As just noted, the analysis for this rulemaking assumes that all changes in volumes of fuel used 

affect only gasoline and diesel, with no effects on use of ethanol, or other renewable fuels.

5.3.2 Calculation of Downstream Emissions

5.3.2.1 Baseline (reference case)

The baseline, or reference case, assumes no action and assumes constant 2010 model year 

performance of the HD fleet, as described in RIA Chapter 2. Since MOVES2010a vehicle sales 

and VMT inputs were developed from AEO2009, EPA first updated these data using relative 

sales and activity growth projections from AEO2011.

10

 The tables that were modified and 

included as user input tables for the baseline run were sourcetypeyear and hpmsvtypeyear. For 

HD pickups and vans, the agency updated sales projections for model years 2011 through 2018 

using forecasts purchased from CSM Worldwide for the light-duty greenhouse gas rule.11 This 

update was done through modifying the base population, along with the sales growth factors for 

model years 2011 through 2018, in the sourcetypeyear table. The sales growth factors for the 

other model years were updated from AEO2011, as mentioned above. Also, extended idling PM 

rates were updated to match aged curb idling PM rates, a correction needed from the default 

emission rates. MOVES2010a defaults, including all other emission rates, were used for all 

other parameters to estimate the baseline emissions inventories. For combination tractors and 

vocational vehicles, the aerodynamic drag and tire rolling resistance coefficients were the default 

MOVES values that represent a fleet-wide average rolling resistance and aerodynamic drag (for 

each MOVES source/vehicle type), which assumes only a low level of adoption, if any, of low 

rolling resistance tires and advanced aerodynamic features. It also assumes that these fleet-wide

coefficients do not change with future model years or by age.

For extended idling emission inventories, MOVES defaults were post-processed to 

account for increased use of auxiliary power units (APUs) for model year 2010 and later, which 

is not assumed in default MOVES. For all alternatives, the agencies assumed that about 30 

percent of all combination long-haul tractors between model years 2010 through 2013 use an 

APU during extended idling. For alternatives where combination long-haul tractors are 

regulated, the agencies assumed that 100 percent of those trucks model year 2014 and later use 

APUs during extended idling. This assumption is based on the expectation that manufacturers 

will use APUs to meet the vehicle GHG standard for combination long-haul tractors. For 

alternatives where combination long-haul tractors are not regulated, the agencies assumed that 30 

percent of those trucks model year 2014 and later use APUs during extended idling. A diesel 

fuel consumption rate of 0.2 gallons per hour for APUs and a factor 10.180 kg CO2 per gallon 

diesel were assumed. EPA also considered that diesel APUs are regulated as non-road small 

engines for criteria (non-GHG) pollutants. Assuming that these APUs emit criteria pollutants at 

the EPA standard, Table 5-3 shows the emission rate of APUs, given an extended idle load 

demand of 4.5 kW (6 hp).12 For SO2, which is not regulated through engines, but rather through 

fuel, the agency assumed a diesel fuel sulfur level of 15 ppm and a diesel fuel density of 6.9 
Regulatory Impact Analysis 

5-6

lb/gal. Total extended idle emissions were calculated by multiplying by the number of extended 

idle hours by the emission rates in Table 5-3.

Table 5-3 Estimated Emission Rates of non-GHG Pollutants from APUs

POLLUTANT EMISSION RATE [g/hr]

CO 36

NOX 26.88a

VOC 6.72a

PM 1.8

SO2 0.0188

CH4 0.0202b

Note: 

aNOX rate was estimated to be 80%, and NMHC 20% of the total NOX+NMHC rate (33.6

g/hr), based on the 2004 model year heavy-duty engine standard.13 VOC was estimated to 

be equal to NMHC for this analysis. 

bExtended idle methane (CH4) emissions are assumed to be 0.3% of VOC emissions, based 

on existing MOVES methane-to-THC fractions for pre-DPF-equipped diesel engines.

5.3.2.2 Control Case

This case represents the final standard levels. The sales and VMT updates implemented 

in the baseline were also used in all the alternatives, including the control case, since the sales 

projections are projected for all future scenarios and are not affected by this program. To 

account for improvements of engine and vehicle efficiency, EPA developed several user inputs 

to run the alternatives in MOVES. Since MOVES does not calculate emissions based on engine 

Federal Test Procedure (FTP) cycle results, EPA used the percent reduction in engine CO2

emissions expected from the program to develop energy inputs for the control case runs. Also, 

EPA used the percent reduction in aerodynamic drag coefficient and tire rolling resistance 

coefficient expected from each alternative to develop road load inputs. Runs were postprocessed to calculate air toxics inventories for diesel vehicles and emissions and fuel 

consumption from APUs. 

