The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks, 42986-43500 [2018-16820]
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42986
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
49 CFR Parts 523, 531, 533, 536, and
537
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Parts 85 and 86
[NHTSA–2018–0067; EPA–HQ–OAR–2018–
0283; FRL–9981–74–OAR]
RIN 2127–AL76; RIN 2060–AU09
The Safer Affordable Fuel-Efficient
(SAFE) Vehicles Rule for Model Years
2021–2026 Passenger Cars and Light
Trucks
Environmental Protection
Agency and National Highway Traffic
Safety Administration.
ACTION: Notice of proposed rulemaking.
AGENCY:
The National Highway Traffic
Safety Administration (NHTSA) and the
Environmental Protection Agency (EPA)
are proposing the ‘‘Safer Affordable
Fuel-Efficient (SAFE) Vehicles Rule for
Model Years 2021–2026 Passenger Cars
and Light Trucks’’ (SAFE Vehicles
Rule). The SAFE Vehicles Rule, if
finalized, would amend certain existing
Corporate Average Fuel Economy
(CAFE) and tailpipe carbon dioxide
emissions standards for passenger cars
and light trucks and establish new
standards, all covering model years
2021 through 2026. More specifically,
NHTSA is proposing new CAFE
standards for model years 2022 through
2026 and amending its 2021 model year
CAFE standards because they are no
longer maximum feasible standards, and
EPA is proposing to amend its carbon
dioxide emissions standards for model
years 2021 through 2025 because they
are no longer appropriate and
reasonable in addition to establishing
new standards for model year 2026. The
preferred alternative is to retain the
model year 2020 standards (specifically,
the footprint target curves for passenger
cars and light trucks) for both programs
through model year 2026, but comment
is sought on a range of alternatives
discussed throughout this document.
Compared to maintaining the post-2020
standards set forth in 2012, current
estimates indicate that the proposed
SAFE Vehicles Rule would save over
500 billion dollars in societal costs and
reduce highway fatalities by 12,700
lives (over the lifetimes of vehicles
through MY 2029). U.S. fuel
consumption would increase by about
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SUMMARY:
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half a million barrels per day (2–3
percent of total daily consumption,
according to the Energy Information
Administration) and would impact the
global climate by 3/1000th of one degree
Celsius by 2100, also when compared to
the standards set forth in 2012.
DATES: Comments: Comments are
requested on or before October 23, 2018.
Under the Paperwork Reduction Act,
comments on the information collection
provisions must be received by the
Office of Management and Budget
(OMB) on or before October 23, 2018.
See the SUPPLEMENTARY INFORMATION
section on ‘‘Public Participation,’’
below, for more information about
written comments.
Public Hearings: NHTSA and EPA
will jointly hold three public hearings
in Washington, DC; the Detroit, MI area;
and in the Los Angeles, CA area. The
agencies will announce the specific
dates and addresses for each hearing
location in a supplemental Federal
Register notice. The agencies will
accept oral and written comments to the
rulemaking documents, and NHTSA
will also accept comments to the Draft
Environmental Impact Statement (DEIS)
at these hearings. The hearings will start
at 10 a.m. local time and continue until
everyone has had a chance to speak. See
the SUPPLEMENTARY INFORMATION section
on ‘‘Public Participation,’’ below, for
more information about the public
hearings.
You may send comments,
identified by Docket No. EPA–HQ–
OAR–2018–0283 and/or NHTSA–2018–
0067, by any of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for sending comments.
• Fax: EPA: (202) 566–9744; NHTSA:
(202) 493–2251.
• Mail:
Æ EPA: Environmental Protection
Agency, EPA Docket Center (EPA/DC),
Air and Radiation Docket, Mail Code
28221T, 1200 Pennsylvania Avenue
NW, Washington, DC 20460, Attention
Docket ID No. EPA–HQ–OAR–2018–
0283. In addition, please mail a copy of
your comments on the information
collection provisions for the EPA
proposal to the Office of Information
and Regulatory Affairs, Office of
Management and Budget (OMB), Attn:
Desk Officer for EPA, 725 17th St. NW,
Washington, DC 20503.
Æ NHTSA: Docket Management
Facility, M–30, U.S. Department of
Transportation, West Building, Ground
Floor, Rm. W12–140, 1200 New Jersey
Avenue SE, Washington, DC 20590.
• Hand Delivery:
ADDRESSES:
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Æ EPA: Docket Center (EPA/DC), EPA
West, Room B102, 1301 Constitution
Avenue NW, Washington, DC, Attention
Docket ID No. EPA–HQ–OAR–2018–
0283. Such deliveries are only accepted
during the Docket’s normal hours of
operation, and special arrangements
should be made for deliveries of boxed
information.
Æ NHTSA: West Building, Ground
Floor, Rm. W12–140, 1200 New Jersey
Avenue SE, Washington, DC 20590,
between 9 a.m. and 4 p.m. Eastern Time,
Monday through Friday, except Federal
holidays.
Instructions: All submissions received
must include the agency name and
docket number or Regulatory
Information Number (RIN) for this
rulemaking. All comments received will
be posted without change to https://
www.regulations.gov, including any
personal information provided. For
detailed instructions on sending
comments and additional information
on the rulemaking process, see the
‘‘Public Participation’’ heading of the
SUPPLEMENTARY INFORMATION section of
this document.
Docket: For access to the dockets to
read background documents or
comments received, go to https://
www.regulations.gov, and/or:
• For EPA: EPA Docket Center (EPA/
DC), EPA West, Room 3334, 1301
Constitution Avenue NW, Washington,
DC 20460. The Public Reading Room is
open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal
holidays. The telephone number for the
Public Reading Room is (202) 566–1744.
• For NHTSA: Docket Management
Facility, M–30, U.S. Department of
Transportation, West Building, Ground
Floor, Rm. W12–140, 1200 New Jersey
Avenue SE, Washington, DC 20590. The
Docket Management Facility is open
between 9 a.m. and 4 p.m. Eastern Time,
Monday through Friday, except Federal
holidays.
FOR FURTHER INFORMATION CONTACT:
EPA: Christopher Lieske, Office of
Transportation and Air Quality,
Assessment and Standards Division,
Environmental Protection Agency, 2000
Traverwood Drive, Ann Arbor, MI
48105; telephone number: (734) 214–
4584; fax number: (734) 214–4816;
email address: lieske.christopher@
epa.gov, or contact the Assessment and
Standards Division, email address:
otaqpublicweb@epa.gov. NHTSA: James
Tamm, Office of Rulemaking, Fuel
Economy Division, National Highway
Traffic Safety Administration, 1200 New
Jersey Avenue SE, Washington, DC
20590; telephone number: (202) 493–
0515.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
SUPPLEMENTARY INFORMATION:
I. Overview of Joint NHTSA/EPA Proposal
II. Technical Foundation for NPRM Analysis
III. Proposed CAFE and CO2 Standards for
MYs 2021–2026
IV. Alternative CAFE and GHG Standards
Considered for MYs 2021/22–2026
V. Proposed Standards, the Agencies’
Statutory Obligations, and Why the
Agencies Propose To Choose Them Over
the Alternatives
VI. Preemption of State and Local Laws
VII. Impacts of the Proposed CAFE and CO2
Standards
VIII. Impacts of Alternative CAFE and CO2
Standards Considered for MYs 2021/22–
2026
IX. Vehicle Classification
X. Compliance and Enforcement
XI. Public Participation
XII. Regulatory Notices and Analyses
I. Overview of Joint NHTSA/EPA
Proposal
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A. Executive Summary
In this notice, the National Highway
Traffic Safety Administration (NHTSA)
and the Environmental Protection
Agency (EPA) (collectively, ‘‘the
agencies’’) are proposing the ‘‘Safer
Affordable Fuel-Efficient (SAFE)
Vehicles Rule for Model Years 2021–
2026 Passenger Cars and Light Trucks’’
(SAFE Vehicles Rule). The proposed
SAFE Vehicles Rule would set
Corporate Average Fuel Economy
(CAFE) and carbon dioxide (CO2)
emissions standards, respectively, for
passenger cars and light trucks
manufactured for sale in the United
States in model years (MYs) 2021
through 2026.1 CAFE and CO2 standards
have the power to transform the vehicle
fleet and affect Americans’ lives in
significant, if not always immediately
obvious, ways. The proposed SAFE
Vehicles Rule seeks to ensure that
government action on these standards is
appropriate, reasonable, consistent with
law, consistent with current and
foreseeable future economic realities,
and supported by a transparent
assessment of current facts and data.
The agencies must act to propose and
finalize these standards and do not have
discretion to decline to regulate.
Congress requires NHTSA to set CAFE
standards for each model year.2
Congress also requires EPA to set
emissions standards for light-duty
vehicles if EPA has made an
‘‘endangerment finding’’ that the
pollutant in question—in this case,
1 NHTSA sets CAFE standards under the Energy
Policy and Conservation Act of 1975 (EPCA), as
amended by the Energy Independence and Security
Act of 2007 (EISA). EPA sets CO2 standards under
the Clean Air Act (CAA).
2 49 U.S.C. 32902.
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CO2—‘‘cause[s] or contribute[s] to air
pollution which may reasonably be
anticipated to endanger public health or
welfare.’’ 3 NHTSA and EPA are
proposing these standards concurrently
because tailpipe CO2 emissions
standards are directly and inherently
related to fuel economy standards,4 and
if finalized, these rules would apply
concurrently to the same fleet of
vehicles. By working together to
develop these proposals, the agencies
reduce regulatory burden on industry
and improve administrative efficiency.
Consistent with both agencies’
statutes, this proposal is entirely de
novo, based on an entirely new analysis
reflecting the best and most up-to-date
information available to the agencies at
the time of this rulemaking. The
agencies worked together in 2012 to
develop CAFE and CO2 standards for
MYs 2017 and beyond; in that
rulemaking action, EPA set CO2
standards for MYs 2017–2025, while
NHTSA set final CAFE standards for
MYs 2017–2021 and also put forth
‘‘augural’’ CAFE standards for MYs
2022–2025, consistent with EPA’s CO2
standards for those model years. EPA’s
CO2 standards for MYs 2022–2025 were
subject to a ‘‘mid-term evaluation,’’ by
which EPA bound itself through
regulation to re-evaluate the CO2
standards for those model years and to
undertake to develop new CO2
standards through a regulatory process
if it concluded that the previously
finalized standards were no longer
appropriate. EPA regulations on the
mid-term evaluation process required
EPA to issue a Final Determination no
later than April 1, 2018 on whether the
GHG standards for MY 2022–2025 lightduty vehicles remain appropriate under
3 42 U.S.C. 7521, see also 74 FR 66495 (Dec. 15,
2009) (‘‘Endangerment and Cause or Contribute
Findings for Greenhouse Gases under Section
202(a) of the Clean Air Act’’).
4 See, e.g., 75 FR 25324, at 25327 (May 7, 2010)
(‘‘The National Program is both needed and
possible because the relationship between
improving fuel economy and reducing tailpipe CO2
emissions is a very direct and close one. The
amount of those CO2 emissions is essentially
constant per gallon combusted of a given type of
fuel. Thus, the more fuel efficient a vehicle is, the
less fuel it burns to travel a given distance. The less
fuel it burns, the less CO2 it emits in traveling that
distance. [citation omitted] While there are
emission control technologies that reduce the
pollutants (e.g., carbon monoxide) produced by
imperfect combustion of fuel by capturing or
converting them to other compounds, there is no
such technology for CO2. Further, while some of
those pollutants can also be reduced by achieving
a more complete combustion of fuel, doing so only
increases the tailpipe emissions of CO2. Thus, there
is a single pool of technologies for addressing these
twin problems, i.e., those that reduce fuel
consumption and thereby reduce CO2 emissions as
well.’’)
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section 202(a) of the Clean Air Act.5 The
regulations also required the issuance of
a draft Technical Assessment Report
(TAR) by November 15, 2017, an
opportunity for public comment on the
draft TAR, and, before making a Final
Determination, an opportunity for
public comment on whether the GHG
standards for MY 2022–2025 remain
appropriate. In July 2016, the draft TAR
was issued for public comment jointly
by the EPA, NHTSA, and the California
Air Resources Board (CARB).6
Following the draft TAR, EPA published
a Proposed Determination for public
comment on December 6, 2016 and
provided less than 30 days for public
comments over major holidays.7 EPA
published the January 2017
Determination on EPA’s website and
regulations.gov finding that the MY
2022–2025 standards remained
appropriate.8
On March 15, 2017, President Trump
announced a restoration of the original
mid-term review timeline. The
President made clear in his remarks,
‘‘[i]f the standards threatened auto jobs,
then commonsense changes’’ would be
made in order to protect the economic
viability of the U.S. automotive
industry.’’ 9 In response to the
President’s direction, EPA announced in
a March 22, 2017, Federal Register
notice, its intention to reconsider the
Final Determination of the mid-term
evaluation of GHGs emissions standards
for MY 2022–2025 light-duty vehicles.10
The Administrator stated that EPA
would coordinate its reconsideration
with the rulemaking process to be
undertaken by NHTSA regarding CAFE
standards for cars and light trucks for
the same model years.
On August 21, 2017, EPA published a
notice in the Federal Register
announcing the opening of a 45-day
public comment period and inviting
stakeholders to submit any additional
comments, data, and information they
believed were relevant to the
Administrator’s reconsideration of the
5 40 CFR 86.1818–12(h)(1); see also 77 FR 62624
(Oct. 15, 2012).
6 81 FR 49217 (Jul. 27, 2016).
7 81 FR 87927 (Dec. 6, 2016).
8 Docket item EPA–HQ–OAR–2015–0827–6270
(EPA–420–R–17–001). This conclusion generated a
significant amount of public concern. See, e.g.,
Letter from Auto Alliance to Scott Pruitt,
Administrator, Environmental Protection Agency
(Feb. 21, 2017); Letter from Global Automakers to
Scott Pruitt, Administrator, Environmental
Protection Agency (Feb. 21, 2017).
9 See https://www.whitehouse.gov/briefingsstatements/remarks-president-trump-americancenter-mobility-detroit-mi/.
10 82 FR 14671 (Mar. 22, 2017).
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
January 2017 Determination.11 EPA held
a public hearing in Washington DC on
September 6, 2017.12 EPA received
more than 290,000 comments in
response to the August 21, 2017
notice.13
EPA has since concluded, based on
more recent information, that those
standards are no longer appropriate.14
NHTSA’s ‘‘augural’’ CAFE standards for
MYs 2022–2025 were not final in 2012
because Congress prohibits NHTSA
from finalizing new CAFE standards for
more than five model years in a single
rulemaking.15 NHTSA was therefore
obligated from the beginning to
undertake a new rulemaking to set
CAFE standards for MYs 2022–2025.
The proposed SAFE Vehicles Rule
begins the rulemaking process for both
agencies to establish new standards for
MYs 2022–2025 passenger cars and light
trucks. Standards are concurrently being
proposed for MY 2026 in order to
provide regulatory stability for as many
years as is legally permissible for both
agencies together.
Separately, the proposed SAFE
Vehicles Rule includes revised
standards for MY 2021 passenger cars
and light trucks. The information now
available and the current analysis
11 82
FR 39551 (Aug. 21, 2017).
FR 39976 (Aug. 23, 2017).
13 The public comments, public hearing
transcript, and other information relevant to the
Mid-term Evaluation are available in docket EPA–
HQ–OAR–2015–0827.
14 83 FR 16077 (Apr. 2, 2018).
15 49 U.S.C. 32902.
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suggest that the CAFE standards
previously set for MY 2021 are no
longer maximum feasible, and the CO2
standards previously set for MY 2021
are no longer appropriate. Agencies
always have authority under the
Administrative Procedure Act to revisit
previous decisions in light of new facts,
as long as they provide notice and an
opportunity for comment, and it is
plainly the best practice to do so when
changed circumstances so warrant.16
Thus, the proposed SAFE Vehicles
Rule would maintain the CAFE and CO2
standards applicable in MY 2020 for
MYs 2021–2026, while taking comment
on a wide range of alternatives,
including different stringencies and
retaining existing CO2 standards and the
augural CAFE standards.17 Table I–4
16 See
FCC v. Fox Television, 556 U.S. 502 (2009).
This does not mean that the miles per
gallon and grams per mile levels that were
estimated for the MY 2020 fleet in 2012 would be
the ‘‘standards’’ going forward into MYs 2021–2026.
Both NHTSA and EPA set CAFE and CO2 standards,
respectively, as mathematical functions based on
vehicle footprint. These mathematical functions
that are the actual standards are defined as ‘‘curves’’
that are separate for passenger cars and light trucks,
under which each vehicle manufacturer’s
compliance obligation varies depending on the
footprints of the cars and trucks that it ultimately
produces for sale in a given model year. It is the
MY 2020 CAFE and CO2 curves which we propose
would continue to apply to the passenger car and
light truck fleets for MYs 2021–2026. The mpg and
g/mi values which those curves would eventually
require of the fleets in those model years would be
known for certain only at the ends of each of those
model years. While it is convenient to discuss
CAFE and CO2 standards as a set ‘‘mpg,’’ ‘‘g/mi,’’
or ‘‘mpg-e’’ number, attempting to define those
values today will end up being inaccurate.
17 Note:
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below presents those alternatives. We
note further that prior to MY 2021, CO2
targets include adjustments reflecting
the use of automotive refrigerants with
reduced global warming potential
(GWP) and/or the use of technologies
that reduce the refrigerant leaks, and
optionally offsets for nitrous oxide and
methane emissions. In the interests of
harmonizing with the CAFE program,
EPA is proposing to exclude air
conditioning refrigerants and leakage,
and nitrous oxide and methane
emissions for compliance with CO2
standards after model year 2020 but
seeks comment on whether to retain
these element, and reinsert A/C leakage
offsets, and remain disharmonized with
the CAFE program. EPA also seeks
comment on whether to change existing
methane and nitrous oxide standards
that were finalized in the 2012 rule.
Specifically, EPA seeks information
from the public on whether those
existing standards are appropriate, or
whether they should be revised to be
less stringent or more stringent based on
any updated data.
While actual requirements will
ultimately vary for automakers
depending upon their individual fleet
mix of vehicles, many stakeholders will
likely be interested in the current
estimate of what the MY 2020 CAFE and
CO2 curves would translate to, in terms
of miles per gallon (mpg) and grams per
mile (g/mi), in MYs 2021–2026. These
estimates are shown in the following
tables.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
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Table 1-1- Average of OEM'
s CAFE an d CO2 E sf 1mat ed R eqmreme nts for Passenger Cars
Model Year
Avg. ofOEMs' Est.
Requirements
CAFE (mpg)
C02 (g/mi)
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
39.1
40.5
42.0
43.7
43.7
43.7
43.7
43.7
43.7
43.7
220
210
201
191
204
204
204
204
204
204
Table 1-2- Average of OEM'
.
d R eqmrem ents for Light Trucks
s CAFE an d CO 2 E st1mate
Model Year
Avg. ofOEMs' Est.
Requirements
CAFE (mpg)
C02 (g/mi)
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
29.5
30.1
30.6
31.3
31.3
31.3
31.3
31.3
31.3
31.3
294
284
277
269
284
284
284
284
284
284
Table 1-3- Average of OEMs' Estimated CAFE and C02 Requirements (Passenger Cars
and Li~ht Trucks)
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34.0
34.9
35.8
36.9
36.9
36.9
36.9
37.0
37.0
37.0
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254
244
236
227
241
241
241
241
240
240
Sfmt 4725
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2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
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Model Year
Avg. ofOEMs' Est.
Requirements
CAFE (mpg)
C0 2 (g/mi)
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
In the tables above, estimated
required CO2 increases between MY
2020 and MY 2021 because, again, EPA
is proposing to exclude CO2-equivalent
emission improvements associated with
air conditioning refrigerants and leakage
(and, optionally, offsets for nitrous
oxide and methane emissions) after
model year 2020.
As explained above, the agencies are
taking comment on a wide range of
Ta bl e I- 4 - R egu atory AI ternat1ves
c urrently un der c ons1
eratwn
Alternative
Change in stringency
A/C
efficiency
and offcycle
..
provisiOns
Baseline/
No-Action
MY 2021 standards remain in place; MYs 2022-2025 augural
CAFE standards are finalized and GHG standards remain
unchanged; MY 2026 standards are set at MY 2025 levels
Existing standards through MY 2020, then 0%/year increases
for both passenger cars and light trucks, for MY s 2021-2026
Existing standards through MY 2020, then 0.5%/year increases
for both passenger cars and light trucks, for MY s 2021-2026
Existing standards through MY 2020, then 0.5%/year increases
for both passenger cars and light trucks, for MY s 2021-2026
No change
1
(Proposed)
2
3
4
5
6
7
8
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alternatives and have specifically
modeled eight alternatives (including
the proposed alternative) and the
current requirements (i.e., baseline/noaction). The modeled alternatives are
provided below:
Existing standards through MY 2020, then 1%/year increases
for passenger cars and 2%/year increases for light trucks, for
MYs 2021-2026
Existing standards through MY 2021, then 1%/year increases
for passenger cars and 2%/year increases for light trucks, for
MY s 2022-2026
Existing standards through MY 2020, then 2%/year increases
for passenger cars and 3 %/year increases for light trucks, for
MYs 2021-2026
Existing standards through MY 2020, then 2%/year increases
for passenger cars and 3 %/year increases for light trucks, for
MYs 2021-2026
Existing standards through MY 2021, then 2%/year increases
for passenger cars and 3 %/year increases for light trucks, for
MY s 2022-2026
No change
No change
Phase out
these
adjustments
overMYs
2022-2026
No change
C02 Equivalent
AC Refrigerant
Leakage,
Nitrous Oxide
and Methane
Emissions
Included for
Compliance?
Yes, for all
MYs 18
No, beginning
19
in MY 2021
No, beginning
in MY 2021
No, beginning
in MY 2021
No, beginning
in MY 2021
No change
No, beginning
in MY 2022
No change
No, beginning
in MY 2021
Phase out
these
adjustments
overMYs
2022-2026
No change
No, beginning
in MY 2021
No, beginning
in MY 2022
Summary of Rationale
Since finalizing the agencies’ previous
joint rulemaking in 2012 titled ‘‘Final
Rule for Model Year 2017 and Later
Light-Duty Vehicle Greenhouse Gas
Emission and Corporate Average Fuel
Economy Standards,’’ and even since
EPA’s 2016 and early 2017 ‘‘mid-term
evaluation’’ process, the agencies have
gathered new information, and have
performed new analysis. That new
information and analysis has led the
18 Carbon dioxide equivalent of air conditioning
refrigerant leakage, nitrous oxide and methane
emissions are included for compliance with the
EPA standards for all MYs under the baseline/no
action alternative. Carbon dioxide equivalent is
calculated using the Global Warming Potential
(GWP) of each of the emissions.
19 Beginning in MY 2021, the proposal provides
that the GWP equivalents of air conditioning
refrigerant leakage, nitrous oxide and methane
emissions would no longer be able to be included
with the tailpipe CO2 for compliance with tailpipe
CO2 standards.
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agencies to the tentative conclusion that
holding standards constant at MY 2020
levels through MY 2026 is maximum
feasible, for CAFE purposes, and
appropriate, for CO2 purposes.
Technologies have played out
differently in the fleet from what the
agencies assumed in 2012.
The technology to improve fuel
economy and reduce CO2 emissions has
not changed dramatically since prior
analyses were conducted: A wide
variety of technologies are still available
to accomplish the goals of the programs,
and a wide variety of technologies
would likely be used by industry to
accomplish these goals. There remains
no single technology that the majority of
vehicles made by the majority of
manufacturers can implement at low
cost without affecting other vehicle
attributes that consumers value more
than fuel economy and CO2 emissions.
Even when used in combination,
technologies that can improve fuel
economy and reduce CO2 emissions still
need to (1) actually work together and
(2) be acceptable to consumers and
avoid sacrificing other vehicle attributes
while also avoiding undue increases in
vehicle cost. Optimism about the costs
and effectiveness of many individual
technologies, as compared to recent
prior rounds of rulemaking, is
somewhat tempered; a clearer
understanding of what technologies are
already on vehicles in the fleet and how
they are being used, again as compared
to recent prior rounds of rulemaking,
means that technologies that previously
appeared to offer significant ‘‘bang for
the buck’’ may no longer do so.
Additionally, in light of the reality that
vehicle manufacturers may choose the
relatively cost-effective technology
option of vehicle lightweighting for a
wide array of vehicles and not just the
largest and heaviest, it is now
recognized that as the stringency of
standards increases, so does the
likelihood that higher stringency will
increase on-road fatalities. As it turns
out, there is no such thing as a free
lunch.20
Technology that can improve both
fuel economy and/or performance may
not be dedicated solely to fuel economy.
As fleet-wide fuel efficiency has
improved over time, additional
improvements have become both more
complicated and more costly. There are
two primary reasons for this
phenomenon. First, as discussed, there
is a known pool of technologies for
improving fuel economy and reducing
CO2 emissions. Many of these
technologies, when actually
implemented on vehicles, can be used
to improve other vehicle attributes such
as ‘‘zero to 60’’ performance, towing,
and hauling, etc., either instead of or in
addition to improving fuel economy and
reducing CO2 emissions. As one
example, a V6 engine can be
turbocharged and downsized so that it
consumes only as much fuel as an inline
4-cylinder engine, or it can be
turbocharged and downsized so that it
consumes less fuel than it would
originally have consumed (but more
than the inline 4-cylinder would) while
also providing more low-end torque. As
another example, a vehicle can be
lightweighted so that it consumes less
fuel than it would originally have
consumed, or so that it consumes the
same amount of fuel it would originally
have consumed but can carry more
content, like additional safety or
infotainment equipment. Manufacturers
employing ‘‘fuel-saving/emissionsreducing’’ technologies in the real world
make decisions regarding how to
employ that technology such that fewer
than 100% of the possible fuel-saving/
emissions-reducing benefits result. They
do this because this is what consumers
want, and more so than exclusively fuel
economy improvements.
This makes actual fuel economy gains
more expensive.
Thus, even though the technologies
may be largely the same, previous
assumptions about how much fuel can
be saved or how much emissions can be
reduced by employing various
technologies may not have played out as
prior analyses suggested, meaning that
previous assumptions about how much
it would cost to save that much fuel or
reduce that much in emissions fall
correspondingly short. For example, the
agencies assumed in the 2010 final rule
that dual clutch transmissions would be
widely used to improve fuel economy
due to expectations of strong
effectiveness and very low cost: In
practice, dual clutch transmissions had
significant customer acceptance issues,
and few manufacturers employ them in
the U.S. market today.21 The agencies
included some ‘‘technologies’’ in the
2012 final rule analysis that were
defined ambiguously and/or in ways
that precluded observation in the
known (MYs 2008 and 2010) fleets,
likely leading to double counting in
cases where the known vehicles already
reflected the assumed efficiency
improvement. For example, the agencies
assumed that transmission ‘‘shift
optimizers’’ would be available and
fairly widely used in MYs 2017–2025,
but involving software controls, a
‘‘technology’’ not defined in a way that
would be observed in the fleet (unlike,
for example, a dual clutch
transmission).
To be clear, this is no one’s ‘‘fault’’—
the CAFE and CO2 standards do not
require manufacturers to use particular
technologies in particular ways, and
both agencies’ past analyses generally
sought to illustrate technology paths to
compliance that were assumed to be as
cost-effective as possible. If
manufacturers choose different paths for
reasons not accounted for in regulatory
analysis, or choose to use technologies
differently from what the agencies
previously assumed, it does not
necessarily mean that the analyses were
unreasonable when performed. It does
mean, however, that the fleet ought to
be reflected as it stands today, with the
technology it has and as that technology
has been used, and consider what
technology remains on the table at this
point, whether and when it can
realistically be available for widespread
use in production, and how much it
would cost to implement.
Incremental additional fuel economy
benefits are subject to diminishing
returns.
As fleet-wide fuel efficiency improves
and CO2 emissions are reduced, the
incremental benefit of continuing to
improve/reduce inevitably decreases.
This is because, as the base level of fuel
economy improves, fewer gallons are
saved from subsequent incremental
improvements. Put simply, a one mpg
increase for vehicles with low fuel
economy will result in far greater
savings than an identical 1 mpg increase
for vehicles with higher fuel economy,
and the cost for achieving a one-mpg
increase for low fuel economy vehicles
is far less than for higher fuel economy
vehicles. This means that improving
fuel economy is subject to diminishing
returns. Annual fuel consumption can
be calculated as follows:
20 Mankiw, N. Gregory, Principles of
Macroeconomics, Sixth Edition, 2012, at 4.
21 In fact, one manufacturer saw enough customer
pushback that it launched a buyback program. See,
e.g., Steve Lehto, ‘‘What you need to know about
the settlement for Ford Powershift owners,’’ Road
and Track, Oct. 19, 2017. Available at https://
www.roadandtrack.com/car-culture/a10316276/
what-you-need-to-know-about-the-proposedsettlement-for-ford-powershift-owners/ (last
accessed Jul. 2, 2018).
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For purposes of illustration, assume a
vehicle owner who drives a light vehicle
15,000 miles per year (a typical
assumption for analytical purposes).22 If
that owner trades in a vehicle with fuel
economy of 15 mpg for one with fuel
economy of 20 mpg, the owner’s annual
fuel consumption would drop from
1,000 gallons to 750 gallons—saving 250
gallons annually. If, however, that
owner were to trade in a vehicle with
fuel economy of 30 mpg for one with
fuel economy of 40 mpg, the owner’s
annual gasoline consumption would
drop from 500 gallons/year to 375
gallons/year—only 125 gallons even
though the mpg improvement is twice
as large. Going from 40 to 50 mpg would
save only 75 gallons/year. Yet, each
additional fuel economy improvement
becomes much more expensive as the
low-hanging fruit of low-cost
technological improvement options are
picked.23 Automakers, who must
nonetheless continue adding technology
to improve fuel economy and reduce
CO2 emissions, will either sacrifice
other performance attributes or raise the
price of vehicles—neither of which is
attractive to most consumers.
If fuel prices are high, the value of
those gallons may be enough to offset
the cost of further fuel economy
improvements, but (1) the most recent
reference case projections in the Energy
Information Administration’s (EIA’s)
Annual Energy Outlook (AEO 2017 and
AEO 2018) do not indicate particularly
high fuel prices in the foreseeable
future, given underlying assumptions,24
and (2) as the baseline level of fuel
economy continues to increase, the
marginal cost of the next gallon saved
similarly increases with the cost of the
technologies required to meet the
savings. The following figure illustrates
the fact that fuel savings and
corresponding avoided costs diminish
with increasing fuel economy, showing
the same basic pattern as a 2014
illustration developed by EIA.25
22 A different vehicle-miles-traveled (VMT)
assumption would change the absolute numbers in
the example, but would not change the
mathematical principles. Today’s analysis uses
mileage accumulation schedules that average about
15,000 miles annually over the first six years of
vehicle operation.
23 The examples in the text above are presented
in mpg because that is a metric which should be
readily understandable to most readers, but the
example would hold true for grams of CO2 per mile
as well. If a vehicle emits 300 g/mi CO2, a 20
percent improvement is 60 g/mi, so that the vehicle
would emit 240 g/mi. At 180 g/mi, a 20%
improvement is 36 g/mi, so the vehicle would get
144 g/mi. In order to continue achieving similarly
large (on an absolute basis) emissions reductions,
mathematics require the percentage reduction to
continue increasing.
24 The U.S. Energy Information Administration
(EIA) is the statistical and analytical agency within
the U.S. Department of Energy (DOE). EIA is the
nation’s premiere source of energy information, and
every fuel economy rulemaking since 2002 (and
every joint CAFE and CO2 rulemaking since 2009)
has applied fuel price projections from EIA’s
Annual Energy Outlook (AEO). AEO projections,
documentation, and underlying data and estimates
are available at https://www.eia.gov/outlooks/aeo/.
25 Today in Energy: Fuel economy improvements
show diminishing returns in fuel savings, U.S.
Energy Information Administration (Jul. 11, 2014),
https://www.eia.gov/todayinenergy/detail.php?id=
17071.
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This effect is mathematical in nature
and long-established, but when
combined with relatively low fuel prices
potentially through 2050, and the
likelihood that a large majority of
American consumers could
consequently continue to place a higher
value on vehicle attributes other than
fuel economy, it makes manufacturers’
ability to sell light vehicles with everhigher fuel economy and ever-lower
carbon dioxide emissions increasingly
difficult. Put more simply, if gas is
cheap and each additional improvement
saves less gas anyway, most consumers
would rather spend their money on
attributes other than fuel economy when
they are considering a new vehicle
purchase, whether that is more safety
technology, a better infotainment
package, a more powerful powertrain, or
other features (or, indeed, they may
prefer to spend the savings on
something other than automobiles).
Manufacturers trying to sell consumers
more fuel economy in such
circumstances may convince consumers
who place weight on efficiency and
reduced carbon emissions, but
consumers decide for themselves what
attributes are worth to them. And while
some contend that consumers do not
sufficiently consider or value future fuel
savings when making vehicle
purchasing decisions,26 information
regarding the benefits of higher fuel
economy has never been made more
readily available than today, with a host
of online tools and mandatory
prominent disclosures on new vehicles
on the Monroney label showing fuel
savings compared to average vehicles.
This is not a question of ‘‘if you build
it, they will come.’’ Despite the
widespread availability of fuel economy
information, and despite manufacturers
building and marketing vehicles with
higher fuel economy and increasing
their offerings of hybrid and electric
vehicles, in the past several years as gas
prices have remained low, consumer
preferences have shifted markedly away
from higher-fuel-economy smaller and
midsize passenger vehicles toward
crossovers and truck-based utility
vehicles.27 Some consumers plainly
26 In docket numbers EPA–HQ–OAR–2015–0827
and NHTSA–2016–0068, see comments submitted
by, e.g., Consumer Federation of America (NHTSA–
2016–0068–0054, at p. 57, et seq.) and the
Environmental Defense Fund (EPA–HQ–OAR–
2015–0827–4086, at p. 18, et seq.).
27 Carey, N. Lured by rising SUV sales,
automakers flood market with models, Reuters
(Mar. 29, 2018), available at https://
www.reuters.com/article/us-autoshow-new-yorksuvs/lured-by-rising-suv-sales-automakers-floodmarket-with-models-idUSKBN1H50KI (last accessed
Jun. 13, 2018). Many commentators have recently
argued that manufacturers are deliberately
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value fuel economy and low CO2
emissions above other attributes, and
thanks in part to CAFE and CO2
standards, they have a plentiful
selection of high-fuel economy and low
CO2-emitting vehicles to choose from,
but those consumers represent a
relatively small percentage of buyers.
Changed petroleum market has
supported a shift in consumer
preferences.
In 2012, the agencies projected fuel
prices would rise significantly, and the
United States would continue to rely
heavily upon imports of oil, subjecting
the country to heightened risk of price
shocks.28 Things have changed
significantly since 2012, with fuel prices
significantly lower than anticipated, and
projected to remain low through 2050.
Furthermore, the global petroleum
market has shifted dramatically with the
United States taking advantage of its
own oil supplies through technological
advances that allow for cost-effective
extraction of shale oil. The U.S. is now
the world’s largest oil producer and
expected to become a net petroleum
exporter in the next decade.29
At least partially in response to lower
fuel prices, consumers have moved
more heavily into crossovers, sport
utility vehicles and pickup trucks, than
anticipated at the time of the last
rulemaking. Because standards are
based on footprint and specified
separately for passenger cars and light
trucks, these shifts do not necessarily
pose compliance challenges by
themselves, but they tend to reduce the
overall average fuel economy rates and
increasing vehicle footprint size in order to get
‘‘easier’’ CAFE and CO2 standards. This
misunderstands, somewhat, how the footprintbased standards work. While it is correct that largerfootprint vehicles have less stringent ‘‘targets,’’ the
difficulty of compliance rests in how far above or
below those vehicles are as compared to their
targets, and more specifically, whether the
manufacturer is selling so many vehicles that are far
short of their targets that they cannot average out
to compliant levels through other vehicles sold that
beat their targets. For example, under the CAFE
program, a manufacturer building a fleet of largerfootprint vehicles may have an objectively lower
mpg-value compliance obligation than a
manufacturer building a more mixed fleet, but it
may still be more challenging for the first
manufacturer to reach its compliance obligation if
it is selling only very-low-mpg variants at any given
footprint. There is only so much that increasing
footprint makes it ‘‘easier’’ for a manufacturer to
reach compliance.
28 The 2012 final rule analysis relied on the
Energy Information Administration’s Annual
Energy Outlook 2012 Early Release, which assumed
significantly higher fuel prices than the AEO 2017
(or AEO 2018) currently available. See 77 FR 62624,
62715 (Oct. 15, 2012) for the 2012 final rule’s
description of the fuel price estimates used.
29 Annual Energy Outlook 2018, U.S. Energy
Information Administration, at 53 (Feb. 6, 2018),
https://www.eia.gov/outlooks/aeo/pdf/
AEO2018.pdf.
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increase the overall average CO2
emission rates of the new vehicle fleet.
Consumers are also demonstrating a
preference for more powerful engines
and vehicles with higher seating
positions and ride height (and
accompanying mass increase relative to
footprint) 30—all of which present
challenges for achieving increased fuel
economy levels and lower CO2 emission
rates.
The Consequence of Unreasonable
Fuel Economy and CO2 Standards:
Increased vehicle prices keep consumers
in older, dirtier, and less safe vehicles.
Consumers tend to avoid purchasing
things that they neither want or need.
The analysis in today’s proposal moves
closer to being able to represent this fact
through an improved model for vehicle
scrappage rates. While neither this nor
a sales response model, also included in
today’s analysis, nor the combination of
the two, are consumer choice models,
today’s analysis illustrates market-wide
impacts on the sale of new vehicles and
the retention of used vehicles. Higher
vehicle prices, which result from morestringent fuel economy standards, have
an effect on consumer purchasing
decisions. As prices increase, the
market-wide incentive to extract
additional travel from used vehicles
increases. The average age of the inservice fleet has been increasing, and
when fleet turnover slows, not only
does it take longer for fleet-wide fuel
economy and CO2 emissions to improve,
but also safety improvements, criteria
pollutant emissions improvements,
many other vehicle attributes that also
provide societal benefits take longer to
be reflected in the overall U.S. fleet as
well because of reduced turnover.
Raising vehicle prices too far, too fast,
such as through very stringent fuel
economy and CO2 emissions standards
(especially considering that, on a fleetwide basis, new vehicle sales and
turnover do not appear strongly
responsive to fuel economy), has effects
beyond simply a slowdown in sales.
Improvements over time have better
longer-term effects simply by not
alienating consumers, as compared to
great leaps forward that drive people out
of the new car market or into vehicles
that do not meet their needs. The
industry has achieved tremendous gains
in fuel economy over the past decade,
and these increases will continue at
least through 2020.
Along with these gains, there have
also been tremendous increases in
vehicle prices, as new vehicles become
increasingly unaffordable—with the
average new vehicle transaction price
30 See
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recently exceeding $36,000—up by
more than $3,000 since 2014 alone.31 In
fact, a recent independent study
indicated that the average new car price
is unaffordable to median-income
families in every metropolitan region in
the United States except one:
Washington, DC.32 That analysis used
the historically accepted approach that
consumers should make a downpayment of at least 20% of a vehicle’s
purchase price, finance for no longer
than four years, and make payments of
10% or less of the consumer’s annual
income to car payments and insurance.
But the market looks nothing like that
these days, with average financing terms
of 68 months, and an increasing
proportion exceeding 72 or even 84
months.33 Longer financing terms may
sradovich on DSK3GMQ082PROD with PROPOSALS2
31 See, e.g., Average New-Car Prices Rise Nearly
4 Percent for January 2018 On Shifting Sales Mix,
According To Kelley Blue Book, Kelley Blue Book,
https://mediaroom.kbb.com/2018-02-01-AverageNew-Car-Prices-Rise-Nearly-4-Percent-For-January2018-On-Shifting-Sales-Mix-According-To-KelleyBlue-Book (last accessed Jun. 15, 2018).
32 Bell, C. What’s an ‘affordable’ car where you
live? The answer may surprise you, Bankrate.com
(Jun. 28, 2017), available at https://
www.bankrate.com/auto/new-car-affordabilitysurvey/ (last accessed Jun. 15, 2018).
33 Average Auto Loan Interest Rates: 2018 Facts
and Figures, ValuePenguin, available at https://
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allow a consumer to keep their monthly
payment affordable but can have serious
potential financial consequences.
Longer-term financing leads (generally)
to higher interest rates, larger finance
charges and total consumer costs, and a
longer period of time with negative
equity. In 2012, the agencies expected
prices to increase under the standards
announced at that time. The agencies
estimated that, compared to a
continuation of the model year 2016
standards, the standards issued through
model year 2025 would eventually
increase average prices by about $1,500–
$1,800.34 35 36 Circumstances have
www.valuepenguin.com/auto-loans/average-autoloan-interest-rates (last accessed Jun. 15, 2018).
34 77 FR 62624, 62666 (Oct. 15, 2012).
35 The $1,500 figure reported in 2012 by NHTSA
reflected application of carried-forward credits in
model year 2025, rather than an achieved CAFE
level that could be sustainably compliant beyond
2025 (with standards remaining at 2025 levels). As
for the 2016 draft TAR, NHTSA has since updated
its modeling approach to extend far enough into the
future that any unsustainable credit deficits are
eliminated. Like analyses published by EPA in
2016, 2017, and early 2018, the $1,800 figure
reported in 2012 by EPA did not reflect either
simulation of manufacturers’ multiyear plans to
progress from the initial MY 2008 fleet to the MY
2025 fleet or any accounting for manufacturers’
potential application of banked credits. Today’s
analysis of both CAFE and CO2 standards accounts
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changed, the analytical methods and
inputs have been updated (including
updates to address issues still present in
analyses published in 2016, 2017, and
early 2018), and today, the analysis
suggests that, compared to the proposed
standards today, the previously-issued
standards would increase average
vehicle prices by about $2,100. While
today’s estimate is similar in magnitude
to the 2012 estimate, it is relative to a
baseline that includes increases in
stringency between MY 2016 and MY
2020. Compared to leaving vehicle
technology at MY 2016 levels, today’s
analysis shows the previously-issued
standards through model year 2025
could eventually increase average
vehicle prices by approximately $2,700.
A pause in continued increases in fuel
economy standards, and cost increases
attributable thereto, is appropriate.
explicitly for multiyear planning and credit
banking.
36 While EPA did not refer to the reported $1,800
as an estimate of the increase in average prices,
because EPA did not assume that manufacturers
would reduce profit margins, the $1,800 estimate is
appropriately interpreted as an estimate of the
average increase in vehicle prices.
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sradovich on DSK3GMQ082PROD with PROPOSALS2
Energy Conservation
EPCA requires that NHTSA, when
determining the maximum feasible
levels of CAFE standards, consider the
need of the Nation to conserve energy.
However, EPCA also requires that
NHTSA consider other factors, such as
37 Data on new vehicle prices are from U.S.
Bureau of Economic Analysis, National Income and
Product Accounts, Supplemental Table 7.2.5S, Auto
and Truck Unit Sales, Production, Inventories,
Expenditures, and Price (https://www.bea.gov/
iTable/iTable.cfm?reqid=19&step=2#reqid=
19&step=3&isuri=1&1921=underlying&1903=2055,
last accessed Jul. 20, 2018). Median Household
Income data are from U.S. Census Bureau, Table A–
1, Households by Total Money Income, Race, and
Hispanic Origin of Householder: 1967 to 2016
(https://www.census.gov/data/tables/2017/demo/
income-poverty/p60-259.html, last accessed Jul. 20,
2018).
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technological feasibility and economic
practicability. The analysis suggests
that, compared to the standards issued
previously for MYs 2021–2025, today’s
proposed rule will eventually (by the
early 2030s) increase U.S. petroleum
consumption by about 0.5 million
barrels per day—about two to three
percent of projected total U.S.
consumption. While significant, this
additional petroleum consumption is,
from an economic perspective, dwarfed
by the cost savings also projected to
result from today’s proposal, as
indicated by the consideration of net
benefits appearing below.
Safety Benefits From Preferred
Alternative
Today’s proposed rule is anticipated
to prevent more than 12,700 on-road
fatalities 38 and significantly more
injuries as compared to the standards
set forth in the 2012 final rule over the
lifetimes of vehicles as more new, safer
vehicles are purchased than the current
(and augural) standards. A large portion
of these safety benefits will come from
38 Over
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the lifetime of vehicles through MY 2029.
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improved fleet turnover as more
consumers will be able to afford newer
and safer vehicles.
Recent NHTSA analysis shows that
the proportion of passengers killed in a
vehicle 18 or more model years old is
nearly double that of a vehicle three
model years old or newer.39 As the
average car on the road is approaching
12 years old, apparently the oldest in
our history,40 major safety benefits will
occur by reducing fleet age. Other safety
benefits will occur from other areas
such as avoiding the increased driving
39 Passenger Vehicle Occupant Injury Severity by
Vehicle Age and Model Year in Fatal Crashes,
Traffic Safety Facts Research Note, DOT HS 812
528. Washington, DC: National Highway Traffic
Safety Administration. April 2018.
40 See, e.g., IHS Markit, Vehicles Getting Older:
Average Age of Light Cars and Trucks in U.S. Rises
Again in 2016 to 11.5 years, IHS Markit Says, IHS
Markit (Nov. 22, 2016), https://news.ihsmarkit.com/
press-release/automotive/vehicles-getting-olderaverage-age-light-cars-and-trucks-us-rises-again-201
(‘‘. . . consumers are continuing the trend of
holding onto their vehicles longer than ever. As of
the end of 2015, the average length of ownership
measured a record 79.3 months, more than 1.5
months longer than reported in the previous year.
For used vehicles, it is nearly 66 months. Both are
significantly longer lengths of ownership since the
same measure a decade ago.’’).