5.3.2.2.1 Emission Rate and Road Load Inputs

The form of the fuel consumption and CO2 emissions standards varies by regulatory

category. Heavy-duty engine standards are in terms of grams of CO2 per brake horsepower-hour 

and gallons of fuel per 100 brake horsepower per hour. The form of the combination tractor and 

vocational vehicles is gallons per 1000 ton-mile and grams of CO2 per ton-mile. For the 

vocational vehicles and combination tractors, the agencies have analyzed the impacts of the 

standards by evaluating the technologies applied to the engines and vehicles separately. 

Table 5-4 describes the improvements expected from the HD engine technologies which may be applied to 

meet the standards. These values remain unchanged between proposal and final rule because no changes 

have been made to the HD engine CO2 and fuel consumption standards. The reductions from the baseline 

were applied to the appropriate source bins in the MOVES emissionrate table. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-7

Table 5-5 contains the combination long-haul tractor and vocational vehicle tire rolling 

resistance, coefficient of drag, and weight reductions expected from the technologies which 

could be used to meet the standards. The levels of reduction in the final rule are greater for the 

long-haul combination tractors’ rolling resistance and Cd due to the refined methodology of 

aggregating the three roof heights of sleeper cabs. In the NPRM, the agencies assumed that 

manufacturers sold equal number of sleeper cabs with low, mid, and high roof heights. For the 

final rule, the agencies obtained sales distribution data from the manufacturers and attributed the 

reductions based on a sales mix assumption of 80 percent high roof, 15 percent mid roof, and 5 

percent low roof sleeper cabs. The table also reflects the reduction in weight assumed in setting 

the final standards which was not evaluated in the NPRM. The value in the table reflects a 400 

pound mass reduction. The short-haul combination tractors in the NPRM were evaluated using a 

day cab sales distribution assumption of equal number of each subcategory. For the final rule, 

the agencies used a sales mix of 10 percent Class 7 low roof, 10 percent Class 7 high roof, 45 

percent Class 8 low roof, and 35 percent Class 8 high roof based on feedback from the 

manufacturers. The short-haul values in the table reflect a modeling assumption that 8 percent of 

all tractors would be considered vocational tractors and therefore will only be required to meet 

the vocational vehicle standards and not show any aerodynamic or weight improvement. The 

vocational tractor population (assumed to be 9,773 vehicles in 2014 based on confidential sales 

information shared by a truck manufacturer) was applied entirely to short-haul tractor population 

which represents 19.7 percent of short-haul tractor population. The weight reduction applied to 

short-haul tractors is 321 pounds which is calculated from a 400 pound weight reduction reduced 

by 19.7 percent. The rolling resistance level in the NPRM was assumed to be reduced by 10 

percent due to the proposed vocational vehicle standards. However, the tire rolling resistance 

reduction in the final rule is assumed to be 5 percent based on the data derived in the tire testing 

program conducted by EPA. The reductions from the baseline summarized in Table 5-5 were 

applied to the corresponding source types in the MOVES sourceusetype table.

Table 5-4 Estimated Reductions in Engine CO2 Emission Rates from this Program

GVWR CLASS FUEL MODEL 

YEARS

CO2 REDUCTION 

FROM BASELINE

HHD (8a-8b) Diesel 2014-2016 3%

2017+ 6%

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

2017+ 9%

Gasoline 2016+ 5%
Regulatory Impact Analysis 

5-8

Table 5-5 Estimated Reductions in Rolling Resistance and Aerodynamic Drag Coefficients from Reference 

Case for Alternative 3 (Model Years 2014 and Later)

TRUCK TYPE REDUCTION IN TIRE 

ROLLING RESISTANCE 

COEFFICIENT FROM 

BASELINE

REDUCTION IN 

AERODYNAMIC 

DRAG COEFFICIENT 

FROM BASELINE

WEIGHT 

REDUCTION 

(LBS.)