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Preferred Alternative
For all of these reasons, the agencies
are proposing to maintain the MY 2020
fuel economy and CO2 emissions
standards for MYs 2021–2026. Our goal
is to establish standards that promote
both energy conservation and safety, in
light of what is technologically feasible
and economically practicable, as
directed by Congress.
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that would otherwise result from higher
fuel efficiency (known as the rebound
effect) and avoiding the mass reductions
in passenger cars that might otherwise
be required to meet the standards
established in 2012.41 Together these
and other factors lead to estimated
annual fatalities under the proposed
standards that are significantly
reduced 42 relative to those that would
occur under current (and augural)
standards.
The Preferred Alternative Would Have
Negligible Environmental Impacts on
Air Quality
Improving fleet turnover will result in
consumers getting into newer and
cleaner vehicles, accelerating the rate at
which older, more-polluting vehicles
are removed from the roadways. Also,
reducing fuel economy (relative to
levels that would occur under
previously-issued standards) would
increase the marginal cost of driving
newer vehicles, reducing mileage
accumulated by those vehicles, and
reducing corresponding emissions. On
the other hand, increasing fuel
consumption would increase emissions
resulting from petroleum refining and
related ‘‘upstream’’ processes. Our
analysis shows that none of the
regulatory alternatives considered in
this proposal would noticeably impact
net emissions of smog-forming or other
‘‘criteria’’ or toxic air pollutants, as
illustrated by the following graph. That
said, the resultant tailpipe emissions
reductions should be especially
beneficial to highly trafficked corridors.
Climate Change Impacts From Preferred
Alternative
The estimated effects of this proposal
in terms of fuel savings and CO2
emissions, again perhaps somewhat
counter-intuitively, is relatively small as
compared to the 2012 final rule.43
NHTSA’s Environmental Impact
Statement performed for this
rulemaking shows that the preferred
alternative would result in 3/1,000ths of
a degree Celsius increase in global
average temperatures by 2100, relative
to the standards finalized in 2012. On a
net CO2 basis, the results are similarly
minimal. The following graph compares
the estimated atmospheric CO2
concentration (789.76 ppm) in 2100
under the proposed standards to the
estimated level (789.11 ppm) under the
standards set forth in 2012—or an 8/
100ths of a percentage increase:
41 The agencies are specifically requesting
comment on the appropriateness and level of the
effects of the rebound effect. The agencies also seek
comment on changes as compared to the 2012
modeling relating to mass reduction assumptions.
During that rulemaking, the analysis limited the
amount of mass reduction assumed for certain
vehicles, which impacted the results regarding
potential for adverse safety effects, even while
acknowledging that manufacturers would not
necessarily choose to avoid mass reductions in the
ways that the agencies assumed. See, 77 FR 623624,
62763 (Oct. 15, 2012). By choosing where and how
to limit assumed mass reduction, the 2012 rule’s
safety analysis reduced the projected apparent risk
to safety associated with aggressive fuel economy
and CO2 targets. That specific assumption has been
removed for today’s analysis.
42 The reduction in annual fatalities varies each
calendar year, averaging 894 fewer fatalities
annually for the CAFE program and 1,150 fewer
fatalities for the CO2 program over calendar years
2036–2045.
43 Counter-intuitiveness is relative, however. The
estimated effects of the 2012 final rule on climate
were similarly small in magnitude, as shown in the
Final EIS accompanying that rule and available on
NHTSA’s website.
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Maintaining the MY 2020 curves for
MYs 2021–2026 will save American
consumers, the auto industry, and the
public a considerable amount of money
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as compared to if EPA retained the
previously-set CO2 standards and
NHTSA finalized the augural standards.
This was identified as the preferred
alternative, in part, because it
maximizes net benefits compared to the
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other alternatives analyzed, recognizing
the statutory considerations for both
agencies. Comment is sought on
whether this is an appropriate basis for
selection.
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Net Benefits From Preferred Alternative
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These estimates, reported as changes
relative to impacts under the standards
issued in 2012, account for impacts on
vehicles produced during model years
2016–2029, as well as (through changes
in utilization) vehicles produced in
earlier model years, throughout those
vehicles’ useful lives. Reported values
are in 2016 dollars, and reflect threepercent and seven-percent discount
rates. Under CAFE standards, costs are
estimated to decrease by $502 billion
overall at a three-percent discount rate
($335 billion at a seven-percent
discount rate); benefits are estimated to
decrease by $326 billion at a threepercent discount rate ($204 billion at a
seven-percent discount rate). Thus, net
benefits are estimated to increase by
$176 billion at a three-percent discount
rate and $132 billion at a seven-percent
discount rate. The estimated impacts
under CO2 standards are similar, with
net benefits estimated to increase by
$201 billion at a three-percent discount
rate and $141 billion at a seven-percent
discount rate.
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Compliance Flexibilities
This proposal also seeks comment on
a variety of changes to NHTSA’s and
EPA’s compliance programs for CAFE
and CO2 as well as related programs.
Compliance flexibilities can generally
be grouped into two categories. The first
category are those compliance
flexibilities that reduce unnecessary
compliance costs and provide for a more
efficient program. The second category
of compliance flexibilities are those that
distort the market—such as by
incentivizing the implementation of one
type of technology by providing credit
for compliance in excess of real-world
fuel savings.
Both programs provide for the
generation of credits based upon fleetwide over-compliance, provide for
adjustments to the test measured value
of each individual vehicle based upon
the implementation of certain fuel
saving technologies, and provide
additional incentives for the
implementation of certain preferred
technologies (regardless of actual fuel
savings). Auto manufacturers and others
have petitioned for a host of additional
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adjustment- and incentive-type
flexibilities, where there is not always
consumer interest in the technologies to
be incentivized nor is there necessarily
clear fuel-saving and emissionsreducing benefit to be derived from that
incentivization. The agencies seek
comment on all of those requests as part
of this proposal.
Over-compliance credits, which can
be built up in part through use of the
above-described per-vehicle
adjustments and incentives, can be
saved and either applied retroactively to
accounts for previous non-compliance,
or carried forward to mitigate future
non-compliance. Such credits can also
be traded to other automakers for cash
or for other credits for different fleets.
But such trading is not pursued openly.
Under the CAFE program, the public is
not made aware of inter-automaker
trades, nor are shareholders. And even
the agencies are not informed of the
price of credits. With the exception of
statutorily-mandated credits, the
agencies seek comment on all aspects of
the current system. The agencies are
particularly interested in comments on
flexibilities that may distort the market.
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The agencies seek comment as to
whether some adjustments and nonstatutory incentives and other
provisions should be eliminated and
stringency levels adjusted accordingly.
In general, well-functioning banking
and trading provisions increase market
efficiency and reduce the overall costs
of compliance with regulatory
objectives. The agencies request
comment on whether the current system
as implemented might need
improvements to achieve greater
efficiencies. We seek comment on
specific programmatic changes that
could improve compliance with current
standards in the most efficient way,
ranging from requiring public disclosure
of some or all aspects of credit trades,
to potentially eliminating credit trading
in the CAFE program. We request
commenters to provide any data,
evidence, or existing literature to help
agency decision-making.
sradovich on DSK3GMQ082PROD with PROPOSALS2
One National Standard
Setting appropriate and maximum
feasible fuel economy and tailpipe CO2
emissions standards requires regulatory
efficiency. This proposal addresses a
fundamental and unnecessary
complication in the currently-existing
regulatory framework, which is the
regulation of GHG emissions from
passenger cars and light trucks by the
State of California through its GHG
standards and Zero Emission Vehicle
(ZEV) mandate and subsequent
adoption of these standards by other
States. Both EPCA and the CAA
preempt State regulation of motor
vehicle emissions (in EPCA’s case,
standards that are related to fuel
economy standards). The CAA gives
EPA the authority to waive preemption
for California under certain
circumstances. EPCA does not provide
for a waiver of preemption under any
circumstances. In short, the agencies
propose to maintain one national
standard—a standard that is set
exclusively by the Federal government.
Proposed Withdrawal of California’s
Clean Air Act Preemption Waiver
EPA granted a waiver of preemption
to California in 2013 for its ‘‘Advanced
Clean Car’’ regulations, composed of its
GHG standards, its ‘‘Low Emission
Vehicle (LEV)’’ program and the ZEV
program,44 and, as allowed under the
CAA, a number of other States adopted
California’s standards.45 The CAA states
that EPA shall not grant a waiver of
preemption if EPA finds that
California’s determination that its
44 78
FR 2112 (Jan. 9, 2013).
Section 177, 42 U.S.C. 7507.
45 CAA
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standards are, in the aggregate, at least
as protective of public health and
welfare as applicable Federal standards,
is arbitrary and capricious; that
California does not need its own
standards to meet compelling or
extraordinary conditions; or that such
California standards and accompanying
enforcement procedures are not
consistent with Section 202(a) of the
CAA. In this proposal, EPA is proposing
to withdraw the waiver granted to
California in 2013 for the GHG and ZEV
requirements of its Advanced Clean
Cars program, in light of all of these
factors.
Attempting to solve climate change,
even in part, through the Section 209
waiver provision is fundamentally
different from that section’s original
purpose of addressing smog-related air
quality problems. When California was
merely trying to solve its air quality
issues, there was a relativelystraightforward technology solution to
the problems, implementation of which
did not affect how consumers lived and
drove. Section 209 allowed California to
pursue additional reductions to address
its notorious smog problems by
requiring more stringent standards, and
allowed California and other States that
failed to comply with Federal air quality
standards to make progress toward
compliance. Trying to reduce carbon
emissions from motor vehicles in any
significant way involves changes to the
entire vehicle, not simply the addition
of a single or a handful of control
technologies. The greater the emissions
reductions are sought, the greater the
likelihood that the characteristics and
capabilities of the vehicle currently
sought by most American consumers
will have to change significantly. Yet,
even decades later, California continues
to be in widespread non-attainment
with Federal air quality standards.46 In
the past decade, California has
disproportionately focused on GHG
emissions. Parts of California have a real
and significant local air pollution
problem, but CO2 is not part of that local
problem.
California’s Tailpipe CO2 Emissions
Standards and ZEV Mandate Conflict
With EPCA
Moreover, California regulation of
tailpipe CO2 emissions, both through its
GHG standards and ZEV program,
conflicts directly and indirectly with
EPCA and the CAFE program. EPCA
expressly preempts State standards
46 See California Nonattainment/Maintenance
Status for Each County by Year for All Criteria
Pollutants, current as of May 31, 2018, at https://
www3.epa.gov/airquality/greenbook/anayo_ca.html
(last accessed June 15, 2018).
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related to fuel economy. Tailpipe CO2
standards, whether in the form of fleetwide CO2 limits or in the form of
requirements that manufacturers selling
vehicles in California sell a certain
number of low- and no-tailpipe-CO2
emissions vehicles as part of their
overall sales, are unquestionably related
to fuel economy standards. Standards
that control tailpipe CO2 emissions are
de facto fuel economy standards
because CO2 is a direct and inevitable
byproduct of the combustion of carbonbased fuels to make energy, and the vast
majority of the energy that powers
passenger cars and light trucks comes
from carbon-based fuels.
Improving fuel economy means
getting the vehicle to go farther on a
gallon of gas; a vehicle that goes farther
on a gallon of gas produces less CO2 per
unit of distance; therefore, improving
fuel economy necessarily reduces
tailpipe CO2 emissions, and reducing
CO2 emissions necessarily improves fuel
economy. EPCA therefore necessarily
preempts California’s Advanced Clean
Cars program to the extent that it
regulates or prohibits tailpipe CO2
emissions. Section VI of this proposal,
below, discusses the CAA waiver and
EPCA preemption in more detail.
Eliminating California’s regulation of
fuel economy pursuant to Congressional
direction will provide benefits to the
American public. The automotive
industry will, appropriately, deal with
fuel economy standards on a national
basis—eliminating duplicative
regulatory requirements. Further,
elimination of California’s ZEV program
will allow automakers to develop such
vehicles in response to consumer
demand instead of regulatory mandate.
This regulatory mandate has required
automakers to spend tens of billions of
dollars to develop products that a
significant majority of consumers have
not adopted, and consequently to sell
such products at a loss. All of this is
paid for through cross subsidization by
increasing prices of other vehicles not
just in California and other States that
have adopted California’s ZEV mandate,
but throughout the country.
Request for Comment
The agencies look forward to all
comments on this proposal, and wish to
emphasize that obtaining public input is
extremely important to us in selecting
from among the alternatives in a final
rule. While the agencies and the
Administration met with a variety of
stakeholders prior to issuance of this
proposal, those meetings have not
resulted in a predetermined final rule
outcome. The Administrative Procedure
Act requires that agencies provide the
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public with adequate notice of a
proposed rule followed by a meaningful
opportunity to comment on the rule’s
content. The agencies are committed to
following that directive.
II. Technical Foundation for NPRM
Analysis
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A. Basics of CAFE and CO2 Standards
Analysis
The agencies’ analysis of CAFE and
CO2 standards involves two basic
elements: first, estimating ways each
manufacturer could potentially respond
to a given set of standards in a manner
that considers potential consumer
response; and second, estimating
various impacts of those responses.
Estimating manufacturers’ potential
responses involves simulating
manufacturers’ decision-making
processes regarding the year-by-year
application of fuel-saving technologies
to specific vehicles. Estimating impacts
involves calculating resultant changes
in new vehicle costs, estimating a
variety of costs (e.g., for fuel) and effects
(e.g., CO2 emissions from fuel
combustion) occurring as vehicles are
driven over their lifetimes before
eventually being scrapped, and
estimating the monetary value of these
effects. Estimating impacts also involves
consideration of the response of
consumers—e.g., whether consumers
will purchase the vehicles and in what
quantities. Both of these basic analytical
elements involve the application of
many analytical inputs.
The agencies’ analysis uses the CAFE
model to estimate manufacturers’
potential responses to new CAFE and
CO2 standards and to estimate various
impacts of those responses. The model
makes use of many inputs, values of
which are developed outside of the
model and not by the model. For
example, the model applies fuel prices;
it does not estimate fuel prices. The
model does not determine the form or
stringency of the standards; instead, the
model applies inputs specifying the
form and stringency of standards to be
analyzed and produces outputs showing
effects of manufacturers working to
meet those standards, which become the
basis for comparing between different
potential stringencies.
DOT’s Volpe National Transportation
Systems Center (often simply referred to
as the ‘‘Volpe Center’’) develops,
maintains, and applies the model for
NHTSA. NHTSA has used the CAFE
model to perform analyses supporting
every CAFE rulemaking since 2001, and
the 2016 rulemaking regarding heavyduty pickup and van fuel consumption
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and GHG emissions also used the CAFE
model for analysis.47
DOT recently arranged for a formal
peer review of the model. In general,
reviewers’ comments strongly supported
the model’s conceptual basis and
implementation, and commenters
provided several specific
recommendations. DOT staff agreed
with many of these recommendations
and have worked to implement them
wherever practicable. Implementing
some of them would require
considerable further research,
development, and testing, and will be
considered going forward. For a handful
of other recommendations, DOT staff
disagreed, often finding the
recommendations involved
considerations (e.g., other policies, such
as those involving fuel taxation) beyond
the model itself or were based on
concerns with inputs rather than how
the model itself functioned. A report
available in the docket for this
rulemaking presents peer reviewers’
detailed comments and
recommendations, and provides DOT’s
detailed responses.48
The agencies also use four DOE and
DOE-sponsored models to develop
inputs to the CAFE model, including
three developed and maintained by
DOE’s Argonne National Laboratory.
The agencies use the DOE Energy
Information Administration’s (EIA’s)
National Energy Modeling System
(NEMS) to estimate fuel prices,49 and
used Argonne’s Greenhouse gases,
Regulated Emissions, and Energy use in
Transportation (GREET) model to
estimate emissions rates from fuel
production and distribution processes.50
DOT also sponsored DOE/Argonne to
use their Autonomie full-vehicle
simulation system to estimate the fuel
economy impacts for roughly a million
combinations of technologies and
vehicle types.51 52
47 While this rulemaking employed the CAFE
model for analysis, EPA and DOT used different
versions of the CAFE model for establishing their
respective standards, and EPA also used the EPA
MOVES model. See 81 FR 73478, 73743 (Oct. 25,
2016).
48 Docket No. NHTSA–2018–0067.
49 See https://www.eia.gov/outlooks/aeo/info_
nems_archive.php. Today’s notice uses fuel prices
estimated using the Annual Energy Outlook (AEO)
2017 version of NEMS (see https://www.eia.gov/
outlooks/archive/aeo17/ and https://www.eia.gov/
outlooks/aeo/data/browser/#/?id=3-AEO2017
&cases=ref2017&sourcekey=0).
50 Information regarding GREET is available at
https://greet.es.anl.gov/index.php. Availability of
NEMS is discussed at https://www.eia.gov/
outlooks/aeo/info_nems_archive.php. Today’s
notice uses fuel prices estimated using the AEO
2017 version of NEMS.
51 As part of the Argonne simulation effort,
individual technology combinations simulated in
Autonomie were paired with Argonne’s BatPAC
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EPA developed two models after
2009, referred to as the ‘‘ALPHA’’ and
‘‘OMEGA’’ models, which provide some
of the same capabilities as the
Autonomie and CAFE models. EPA
applied the OMEGA model to conduct
analysis of GHG standards promulgated
in 2010 and 2012, and the ALPHA and
OMEGA models to conduct analysis
discussed in the above-mentioned 2016
Draft TAR and Proposed and Final
Determinations regarding standards
beyond 2021. In an August 2017 notice,
the agencies requested comments on,
among other things, whether EPA
should use alternative methodologies
and modeling, including DOE/
Argonne’s Autonomie full-vehicle
simulation tool and DOT’s CAFE
model.53
Having reviewed comments on the
subject and having considered the
matter fully, the agencies have
determined it is reasonable and
appropriate to use DOE/Argonne’s
model for full-vehicle simulation, and to
use DOT’s CAFE model for analysis of
regulatory alternatives. EPA interprets
Section 202(a) of the CAA as giving the
agency broad discretion in how it
develops and sets GHG standards for
light-duty vehicles. Nothing in Section
202(a) mandates that EPA use any
specific model or set of models for
analysis of potential CO2 standards for
light-duty vehicles. EPA weighs many
factors when determining appropriate
levels for CO2 standards, including the
cost of compliance (see Section
202(a)(2)), lead time necessary for
compliance (also Section 202(a)(2)),
safety (see NRDC v. EPA, 655 F.2d 318,
336 n. 31 (D.C. Cir. 1981) and other
impacts on consumers,54 and energy
impacts associated with use of the
technology.55 Using the CAFE model
model to estimate the battery cost associated with
each technology combination based on
characteristics of the simulated vehicle and its level
of electrification. Information regarding Argonne’s
BatPAC model is available at https://
www.cse.anl.gov/batpac/.
52 Additionally, the impact of engine technologies
on fuel consumption, torque, and other metrics was
characterized using GT POWER simulation
modeling in combination with other engine
modeling that was conducted by IAV Automotive
Engineering, Inc. (IAV). The engine characterization
‘‘maps’’ resulting from this analysis were used as
inputs for the Autonomie full-vehicle simulation
modeling. Information regarding GT Power is
available at https://www.gtisoft.com/gt-suiteapplications/propulsion-systems/gt-power-enginesimulation-software.
53 82 FR 39533 (Aug. 21, 2017).
54 Since its earliest Title II regulations, EPA has
considered the safety of pollution control
technologies. See 45 FR 14496, 14503 (1980).
55 See George E. Warren Corp. v. EPA, 159 F.3d
616, 623–624 (D.C. Cir. 1998) (ordinarily
permissible for EPA to consider factors not
specifically enumerated in the Act).
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allows consideration of the following
factors: the CAFE model explicitly
evaluates the cost of compliance for
each manufacturer, each fleet, and each
model year; it accounts for lead time
necessary for compliance by directly
incorporating estimated manufacturer
production cycles for every vehicle in
the fleet, ensuring that the analysis does
not assume vehicles can be redesigned
to incorporate more technology without
regard to lead time considerations; it
provides information on safety effects
associated with different levels of
standards and information about many
other impacts on consumers, and it
calculates energy impacts (i.e., fuel
saved or consumed) as a primary
function, besides being capable of
providing information about many other
factors within EPA’s broad CAA
discretion to consider.
Because the CAFE model simulates a
wide range of actual constraints and
practices related to automotive
engineering, planning, and production,
such as common vehicle platforms,
sharing of engines among different
vehicle models, and timing of major
vehicle redesigns, the analysis produced
by the CAFE model provides a
transparent and realistic basis to show
pathways manufacturers could follow
over time in applying new technologies,
which helps better assess impacts of
potential future standards. Furthermore,
because the CAFE model also accounts
fully for regulatory compliance
provisions (now including CO2
compliance provisions), such as
adjustments for reduced refrigerant
leakage, production ‘‘multipliers’’ for
some specific types of vehicles (e.g.,
PHEVs), and carried-forward (i.e.,
banked) credits, the CAFE model
provides a transparent and realistic
basis to estimate how such technologies
might be applied over time in response
to CAFE or CO2 standards.
There are sound reasons for the
agencies to use the CAFE model going
forward in this rulemaking. First, the
CAFE and CO2 fact analyses are
inextricably linked. Furthermore, the
analysis produced by the CAFE model
and DOE/Argonne’s Autonomie
addresses several analytical needs. The
CAFE model provides an explicit yearby-year simulation of manufacturers’
application of technology to their
products in response to a year-by-year
progression of CAFE standards and
accounts for sharing of technologies and
the implications for timing, scope, and
limits on the potential to optimize
powertrains for fuel economy. In the
real world, standards actually are
specified on a year-by-year basis, not
simply some single year well into the
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future, and manufacturers’ year-by-year
plans involve some vehicles ‘‘carrying
forward’’ technology from prior model
years and some other vehicles possibly
applying ‘‘extra’’ technology in
anticipation of standards in ensuing
model years, and manufacturers’
planning also involves applying credits
carried forward between model years.
Furthermore, manufacturers cannot
optimize the powertrain for fuel
economy on every vehicle model
configuration—for example, a given
engine shared among multiple vehicle
models cannot practicably be split into
different versions for each configuration
of each model, each with a slightly
different displacement. The CAFE
model is designed to account for these
real-world factors.
Considering the technological
heterogeneity of manufacturers’ current
product offerings, and the wide range of
ways in which the many fuel economyimproving/CO2 emissions-reducing
technologies included in the analysis
can be combined, the CAFE model has
been designed to use inputs that provide
an estimate of the fuel economy
achieved for many tens of thousands of
different potential combinations of fuelsaving technologies. Across the range of
technology classes encompassed by the
analysis fleet, today’s analysis involves
more than a million such estimates.
While the CAFE model requires no
specific approach to developing these
inputs, the National Academy of
Sciences (NAS) has recommended, and
stakeholders have commented, that fullvehicle simulation provides the best
balance between realism and
practicality. DOE/Argonne has spent
several years developing, applying, and
expanding means to use distributed
computing to exercise its Autonomie
full-vehicle simulation tool over the
scale necessary for realistic analysis of
CAFE or average CO2 standards. This
scalability and related flexibility (in
terms of expanding the set of
technologies to be simulated) makes
Autonomie well-suited for developing
inputs to the CAFE model.
Additionally, DOE/Argonne’s
Autonomie also has a long history of
development and widespread
application by a much wider range of
users in government, academia, and
industry. Many of these users apply
Autonomie to inform funding and
design decisions. These real-world
exercises have contributed significantly
to aspects of Autonomie important to
producing realistic estimates of fuel
economy levels and CO2 emission rates,
such as estimation and consideration of
performance, utility, and driveability
metrics (e.g., towing capability, shift
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business, frequency of engine on/off
transitions). This steadily increasing
realism has, in turn, steadily increased
confidence in the appropriateness of
using Autonomie to make significant
investment decisions. Notably, DOE
uses Autonomie for analysis supporting
budget priorities and plans for programs
managed by its Vehicle Technologies
Office (VTO). Considering the
advantages of DOE/Argonne’s
Autonomie model, it is reasonable and
appropriate to use Autonomie to
estimate fuel economy levels and CO2
emission rates for different
combinations of technologies as applied
to different types of vehicles.
Commenters have also suggested that
the CAFE model’s graphical user
interface (GUI) facilitates others’ ability
to use the model quickly—and without
specialized knowledge or training—and
to comment accordingly.56 For today’s
proposal, DOT has significantly
expanded and refined this GUI,
providing the ability to observe the
model’s real-time progress much more
closely as it simulates year-by-year
compliance with either CAFE or CO2
standards.57 Although the model’s
ability to produce realistic results is
independent of the model’s GUI, it is
anticipated the CAFE model’s GUI will
facilitate stakeholders’ meaningful
review and comment during the
comment period.
Beyond these general considerations,
several specific related technical
comments and considerations underlie
the agencies’ decision in this area, as
discussed, where applicable, in the
remainder of this Section.
Other commenters expressed a
number of concerns with whether
DOT’s CAFE model could be used for
CAA analysis. Many of these concerns
focused on inputs used by the CAFE
model for prior rulemaking
analyses.58 59 60 Because inputs are
56 From Docket Number EPA–HQ–OAR–2015–
0827, see Comment by Global Automakers, Docket
ID EPA–HQ–OAR–2015–0827–9728, at 34.
57 The updated GUI provides a range of graphs
updated in real time as the model operates. These
graphs can be used to monitor fuel economy or CO2
ratings of vehicles in manufacturers’ fleets and to
monitor year-by-year CAFE (or average CO2 ratings),
costs, avoided fuel outlays, and avoided CO2-related
damages for specific manufacturers and/or specific
fleets (e.g., domestic passenger car, light truck).
Because these graphs update as the model
progresses, they should greatly increase users’
understanding of the model’s approach to
considerations such as multiyear planning,
payment of civil penalties, and credit use.
58 For example, EDF’s recent comments (EDF at
12, Docket ID. EPA–HQ–OAR–2015–0827–9203)
stated ‘‘the data that NHTSA needs to input into its
model is sensitive confidential business
information that is not transparent and cannot be
independently verified . . .’’ and claimed ‘‘the
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exogenous to any model, they do not
determine whether it would be
reasonable and appropriate for EPA to
use DOT’s model for analysis. Other
concerns focused on characteristics of
the CAFE model that were developed to
better align the model with EPCA and
EISA; the model has been revised to
accommodate both EPCA/EISA and
CAA analysis, as explained further
below. Some commenters also argued
that use of any models other than
ALPHA and OMEGA for CAA analysis
would constitute an arbitrary and
capricious delegation of EPA’s decisionmaking authority to DOT, if DOT
models are used for analysis instead.
These comments were made prior to the
development of the CAA analysis
function in the CAFE model, and,
moreover, appear to conflate the
analytical tool used to inform decisionmaking with the action of making the
decision. As explained elsewhere in this
document and as made repeatedly clear
over the past several rulemakings, the
CAFE model neither sets standards nor
dictates where and how to set standards;
it simply informs as to the effects of
setting different levels of standards. In
this rulemaking, EPA will be making its
own decisions regarding what CO2
standards would be appropriate under
the CAA. The CAA does not require
EPA to create a specific model or use a
specific model of its own creation in
setting GHG standards. The fact EPA’s
OMEGA model’s focus on direct technological
inputs and costs—as opposed to industry selfreported data—ensures the model more accurately
characterizes the true feasibility and cost
effectiveness of deploying greenhouse gas reducing
technologies.’’ Neither statement is correct, as
nothing about either the CAFE or OMEGA model
either obviates or necessitates the use of CBI to
develop inputs.
59 In recent comments (CARB at 28, Docket ID.
EPA–HQ–OAR–2015–0827–9197), CARB stated
‘‘another promising technology entering the market
was not even included in the NHTSA compliance
modeling’’ and that EPA assumes a five-year
redesign cycle, whereas NHTSA assumes a six to
seven-year cycle.’’ Though presented as criticisms
of the models, these comments—at least with
respect to the CAFE model—actually concern
model inputs. NHTSA did not agree with CARB
about the commercialization potential of the engine
technology in question (‘‘Atkinson 2’’) and applied
model inputs accordingly. Also, rather than
applying a one-size-fits-all assumption regarding
redesign cadence, NHTSA developed estimates
specific to each vehicle model and applied these as
model inputs.
60 NRDC’s recent comments (NRDC at 37, Docket
ID. EPA–HQ–OAR–2015–0827–9826) state EPA
should not use the CAFE model because it ‘‘allows
manufacturers to pay civil penalties in lieu of
meeting the standards, an alternative compliance
pathway currently allowed under EISA and EPCA.’’
While the CAFE model can simulate civil penalty
payment, NRDC’s comment appears to overlook the
fact that this result depends on model inputs; the
inputs can easily be specified such that the CAFE
model will set aside civil penalty payment as an
alternative to compliance.
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decision may be informed by non-EPAcreated models does not, in any way,
constitute a delegation of its statutory
power to set standards or decisionmaking authority.61 Arguing to the
contrary would suggest, for example,
that EPA’s decision would be invalid
because it relied on EIA’s Annual
Energy Outlook for fuel prices rather
than developing its own model for
estimating future trends in fuel prices.
Yet, all Federal agencies that have
occasion to use forecasts of future fuel
prices regularly (and appropriately)
defer to EIA’s expertise in this area and
rely on EIA’s NEMS-based analysis in
the AEO, even when those same
agencies are using EIA’s forecasts to
inform their own decision-making.
Moreover, DOT’s CAFE model with
inputs from DOE/Argonne’s Autonomie
model has produced analysis supporting
rulemaking under the CAA. In 2015,
EPA proposed new GHG standards for
MY 2021–2027 heavy-duty pickups and
vans, finalizing standards in 2016.
Supporting the NPRM and final rule,
EPA relied on analysis implemented by
DOT using DOT’s CAFE model, and
DOT used inputs developed by DOE/
Argonne using DOE/Argonne’s
Autonomie model.
The following sections provide a brief
technical overview of the CAFE model,
including changes NHTSA made to the
model since 2012, before discussing
inputs to the model and then diving
more deeply into how the model works.
For more information on the latter topic,
see the CAFE model documentation July
2018 draft, available in the docket for
this rulemaking and on NHTSA’s
website.
1. Brief Technical Overview of the
Model
The CAFE model is designed to
simulate compliance with a given set of
CAFE or CO2 standards for each
manufacturer selling vehicles in the
United States. The model begins with a
representation of the current (for today’s
analysis, model year 2016) vehicle
model offerings for each manufacturer
61 ‘‘[A] federal agency may turn to an outside
entity for advice and policy recommendations,
provided the agency makes the final decisions
itself.’’ U.S. Telecom. Ass’n v. FCC, 359 F.3d 554,
565–66 (D.C. Cir. 2004). To the extent commenters
meant to suggest outside parties have a reliance
interest in EPA using ALPHA and OMEGA to set
standards, EPA does not agree a reliance interest is
properly placed on an analytical methodology (as
opposed to on the standards themselves). Even if it
were, all parties that closely examined ALPHA and
OMEGA-based analyses in the past either also
simultaneously closely examined CAFE and
Autonomie-based analyses in the past, or were fully
capable of doing so, and thus, should face no
additional difficulty now they have only one set of
models and inputs/outputs to examine.
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that includes the specific engines and
transmissions on each model variant,
observed sales volumes, and all fuel
economy improvement technology that
is already present on those vehicles.
From there it adds technology, in
response to the standards being
considered, in a way that minimizes the
cost of compliance and reflects many
real-world constraints faced by
automobile manufacturers. After
simulating compliance, the model
calculates impacts of the simulated
standard: technology costs, fuel savings
(both in gallons and dollars), CO2
reductions, social costs and benefits,
and safety impacts.
Today’s analysis reflects several
changes made to the CAFE model since
2012, when NHTSA used the model to
estimate the effects, costs, and benefits
of final CAFE standards for light-duty
vehicles produced during MYs 2017–
2021 and augural standards for MYs
2022–2025. Key changes relevant to this
analysis include the following:
• Expansion of model inputs,
procedures, and outputs to
accommodate technologies not included
in prior analyses,
• Updated approach to estimating the
combined effect of fuel-saving
technologies using large scale
simulation modeling,
• Modules that dynamically estimate
new vehicle sales and existing vehicle
scrappage in response to changes to new
vehicle prices that result from
manufacturers’ compliance actions,
• A safety module that estimates the
changes in light-duty traffic fatalities
resulting from changes to vehicle
exposure, vehicle retirement rates, and
reductions in vehicle mass to improve
fuel economy,
• Disaggregation of each
manufacturer’s fleet into separate
‘‘domestic’’ passenger car and ‘‘import’’
passenger car fleets to better represent
the statutory requirements of the CAFE
program,
• Changes to the algorithm used to
apply technologies, enabling more
explicit accounting of shared vehicle
components (engines, transmissions,
platforms) and ‘‘inheritance’’ of major
technology within or across powertrains
and/or platforms over time,
• An industry labor quantity module,
which estimates net changes in the
amount of U.S. automobile labor for
dealerships, Tier 1 and 2 supplier
companies, and original equipment
manufacturers (OEMs),
• Cost estimation of batteries for
electrification technologies incorporates
an updated version of Argonne National
Laboratory’s BatPAC (battery) model for
hybrid electric vehicles (HEVs), plug-in
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hybrid electric vehicles (PHEVs), and
battery electric vehicles (BEVs),
consistent with how we estimate
effectiveness for those values,
• Expanded accounting for CAFE
credits carried over from years prior to
those included in the analysis (a.k.a.
‘‘banked’’ credits) and application to
future CAFE deficits to better evaluate
anticipated manufacturer responses to
proposed standards,62
• The ability to represent a
manufacturer’s preference for fine
payment (rather than achieving full
compliance exclusively through fuel
economy improvements) on a year-byyear basis,
• Year-by-year simulation of how
manufacturers could comply with EPA’s
CO2 standards, including
Æ Calculation of vehicle models’ CO2
emission rates before and after
application of fuel-saving (and,
therefore, CO2-reducing) technologies,
Æ Calculation of manufacturers’ fleet
average CO2 emission rates,
Æ Calculation of manufacturers’ fleet
average CO2 emission rates under
attribute-based CO2 standards,
Æ Accounting for adjustments to
average CO2 emission rates reflecting
reduction of air conditioner refrigerant
leakage,
Æ Accounting for the treatment of
alternative fuel vehicles for CO2
compliance,
Æ Accounting for production
‘‘multipliers’’ for PHEVs, BEVs,
compressed natural gas (CNG) vehicles,
and fuel cell vehicles (FCVs),
Æ Accounting for transfer of CO2
credits between regulated fleets,
Æ Accounting for carried-forward
(a.k.a. ‘‘banked’’) CO2 credits, including
credits from model years earlier than
modeled explicitly.
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2. Sensitivity Cases and Why We
Examine Them
Today’s notice presents estimated
impacts of the proposed CAFE and CO2
standards defining the proposals,
relative to a baseline ‘‘no action’’
regulatory alternative under which the
standards announced in 2012 remain in
place through MY 2025 and continue
unchanged thereafter. Relative to this
same baseline, today’s notice also
presents analysis estimating impacts
under a range of other regulatory
62 While EPCA/EISA precludes NHTSA from
considering manufacturers’ potential use of credits
in model years for which the agency is establishing
new standards, NHTSA considers credit use in
earlier model years. Also, as allowed by NEPA,
NHTSA’s EISs present results of analysis that
considers manufacturers’ potential use of credits in
all model years, including those for which the
agency is establishing new standards.
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alternatives the agencies are
considering. All but one involve
different standards, and three involve a
gradual discontinuation of CAFE and
GHG adjustments reflecting the
application of technologies that improve
air conditioner efficiency or, in other
ways, improve fuel economy under
conditions not represented by longstanding fuel economy test procedures.
Like the baseline no action alternative,
all of these alternatives are more
stringent than the preferred alternative.
Section III and Section IV describe the
preferred and other regulatory
alternatives, respectively.
These alternatives were examined
because they will be considered as
options for the final rule. The agencies
seek comment on these alternatives,
seek any relevant data and information,
and will review responses. That review
could lead to the selection of one of the
other regulatory alternatives for the final
rule or some combination of the other
regulatory alternatives (e.g., combining
passenger cars standards from one
alternative with light truck standards
from a different alternative).
Because outputs depend on inputs
(e.g., the results of the analysis in terms
of quantities and kinds of technologies
required to meet different levels of
standards, and the societal and private
benefits associated with manufacturers
meeting different levels of standards
depend on input data, estimates, and
assumptions), the analysis also explores
the sensitivity of results to many of
these inputs. For example, the net
benefits of any regulatory alternative
will depend strongly on fuel prices well
beyond 2025. Fuel prices a decade and
more from now are not knowable with
certainty. The sensitivity analysis
involves repeating the ‘‘central’’ or
‘‘reference case’’ analysis under
alternative inputs (e.g., higher fuel
prices in one case, lower fuel prices in
another case), and exploring changes in
analytical results, which is discussed
further in the agencies’ Preliminary
Regulatory Impact Analysis (PRIA)
accompanying today’s notice.
B. Developing the Analysis Fleet for
Assessing Costs, Benefits, and Effects of
Alternative CAFE Standards
The following sections describe what
the analysis fleet is and why it is used,
how it was developed for this NPRM,
and the analysis-fleet-related topics on
which comment is sought.
1. Purpose of Developing and Using an
Analysis Fleet
The starting point for the evaluation
of the potential feasibility of different
stringency levels for future CAFE and
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CO2 standards is the analysis fleet,
which is a snapshot of the recent
vehicle market. The analysis fleet
provides a snapshot to project what
vehicles will exist in future model years
covered by the standards and what
technologies they will have, and then
evaluate what additional technologies
can feasibly be applied to those vehicles
in a cost-effective way to raise their fuel
economy and lower their CO2 emission
levels.63
Part of reflecting what vehicles will
exist in future model years is knowing
which vehicles are produced by which
manufacturers, how many of each are
sold, and whether they are passenger
cars or light trucks. This is important
because it improves our understanding
of the overall impacts of different levels
of CAFE and CO2 standards; overall
impacts result from industry’s response
to standards, and industry’s response is
made up of individual manufacturer
responses to the standards in light of the
overall market and their individual
assessment of consumer acceptance.
Having an accurate picture of
manufacturers’ existing fleets (and the
vehicle models in them) that will be
subject to future standards helps us
better understand individual
manufacturer responses to those future
standards in addition to potential
changes in those standards.
Another part of reflecting what
vehicles will exist in future model years
is knowing what technologies are
already on those vehicles. Accounting
for technologies already being on
vehicles helps avoid ‘‘double-counting’’
the value of those technologies, by
assuming they are still available to be
applied to improve fuel economy and
reduce CO2 emissions. It also promotes
more realistic determinations of what
additional technologies can feasibly be
applied to those vehicles: if a
manufacturer has already started down
a technological path to fuel economy or
performance improvements, we do not
assume it will completely abandon that
path because that would be unrealistic
and would not accurately represent
manufacturer responses to standards.
Each vehicle model (and configurations
of each model) in the analysis fleet,
therefore, has a comprehensive list of its
technologies, which is important
because different configurations may
have different technologies applied to
63 The CAFE model does not generate compliance
paths a manufacturer should, must, or will deploy.
It is intended as a tool to demonstrate a compliance
pathway a manufacturer could choose. It is almost
certain all manufacturers will make compliance
choices differing from those projected in the CAFE
model.
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them.64 Additionally, the analysis
accounts for platforms within
manufacturers’ fleets, recognizing
platforms will share technologies, and
the vehicles that make up that platform
should receive (or not receive)
additional technological improvements
together. The specific engineering
characteristics of each model/
configuration are available in the
aforementioned input file.65 For the
regulatory alternatives considered in
today’s proposal, estimates of rates at
which various technologies might be
expected to penetrate manufacturers’
fleets (and the overall market) are
summarized below in Sections VI and
VII, and in Chapter 6 of the
accompanying PRIA and in detailed
model output files available at NHTSA’s
website. A solid characterization of a
recent model year as an analytical
starting point helps to realistically
estimate ways manufacturers could
potentially respond to different levels of
standards, and the modeling strives to
realistically simulate how
manufacturers could progress from that
starting point. Nevertheless,
manufacturers can respond in many
ways beyond those represented in the
analysis (e.g., applying other
technologies, shifting production
volumes, changing vehicle footprint),
such that it is impossible to predict with
any certainty exactly how each
manufacturer will respond. Therefore,
recent trends in manufacturer
performance and technology
application, although of interest in
terms of understanding manufacturers’
current compliance positions, are not in
themselves innately indicative of future
potential.
Yet, another part of reflecting what
vehicles will exist in future model years
is having reasonable real-world
assumptions about when certain
technologies can be applied to vehicles.
Each vehicle model/configuration in the
analysis fleet also has information about
its redesign schedule, i.e., the last year
it was redesigned and when the
agencies expect it to be redesigned
again. Redesign schedules are a key part
of manufacturers’ business plans, as
each new product can cost more than
$1.0B and involve a significant portion
of a manufacturer’s scarce research,
64 Considering each vehicle model/configuration
also improves the ability to consider the differential
impacts of different levels of potential standards on
different manufacturers, since all vehicle model/
configurations ‘‘start’’ at different places, in terms
of the technologies they already have and how
those technologies are used.
65 Available with the model and other input files
supporting today’s announcement at https://
www.nhtsa.gov/corporate-average-fuel-economy/
compliance-and-effects-modeling-system.
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development, and manufacturing and
equipment budgets and resources.66
Manufacturers have repeatedly told the
agencies that sustainable business plans
require careful management of resources
and capital spending, and that the
length of time each product remains in
production is crucial to recouping the
upfront product development and plant/
equipment costs, as well as the capital
needed to fund the development and
manufacturing equipment needed for
future products. Because the production
volume of any given vehicle model
varies within a manufacturer’s product
line and also varies among different
manufacturers, redesign schedules
typically vary for each model and
manufacturer. Some (relatively few)
technological improvements are small
enough they can be applied in any
model year; others are major enough
they can only be cost-effectively applied
at a vehicle redesign, when many other
things about the vehicle are already
changing. Ensuring the CAFE model
makes technological improvements to
vehicles only when it is feasible to do
so also helps the analysis better
represent manufacturer responses to
different levels of standards.
A final important aspect of reflecting
what vehicles will exist in future model
years and potential manufacturer
responses to standards is estimating
how future sales might change in
response to different potential
standards. If potential future standards
appear likely to have major effects in
terms of shifting production from cars to
trucks (or vice versa), or in terms of
shifting sales between manufacturers or
groups of manufacturers, that is
important for the agencies to consider.
For previous analyses, the CAFE model
used a static forecast contained in the
analysis fleet input file, which specified
changes in production volumes over
time for each vehicle model/
configuration. This approach yielded
results that, in terms of production
volumes, did not change between
scenarios or with changes in important
model inputs. For example, very
stringent standards with very high
technology costs would result in the
same estimated production volumes as
less stringent standards with very low
technology costs.
New for today’s proposal, the CAFE
model begins with the first-year
production volumes (i.e., MY 2016 for
today’s analysis) and adjusts ensuing
sales mix year by year (between cars and
66 Shea, T. Why Does It Cost So Much For
Automakers To Develop New Models?, Autoblog
(Jul. 27, 2010), https://www.autoblog.com/2010/07/
27/why-does-it-cost-so-much-for-automakers-todevelop-new-models/.
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trucks, and between manufacturers)
endogenously as part of the analysis,
rather than using external forecasts of
future car/truck split and future
manufacturer sales volumes. This leads
the model to produce different estimates
of future production volumes under
different standards and in response to
different inputs, reflecting the
expectation that regulatory standards
and other external factors will, in fact,
impact the market.
The input file for the CAFE model
characterizing the analysis fleet 67
includes a large amount of data about
vehicle models/configurations, their
technological characteristics, the
manufacturers and fleets to which they
belong, and initial prices and
production volumes which provide the
starting points for projection (by the
sales model) to ensuing model years.
The following sections discuss aspects
of how the analysis fleet was built for
this proposal and seek comment on
those topics.
2. Source Data for Building the Analysis
Fleet
The source data for the vehicle
models/configurations in the analysis
fleet and their technologies is a central
input for the analysis. The sections
below discuss pros and cons of different
potential sources and what was used for
this proposal.
(a) Use of Confidential Business
Information Versus Publicly-Releasable
Sources
Since 2001, CAFE analysis has used
either confidential, forward-estimating
product plans from manufacturers, or
publicly available data on vehicles
already sold, as a starting point for
determining what technologies can be
applied to what vehicles in response to
potential different levels of standards.
These two sources present a tradeoff.
Confidential product plans
comprehensively represent what
vehicles a manufacturer expects to
produce in coming years, accounting for
plans to introduce new vehicles and
fuel-saving technologies and, for
example, plans to discontinue other
vehicles and even brands. This
information can be very thorough and
can improve the accuracy of the
analysis, but for competitive reasons,
most of this information must be
redacted prior to publication with
rulemaking documentation. This makes
it difficult for public commenters to
reproduce the analysis for themselves as
67 Available with the model and other input files
supporting today’s announcement at https://
www.nhtsa.gov/corporate-average-fuel-economy/
compliance-and-effects-modeling-system.
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they develop their comments. Some
non-industry commenters have also
expressed concern manufacturers would
have an incentive in the submitted
plans to (deliberately or not)
underestimate their future fuel economy
capabilities and overstate their
expectations about, for example, the
levels of performance of future vehicle
models in order to affect the analysis.
Since 2010, EPA and NHTSA have
based analysis fleets almost exclusively
on information from commercial and
public sources, starting with CAFE
compliance data and adding
information from other sources.
An analysis fleet based primarily on
public sources can be released to the
public, solving the issue of commenters
being unable to reproduce the overall
analysis when they want to. However,
industry commenters have argued such
an analysis fleet cannot accurately
reflect manufacturers actual plans to
apply fuel-saving technologies (e.g.,
manufacturers may apply turbocharging
to improve not just fuel economy, but
also to improve vehicle performance) or
manufacturers’ plans to change product
offerings by introducing some vehicles
and brands and discontinuing other
vehicles and brands, precisely because
that information is typically
confidential business information (CBI).