Combination long-haul 9.6% 12.1% 400

Combination short-haul 7.0% 5.9% 321

Vocational vehicles

(Single-unit trucks, 

refuse trucks, motor 

homes, buses, and light 

commercial trucks) 

5.0% 0% 0

The HD pickup truck standards are evaluated in terms of grams of CO2 per mile or 

gallons of fuel per 100 miles. Since nearly all HD pickup trucks and vans will be certified on a 

chassis dynamometer, the CO2 reductions for these vehicles will not be represented as engine 

and road load reduction components, but total vehicle CO2 reductions. Table 5-6 describes the 

estimated expected changes in engine and vehicle technologies from this final rulemaking, which 

were input into MOVES for estimating control case emissions inventories. Table 5-6 remains 

unchanged between proposal and final rule because no changes have been made to the HD 

pickup truck and van CO2 and fuel consumption standards.

Table 5-6 Estimated Total Vehicle CO2 Reductions for HD Pickup Trucks and Vans

GVWR 

CLASS

FUEL MODEL 

YEARS

CO2 REDUCTION 

FROM BASELINE

LHD 2b-3 Gasoline 2014 1.5%

2015 2%

2016 4%

2017 6%

2018+ 10%

Diesel 2014 2.3%

2015 3%

2016 6%

2017 9%

2018+ 15%

Engine CO2 reductions (

Table 5-4) and HD pickup/van total vehicle CO2 reductions (Table 5-6) were modified in 

the emissionrate table in MOVES. The percentage reductions were applied to the default energy

rates. The improvements in tire rolling resistance and drag coefficient were modified in the 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-9

sourceusetype table. The percentage reductions were applied to the road load coefficients. It 

was assumed that 100 percent of Class 7/8 combination long-haul tractors model year 2014 and 

later use APUs during extended idling. Emissions from APUs in the control case were 

calculated in the same way as the baseline (see Table 5-3)

5.3.2.2.2 VMT Inputs

The HPMSVtype table was modified to reflect VMT rebound. This table contains VMT 

growth factors from one calendar year to the next, starting from an absolute VMT estimate for

calendar year 1999. For the control case, we increased the HD pickup/van absolute VMT by 

1.18%, the vocational vehicle absolute VMT by 1.33%, and the combination tractor absolute

VMT by 0.50% from baseline levels, based on the analysis in RIA Section 9.2. Since VMT 

growth is by calendar year and not model year, to ensure that only model years affected by the 

program experienced VMT rebound, the results from the baseline run were used in the control 

case inventories for model years prior to the rules’ implementation.

5.3.2.2.3 Diesel Air Toxics Calculations

The composition of VOCs for heavy-duty diesel engines without model year 2007 and 

later emission controls versus those engines with such controls vary significantly. Thus, EPA 

developed one set of toxic to VOC ratios for pre-2007 diesel engines and another set for 2007 

and later engines. Since light-duty diesels comprise a very small portion of the fleet, the same 

ratios were applied to all diesel vehicle classes to streamline modeling. 

EPA relied on a database compiled for the Coordinating Research Council (CRC E-75) 

and National Renewable Energy Laboratory (NREL) to develop toxic to VOC ratios for pre2007 model year engines.14

 This database was developed from a literature survey and included 

data from 13 different studies. The studies included in this database were conducted in a number 

of different countries, included heavy-duty and light-duty engines, a variety of diesel and 

biodiesel fuels, and a number of different operating modes and cycles. The methodology they 

used to develop ratios is described in detail in their technical report. Data from tests using nonconventional diesel fuel (Fischer-Tropsch, bioDiesel, ethanol-Diesel blends, emulsified fuel, 

European blends, and other obvious research fuels) were excluded, as were data from non-heavyduty engines. 

Toxic-to-VOC ratios for benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and 

acrolein were developed by EPA from the CRC E-75 database. EPA relied on United States data 

from heavy-duty diesel engines running on conventional diesel fuels, collected on test cycles 

representative of real world operation. Some studies measured emissions over distance, while 

other studies measure emissions relative to engine work. For studies which measured emissions 

relative to distance, we calculated mean emissions per mile for toxics and VOC, then calculated 

a ratio of toxics to VOC. For studies which measured emissions relative to engine work, we 

calculated mean emissions per brake horsepower hour for toxics and VOC, then calculated a 

second ratio of toxics to VOC. We then calculated a composite ratio using sample size to weight 

the two ratios. The resulting ratios are provided in Table 5-7.
Regulatory Impact Analysis 

5-10

For model year 2007 and later heavy-duty diesels, advanced emission controls change the 

composition of VOCs. For these engines, we relied on speciated emissions data from the 

Advanced Collaborative Emissions Study (ACES), directed by the Health Effects Institute and 

Coordinating Research Council, with participation from a range of government and private 

sector sponsors.15 Detailed emissions data from the study were provided to EPA at the request of 

the Coordinating Research Council. The data were collected on four engines on several test 

cycles with low sulfur diesel fuel. EPA used data from a 16-hour transient cycle. Toxic to VOC 

ratios obtained from the ACES data are provided in Table 5-7. Because diesel VOC estimates 

had not been updated in MOVES for model year 2007 and later heavy-duty diesel trucks, these 

data were also used to determine a VOC-to-total hydrocarbon (THC) ratio for those trucks. This 

ratio of 0.5327 was used in conjunction with the MOVES results for THC to estimate VOC 

emissions from model year 2007 and later heavy-duty diesel trucks.