A fully-publicly-releasable analysis fleet
holds vehicle characteristics unchanged
over time and arguably lacks some level
of accuracy when projected into the
future. For example, over time,
manufacturers introduce new products
and even entire brands. On the other
hand, plans announced in press releases
do not always ultimately bear out, nor
do commercially-available third-party
forecasts. Assumptions could be made
about these issues to improve the
accuracy of a publicly-releasable
analysis fleet, but concerns include that
this information would either be largely
incorrect, or information would be
released that manufacturers would
consider CBI. We seek comment on how
to address this issue going forward,
recognizing the competing interests
involved and also recognizing typical
timeframes for CAFE and CO2 standards
rulemakings.
(b) Use of MY 2016 CAFE Compliance
Data Versus Other Starting Points
Based on the assumption that a
publicly-available analysis fleet
continues to be desirable, for this
NPRM, an analysis fleet was constructed
starting with CAFE compliance
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information from manufacturers.68
Information from MY 2016 was chosen
as the foundation for today’s analysis
fleet because, at the time the rulemaking
analysis was initiated, the 2016 fleet
represented the most up-to-date
information available in terms of
individual vehicle models and
configurations, production technology
levels, and production volumes. If MY
2017 data had been used while this
analysis was being developed, the
agencies would have needed to use
product planning information that could
not be made available to the public until
a later date.
The analysis fleet was initially
developed with 2016 mid-model year
compliance data because final
compliance data was not available at
that time, and the timing provided
manufacturers the opportunity to review
and comment on the characterization of
their vehicles in the fleet. With a view
toward developing an accurate
characterization of the 2016 fleet to
serve as an analytical starting point,
corrections and updates to mid-year
data (e.g., to production estimates) were
sought, in addition to corroboration or
correction of technical information
obtained from commercial and other
sources (to the extent that information
was not included in compliance data),
although future product planning
information from manufacturers (e.g.,
future product offerings, products to be
discontinued) was not requested, as
most manufacturers view such
information as CBI. Manufacturers
offered a range of corrections to indicate
engineering characteristics (e.g.,
footprint, curb weight, transmission
type) of specific vehicle model/
configurations, as well as updates to
fuel economy and production volume
estimates in mid-year reporting. After
following up on a case-by-case basis to
investigate significant differences, the
analysis fleet was updated.
Sales, footprint, and fuel economy
values with final compliance data were
also updated if that data was available.
In a few cases, final production and fuel
economy values may be slightly
different for specific model year 2016
vehicle models and configurations than
are indicated in today’s analysis;
however, other vehicle characteristics
(e.g., footprint, curb weight, technology
content) important to the analysis
should be accurate. While some
commenters have, in the past, raised
concerns that non-final CAFE
compliance data is subject to change,
68 CO emissions rates are directly related to fuel
2
economy levels, and the CAFE model uses the latter
to calculate the former.
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the potential for change is likely not
significant enough to merit using final
data from an earlier model year
reflecting a more outdated fleet.
Moreover, even ostensibly final CAFE
compliance data can sometimes be
subject to later revision (e.g., if errors in
fuel economy tests are discovered), and
the purpose of today’s analysis is not to
support enforcement actions but rather
to provide a realistic assessment of
manufacturers’ potential responses to
future standards.
Manufacturers integrated a significant
amount of new technology in the MY
2016 fleet, and this was especially true
for newly-designed vehicles launched in
MY 2016. While subsequent fleets will
involve even further application of
technology, using available data for MY
2016 provides the most realistic detailed
foundation for analysis that can be made
available publicly in full detail,
allowing stakeholders to independently
reproduce the analysis presented in this
proposal. Insofar as future product
offerings are likely to be more similar to
vehicles produced in 2016 than to
vehicles produced in earlier model
years, using available data regarding the
2016 model year provides the most
realistic, publicly releasable foundation
for constructing a forecast of the future
vehicle market for this proposal.
A number of comments to the Draft
TAR, EPA’s Proposed Determination,
and EPA’s 2017 Request for Comment 69
stated that the most up-to-date analysis
fleet possible should be used, because a
more up-to-date analysis fleet will better
capture how manufacturers apply
technology and will account better for
vehicle model/configuration
introductions and deletions.70 On the
other hand, some commenters suggested
that because manufacturers continue
improving vehicle performance and
utility over time, an older analysis fleet
should be used to estimate how the fleet
could have evolved had manufacturers
applied all technological potential to
69 82
FR 39551 (Aug. 21, 2017).
example, in 2016 comments to dockets
EPA–HQ–OAR–2015–0827 and NHTSA–2016–
0068, the Alliance of Automobile Manufacturers
commented that ‘‘the Alliance supports the use of
the most recent data available in establishing the
baseline fleet, and therefore believes that NHTSA’s
selection [of, at the time, model year 2015] was
more appropriate for the Draft TAR.’’ (Alliance at
82, Docket ID. EPA–HQ–OAR–2015–0827–4089)
Global Automakers commented that ‘‘a one-year
difference constitutes a technology change-over for
up to 20% of a manufacturer’s fleet. It was also
generally understood by industry and the agencies
that several new, and potentially significant,
technologies would be implemented in MY 2015.
The use of an older, outdated baseline can have
significant impacts on the modeling of subsequent
Reference Case and Control Case technologies.’’
(Global Automakers at A–10, Docket ID. EPA–HQ–
OAR–2015–0827–4009).
70 For
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fuel economy rather than continuing to
improve vehicle performance and
utility.71 Because manufacturers change
and improve product offerings over
time, conducting analysis with an older
analysis fleet (or with a fleet using fuel
economy levels and CO2 emissions rates
that have been adjusted to reflect an
assumed return to levels of performance
and utility typical of some past model
year) would miss this real-world trend.
While such an analysis could
demonstrate what industry could do if,
for example, manufacturers devoted all
technological improvements toward
raising fuel economy and reducing CO2
emissions (and if consumers decided to
purchase these vehicles), we do not
believe it would be consistent with a
transparent examination of what effects
different levels of standards would have
on individual manufacturers and the
fleet as a whole.
Generally, all else being equal, using
a newer analysis fleet will produce more
realistic estimates of impacts of
potential new standards than using an
outdated analysis fleet. However, among
relatively current options, a balance
must be struck between, on one hand,
inputs’ freshness, and on the other,
inputs’ completeness and accuracy.72
During assembly of the inputs for
today’s analysis, final compliance data
was available for the MY 2015 model
year but not in a few cases for MY 2016.
However, between mid-year compliance
information and manufacturers’ specific
updates discussed above, a robust and
detailed characterization of the MY
2016 fleet was developed. However,
while information continued to develop
regarding the MY 2017 and, to a lesser
extent MY 2018 and even MY 2019
fleets, this information was—even in
mid-2017—too incomplete and
inconsistent to be assembled with
71 For example, in 2016 comments to dockets
EPA–HQ–OAR–2015–0827 and NHTSA–2016–
0068, UCS stated ‘‘in modeling technology
effectiveness and use, the agencies should use 2010
levels of performance as the baseline.’’ (UCS at 4,
Docket ID. EPA–HQ–OAR–2015–0827–4016).
72 Comments provided through a recent peer
review of the CAFE model recognize the need for
this balance. For example, referring to NHTSA’s
2016 analysis documented in the draft TAR, one of
the peer reviewers commented as follows: ‘‘The
NHTSA decision to use MY 2015 data is wise. In
the TAR they point out that a MY 2016 foundation
would require the use of confidential data, which
is less desirable. Clearly they would also have a
qualitative vision of the MY 2016 landscape while
employing MY 2015 as a foundation. Although MY
2015 data may still be subject to minor revision,
this is unlikely to impact the predictive ability of
the model . . . A more complex alternative
approach might be to employ some 2016 changes
in technology, and attempt a blend of MY 2015 and
MY 2016, while relying of estimation gained from
only MY 2015 for sales. This approach may add
some relevancy in terms of technology, but might
introduce substantial error in terms of sales.’’
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confidence into an analysis fleet for
modeling supporting deliberations
regarding today’s proposal.
In short, the 2016 fleet was, in fact,
the most up-to-date fleet that could be
produced for this NPRM. Moreover,
during late 2016 and early 2017, nearly
all manufacturers provided comments
on the characterization of their vehicles
in the analysis fleet, and many provided
specific feedback about their vehicles,
including aerodynamic drag
coefficients, tire rolling resistance
values, transmission efficiencies, and
other information used in the analysis.
NHTSA worked with manufacturers to
clarify and correct some information
and integrated the information into a
single input file for use in the CAFE
model. Accordingly, the current
analysis fleet is reasonable to use for
purposes of the NPRM analysis.
As always, however, ways to improve
the analysis fleet used for subsequent
modeling to evaluate potential new
CAFE and CO2 standards will undergo
continuous consideration. As described
above, the compliance data is only the
starting point for developing the
analysis fleet; much additional
information comes directly from
manufacturers (such as details about
technologies, platforms, engines,
transmissions, and other vehicle
information, that may not be present in
compliance data), and other information
must come from commercial and public
sources (for example, fleet-wide
information like market share, because
individual manufacturers do not
provide this kind of information). If
newer compliance data (i.e., MY 2017)
becomes available and can be analyzed
during the pendency of this rulemaking,
and if all of the other necessary steps
can be performed, the analysis fleet will
be updated, as feasible, and made
publicly available. The agencies seek
comment on the option used today and
any other options, as well as on the
tradeoffs between, on one hand, fidelity
with manufacturers’ actual plans and,
on the other, the ability to make detailed
analysis inputs and outputs publicly
available.
(c) Observed Technology Content of
2016 Fleet
As explained above, the analysis fleet
is defined not only by the vehicle
models/configurations it contains but
also by the technologies on those
vehicles. Each vehicle model/
configuration in the analysis fleet has an
associated list of observed technologies
and equipment that can improve fuel
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economy and reduce CO2 emissions.73
With a portfolio of descriptive
technologies arranged by manufacturer
and model, the analysis fleet can be
summarized and project how vehicles in
that fleet may improve over time via the
application of additional technology.
In many cases, vehicle technology is
clearly observable from the 2016
compliance data (e.g., compliance data
indicates clearly which vehicles have
turbochargers and which have
continuously variable transmissions),
but in some cases technology levels are
less observable. For the latter, like levels
of mass reduction, the analysis
categorized levels of technology already
used in a given vehicle. Similarly,
engineering judgment was used to
determine if higher mass reduction
levels may be used practicably and
safely in a given vehicle.
Either in mid-year compliance data
for MY 2016 or, separately and at the
agencies’ invitation (as discussed
above), most manufacturers identified
most of the technology already present
in each of their MY 2016 vehicle model/
configurations. This information was
not as complete for all manufacturers’
products as needed for today’s analysis,
so in some cases, information was
supplemented with publicly available
data, typically from manufacturer media
sites. In limited cases, manufacturers
did not supply information, and
information from commercial and
publicly available sources was used.
(d) Mapping Technology Content of
2016 Fleet to Argonne Technology
Effectiveness Simulation Work
While each vehicle model/
configuration in the analysis fleet has its
list of observed technologies and
equipment, the ways in which
manufacturers apply technologies and
equipment do not always coincide
perfectly with how the analysis
characterizes the various technologies
that improve fuel economy and reduce
CO2 emissions. To improve how the
observed vehicle fleet ‘‘fits into’’ the
analysis, each vehicle model/
configuration is ‘‘mapped’’ to the full73 These technologies are generally grouped into
the following categories: Vehicle technologies
include mass reduction, aerodynamic drag
reduction, low rolling resistance tires, and others.
Engine technologies include engine attributes
describing fuel type, engine aspiration, valvetrain
configuration, compression ratio, number of
cylinders, size of displacement, and others.
Transmission technologies include different
transmission arrangements like manual, 6-speed
automatic, 8-speed automatic, continuously
variable transmission, and dual-clutch
transmissions. Hybrid and electric powertrains may
complement traditional engine and transmission
designs or replace them entirely.
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vehicle simulation modeling 74 by
Argonne National Laboratory that is
used to estimate the effectiveness of the
fuel economy-improving/CO2
emissions-reducing technologies
considered. Argonne produces fullvehicle simulation modeling for many
combinations of technologies, on many
types of vehicles, but it did not simulate
literally every single vehicle model/
configuration in the analysis fleet
because it would be impractical to
assemble the requisite detailed
information—much of which would
likely only be provided on a
confidential basis—specific to each
vehicle model/configuration and
because the scale of the simulation
effort would correspondingly increase
by at least two orders of magnitude.
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74 Full-vehicle simulation modeling uses software
and physics models to compute and estimate energy
use of a vehicle during explicit driving conditions.
Section II.D below contains more information on
the Argonne work for this analysis.
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Instead, Argonne simulated 10 different
vehicle types, corresponding to the
‘‘technology classes’’ generally used in
CAFE analysis over the past several
rulemakings (e.g., small car, small
performance car, pickup truck, etc.).
Each of those 10 different vehicle types
was assigned a set of ‘‘baseline
characteristics,’’ to which Argonne
added combinations of fuel-saving
technologies and then ran simulations
to determine the fuel economy achieved
when applying each combination of
technologies to that vehicle type given
its baseline characteristics. These
inputs, discussed at greater length in
Sections II.D and II.G, provide the basis
for the CAFE model’s estimation of fuel
economy levels and CO2 emission rates.
In the analysis fleet, inputs assign
each specific vehicle model/
configuration to a technology class, and
once there, map to the simulation
within that technology class most
closely matching the combination of
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observed technologies and equipment
on that vehicle.75 This mapping to a
specific simulation result most closely
representing a given vehicle model/
configuration’s initial technology
‘‘state’’ enables the CAFE model to
estimate the same vehicle model/
configuration’s fuel economy after
application of some other combination
of technologies, leading to an alternative
technology state.
BILLING CODE 4910–59–P
75 Mapping vehicle model/configurations in the
analysis fleet to Argonne simulations was generally
straightforward, but occasionally the mapping was
complicated by factors like a vehicle model/
configuration being a great match for simulations
within more than one technology class (in which
case, the model/configuration was assigned to the
technology class that it best matched), or when
technologies on the model/configuration were
difficult to observe directly (like friction reduction
or parasitic loss characteristics of a transmission, in
which case the agencies relied on manufacturerreported data or CBI to help map the vehicle to a
simulation).
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Table 11-1- List of Tech
•th Data S
for Tech
A.
t
Tech Group
Single Overhead Cam
Public Specifications
Basic Engines
Public Specifications
Basic Engines
Overhead Valve
SOHC
DOHC
OHV
Public Specifications
Basic Engines
Variable Valve Timing
VVT
Public Specifications
Basic Engines
Variable Valve Lift
VVL
Public Specifications
Basic Engines
Stoichiometric Gasoline Direct Injection
SGDI
Public Specifications
Basic Engines
Cylinder Deactivation
DEAC
Public Specifications
Basic Engines
Turbocharged Engine
TURBOl
Public Specifications
Advanced Engines
Advanced Turbocharged Engine
TURB02
Manufacturer CBI
Advanced Engines
Turbocharged Engine with Cooled Exhaust Gas Recirculation
CEGRl
Manufacturer CBI
Advanced Engines
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High Compression Ratio Engine
HCRl
Public Specifications
Advanced Engines
EPA High Compression Ratio Engine, with Cylinder Deactivation
HCR2
Not commercialized in MY 2016
Advanced Engines
Variable Compression Ratio Engine
VCR
Not commercialized in MY 2016
Advanced Engines
Advanced Cylinder Deactivation (Skip Fire)
ADEAC
Not commercialized in MY 2016
Advanced Engines
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Advanced Diesel Engine
ADSL
Public Specifications
Advanced Engines
Advanced Diesel Engine Improvements
DSLI
Not commercialized in MY 2016
Advanced Engines
Compressed Natural Gas
CNG
Public Specifications
Advanced Engines
Manual Transmission - 5 Speed
MT5
Public Specifications
Transmissions
Manual Transmission - 6 Speed
MT6
Public Specifications
Transmissions
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Manual Transmission - 7 Speed
MT7
Public Specifications
Transmissions
Automatic Transmission- 5 Speed
AT5
Public Specifications
Transmissions
Automatic Transmission- 6 Speed
AT6
Public Specifications
Transmissions
Automatic Transmission - 6 Speed with Efficiency Improvements
AT6L2
Manufacturer CBI
Transmissions
Automatic Transmission - 7 Speed
AT7
Public Specifications
Transmissions
Automatic Transmission- 8 Speed
AT8
Public Specifications
Transmissions
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Dual Overhead Cam
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Abbreviation
Frm 00024
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Technology Name
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Manufacturer CBT
Transmissions
Automatic Transmission - 8 Speed with Maximum Efficiency
Improvements
Automatic Transmission- 9 Speed
AT8L3
Not commercialized in MY 2016
Transmissions
AT9
Public Specifications
Transmissions
Automatic Transmission- 10 Speed
ATlO
Public Specifications
Transmissions
Automatic Transmission- 10 Speed with Maximum Efficiency
Improvements
Dual Clutch Transmission - 6 Speed
AT10L2
Not commercialized in MY 2016
Transmissions
DCT6
Public Specifications
Transmissions
Dual Clutch Transmission - 8 Speed
DCT8
Public Specifications
Transmissions
Continuously Variable Transmission
CVT
Public Specifications
Transmissions
Continuously Variable Transmission with Efficiency
Improvements
No Electrification Technologies (Baseline)
CVTL2A/
CVT2B
CONV
Manufacturer CBI
Transmissions
Public Specifications
Electrification
12V Start-Stop
SS12V
Public Specifications
Electrification
Belt Integrated Starter Generator
BISG
Public Specifications
Electrification
Sfmt 4725
Crank Integrated Starter Generator
CISG
Public Specifications
Electrification
Strong Hybrid Electric Vehicle, Parallel
SHEVP2
Public Specifications
Electrification
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Strong Hybrid Electric Vehicle, Power Split
SHEVPS
Public Specifications
Electrification
Plug-in Hybrid Vehicle with 30 miles of range
PHEV30
Public Specifications
Electrification
Plug-in Hybrid Vehicle with 50 miles of range
PHEV50
Public Specifications
Electrification
Battery Electric Vehicle with 200 miles of range
BEV200
Public Specifications
Electrification
Fuel Cell Vehicle
FCV
Public Specifications
Electrification
Baseline Tire Rolling Resistance
ROLLO
Manufacturer CBI
Rolling Resistance
Tire Rolling Resistance, 10% Improvement
ROLLlO
Manufacturer CBI
Rolling Resistance
Tire Rolling Resistance, 20% Improvement
ROLL20
Manufacturer CBI
Rolling Resistance
Baseline Mass Reduction Technology
MRO
Mass Reduction
Mass Reduction- 5% of Glider
MRl
Public Specifications &
Manufacturer CBI
Public Specifications &
Manufacturer CBI
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23:42 Aug 23, 2018
Automatic Transmission - 8 Speed with Efficiency Improvements
Mass Reduction
43009
EP24AU18.010
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Manufacturer CBI
Aerodynamic Drag
Aerodynamic Drag, 10% Drag Coefficient Reduction
AER010
Manufacturer CBI
Aerodynamic Drag
Aerodynamic Drag, 15% Drag Coefficient Reduction
AER015
Manufacturer CBI
Aerodynamic Drag
Aerodynamic Drag, 20% Drag Coefficient Reduction
AER020
Manufacturer CBI
Aerodynamic Drag
Electric Power Steering
EPS
Public Specifications
Improved Accessories
IACC
Manufacturer CBI
Low Drag Brakes
LDB
Manufacturer CBI
24AUP2
Secondary Axle Disconnect
SAX
Manufacturer CBI
Additional
Technologies
Additional
Technologies
Additional
Technologies
Additional
Technologies
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AEROO
Aerodynamic Drag, 5% Drag Coefficient Reduction
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EP24AU18.011
MR2
Mass Reduction - 10% of Glider
MR3
Mass Reduction- 15% of Glider
MR4
Mass Reduction - 20% of Glider
MR5
Mass Reduction
Mass Reduction
Mass Reduction
Mass Reduction
Aerodynamic Drag
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Baseline Aerodynamic Drag Technology
Public Specifications &
Manufacturer CBI
Public Specifications &
Manufacturer CBI
Public Specifications &
Manufacturer CBI
Public Specifications &
Manufacturer CBI
Manufacturer CBI
Mass Reduction - 7.5% of Glider
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BILLING CODE 4910–59–C
sradovich on DSK3GMQ082PROD with PROPOSALS2
(e) Shared Vehicle Platforms, Engines,
and Transmissions
Another aspect of characterizing
vehicle model/configurations in the
analysis fleet is based on whether they
share a ‘‘platform’’ with other vehicle
model/configurations. A ‘‘platform’’
refers to engineered underpinnings
shared on several differentiated
products. Manufacturers share and
standardize components, systems,
tooling, and assembly processes within
their products (and occasionally with
the products of another manufacturer) to
cost-effectively maintain vibrant
portfolios.76
Vehicle model/configurations derived
from the same platform are so identified
in the analysis fleet. Many
manufacturers’ use of vehicle platforms
is well documented in the public record
and widely recognized among the
vehicle engineering community.
Engineering knowledge, information
from trade publications, and feedback
from manufacturers and suppliers was
also used to assign vehicle platforms in
the analysis fleet.
When the CAFE model is deciding
where and how to add technology to
vehicles, if one vehicle on the platform
receives new technology, other vehicles
on the platform also receive the
technology as part of their next major
redesign or refresh.77 Similar to vehicle
platforms, manufacturers create engines
that share parts.78 One engine family
76 The concept of platform sharing has evolved
with time. Years ago, manufacturers rebadged
vehicles and offered luxury options only on
premium nameplates (and manufacturers shared
some vehicle platforms in limited cases). Today,
manufacturers share parts across highly
differentiated vehicles with different body styles,
sizes, and capabilities that may share the same
platform. For instance, the Honda Civic and Honda
CR–V share many parts and are built on the same
platform. Engineers design chassis platforms with
the ability to vary wheelbase, ride height, and even
driveline configuration. Assembly lines can
produce hatchbacks and sedans to cost-effectively
utilize manufacturing capacity and respond to shifts
in market demand. Engines made on the same line
may power small cars or mid-size sport utility
vehicles. Additionally, although the agencies’
analysis, like past CAFE analyses, considers
vehicles produced for sale in the U.S., the agency
notes these platforms are not constrained to vehicle
models built for sale in the United States; many
manufacturers have developed, and use, global
platforms, and the total number of platforms is
decreasing across the industry. Several automakers
(for example, General Motors and Ford) either plan
to, or already have, reduced their number of
platforms to less than 10 and account for the
overwhelming majority of their production volumes
on that small number of platforms.
77 The CAFE model assigns mass reduction
technology at a platform level, but many other
technologies may be assigned and shared at a
vehicle nameplate or vehicle model level.
78 For instance, manufacturers may use different
piston strokes on a common engine block or bore
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may appear on many vehicles on a
platform, and changes to that engine
may or may not carry through to all the
vehicles. Some engines are shared
across a range of different vehicle
platforms. Vehicle model/configurations
in the analysis fleet that share engines
belonging to the same platform are also
identified as such.
It is important to note that
manufacturers define common engines
differently. Some manufacturers
consider engines as ‘‘common’’ if the
engines shared an architecture,
components, or manufacturing
processes. Other manufacturers take a
narrower definition, and only assume
‘‘common’’ engines if the parts in the
engine assembly are the same. In some
cases, manufacturers designate each
engine in each application as a unique
powertrain.79 Engine families for each
manufacturer were tabulated and
assigned 80 based on data-driven
criteria. If engines shared a common
cylinder count and configuration,
displacement, valvetrain, and fuel type,
those engines may have been considered
together. Additionally, if the
compression ratio, horsepower, and
displacement of engines were only
slightly different, those engines were
considered to be the same for the
purposes of redesign and sharing.
Vehicles in the analysis fleet with the
same engine family will therefore adopt
engine technology in a coordinated
fashion.81 By grouping engines together,
the CAFE model controls future engine
out common engine block castings with different
diameters to create engines with an array of
displacements. Head assemblies for different
displacement engines may share many components
and manufacturing processes across the engine
family. Manufacturers may finish crankshafts with
the same tools, to similar tolerances. Engines on the
same architecture may share pistons, connecting
rods, and the same engine architecture may include
both six and eight cylinder engines.
79 For instance, a manufacturer may have listed
two engines for a pair that share designs for the
engine block, the crank shaft, and the head because
the accessory drive components, oil pans, and
engine calibrations differ between the two. In
practice, many engines share parts, tooling, and
assembly resources, and manufacturers often
coordinate design updates between two similar
engines.
80 Engine family is referred to in the analysis as
an ‘‘engine code.’’
81 Specifically, if such vehicles have different
design schedules (i.e., refresh and redesign
schedules), and a subset of vehicles using a given
engine add engine technologies in the course of a
redesign or refresh that occurs in an early model
year (e.g., 2018), other vehicles using the same
engine ‘‘inherit’’ these technologies at the soonest
ensuing refresh or redesign. This is consistent with
a view that, over time, most manufacturers are
likely to find it more practicable to shift production
to a new version of an engine than to indefinitely
continue production of both the new engine and a
‘‘legacy’’ engine.
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families to retain reasonable powertrain
complexity.82
Like with engines, manufacturers
often use transmissions that are the
same or similar on multiple vehicles.83
To reflect this reality, shared
transmissions were considered for
manufacturers as appropriate. To define
common transmissions, the agencies
considered transmission type (manual,
automatic, dual-clutch, continuously
variable), number of gears, and vehicle
architecture (front-wheel-drive, rearwheel-drive, all-wheel-drive based on a
front-wheel-drive platform, or all-wheeldrive based on a rear-wheel-drive
platform). If vehicles shared these
attributes, these transmissions were
grouped for the analysis. Vehicles in the
analysis fleet with the same
transmission configuration 84 will adopt
transmission technology together, as
described above.85
Having all vehicles that share a
platform (or engines that are part of a
family) adopt fuel economy-improving/
CO2 emissions-reducing technologies
together, subject to refresh/redesign
constraints, reflects the real-world
considerations described above but also
overlooks some decisions manufacturers
might make in the real world in
response to market pull, meaning that
even though the analysis fleet is
incredibly complex, it is also oversimplified in some respects compared to
the real world. For example, the CAFE
model does not currently attempt to
simulate the potential for a
manufacturer to shift the application of
technologies to improve performance
rather than fuel economy. Therefore, the
model’s representation of the
‘‘inheritance’’ of technology can lead to
estimates a manufacturer might
eventually exceed fuel economy
82 This does mean, however, that for
manufacturers that submitted highly atomized
engine and transmission portfolios, there is a
practical cap on powertrain complexity and the
ability of the manufacturer to optimize the
displacement of (a.k.a. ‘‘right size’’) engines
perfectly for each vehicle configuration.
83 Manufacturers may produce transmissions that
have nominally different machining to castings, or
manufacturers may produce transmissions that are
internally identical, except for final output gear
ratio. In some cases, manufacturers sub-contract
with suppliers that deliver whole transmissions. In
other cases, manufacturers form joint-ventures to
develop shared transmissions, and these
transmission platforms may be offered in many
vehicles across manufacturers. Manufacturers use
supplier and joint-venture transmissions to a greater
extent than engines.
84 Transmission configurations are referred to in
the analysis as ‘‘transmission codes.’’
85 Similar to the inheritance approach outlined
for engines, if one vehicle application of a shared
transmission family upgraded the transmission,
other vehicle applications also upgraded the
transmission at the next refresh or redesign year.
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standards as technology continues to
propagate across shared platforms and
engines. In the past, there were some
examples of extended periods during
which some manufacturers exceeded
one or both of the CAFE and/or GHG
standards, but in plenty of other
examples, manufacturers chose to
introduce (or even reintroduce)
technological complexity into their
vehicle lineups in response to buyer
preferences. Going forward, and
recognizing the recent trend for
consolidating platforms, it seems likely
manufacturers will be more likely to
choose efficiency over complexity in
this regard; therefore, the potential
should be lower that today’s analysis
turns out to be over-simplified
compared to the real world.
Options will be considered to further
refine the representation of sharing and
inheritance of technology, possibly
including model revisions to account for
tradeoffs between fuel economy and
performance when applying technology.
Please provide comments on the sharing
and inheritance-related aspects of the
analysis fleet and the CAFE model along
with information that would support
refinement of the current approach or
development and implementation of
alternative approaches.
(f) Estimated Product Design Cycles
sradovich on DSK3GMQ082PROD with PROPOSALS2
Another aspect of characterizing
vehicle model/configurations in the
analysis fleet is based on when they can
next be refreshed or redesigned.
Redesign schedules play an important
role in determining when new
technologies may be applied. Many
technologies that improve fuel economy
and reduce CO2 emissions may be
difficult to incorporate without a major
product redesign. Therefore, each
vehicle model in the analysis fleet has
an associated redesign schedule, and the
CAFE model uses that schedule to
restrict significant advances in some
technologies (like major mass reduction)
to redesign years, while allowing
manufacturers to include minor
advances (such as improved tire rolling
resistance) during a vehicle ‘‘refresh,’’ or
a smaller update made to a vehicle,
which can happen between redesigns.
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In addition to refresh and redesign
schedules associated with vehicle
model/configurations, vehicles that
share a platform subsequently have
platform-wide refresh and redesign
schedules for mass reduction
technologies.
To develop the refresh/redesign
cycles used for the MY 2016 vehicles in
the analysis fleet, information from
commercially available sources was
used to project redesign cycles through
MY 2022, as for NHTSA’s analysis for
the Draft TAR published in 2016.86
Commercially available sources’
estimates through MY 2022 are
generally supported by detailed
consideration of public announcements
plus related intelligence from suppliers
and other sources, and recognize that
uncertainty increases considerably as
the forecasting horizon is extended. For
MYs 2023–2035, in recognition of that
uncertainty, redesign schedules were
extended considering past pacing for
each product, estimated schedules
through MY 2022, and schedules for
other products in the same technology
classes. As mentioned above, potentially
confidential forward-looking
information was not requested from
manufacturers; nevertheless, all
manufacturers had an opportunity to
review the estimates of product-specific
redesign schedules, a few manufacturers
provided related forecasts and, for the
most part, that information corroborated
the estimates.
Some commenters suggested
supplanting these estimated redesign
schedules with estimates applying faster
86 In some cases, data from commercially
available sources was found to be incomplete or
inconsistent with other available information. For
instance, commercially available sources identified
some newly imported vehicles as new platforms,
but the international platform was midway through
the product lifecycle. While new to the U.S. market,
treating these vehicles as new entrants would have
resulted in artificially short redesign cycles if
carried forward, in some cases. Similarly,
commercially available sources labeled some
product refreshes as redesigns, and vice versa. In
these limited cases, the data was revised to be
consistent with other available information or
typical redesign and refresh schedules, for the
purpose of the CAFE modeling. In these limited
cases, the forecast time between redesigns and
refreshes was updated to match the observed past
product timing.
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cycles (e.g., four to five years), and this
approach was considered for the
analysis.87 Some manufacturers tend to
operate with faster redesign cycles and
may continue to do so, and
manufacturers tend to redesign some
products more frequently than others.
However, especially considering that
information presented by manufacturers
largely supports estimates discussed
above, applying a ‘‘one size fits all’’
acceleration of redesign cycles would
likely not improve the analysis; instead,
doing so would likely reduce
consistency with the real world,
especially for light trucks. Moreover, if
some manufacturers accelerate
redesigns in response to new standards,
doing so would likely involve costs
(greater levels of stranded capital,
reduced opportunity to benefit from
‘‘learning’’-related cost reductions)
greater than reflected in other inputs to
the analysis. However, a wider range of
technologies can practicably be applied
during mid-cycle ‘‘freshenings’’ than
has been represented by past analyses,
and this part of the analysis has been
expanded, as discussed below in
Section II.D.88 Also, in the sensitivity
analysis supporting today’s proposal
and presented in Chapter 13 of the
PRIA, one case involving faster redesign
schedules and one involving slower
redesign schedules has been analyzed.
Manufacturers use diverse strategies
with respect to when, and how often
they update vehicle designs. While most
vehicles have been redesigned sometime
in the last five years, many vehicles
have not. In particular, vehicles with
lower annual sales volumes tend to be
redesigned less frequently, perhaps
giving manufacturers more time to
amortize the investment needed to bring
the product to market. In some cases,
manufacturers continue to produce and
sell vehicles designed more than a
decade ago.
87 In response to the EPA’s August 21, 2017,
Request for Comments (docket numbers EPA–HQ–
OAR–2015–0827 and NHTSA–2016–0068), see, e.g.,
CARB at 28 (Docket ID. EPA–HQ–OAR–2015–0827–
9197), EDF at 12 (Docket ID. EPA–HQ–OAR–2015–
0827–9203), and NRDC, et. al. at 29–33 (Docket ID.
EPA–HQ–OAR–2015–0827–9826).
88 NRDC, et al., at 32.
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Each manufacturer may use different
strategies throughout their product
portfolio, and a component of each
strategy may include the timing of
89 Technology class, or tech class, refers to a
group of fuel-economy simulations of similar
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refresh and redesign cycles. Table II–3
below summarizes the average time
between redesigns, by manufacturer, by
vehicle technology class.89 Dashes mean
the manufacturer has no volume in that
vehicle technology class in the MY 2016
analysis fleet. Across the industry,
manufacturers average 6.5 years
between product redesigns.
vehicles. As explained, each vehicle is assigned to
a representative simulation to estimate technology
effectiveness for purposes of the analysis.
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There are a few notable observations
from this table. Pick-up trucks have
much longer redesign schedules (7.8
years on average) than small cars (5.5
years on average). Some manufacturers
redesign vehicles often (every 5.2 years
in the case of Hyundai), while other
manufacturers redesign vehicles less
often (FCA waits on average 8.6 years
between vehicle redesigns). Across the
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industry, light-duty vehicle designs last
for about 6.5 years.
Even if two manufacturers have
similar redesign cadence, the model
years in which the redesigns occur may
still be different and dependent on
where each of the manufacturer’s
products are in their life cycle.
Table II–4 summarizes the average age
of manufacturers’ offering by vehicle
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technology class. A value of ‘‘0.0’’
means that every vehicle for a
manufacturer in that vehicle technology
class, represented in the MY 2016
analysis fleet was new in MY 2016.
Across the industry, manufacturers
redesigned MY 2016 vehicles an average
of 3.2 years earlier.
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Based on historical observations and
refresh/redesign schedule forecasts,
careful consideration to redesign cycles
for each manufacturer and each vehicle
is important. Simply assuming every
vehicle is redesigned by 2021 and by
2025 is not appropriate, as this would
misrepresent both the likely timing of
redesigns and the likely time between
redesigns in most cases.
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C. Development of Footprint-Based
Curve Shapes
As in the past four CAFE rulemakings,
the most recent two of which included
related standards for CO2 emissions,
NHTSA and EPA are proposing to set
attribute-based CAFE standards that are
defined by a mathematical function of
vehicle footprint, which has observable
correlation with fuel economy and
90 49
U.S.C. 32902(a)(3)(A).
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vehicle emissions. EPCA, as amended
by EISA, expressly requires that CAFE
standards for passenger cars and light
trucks be based on one or more vehicle
attributes related to fuel economy and
be expressed in the form of a
mathematical function.90 While the
CAA includes no specific requirements
regarding GHG regulation, EPA has
chosen to adopt standards consistent
with the EPCA/EISA requirements in
the interest of simplifying compliance
for the industry since 2010.91 Section
II.C.1 describes the advantages of
attribute standards, generally. Section
II.C.2 explains the agencies’ specific
decision to use vehicle footprint as the
attribute over which to vary stringency
for past and current rules. Section II.C.3
discusses the policy considerations in
selecting the specific mathematical
function. Section II.C.4 discusses the
Under attribute-based standards,
every vehicle model has fuel economy
and CO2 targets, the levels of which
depend on the level of that vehicle’s
determining attribute (for this proposed
rule, footprint is the determining
attribute, as discussed below). The
manufacturer’s fleet average
performance is calculated by the
harmonic production-weighted average
of those targets, as defined below:
91 Such an approach is permissible under section
202(a) of the CAA, and EPA has used the attribute-
based approach in issuing standards under
analogous provisions of the CAA.
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methodologies used to develop current
attribute-based standards, and the
agencies’ current proposal to continue
to do so for MYs 2022–2026. Section
II.C.5 discusses the methodologies used
to reconsider the mathematical function
for the proposed standards.
1. Why attribute-based standards, and
what are the benefits?
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Here, i represents a given model 92 in
a manufacturer’s fleet, Productioni
represents the U.S. production of that
model, and Targeti represents the target
as defined by the attribute-based
standards. This means no vehicle is
required to meet its target; instead,
manufacturers are free to balance
improvements however they deem best
within (and, given credit transfers, at
least partially across) their fleets.
The idea is to select the shape of the
mathematical function relating the
standard to the fuel economy-related
attribute to reflect the trade-offs
manufacturers face in producing more
of that attribute over fuel efficiency (due
to technological limits of production
and relative demand of each attribute).
If the shape captures these trade-offs,
every manufacturer is more likely to
continue adding fuel efficient
technology across the distribution of the
attribute within their fleet, instead of
potentially changing the attribute—and
other correlated attributes, including
fuel economy—as a part of their
compliance strategy. Attribute-based
standards that achieve this have several
advantages.
First, assuming the attribute is a
measurement of vehicle size, attributebased standards reduce the incentive for
manufacturers to respond to CAFE
standards by reducing vehicle size in
ways harmful to safety.93 Larger
vehicles, in terms of mass and/or crush
space, generally consume more fuel, but
are also generally better able to protect
occupants in a crash.94 Because each
92 If a model has more than one footprint variant,
here each of those variants is treated as a unique
model, i, since each footprint variant will have a
unique target.
93 The 2002 NAS Report described at length and
quantified the potential safety problem with average
fuel economy standards that specify a single
numerical requirement for the entire industry. See
Transportation Research Board and National
Research Council. 2002. Effectiveness and Impact of
Corporate Average Fuel Economy (CAFE)
Standards, Washington, DC: The National
Academies Press (‘‘2002 NAS Report’’) at 5, finding
12, available at https://www.nap.edu/catalog/
10172/effectiveness-and-impact-of-corporateaverage-fuel-economy-cafe-standards (last accessed
June 15, 2018). Ensuing analyses, including by
NHTSA, support the fundamental conclusion that
standards structured to minimize incentives to
downsize all but the largest vehicles will tend to
produce better safety outcomes than flat standards.
94 Bento, A., Gillingham, K., & Roth, K. (2017).
The Effect of Fuel Economy Standards on Vehicle
Weight Dispersion and Accident Fatalities. NBER
Working Paper No. 23340. Available at https://
www.nber.org/papers/w23340 (last accessed June
15, 2018).
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vehicle model has its own target
(determined by a size-related attribute),
properly fitted attribute-based standards
provide little, if any, incentive to build
smaller vehicles simply to meet a fleetwide average, because smaller vehicles
are subject to more stringent compliance
targets.
Second, attribute-based standards, if
properly fitted, better respect
heterogeneous consumer preferences
than do single-valued standards. As
discussed above, a single-valued
standard encourages a fleet mix with a
larger share of smaller vehicles by
creating incentives for manufacturers to
use downsizing the average vehicle in
their fleet (possibly through fleet
mixing) as a compliance strategy, which
may result in manufacturers building
vehicles for compliance reasons that
consumers do not want. Under a sizerelated, attribute-based standard,
reducing the size of the vehicle is a less
viable compliance strategy because
smaller vehicles have more stringent
regulatory targets. As a result, the fleet
mix under such standards is more likely
to reflect aggregate consumer demand
for the size-related attribute used to
determine vehicle targets.
Third, attribute-based standards
provide a more equitable regulatory
framework across heterogeneous
manufacturers who may each produce
different shares of vehicles along
attributes correlated with fuel
economy.95 A single, industry-wide
CAFE standard imposes
disproportionate cost burden and
compliance challenges on
manufacturers who produce more
vehicles with attributes inherently
correlated with lower fuel economy—
i.e. manufacturers who produce, on
average, larger vehicles. As discussed
above, retaining the ability for
manufacturers to produce vehicles
which respect heterogeneous market
preferences is an important
consideration. Since manufacturers may
target different markets as a part of their
business strategy, ensuring that these
manufacturers do not incur a
disproportionate share of the regulatory
cost burden is an important part of
conserving consumer choices within the
market.
95 2002
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2. Why footprint as the attribute?
It is important that the CAFE and CO2
standards be set in a way that does not
encourage manufacturers to respond by
selling vehicles that are less safe.
Vehicle size is highly correlated with
vehicle safety—for this reason, it is
important to choose an attribute
correlated with vehicle size (mass or
some dimensional measure). Given this
consideration, there are several policy
and technical reasons why footprint is
considered to be the most appropriate
attribute upon which to base the
standards, even though other vehicle
size attributes (notably, curb weight) are
more strongly correlated with fuel
economy and emissions.
First, mass is strongly correlated with
fuel economy; it takes a certain amount
of energy to move a certain amount of
mass. Footprint has some positive
correlation with frontal surface area,
likely a negative correlation with
aerodynamics, and therefore fuel
economy, but the relationship is less
deterministic. Mass and crush space
(correlated with footprint) are both
important safety considerations. As
discussed below and in the
accompanying PRIA, NHTSA’s research
of historical crash data indicates that
holding footprint constant, and
decreasing the mass of the largest
vehicles, will have a net positive safety
impact to drivers overall, while holding
footprint constant and decreasing the
mass of the smallest vehicles will have
a net decrease in fleetwide safety.
Properly fitted footprint-based standards
provide little, if any, incentive to build
smaller vehicles to meet CAFE and CO2
standards, and therefore help minimize
the impact of standards on overall fleet
safety.
Second, it is important that the
attribute not be easily manipulated in a
manner that does not achieve the goals
of EPCA or other goals, such as safety.
Although weight is more strongly
correlated with fuel economy than
footprint, there is less risk of
manipulation (changing the attribute(s)
to achieve a more favorable target) by
increasing footprint under footprintbased standards than there would be by
increasing vehicle mass under weightbased standards. It is relatively easy for
a manufacturer to add enough weight to
a vehicle to decrease its applicable fuel
economy target a significant amount, as
compared to increasing vehicle
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• Given the same industry-wide
average required fuel economy or CO2
standard, dramatically steeper standards
tend to place greater compliance
burdens on limited-line manufacturers
(depending of course, on which vehicles
are being produced).
• If cutpoints are adopted, given the
same industry-wide average required
fuel economy, moving small-vehicle
cutpoints to the left (i.e., up in terms of
fuel economy, down in terms of CO2
emissions) discourages the introduction
of small vehicles, and reduces the
incentive to downsize small vehicles in
ways that could compromise overall
highway safety.
• If cutpoints are adopted, given the
same industry-wide average required
fuel economy, moving large-vehicle
cutpoints to the right (i.e., down in
terms of fuel economy, up in terms of
CO2 emissions) better accommodates the
design requirements of larger vehicles
— especially large pickups — and
extends the size range over which
downsizing is discouraged.
3. What mathematical function should
be used to specify footprint-based
standards?
In requiring NHTSA to ‘‘prescribe by
regulation separate average fuel
economy standards for passenger and
non-passenger automobiles based on 1
or more vehicle attributes related to fuel
economy and express each standard in
the form of a mathematical function’’,
EPCA/EISA provides ample discretion
regarding not only the selection of the
attribute(s), but also regarding the
nature of the function. The CAA
provides no specific direction regarding
CO2 regulation, and EPA has continued
to harmonize this aspect of its CO2
regulations with NHTSA’s CAFE
regulations. The relationship between
fuel economy (and GHG emissions) and
footprint, though directionally clear
(i.e., fuel economy tends to decrease and
CO2 emissions tend to increase with
increasing footprint), is theoretically
vague, and quantitatively uncertain; in
other words, not so precise as to a priori
yield only a single possible curve.
The decision of how to specify this
mathematical function therefore reflects
some amount of judgment. The function
can be specified with a view toward
achieving different environmental and
petroleum reduction goals, encouraging
different levels of application of fuelsaving technologies, avoiding any
adverse effects on overall highway
safety, reducing disparities of
manufacturers’ compliance burdens,
and preserving consumer choice, among
other aims. The following are among the
specific technical concerns and
resultant policy tradeoffs the agencies
have considered in selecting the details
of specific past and future curve shapes:
• Flatter standards (i.e., curves)
increase the risk that both the size of
vehicles will be reduced, potentially
compromising highway safety, and
reducing any utility consumers would
have gained from a larger vehicle.
• Steeper footprint-based standards
may create incentives to upsize
vehicles, potentially oversupplying
vehicles of certain footprints beyond
what consumers would naturally
demand, and thus increasing the
possibility that fuel savings and CO2
reduction benefits will be forfeited
artificially.
• Given the same industry-wide
average required fuel economy or CO2
standard, flatter standards tend to place
greater compliance burdens on full-line
manufacturers.
Here, Target is the fuel economy
target applicable to vehicles of a given
footprint in square feet (Footprint). The
upper asymptote, a, and the lower
asymptote, b, are specified in mpg; the
reciprocal of these values represent the
lower and upper asymptotes,
respectively, when the curve is instead
specified in gallons per mile (gpm). The
98 The right cutpoint for the light truck curve was
moved further to the right for MYs 2017–2021, so
that more possible footprints would fall on the
sloped part of the curve. In order to ensure that, for
all possible footprints, future standards would be at
least as high as MY 2016 levels, the final standards
for light trucks for MYs 2017–2021 is the maximum
of the MY 2016 target curves and the target curves
for the give MY standard. This is defined further in
the 2012 final rule. See 77 FR 62624, at 62699–700
(Oct. 15, 2012).