All model year APUs were treated like pre-2007 engines with respect to toxics 

calculations because APUs are not equipped with the emission controls technology of model 

year 2007 and later engines.

Table 5-7 Air Toxics Ratios Post-Processed Against Hydrocarbon Results from MOVES

MODEL YEARS POLLUTANT RATIO to VOC

Pre-2007 engines 

and all model year 

APUs

Benzene 0.0078

1,3-butadiene 0.0029

Formaldehyde 0.0782

Acetaldehyde 0.0356

Acrolein 0.0066

2007 and later 

engines

Benzene 0.0129

1,3-butadiene 0.0008

Formaldehyde 0.2174

Acetaldehyde 0.0693

Acrolein 0.0100

5.3.3 Calculation of Upstream Emissions

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

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

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

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

impacts presented here can be found in the Technical Support Document and the docket memo, 

“Calculation of Upstream Emissions for the GHG Vehicle Rule,” initially created for use in the 

Light-Duty Greenhouse Gas rulemaking.16 

The agencies recognize the unique GHG emission characteristics associated with 

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

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

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

of individual biofuels can vary significantly from both petroleum-based fuels and from one 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-11

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

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

aggregate lifecycle emissions including non-tailpipe GHG emissions (such as feedstock growth,

transportation, fuel production, and land use), lifecycle GHG emissions in 2022 for biodiesel 

from soy, using certain advanced production technologies, are about 50 percent less than diesel 

from petroleum. 

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

the agencies will need to consider the unique emission characteristics associated with biofuels. 

More broadly, the agencies recognize that biofuels, including biodiesel, will play an important 

role in reducing the nation’s dependence on foreign oil, thereby increasing domestic energy

security.

The results of the upstream analysis are shown in Table 5-10 and Table 5-12.

5.3.4 Calculation of HFC EmissionsA

EPA is finalizing as proposed air conditioning (AC) leakage standards for HD pickup 

trucks and vans and combination tractors to reduce HFC emissions. The Vintaging Model, 

developed by the EPA Office of Atmospheric programs, produces HFC inventories for several 

categories of stationary and mobiles sources. However, it does not include air conditioning 

systems in medium and heavy duty trucks within its inventory calculations. For this rulemaking, 

we conducted an analysis based on the inputs to the Vintaging Model and the inputs to the 

MOVES analysis discussed in Chapter 5.3.2.1 above. 

The general equation for calculating HFC emissions follows:

HFC emissionsYear x = AC SystemsYear x x Average Charge Size x HFC loss rate 

We determined the number of functioning AC systems in each year based on the 

projected sales of vehicles, the fraction of vehicles with AC systems, and the average lifetime of 

an air conditioning system. Sales were drawn from the MOVES analysis and we assumed that 

every vehicle had a functioning AC system when sold based on feedback received from truck 

manufacturers. The Vintaging Model assumes that all light duty passenger vehicle AC systems 

(in the U.S.) last exactly 12 years.17 For lack of better information, we assumed that heavy duty 

vehicles AC systems last for the same period of time as light duty vehicles. Light, medium and 

heavy duty vehicles use largely the same components in their air conditioning systems, which 

would indicate similar periods of durability. 

 

A The U.S. has submitted a proposal to the Montreal Protocol which, if adopted, would phasedown production and 

consumption of HFCs.
Regulatory Impact Analysis 

5-12

The charge size was determined using the Minnesota refrigerant leakage database.18 EPA 

sorted the data based on AC charge size and evaluated only the largest 25 percent of AC systems. 

The average charge size is 1,025 grams of refrigerant.