96 See
74 FR at 14359 (Mar. 30, 2009).
74 FR 14196, 14363–14370 (Mar. 30, 2009)
for NHTSA discussion of curve fitting in the MY
2011 CAFE final rule.
97 See
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4. What mathematical functions have
been used previously, and why?
Notwithstanding the aforementioned
discretion under EPCA/EISA, data
should inform consideration of potential
mathematical functions, but how
relevant data is defined and interpreted,
and the choice of methodology for
fitting a curve to that data, can and
should include some consideration of
specific policy goals. This section
summarizes the methodologies and
policy concerns that were considered in
developing previous target curves (for a
complete discussion see the 2012 FRIA).
As discussed below, the MY 2011
final curves followed a constrained
logistic function defined specifically in
the final rule.97 The MYs 2012–2021
final standards and the MYs 2022–2025
augural standards are defined by
constrained linear target functions of
footprint, as shown below: 98
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footprint, which is a much more
complicated change that typically takes
place only with a vehicle redesign.
Further, some commenters on the MY
2011 CAFE rulemaking were concerned
that there would be greater potential for
gaming under multi-attribute standards,
such as those that also depend on
weight, torque, power, towing
capability, and/or off-road capability. As
discussed in NHTSA’s MY 2011 CAFE
final rule,96 it is anticipated that the
possibility of gaming is lowest with
footprint-based standards, as opposed to
weight-based or multi-attribute-based
standards. Specifically, standards that
incorporate weight, torque, power,
towing capability, and/or off-road
capability in addition to footprint would
not only be more complex, but by
providing degrees of freedom with
respect to more easily-adjusted
attributes, they could make it less
certain that the future fleet would
actually achieve the projected average
fuel economy and CO2 levels. This is
not to say that a footprint-based system
will eliminate gaming, or that a
footprint-based system will eliminate
the possibility that manufacturers will
change vehicles in ways that
compromise occupant protection, but
footprint-based standards achieve the
best balance among affected
considerations. Please provide
comments on whether vehicular
footprint is the most suitable attribute
upon which to base standards.
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slope, c, and the intercept, d, of the
linear portion of the curve are specified
as gpm per change in square feet, and
gpm, respectively.
The min and max functions will take
the minimum and maximum values
within their associated parentheses.
Thus, the max function will first find
the maximum of the fitted line at a
given footprint value and the lower
asymptote from the perspective of gpm.
If the fitted line is below the lower
asymptote it is replaced with the floor,
which is also the minimum of the floor
and the ceiling by definition, so that the
target in mpg space will be the
reciprocal of the floor in mpg space, or
simply, a. If, however, the fitted line is
not below the lower asymptote, the
fitted value is returned from the max
function and the min function takes the
minimum value of the upper asymptote
(in gpm space) and the fitted line. If the
fitted value is below the upper
asymptote, it is between the two
asymptotes and the fitted value is
appropriately returned from the min
function, making the overall target in
mpg the reciprocal of the fitted line in
gpm. If the fitted value is above the
upper asymptote, the upper asymptote
is returned is returned from the min
function, and the overall target in mpg
is the reciprocal of the upper asymptote
in gpm space, or b.
In this way curves specified as
constrained linear functions are
specified by the following parameters:
a = upper limit (mpg)
b = lower limit (mpg)
c = slope (gpm per sq. ft.)
d = intercept (gpm)
sradovich on DSK3GMQ082PROD with PROPOSALS2
The slope and intercept are specified
as gpm per sq. ft. and gpm instead of
mpg per sq. ft. and mpg because fuel
consumption and emissions appear
roughly linearly related to gallons per
mile (the reciprocal of the miles per
gallon).
(a) NHTSA in MY 2008 and MY 2011
CAFE (Constrained Logistic)
For the MY 2011 CAFE rule, NHTSA
estimated fuel economy levels by
footprint from the MY 2008 fleet after
normalization for differences in
technology,99 but did not make
adjustments to reflect other vehicle
attributes (e.g., power-to-weight ratios).
Starting with the technology-adjusted
passenger car and light truck fleets,
NHTSA used minimum absolute
deviation (MAD) regression without
sales weighting to fit a logistic form as
a starting point to develop mathematical
99 See 74 FR 14196, 14363–14370 (Mar. 30, 2009)
for NHTSA discussion of curve fitting in the MY
2011 CAFE final rule.
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functions defining the standards.
NHTSA then identified footprints at
which to apply minimum and
maximum values (rather than letting the
standards extend without limit) and
transposed these functions vertically
(i.e., on a gallons-per-mile basis,
uniformly downward) to produce the
promulgated standards. In the preceding
rule, for MYs 2008–2011 light truck
standards, NHTSA examined a range of
potential functional forms, and
concluded that, compared to other
considered forms, the constrained
logistic form provided the expected and
appropriate trend (decreasing fuel
economy as footprint increases), but
avoided creating ‘‘kinks’’ the agency
was concerned would provide
distortionary incentives for vehicles
with neighboring footprints.100
(b) MYs 2012–2016 Standards
(Constrained Linear)
For the MYs 2012–2016 rule,
potential methods for specifying
mathematical functions to define fuel
economy and CO2 standards were
reevaluated. These methods were fit to
the same MY 2008 data as the MY 2011
standard. Considering these further
specifications, the constrained logistic
form, if applied to post-MY 2011
standards, would likely contain a steep
mid-section that would provide undue
incentive to increase the footprint of
midsize passenger cars.101 A range of
methods to fit the curves would have
been reasonable, and a minimum
absolute deviation (MAD) regression
without sales weighting on a
technology-adjusted car and light truck
fleet was used to fit a linear equation.
This equation was used as a starting
point to develop mathematical functions
defining the standards. Footprints were
then identified at which to apply
minimum and maximum values (rather
than letting the standards extend
without limit). Finally, these
constrained/piecewise linear functions
were transposed vertically (i.e., on a
gpm or CO2 basis, uniformly downward)
by multiplying the initial curve by a
single factor for each MY standard to
produce the final attribute-based targets
for passenger cars and light trucks
described in the final rule.102 These
transformations are typically presented
100 See 71 FR 17556, 17609–17613 (Apr. 6, 2006)
for NHTSA discussion of ‘‘kinks’’ in the MYs 2008–
2011 light truck CAFE final rule (there described as
‘‘edge effects’’). A ‘‘kink,’’ as used here, is a portion
of the curve where a small change in footprint
results in a disproportionally large change in
stringency.
101 75 FR at 25362.
102 See generally 74 FR at 49491–96; 75 FR at
25357–62.
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as percentage improvements over a
previous MY target curve.
(c) MYs 2017 and Beyond Standards
(Constrained Linear)
The mathematical functions finalized
in 2012 for MYs 2017 and beyond
changed somewhat from the functions
for the MYs 2012–2016 standards. These
changes were made to both address
comments from stakeholders, and to
further consider some of the technical
concerns and policy goals judged more
preeminent under the increased
uncertainty of the impacts of finalizing
and proposing standards for model
years further into the future.103
Recognizing the concerns raised by fullline OEMs, it was concluded that
continuing increases in the stringency of
the light truck standards would be more
feasible if the light truck curve for MYs
2017 and beyond was made steeper than
the MY 2016 truck curve and the right
(large footprint) cut-point was extended
only gradually to larger footprints. To
accommodate these considerations, the
2012 final rule finalized the slope fit to
the MY 2008 fleet using a salesweighted, ordinary least-squares
regression, using a fleet that had
technology applied to make the
technology application across the fleet
more uniform, and after adjusting the
data for the effects of weight-tofootprint. Information from an updated
MY 2010 fleet was also considered to
support this decision. As the curve was
vertically shifted (with fuel economy
specified as mpg instead of gpm or CO2
emissions) upwards, the right cutpoint
was progressively moved for the light
truck curves with successive model
years, reaching the final endpoint for
MY 2021; this is further discussed and
shown in Chapter 4.3 of the PRIA.
5. Reconsidering the Mathematical
Functions for This Proposal
(a) Why is it important to reconsider the
mathematical functions?
By shifting the developed curves by a
single factor, it is assumed that the
underlying relationship of fuel
consumption (in gallons per mile) to
vehicle footprint does not change
significantly from the model year data
used to fit the curves to the range of
model years for which the shifted curve
shape is applied to develop the
standards. However, it must be
recognized that the relationship
103 The MYs 2012–2016 final standards were
signed April 1st, 2010—putting 6.5 years between
its signing and the last affected model year, while
the MYs 2017–2021 final standards were signed
August 28th, 2012—giving just more than nine
years between signing and the last affected final
standards.
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conducted that do not require
underlying engineering models of how
fuel economy and footprint might be
expected to be related, and a separate
analysis that uses vehicle simulation
results as the basis to estimate the
relationship from a perspective more
explicitly informed by engineering
theory was conducted as well. Despite
changes in the new vehicle fleet both in
terms of technologies applied and in
market demand, the underlying
statistical relationship between footprint
and fuel economy has not changed
significantly since the MY 2008 fleet
used for the 2012 final rule; therefore,
it is proposed to continue to use the
curve shapes fit in 2012. The analysis
and reasoning supporting this decision
follows.
(b) What statistical analyses did NHTSA
consider?
In considering how to address the
various policy concerns discussed
above, data from the MY 2016 fleet was
considered, and a number of descriptive
statistical analyses (i.e., involving
observed fuel economy levels and
footprints) using various statistical
methods, weighting schemes, and
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adjustments to the data to make the
fleets less technologically heterogeneous
were performed. There were several
adjustments to the data that were
common to all of the statistical analyses
considered.
With a view toward isolating the
relationship between fuel economy and
footprint, the few diesels in the fleet
were excluded, as well as the limited
number of vehicles with partial or full
electric propulsion; when the fleet is
normalized so that technology is more
homogenous, application of these
technologies is not allowed. This is
consistent with the methodology used
in the 2012 final rule.
The above adjustments were applied
to all statistical analyses considered,
regardless of the specifics of each of the
methods, weights, and technology level
of the data, used to view the
relationship of vehicle footprint and
fuel economy. Table II–5, below,
summarizes the different assumptions
considered and the key attributes of
each. The analysis was performed
considering all possible combinations of
these assumptions, producing a total of
eight footprint curves.
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between vehicle footprint and fuel
economy is not necessarily constant
over time; newly developed
technologies, changes in consumer
demand, and even the curves
themselves could, if unduly susceptible
to gaming, influence the observed
relationships between the two vehicle
characteristics. For example, if certain
technologies are more effective or more
marketable for certain types of vehicles,
their application may not be uniform
over the range of vehicle footprints.
Further, if market demand has shifted
between vehicle types, so that certain
vehicles make up a larger share of the
fleet, any underlying technological or
market restrictions which inform the
average shape of the curves could
change. That is, changes in the
technology or market restrictions
themselves, or a mere re-weighting of
different vehicles types, could reshape
the fit curves.
For the above reasons, the curve
shapes were reconsidered using the
newest available data, from MY 2016.
With a view toward corroboration
through different techniques, a range of
descriptive statistical analyses were
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(1) Current Technology Level Curves
The ‘‘current technology’’ level curves
exclude diesels and vehicles with
electric propulsion, as discussed above,
but make no other changes to each
model year fleet. Comparing the MY
2016 curves to ones built under the
same methodology from previous model
year fleets shows whether the observed
curve shape has changed significantly
over time as standards have become
more stringent. Importantly, these
curves will include any market forces
which make technology application
variable over the distribution of
footprint. These market forces will not
be present in the ‘‘maximum
technology’’ level curves: By making
technology levels homogenous, this
variation is removed. The current
technology level curves built using both
regression types and both regression
weight methodologies from the MY
2008, MY 2010, and MY 2016 fleets,
shown in more detail in Chapter 4.4.2.1
of the PRIA, support the curve slopes
finalized in the 2012 final rule. The
curves built from most methodologies
using each fleet generally shift, but
remain very similar in slope. This
suggests that the relationship of
footprint to fuel economy, including
both technology and market limits, has
not significantly changed.
(2) Maximum Technology Level Curves
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As in prior rulemakings, technology
differences between vehicle models
were considered to be a significant
factor producing uncertainty regarding
the relationship between fuel
consumption and footprint. Noting that
attribute-based standards are intended
to encourage the application of
additional technology to improve fuel
efficiency and reduce CO2 emissions
across the distribution of footprint in
the fleet, approaches were considered in
which technology application is
simulated for purposes of the curve
fitting analysis in order to produce fleets
that are less varied in technology
content. This approach helps reduce
‘‘noise’’ (i.e., dispersion) in the plot of
vehicle footprints and fuel consumption
levels and identify a more technologyneutral relationship between footprint
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and fuel consumption. The results of
updated analysis for maximum
technology level curves are also shown
in Chapter 4.4.2.2 of the PRIA.
Especially if vehicles progress over time
toward more similar size-specific
efficiency, further removing variation in
technology application both better
isolates the relationship between fuel
consumption and footprint and further
supports the curve slopes finalized in
the 2012 final rule.
(c) What other methodologies were
considered?
The methods discussed above are
descriptive in nature, using statistical
analysis to relate observed fuel economy
levels to observed footprints for known
vehicles. As such, these methods are
clearly based on actual data, answering
the question ‘‘how does fuel economy
appear to be related to footprint?’’
However, being independent of explicit
engineering theory, they do not answer
the question ‘‘how might one expect
fuel economy to be related to footprint?’’
Therefore, as an alternative to the above
methods, an alternative methodology
was also developed and applied that,
using full-vehicle simulation, comes
closer to answer the second question,
providing a basis to either corroborate
answers to the first, or suggest that
further investigation could be
important.
As discussed in the 2012 final rule,
several manufacturers have
confidentially shared with the agencies
what they described as ‘‘physics-based’’
curves, with each OEM showing
significantly different shapes for the
footprint-fuel economy relationships.
This variation suggests that
manufacturers face different curves
given the other attributes of the vehicles
in their fleets (i.e., performance
characteristics) and/or that their curves
reflected different levels of technology
application. In reconsidering the shapes
of the proposed MYs 2021–2026
standards, a similar estimation of
physics-based curves leveraging thirdparty simulation work form Argonne
National Laboratories (ANL) was
developed. Estimating physics-based
curves better ensures that technology
and performance are held constant for
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all footprints; augmenting a largely
statistical analysis with an analysis that
more explicitly incorporates engineering
theory helps to corroborate that the
relationship between fuel economy and
footprint is in fact being characterized.
Tractive energy is the amount of
energy it will take to move a vehicle.104
Here, tractive energy effectiveness is
defined as the share of the energy
content of fuel consumed which is
converted into mechanical energy and
used to move a vehicle—for internal
combustion engine (ICE) vehicles, this
will vary with the relative efficiency of
specific engines. Data from ANL
simulations suggest that the limits of
tractive energy effectiveness are
approximately 25% for vehicles with
internal combustion engines which do
not possess ISG, other hybrid, plug-in,
pure electric, or fuel cell technology.
A tractive energy prediction model
was also developed to support today’s
proposal. Given a vehicle’s mass, frontal
area, aerodynamic drag coefficient, and
rolling resistance as inputs, the model
will predict the amount of tractive
energy required for the vehicle to
complete the Federal test cycle. This
model was used to predict the tractive
energy required for the average vehicle
of a given footprint 105 and ‘‘body
technology package’’ to complete the
cycle. The body technology packages
considered are defined in Table II–6,
below. Using the absolute tractive
energy predicted and tractive energy
effectiveness values spanning possible
ICE engines, fuel economy values were
then estimated for different body
technology packages and engine tractive
energy effectiveness values.
104 Thomas, J. ‘‘Drive Cycle Powertrain
Efficiencies and Trends Derived from EPA Vehicle
Dynamometer Results,’’ SAE Int. J. Passeng. Cars—
Mech. Syst. 7(4):2014, doi:10.4271/2014–01–2562.
Available at https://www.sae.org/publications/
technical-papers/content/2014-01-2562/ (last
accessed June 15, 2018).
105 The mass reduction curves used elsewhere in
this analysis were used to predict the mass of a
vehicle with a given footprint, body style box, and
mass reduction level. The ‘Body style Box’ is 1 for
hatchbacks and minivans, 2 for pickups, and 3 for
sedans, and is an important predictor of
aerodynamic drag. Mass is an essential input in the
tractive energy calculation.
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Chapter 6 of the PRIA shows the
resultant CAFE levels estimated for the
vehicle classes ANL simulated for this
analysis, at different footprint values
and by vehicle ‘‘box.’’ Pickups are
considered 1-box, hatchbacks and
minivans are 2-box, and sedans are 3box. These estimates are compared with
the MY 2021 standards finalized in
2012. The general trend of the simulated
data points follows the pattern of the
previous MY 2021 standards for all
technology packages and tractive energy
effectiveness values presented in the
PRIA. The tractive energy curves are
intended to validate the curve shapes
against a physics-based alternative, and
the analysis suggests that the curve
shapes track the physical relationship
between fuel economy and tractive
energy for different footprint values.
Physical limitations are not the only
forces manufacturers face; they must
also produce vehicles that consumers
will purchase. For this reason, in setting
future standards, the analysis will
continue to consider information from
statistical analyses that do not
homogenize technology applications in
addition to statistical analyses which
do, as well as a tractive energy analysis
similar to the one presented above.
The relationship between fuel
economy and footprint remains
directionally discernable but
quantitatively uncertain. Nevertheless,
each standard must commit to only one
function. Approaching the question
‘‘how is fuel economy related to
footprint’’ from different directions and
applying different approaches will
provide the greatest confidence that the
single function defining any given
standard appropriately and reasonably
reflects the relationship between fuel
economy and footprint. Please provide
comments on this tentative conclusion
and the above discussion.
D. Characterization of Current and
Anticipated Fuel-Saving Technologies
The analysis evaluates a wide array of
technologies manufacturers could use to
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improve the fuel economy of new
vehicles, in both the near future and the
timeframe of this proposed rulemaking,
to meet the fuel economy and CO2
standards proposed in this rulemaking.
The analysis evaluated costs for these
technologies, and looked at how these
costs may change over time. The
analysis also considered how fuelsaving technologies may be used on
many types of vehicles (ranging from
small cars to trucks) and how the
technologies may perform in improving
fuel economy and CO2 emissions in
combination with other technologies.
With cost and effectiveness estimates for
technologies, the analysis can forecast
how manufacturers may respond to
potential standards and can estimate the
associated costs and benefits related to
technology and equipment changes.
This assists the assessment of
technological feasibility and is a
building block for the consideration of
economic practicability of potential
standards.
NHTSA, EPA, and CARB issued the
Draft Technical Assessment Report
(Draft TAR) 106 as the first step in the
EPA MTE process. The Draft TAR
provided an opportunity for the
agencies to share with the public
updated technical analysis relevant to
development of future standards. For
this NPRM, the analysis relies on
portions of the analysis presented in the
Draft TAR, along with new information
that has been gathered and developed
since conducting that analysis, and the
significant, substantive input that was
received during the public comment
period.
The Draft TAR considered many
technologies previously assessed in the
2012 final rule.107 In some cases,
manufacturers have nearly universally
adopted a technology in today’s new
vehicle fleet (for example, electric
power steering). In other cases,
106 Available at https://www.nhtsa.gov/staticfiles/
rulemaking/pdf/cafe/Draft-TAR-Final.pdf (last
accessed June 15, 2018).
107 77 FR 62624 (Oct. 15, 2012).
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manufacturers occasionally use a
technology in today’s new vehicle fleet
(like turbocharged engines). For a few
technologies considered in the 2012
rulemaking, manufacturers began
implementing the technologies but have
since largely pivoted to other
technologies due to consumer
acceptance issues (for instance, in some
cases drivability and performance feel
issues associated with dual clutch
transmissions without a torque
converter) or limited commercial
success. The analysis utilizes new
information as manufacturers’ use of
technologies evolves.
Some of the emerging technologies
described in the Draft TAR were not
included in this analysis, but this
includes some additional technologies
not previously considered. As industry
invents and develops new fuel-savings
technologies, and as suppliers and
manufacturers produce and apply the
technologies, and as consumers react to
the new technologies, efforts are
continued to learn more about the
capabilities and limitations of new
technologies. While a technology is in
early development, theoretical
constructs, limited access to test data,
and CBI is relied on to assess the
technology. After manufacturers
commercialize the technology and bring
products to market, the technology may
be studied in more detail, which
generally leads to the most reliable
information about the technology. In
addition, once in production, the
technology is represented in the fuel
economy and CO2 status of the baseline
fleet. The technology analysis is kept as
current as possible in light of the
ongoing technology development and
implementation in the automotive
industry.
Some technology assumptions have
been updated since the MYs 2017–2025
final rule and, in many cases, since the
2016 Draft TAR. In some cases, EPA and
NHTSA presented different analytical
approaches in the Draft TAR; the
analysis is now presented using the
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same direct manufacturing costs, retail
costs, and learning rates. In addition,
the effectiveness of fuel-economy
technologies is now assessed based on
the same assumptions, and with the
same tools. Finally, manufacturers’
response to stringency alternatives is
forecast with the same simulation
model.
Since the 2017 and later final rule,
many cost assessments, including tear
down studies, were funded and
completed, and presented as part of the
Draft TAR analysis. These studies
evaluated transmissions, engines,
hybrid technologies, and mass
reduction.108 As a result, the analysis
uses updated cost estimates for many
technologies, some of which have been
updated since the Draft TAR. In
addition to those studies, the analysis
also leveraged research reports from
other organizations to assess costs.109
Today’s analysis also updates the costs
to 2016 dollars, as in many cases
technology costs were estimated several
years ago.
The analysis uses an updated, peerreviewed model developed by ANL for
the Department of Energy to provide a
more rigorous estimate for battery costs.
The new battery model provides an
estimate future for battery costs for
hybrids, plug-in hybrids, and electric
vehicles, taking into account the
different battery design characteristics
and taking into account the size of the
battery for different applications.110
In the Draft TAR, two possible
methodologies to estimate indirect costs
from direct manufacturing costs,
described as ‘‘indirect cost multipliers’’
and ‘‘retail price equivalent’’ were
presented. Both of these methodologies
attempted to relate the price of parts for
108 FEV prepared several cost analysis studies for
EPA on subjects ranging from advanced 8-speed
transmissions to belt alternator starter, or Start/Stop
systems. NHTSA also contracted with Electricore,
EDAG, and Southwest Research on teardown
studies evaluating mass reduction and
transmissions. The 2015 NAS report on fuel
economy technologies for light-duty vehicles also
evaluated the agencies’ technology costs developed
based on these teardown studies, and the
technology costs used in this proposal were
updated accordingly. These studies are discussed in
detail in Chapter 6 of the PRIA accompanying this
proposal.
109 For example, the agencies relied on reports
from the Department of Energy’s Office of Energy
Efficiency & Renewable Energy’s Vehicle
Technologies Office. More information on that
office is available at https://www.energy.gov/eere/
vehicles/vehicle-technologies-office. Other agency
reports that were relied on for technology or other
information are referenced throughout this proposal
and accompanying PRIA.
110 For instance, battery electric vehicles with
high levels of mass reduction may use a smaller
battery than a comparable vehicle with less mass
reduction technology and still deliver the same
range on a charge.