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

rate in the Vintaging Model was applicable to the current analysis, as shown in Table 5-8. The 

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

Although vehicle AC systems are serviced during discrete events and not usually every year, 

emissions from those events are averaged over the lifetime of the AC system in the Vintaging 

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

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

Table 5-8 Annual In-use Vehicle HFC134a Emission Rate from Vintaging Model

KIND OF LOSS LOSS FRACTION

Leakage 8%

Maintenance /Servicing 10%

End of Life 43%

Of note, the Vintaging Model assumes that charge loss is replaced every year; i.e.,

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

constant rate of 180 grams per year. While this loss rate is not accurate for any single vehicle, it 

is assumed accurate for the fleet as a whole. While other emissions, such as fugitive emissions at 

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

emissions are accounted for within the average annual loss rate. 

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

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

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

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

does not take credit for these emission reductions. EPA requested better information on HFC 

leakage rates in modern vehicles, with a particular emphasis on in-use vehicles, in the proposal, 

but did not receive any comments. 

Based on the MN 2010 database, we determined that it is possible to reduce the HFC 

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

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

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

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

We then applied the 13 percent reduction to the baseline 18 percent leakage rate to develop a

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

rate which should be credited to this rulemaking.

19

 

B The U.S. EPA has reclamation requirements for refrigerants in place under Title VI of the Clean Air Act.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-13

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

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

technology has been applied to 100 percent of the new HD pickup trucks and vans and Class 7/8 

tractors starting in 2014 model year, as required by the final standards. 

Total HFC reductions are 305 metric tons over the MY 2010 baseline AC system in 2030 

and 417 metric tons in 2050. This is equivalent to a reduction of 122,338 metric tons of CO2eq

in 2018; 436,483 metric tons of CO2eq emissions in 2030; and 596,396 metric tons CO2eq in 

2050.20 The difference in the emissions reductions between the final rules and the proposal are 

due to changes in HD pickup truck and van and tractors sales projections, as detailed in above in 

Chapter 5.3.2.1.

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

in heavy-duty vehicles to California Air Resources Board.21 ERG delivered a presentation of the 

results during a CARB workshop held on January 6, 2011. The study included a total of 70 

medium- and heavy-duty vehicles and off-road equipment, of which18 of the samples were HD 

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

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

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

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

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

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

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

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

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

our estimates for HFC reductions may understate the benefits of the program we are finalizing 

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

future.

5.4 Greenhouse Gas Emission Impacts

After all the MOVES runs and post-processing was completed, baseline and control case 

inventories were totaled for all vehicle types and emission processes to estimate total 

downstream GHG impacts of the program. Table 5-9 summarizes these downstream GHG 

impacts and fuel savings from baseline to control case for calendar year 2030. All emissions 

impacts reflect the heavy-duty sector only, and do not include emissions from light-duty vehicles 

or any other vehicle sector.

Table 5-9 Downstream GHG Impacts in 2030

POLLUTANT

CALENDAR 

YEAR 2030

% CHANGE vs.

2030 BASELINE

Δ CO2 (metric tons) -60,710,570 -10.1%

Δ CH4 (metric tons CO2EQ) -785,449 -53.8%

Δ N2O (metric tons CO2EQ) 2,851 0.4%
Regulatory Impact Analysis 

5-14

Δ HFC (metric tons CO2EQ) -436,483 -13%

Δ Total CO2EQ (metric tons) -61,929,651 -10.3%

Δ Gasoline Fuel (billion 

gallons) -0.349 -6.5%

Δ Diesel Fuel (billion gallons) -5.67 -10.4%

Table 5-10 summarizes the upstream GHG impacts in 2030. The reductions in GHGs are 

proportional to the amount of fuel saved.

Table 5-10 Upstream GHG Impacts in 2030

POLLUTANT

CALENDAR 

YEAR 2030

% CHANGE vs.

2030 BASELINE

CO2 (metric tons) -12,241,470 -10.2%

CH4 (metric tons CO2EQ) -1,888,769 -10.2%

N2O (metric tons CO2EQ) -59,100 -10.2%

Total CO2EQ (metric tons) -14,189,339 -10.2%

5.5 Non-Greenhouse Gas Emission Impacts

After all the MOVES runs and post-processing were completed, baseline and control case 

inventories were aggregated for all vehicle types and emission processes to estimate total 

downstream non-GHG impacts of the program. Table 5-11 summarizes these downstream nonGHG impacts for calendar year 2030. The non-GHG impacts of the program are driven by the 

increased use of APUs and, for certain pollutants, improved aerodynamics and tire rolling 

resistance. Use of APUs increases PM2.5 downstream inventories compared to the baseline case 

because APUs are not required to be equipped with diesel particulate filters, like the on-road 

engines are for model year 2007 and later. To a much smaller extent, VMT rebound increases 

emissions of all pollutants proportional to the VMT rebound amount.

Table 5-11 Downstream impacts for key non-GHG pollutants (Short tons)

POLLUTANT

CALENDAR 

YEAR 2030

% CHANGE vs. 

2030 BASELINE

Δ 1,3-Butadiene 0.4 0.1%

Δ Acetaldehyde -1,908 -40.5%

Δ Acrolein -263 -40.2%

Δ Benzene -341 -15.5%

Δ Carbon Monoxide -52,299 -2.0%

Δ Formaldehyde -6,255 -46.9%

Δ Oxides of Nitrogen -235,052 -22.0%

Δ Particulate Matter 

(below 2.5 micrometers)

1,751 8.4%

Δ Oxides of Sulfur -423 -8.7%

Δ Volatile Organic Compounds -25,502 -19.1%
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-15

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

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

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

in the analysis year and the emission factors associated with each process or subprocess. In 

general this life cycle analysis uses the same methodology as the Renewable Fuel Standard 

(RFS2) rule. It relies partially on the GREET model, developed by the Department of Energy’s 

Argonne National Laboratory (ANL), but takes advantage of additional information and models 

to significantly strengthen and expand on the GREET analysis. 

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

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

modeling, such as the Tier 4 diesel truck standards published in 2001 and the locomotive and 

commercial marine standards finalized in 200822. In addition, GREET does not include air 

toxics. Thus emission factors for the following air toxics were added: benzene, 1,3-butadiene, 

formaldehyde, acetaldehyde, and acrolein. These upstream toxics emission factors were 

calculated from the 2002 National Emissions Inventory (NEI), a risk and technology review for 

petroleum refineries, speciated emission profiles in EPA's SPECIATE database, or the Mobile 

Source Air Toxics rule (MSAT) inventory for benzene; these pollutant tons were divided by

refinery energy use or gasoline distribution quantities published by the DOE Energy Information 

Administration (EIA) to get emission factors in terms of grams per million BTU of finished 

gasoline and diesel. 

Results of these emission inventory impact calculations relative to the baseline for 2030 

are shown in Table 5-12 for the criteria pollutants and individual air toxic pollutants. 

The program is projected to provide reductions in all pollutants associated with gasoline 

production and distribution as the projected fuel savings reduce the quantity of gasoline needed.

Table 5-12 Upstream Impacts for Key non-GHG Pollutants (Short Tons)

POLLUTANT

CALENDAR YEAR

2030

% CHANGE vs.

2030 BASELINE

Δ 1,3-Butadiene -0.9 -10.1%

Δ Acetaldehyde -3 -10.1%

Δ Acrolein -0.5 -10.1%

Δ Benzene -19 -9.3%

Δ Carbon Monoxide -3,331 -10.1%

Δ Formaldehyde -26 -10.1%

Δ Oxides of Nitrogen -9,975 -10.1%

Δ Particulate Matter 

(below 2.5 micrometers)

-1,379 -10.1%

Δ Oxides of Sulfur -6,395 -10.1%

Δ Volatile Organic Compounds -4,367 -8.2%
Regulatory Impact Analysis 

5-16

5.6 Inventories Used for Air Quality Analyses

This section describes the processes used in calculating heavy-duty vehicle non-GHG

inventories for the air quality (AQ) modeling analysis. Air quality modeling requires significant 

lead time, and consequently the air quality inventories were completed significantly before the 

inventories presented in this final action. Air quality modeling was done for calendar year 2030. 

This section describes the differences in heavy-duty vehicle non-GHG emissions inventories 

between the final rules and the air quality modeling.

5.6.1 Downstream Inventories

The downstream emission inventories for 2030 presented in this chapter are slightly

different from the emissions inventories used in the air quality modeling presented in Chapter 8. 

Specifically, since the air quality modeling required a significant lead time, the inventories used 

for this analysis were calculated from inputs developed for the proposal.

23

 Differences between 

the final and the air quality inventories are due mostly to regional temperature effects. The 

inventories for the final rules were run by year for the whole nation. This was sufficient for 

nationwide emissions estimates and assumes a uniform VMT-weighted average national 

temperature. The air quality inventories required a finer scale and were run by state and month. 

MOVES2010a was used in conjunction with an internal default database MOVESDB20100913, 

which contained performance updates from the MOVESDB20100826, the database originally

released with MOVES2010a. Seasonal and regional variations in temperature and humidity

were accounted for. The national inventories included Puerto Rico and the U.S. Virgin Islands, 

but the air quality inventories did not. The national inventories only included running exhaust, 

start exhaust, and extended idling exhaust emissions processes, whereas the air quality

inventories included other minor emissions processes, such as crankcase exhaust.

The MOVES output for air quality modeling was stratified into Source Classification 

Codes, the basis for stratification of inputs to the air quality modeling. The national inventories 

output was stratified by source type (vehicle type). Table 5-13 shows the aggregated 

downstream emissions inventories in 2030 from the heavy-duty vehicle sector for both the air 

quality modeling and final rule. It should be noted that the air quality modeling inventories 

relied on state-supplied inventory projections for California. These projections do not reflect 

potential air quality benefits of the standards being finalized in this rule. Onroad emission 

changes for California from this rule would have included reductions in NOX, VOCs, and SO2 as 

well as some smaller increases in direct PM. Although full-scale photochemical modeling is 

necessary to accurately project air quality impacts, it is likely that the emissions changes in 

California would have resulted in a net benefit. As a result, the modeled inventory and air 

quality changes and the monetized benefits associated with this final action are likely an

underestimate.

Table 5-13 Comparison of Calendar Year 2030 Heavy-Duty Vehicle Downstream Final Rule National 

Inventories and Inventories Used for Air Quality (AQ) [Short tons]

REFERENCE CONTROL

POLLUTANT Final AQ Difference Final AQ Difference

1,3-butadiene 305 364 19% 306 365 16%
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-17

Acetaldehyde 4,716 5,229 11% 2,808 3,364 17%

Acrolein 653 722 11% 391 465 16%

Benzene 2,199 2,563 17% 1,858 2,231 17%

CO 2,646,583 2,852,513 8% 2,594,341 2,803,402 7%

Formaldehyde 13,344 14,577 9% 7,089 8,462 16%

NOX 1,068,212 1,144,571 7% 832,813 927,099 10%

PM2.5 20,743 23,926 15% 22,503 24,158 7%

SO2 4,852 3,366 -31% 4,424 3,061 -45%

VOC 133,377 146,416 10% 108,112 121,825 11%

5.6.2 Upstream Inventories

Petroleum production includes crude oil extraction and transport to refineries. As in the 

nationwide analysis presented in the proposal as well as these final rules, we assumed that (a) 

50% of the change in gasoline and diesel supply was projected to come from domestic refineries, 

and (b) 10% of the change in crude being used by domestic refineries would be domestic crude. 

Thus, using our assumption that 1.0 gallon less of gasoline equates to approximately 1.0 gallon 

less crude throughput, the reduction in crude extraction and transport would equal about 5% of 

the change in gasoline volume. To generate the emission inventory adjustment factors for air 

quality modeling these reductions were applied to the projected crude supply to US refineries, 

per AEO 2009 (stimulus version).24 The resulting estimates are shown in Table 5-14. The percent 

reductions were applied to the NEI projected inventories for 2030. The 0.61% reduction was 

applied to all Source Classification Codes associated with petroleum extraction, and the 6.09% 

reduction was applied to all Source Classification Codes associated with gasoline and diesel 

refining.25

Table 5-14 Volumes and Reductions Associated with HD National Program in 2030

Crude Supply to US Refineries, per AEO2010 228 bgal

Reduction in Gasoline/Diesel Consumption 5.79 bgal

Reduction in Domestic-Refined Gasoline/Diesel Vol 2.89 bgal

Reduction in Domestic Refining of Crude (US & Imported Crude) 2.89 bgal

Reduction in Domestic-Refined Gasoline/Diesel from Domestic Crude 0.29 bgal

Reduction in Domestic Crude Production & Transport to refineries 0.29 bgal

Percent Reduction in Domestic Refining 1.27%

Percent Reduction in Domestic Crude Production & Transport 0.13%
Regulatory Impact Analysis 

5-18

References

1

Intergovernmental Panel on Climate Change Working Group I. 2007. Climate Change 2007 - The Physical 

Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on 

Climate Change.

2 U.S. Environmental Protection Agency. 2009. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2007. 

EPA 430-R-09-004. Available at

http://epa.gov/climatechange/emissions/downloads09/GHG2007entire_report-508.pdf 

3 U.S. EPA. 2009 Technical Support Document for Endangerment and Cause or Contribute

Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, DC. pp. 180-194. 

Available at

http://epa.gov/climatechange/endangerment/downloads/Endangerment%20TSD.pdf 

4 Argonne National Laboratory. The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation 

(GREET) Model versions 1.7 and 1.8. http://www.transportation.anl.gov/modeling_simulation/GREET/. Docket 

ID: EPA-HQ-OAR-2009-0472-0215

5

Intergovernmental Panel on Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative 

Forcing. September 2007. http://www.ipcc.ch/pdf/assessment-report/ar4/wg1/ar4-wg1-chapter2.pdf . Docket ID: 

EPA-HQ-OAR-2009-0472-0117

6

http://www.epa.gov/otaq/models/moves/index.htm

7 Memorandum to the Docket “Moves Inputs” Docket Number EPA-HQ-OAR-2010-0162 Docket Identification 

Number EPA-HQ-OAR-2010-0162-0153

8 U.S. EPA. Draft Regulatory Impact Analysis: Changes to Renewable Fuel Standard Program. Chapters 2 and 

3.May 26, 2009. Docket ID: EPA-HQ-OAR-2009-0472-0119

9 U.S. EPA. 2008. RFS2 Modified version of GREET1.7 Upstream Emissions Spreadsheet, October 31, 2008. 

Docket ID: EPA-HQ-OAR-2009-0472-0191

10 Annual Energy Outlook 2011. http://www.eia.doe.gov/oiaf/aeo/

11 Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average 

Fuel Economy Standards, Joint Technical Support Document. EPA-420-R-10-901, April 2010. 

http://www.epa.gov/otaq/climate/regulations/420r10901.pdf

12 Tier 4, less-than-8 kW nonroad compression-ignition engine exhaust emissions standards assumed for APUs: 

http://www.epa.gov/otaq/standards/nonroad/nonroadci.htm

13 Heavy-duty highway compression ignition engine exhaust emission standards. For MY 2004, HD standard is 2.5 

g/bhp-hr NOx+NMHC, with a limit of 0.5 g/bhp-hr NMHC. http://www.epa.gov/otaq/standards/heavy-duty/hdciexhaust.htm For MY 2004, HD standard is 2.5 g/bhp-hr NOx+NMHC, with a limit of 0.5 g/bhp-hr NMHC. 

14 Hsu ,Y., and Mullen, M. 2007. Compilation of Diesel Emissions Speciation Data. Prepared by E. H. Pechan and 

Associates for the Coordinating Research Council. CRC Contract No. E-75, October, 2007. Available at 

www.crcao.org.

15Khalek, I., Bougher, T., and Merritt, P. M. 2009. Phase 1 of the Advanced Collaborative Emissions Study. 

Prepared by Southwest Research Institute for the Coordinating Research Council and the Health Effects Institute, 

June 2009. Available at www.crcao.org.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***

5-19

16 Craig Harvey, EPA, “Calculation of Upstream Emissions for the GHG Vehicle Rule.” 2009. Docket ID: EPAHQ-OAR-2009-0472-0216

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

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

(worldwide) of 9 to 12 years.

18 The Minnesota refrigerant leakage data can be found at 

http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata

19 Using 18% as the base emission rate may overstate the net emission reductions. However, recent number from 

the ERG Report to CARB studying the leakage rate of heavy-duty vehicles are actually much larger (range of near 0 

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

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

modification would be. No comments were recieved and EPA is not modifying the calculation methodology from 

the proposal.

20 Using a Global Warming Potential of 1,430 for HFC-134a.

21 Eastern Research Group. “A Study of R134a Leaks in Heavy Duty Vehicles.” CARB Contract 06-342. 

Presented during CARB Seminar on January 6, 2011.

22 http://www.epa.gov/otaq/marine.htm, http://www.epa.gov/otaq/locomotives.htm

23 Proposed Relumading to Establish Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for 

Medium- and Heavy-Duty Engines and Vehicles, Draft Regulatory Impact Analysis, Chapter 5. EPA-420-D-10-901, 

October 2010. http://www.epa.gov/otaq/climate/regulations/420d10901.pdf

24 Energy Information Administration. Annual Energy Outlook 2009. Supplemental Transportation Tables. April 

2009. http://www.eia.doe.gov/oiaf/aeo/supplement/sup_tran.xls. EPA-HQ-OAR-2009-0472-0121

25 U.S. EPA. 2009. “For LD GHG AQ Modeling, 2030 Control Case: Adjustments to Oil Refining, and Crude 

Production/Transport SCCs,” spreadsheet file: “Oil_Prod_Transp_Refine_2030_adjust.xls,” 11/6/2009.