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fuel-saving technologies to a retail price.
Today’s analysis utilizes the direct
manufacturing costs (DMC) and the
retail price equivalent (RPE)
methodology published in the Draft
TAR.
Two tools to estimate effectiveness of
fuel-saving technologies were used in
the Draft TAR, and for today’s analysis,
only one tool was used (Autonomie).111
Previously, EPA developed ‘‘ALPHA’’,
an in-house model that estimated fuelsavings for technologies, which
provided a foundation for EPA’s
analysis. EPA’s ‘‘ALPHA’’ results were
used to calibrate a much simpler
‘‘Lumped Parameter Model’’ that was
developed by EPA to estimate
technology effectiveness for many
technologies. The Lumped Parameter
Model (LPM) approximated simulation
modeling results instead of directly
using the results and lead to less
accurate estimates of technology
effectiveness. Many stakeholders
questioned the efficacy of the Lumped
Parameter Model and ALPHA
assumptions and outputs in
combination,112 especially as the tool
was used to evaluate increasingly
heterogeneous combinations of
technologies in the baseline fleet.113 For
today’s analysis, EPA and NHTSA used
an updated version of the Autonomie
model—an improved version of what
NHTSA presented in the 2016 Draft
TAR—to assess technology effectiveness
of technologies and combinations of
technologies. The Department of
Energy’s ANL developed Autonomie
and the underpinning model
assumptions leveraged research from
the DOE’s Vehicle Technologies Office
and feedback from the public.
Autonomie is commercially available
and widely used; third parties such as
suppliers, automakers, and academic
researchers (who publish findings in
peer reviewed academic journals)
commonly use the Autonomie
simulation software.
Similarly for today’s analysis, only
one tool is used. Previously, EPA
developed ‘‘OMEGA,’’ a tool that looked
at costs of technologies and
effectiveness of technologies (as
estimated by EPA’s Lumped Parameter
111 ANL’s Full-Vehicle Simulation Autonomie
Model is discussed in Chapter 6 of the PRIA and
in the ANL Model Documentation available at
Docket No. NHTSA–2018–0067.
112 At NHTSA–2016–0068–0082, p. 49, FCA
provided the following comments, ‘‘FCA believes
EPA is overestimating the benefits of technology. As
the LPM is calibrated to those projections, so too
is the LPM too optimistic.’’ FCA also shared the
chart, ‘‘LPM vs. Actual for 8 Speed Transmissions.’’
113 See e.g., Automotive News ‘‘CAFE math gets
trickier as industry innovates’’ (Kulisch), March 26,
2018.
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Model or ALPHA), and applied cost
effective technologies to manufacturers’
fleets in response to potential standards.
Many stakeholders commented that the
OMEGA model oversimplified fleetwide analysis, resulting in significant
shortcomings.114 For instance, OMEGA
assumed manufacturers would redesign
all vehicles in the fleet by 2021, and
then again by 2025; stakeholders
purported that these assumptions did
not reflect practical constraints in many
manufacturers’ business models.115
Additionally, stakeholders commented
that OMEGA did not adequately take
into consideration common parts like
shared engines, shared transmissions,
and engineering platforms. The CAFE
model does consider refresh and
redesign cycles and parts sharing. The
CAFE model can evaluate responses to
any policy alternative on a year-by-year
basis, as required by EPCA/EISA 116 and
as allowed by the CAA, and can also
account for manufacturers’ year-by-year
plans that involve ‘‘carrying forward’’
technology from prior model years, and
some other vehicles possibly applying
‘‘extra’’ technology in anticipation of
standards in ensuing model years. For
today’s analysis, an updated version of
the CAFE model is used—an improved
version of what NHTSA presented in
the 2016 Draft TAR—to assess
manufacturers’ response to policy
alternatives. See Section II.A.1 above for
further discussion of the decision to use
the CAFE model for the NPRM analysis.
Each aforementioned change is
discussed briefly in the remainder of
this section and in much greater detail
in Chapter 6 of the PRIA. A brief
summary of the technologies considered
in this proposal is discussed below.
Please provide comments on all aspects
of the analysis as discussed here and as
detailed in the PRIA.
114 The Alliance of Automobile Manufacturers
commented that ‘‘the OMEGA model is overoptimized and unrealistic . . . many of these issues
either are not present or are accounted for in DOT’s
Volpe model. The Alliance therefore recommends
that EPA focus on ensuring needs specific to its
regulatory analysis are appropriately addressed in
the Volpe model.’’ Alliance at 48 (Docket ID. EPA–
HQ–OAR–2015–0827–9194).
115 For example, FCA provided the following
comments: ‘‘EPA’s expectation of 10–20% mass
reduction rates across 70% of FCA’s fleet, which
includes a 70% truck mix, is simply unreasonable
as the magnitude of change would require complete
product redesigns in less than eight years
shortening existing production needed to amortize
the large capital cost involved.’’ FCA at 19 (Docket
ID. EPA–HQ–OAR–2015–0827–6160).
116 49 U.S.C. 32902(b)(2)(B).
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1. Data Sources and Processes for
Developing Individual Technology
Assumptions
Technology assumptions were
developed that provide a foundation for
conducting a fleet-wide compliance
analysis. As part of this effort, the
analysis estimated technology costs,
projected technology effectiveness
values, and identified possible
limitations for some fuel-saving
technologies. There is a preference to
use values developed from careful
review of commercialized technologies;
however, in some cases for technologies
that are new, and are not yet for sale in
any vehicle, the analysis relied on
information from other sources,
including CBI and third-party research
reports and publications. Many
emerging technologies are still being
evaluated for the analysis supporting
the final rule, including those that are
currently emerging.
For today’s analysis, one set of cost
assumptions, one set of effectiveness
values (developed with one tool), and
one set of assumptions about the
limitations of some technologies are
presented. Many sources of data were
evaluated, in addition to many
stakeholder comments received on the
Draft TAR. Throughout the process of
developing the assumptions for today’s
analysis, the preferred approach was to
harmonize on sources and
methodologies that were data-driven
and reproducible in independent
verification, produced using tools
utilized by OEMs, suppliers, and
academic institutions, and using tools
that could support both CAFE and CO2
analysis. A single set of assumptions
also facilitates and focuses public
comment by reducing burden on
stakeholders who seek to review all of
the supporting documentation for this
proposal.
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(a) Technology Costs
The analysis estimated present and
future costs for fuel-saving technologies,
taking into consideration the type of
vehicle, or type of engine if technology
costs vary by application. Cost estimates
were developed based on three main
inputs. First, direct manufacturing costs
(DMC), or the component costs of the
physical parts and systems, were
considered, with estimated costs
assuming high volume production.
DMCs generally do not include the
indirect costs of tools, capital
equipment, and financing costs, nor do
they cover indirect costs like
engineering, sales, and administrative
support. Second, indirect costs via a
scalar markup of direct manufacturing
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costs (the retail price equivalent, or
RPE) was taken into account. Finally,
costs for technologies may change over
time as industry streamlines design and
manufacturing processes. Potential cost
improvements with learning effects (LE)
were also considered. The retail cost of
equipment in any future year is
estimated to be equal to the product of
the DMC, RPE, and LE. Considering the
retail cost of equipment, instead of
merely direct manufacturing costs, is
important to account for the real-world
price effects of a technology, as well as
market realities. Absent government
mandate, a manufacturer will not
undertake expensive development and
support costs to implement technologies
without realistic prospects of consumer
willingness to pay enough for such
technology to allow for the
manufacturer to recover its investment.
(1) Direct Manufacturing Costs
In many instances, the analysis used
agency-sponsored tear-down studies of
vehicles and parts to estimate the direct
manufacturing costs of individual
technologies. In the simplest cases, the
studies produced results that confirmed
third-party industry estimates, and
aligned with confidential information
provided by manufacturers and
suppliers. In cases with a large
difference between the tear-down study
results and credible independent
sources, study assumptions were
scrutinized, and sometimes the analysis
was revised or updated accordingly.117
Studies were conducted on vehicles and
technologies that would cover a breadth
of fuel-savings technologies, but because
tear-down studies can be time-intensive
and expensive, the agencies did not
sponsor teardown studies for every
technology. For some technologies,
independent tear-down studies were
also utilized, in addition to other
publications and confidential business
information.118 Due to the variety of
technologies and their applications, a
detailed tear-down study could not be
conducted for every technology,
including pre-production technologies.
Many fuel-saving technologies were
considered that are pre-production, or
sold in very small pilot volumes. For
emerging technologies that could be
applied in the rulemaking timeframe, a
tear-down study cannot be conducted to
117 For instance, in previous analysis, EPA
referenced an old study that purported the first 7–
10% of mass reduction to be ‘‘free’’ or at a
significant ‘‘cost savings’’ to for many vehicles and
many manufacturers.
118 The analysis referenced studies from private
businesses and business analysts for emerging
technologies and for off-the-shelf technologies that
were commercially mature.
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assess costs because the product is not
yet in the marketplace for evaluation. In
these cases, third-party estimates and
confidential information from suppliers
and manufacturers are relied upon;
however, there are some common
pitfalls with relying on confidential
business information to estimate costs.
The agencies and the source may have
had incongruent or incompatible
definitions of ‘‘baseline.’’ 119 The source
may have provided direct manufacturer
costs at a date many years in the future,
and assumed very high production
volumes, important caveats to consider
for agency analysis. In addition, a
source, under no contractual obligation
to the agencies, may provide incomplete
and/or misleading information. In other
cases, intellectual property
considerations and strategic business
partnerships may have contributed to a
manufacturer’s cost information and
could be difficult to account for in the
model as not all manufacturer’s may
have access to proprietary technologies
at stated costs. New information is
carefully evaluated in light of these
common pitfalls, especially regarding
emerging technologies. The analysis
used third-party, forward looking
information for advanced cylinder
deactivation and variable compression
ratio engines, and while these cost
estimates may be cursory (as is the case
with many emerging technologies prior
to commercialization), the agencies took
care to use early information provided
fairly and reasonably. While costs for
fuel-saving technologies reflect the best
estimates available today, technology
cost estimates will likely change in the
future as technologies are deployed and
as production is expanded. For
emerging technologies, the best
information available at the time of the
analysis was utilized, and cost
assumptions will continue to be
updated.
(2) Indirect Costs
As explained above, in addition to
direct manufacturing costs, the analysis
estimates and considers indirect
manufacturing costs. To estimate
indirect costs, direct manufacturing
costs are multiplied by a factor to
represent the average price for fuelsaving technologies at retail. This factor,
referred to as the retail price
equivalence (RPE), accounts for indirect
costs like engineering, sales, and
administrative support, as well as other
overhead costs, business expenses,
warranty costs, and return on capital
119 ‘‘Baseline’’ here refers to a reference part,
piece of equipment, or engineering system that
efficiency improvements and costs are relative to.
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considerations. This approach to the
RPE remains unchanged from the RPE
approach NHTSA presented in the Draft
TAR.
The RPE was chosen for this analysis
instead of indirect cost multipliers
(ICM) because it provides the best
estimate of indirect costs. For a more
detailed discussion of the approach to
indirect costs, see PRIA Chapter 9.
(3) Stranded Capital Costs
Past analyses accounted for costs
associated with stranded capital when
fuel economy standards caused a
technology to be replaced before its
costs were fully amortized. The idea
behind stranded capital is that
manufacturers amortize research,
development, and tooling expenses over
many years, especially for engines and
transmissions. The traditional
production life-cycles for transmissions
and engines have been a decade or
longer. If a manufacturer launches or
updates a product with fuel-saving
technology, and then later replaces that
technology with an unrelated or
different fuel-saving technology before
the equipment and research and
development investments have been
fully paid off, there will be unrecouped,
or stranded, capital costs. Quantifying
stranded capital costs attempted to
account for such lost investments. In the
Draft TAR analysis, there were only a
few technologies for a few
manufacturers that were projected to
have stranded capital costs.
As more technologies are included in
this analysis, and as the CAFE model
has been expanded to account for
platform and engine sharing and
updated with redesign and refresh
cycles, accounting for stranded capital
has become increasingly complex.
Separately, the fact that manufacturers
may be shifting their investment
strategies in ways that may affect
stranded capital calculations was
considered. For instance, Ford and
General Motors agreed to jointly
develop next generation transmission
technologies,120 and some suppliers sell
similar transmissions to multiple
manufacturers. These arrangements
allow manufacturers to share in capital
expenditures, or amortize expenses
more quickly. Manufacturers
increasingly share parts on vehicles
around the globe, achieving greater scale
and greatly affecting tooling strategies
and costs. Given these trends in the
120 See, e.g., Nick Bunkley, Ford to invest $1.4
billion to build 10-speed transmissions for 2017 F–
150, Automotive News (Apr. 26, 2016), https://
www.autonews.com/article/20160426/OEM01/
160429878/ford-to-invest-$1.4-billion-to-build-10speed-transmissions-for-2017.
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industry and their uncertain effect on
capital amortization, and given the
difficulty of handling this uncertainty in
the CAFE model, this analysis does not
account for stranded capital. However,
these trends will be monitored to assess
the role of stranded capital moving
forward.
The analysis continues to rely on
projected refresh and redesign cycles in
the CAFE model to moderate the
cadence for technology adoption and
limit the occurrence of stranded capital
and the need to account for it. Stranded
capital is an important consideration to
appropriately account for costs if there
is too rapid of a turnover for certain
technologies.
(4) Cost Learning
Manufacturers make improvements to
production processes over time, often
resulting in lower costs. Today’s
analysis estimates cost learning by
considering Wright’s learning theory,
which states that as every time
cumulative volume for a product
doubles, the cost lowers by a scalar
factor. The analysis accounts for
learning effects with model year-based
cost learning forecasts for each
technology that reduce direct
manufacturing costs over time.
Historical use of technologies were
evaluated, and industry forecasts were
reviewed to estimate future volumes for
the purpose of developing the model
year-based technology cost learning
curves. The CAFE model does not
dynamically update learning curves,
based on compliance pathways chosen
in simulation.
As discussed above, cost inputs to the
CAFE model incorporate estimates of
volume-based learning. As an
alternative approach, Volpe Center staff
have considered modifications such that
the CAFE model would calculate
degrees of volume-based learning
dynamically, responding to the model’s
application of affected technologies.
While it is intuitive that the degree of
cost reduction achieved through
experience producing a given
technology should depend on the actual
accumulated experience (i.e., volume)
producing that technology, staff have
thus far found such dynamic
implementation in the CAFE model
infeasible. Insufficient data has been
available regarding manufacturers’
historical application of specific
technology. Also, insofar as underlying
direct manufacturing costs already make
some assumptions about volume and
scale, insufficient information is
currently available to determine how to
dynamically adjust these underlying
costs. It should be noted that if learning
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responds dynamically to volume, and
volume responds dynamically to
learning, an internally consistent model
solution would likely require iteration
of the CAFE model to seek a stable
solution within the model’s
representation multiyear planning. Thus
far, these challenges suggest it would be
infeasible to calculate degrees of
volume-based learning in a manner that
responds dynamically to modeled
technology application. Nevertheless,
the agencies invite comment on the
issue, and seek data and methods that
would provide the basis for a
practicable approach to doing so.
Today’s analysis also updates the way
learning effects apply to costs. In the
Draft TAR analysis, NHTSA applied
learning curves only to the incremental
direct manufacturing costs or costs over
the previous technology on the tech
tree. In practice, two things were
observed: (1) If the incremental direct
manufacturing costs were positive,
technologies could not become less
expensive than their predecessors on
the tech tree, and (2) absolute costs over
baseline technology depended on the
learning curves of root technologies on
the tech tree. Today’s analysis applies
learning effects to the incremental cost
over the null technology state on the
tech tree. After this step, the analysis
calculates year-by-year incremental
costs over preceding technologies on the
tech tree to create the CAFE model
inputs.
Direct manufacturing costs and
learning effects for many technologies
were reviewed by evaluating historical
use of technologies and industry
forecasts to estimate future volumes.
This approach produced reasonable
estimates for technologies already in
production. For technologies not yet in
production in MY 2016, the cumulative
volume in MY 2016 is zero, because
manufacturers have not yet produced
the technologies. For pre-production
cost estimates, the analysis often relies
on confidential business information
sources to predict future costs. Many
sources for pre-production cost
estimates include significant learning
effects, often providing cost estimates
assuming high volume production, and
often for a timeframe late in the first
production generation or early in the
second generation of the technology.
Rapid doubling and re-doubling of a low
cumulative volume base with Wright’s
learning curves can provide unrealistic
cost estimates. In addition, direct
manufacturing cost projections can vary
depending on the initial production
volume assumed. Direct costs with
learning were carefully examined, and
adjustments were made to the starting
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point for those technologies on the
learning curve to better align with the
assumptions used for the initial direct
cost estimate. See PRIA Chapter 9 for
more detailed information on cost
learning.
(b) Technology Effectiveness
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(1) Technology Effectiveness Simulation
Modeling
Full-vehicle simulation modeling was
used to estimate the fuel economy
improvements manufacturers could
make to their fleet by adding new
technologies, taking into account MY
2016 vehicle specifications, as well as
how combinations of technologies
interact. Full-vehicle simulation
modeling uses computer software and
physics-based models to predict how
combinations of technologies perform
together.
The simulation and modeling requires
detailed specifications for each
technology that describes its efficiency
and performance-related characteristics.
Those specifications generally come
from design specifications, laboratory
measurements, simulation or modeling,
and may involve additional analysis.
For example, the analysis used engine
maps showing fuel use vs. engine torque
vs. engine speed, and transmission
maps taking into account gear efficiency
for a range of loads and speeds. With
physics-based technology specifications,
full-vehicle simulation modeling can be
used to estimate technology
effectiveness for various combinations
and permutations of technologies for
many vehicle classes. To develop the
specifications used for the simulation
and modeling, laboratory test data was
evaluated for production and preproduction technologies, technical
publications, manufacturer and supplier
CBI, and simulation modeling of
specific technologies. Evaluating
recently introduced production
products to inform the technology
effectiveness models of emerging
technologies is preferred because doing
so allows for a more reliable analysis of
incremental improvements over
previous technologies; however, some
technologies were considered that are
not yet in production. As technologies
evolve and new applications emerge,
this work will be continued and may
include additional technologies and/or
updated modeling for the final rule. The
details of new and emerging
technologies are discussed in PRIA
Chapter 6.
Using full-vehicle simulation
modeling has two primary advantages
over using single or limited point
estimates for fuel efficiency
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improvements of technologies. First,
technology effectiveness often differs
significantly depending on the type of
vehicle and the other technologies that
are on the vehicle, and this is shown in
full-vehicle simulations. Different
technologies may provide different fuel
economy improvements depending on
whether they are implemented alone or
in tandem with other technologies.
Single point estimates often
oversimplify these important, complex
relationships and lead to less accurate
effectiveness estimates. Also, because
manufacturers often implement a
number of fuel-saving technologies
simultaneously at vehicle redesigns, it is
generally difficult to isolate the effect of
individual technologies using laboratory
measurement of production vehicles
alone. Simulation modeling offers the
opportunity to isolate the effects of
individual technologies by using a
single or small number of baseline
configurations and incrementally
adding technologies to those baseline
configurations. This provides a
consistent reference point for the
incremental effectiveness estimates for
each technology and for combinations of
technologies for each vehicle type and
reduces potential double counting or
undercounting technology effectiveness.
Note: It is most important that the
incremental effectiveness of each
technology and combinations be
accurate and relative to a consistent
baseline, because it is the incremental
effectiveness that is applied to each
vehicle model/configuration in the MY
2016 baseline fleet (and to each vehicle
model/configuration’s absolute fuel
economy value) to determine the
absolute fuel economy of the model/
configuration with the additional
technology. The absolute fuel economy
values of the simulation modeling runs
by themselves are used only to
determine the incremental effectiveness
and are never used directly to assign an
absolute fuel economy value to any
vehicle model/configuration for the
rulemaking analysis. Therefore,
commenters on technology effectiveness
should be specific about the incremental
effectiveness of technologies relative to
other specifically defined technologies.
The fuel economy of a specific vehicle
or simulation modeling run in isolation
may be less useful.
Second, full-vehicle simulation
modeling requires explicit
specifications and assumptions for each
technology; therefore, these
assumptions can be presented for public
review and comment. For instance,
transmission gear efficiencies, shift
logic, and gear ratios are explicitly
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stated as model inputs and are available
for review and comment. For today’s
analysis, every effort was made to make
the input specifications and modeling
assumptions available for review and
comment. PRIA Chapter 6 and
referenced documents provide more
detailed information.
Technology development and
application will be monitored to acquire
more information for the final rule. The
agencies may update the analysis for the
final rule based on comments and/or
new information that becomes available.
Today’s analysis utilizes effectiveness
estimates for technologies developed
using Autonomie software,121 a physicsbased full-vehicle simulation tool
developed and maintained by the
Department of Energy’s ANL.
Autonomie has a long history of
development and widespread
application by users in industry,
academia, research institutions and
government.122 Real-world use has
contributed significantly to aspects of
Autonomie important to producing
realistic estimates of fuel economy and
CO2 emission rates, such as estimation
and consideration of performance,
utility, and driveability metrics (e.g.,
towing capability, shift business,
frequency of engine on/off transitions).
This steadily increasing realism has, in
turn, steadily increased confidence in
the appropriateness of using Autonomie
to make significant investment
decisions. Notably, DOE uses
Autonomie for analysis supporting
budget priorities and plans for programs
managed by its Vehicle Technologies
Office (VTO) and to decide among
competing vehicle technology R&D
projects.
In the 2015 National Academies of
Science (NAS) study of fuel economy
improving technologies, the Committee
recommended that the agencies use fullvehicle simulation to improve the
analysis method of estimating
technology effectiveness.123 The
committee acknowledged that
developing and executing tens or
hundreds of thousands of constantly
changing vehicle packages models in
121 More information about Autonomie is
available at https://www.anl.gov/technology/
project/autonomie-automotive-system-design (last
accessed June 21, 2018).
122 ANL Model Documentation, ‘‘A Detailed
Vehicle Simulation Process To Support CAFE
Standards’’ ANL/ESD–18/6.
123 National Research Council. 2015. Cost,
Effectiveness, and Deployment of Fuel Economy
Technologies for Light-Duty Vehicles. Washington,
DC: The National Academies Press [hereinafter
‘‘2015 NAS Report’’] at pg. 263, available at https://
www.nap.edu/catalog/21744/cost-effectivenessand-deployment-of-fuel-economy-technologies-forlight-duty-vehicles (last accessed June 21, 2018).
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real-time is extremely challenging.
While initially this approach was not
considered practical to implement, a
process developed by Argonne in
collaboration with NHTSA and the DOT
Volpe Center has succeeded in enabling
large scale simulation modeling. For
more details about the Autonomie
simulation model and its submodels
and inputs, see PRIA Chapter 6.2.
Today’s analysis modeled more than
50 fuel economy-improving
technologies, and combinations thereof,
on 10 vehicle types (an increase from
five vehicle types in NHTSA’s Draft
TAR analysis). While 10 vehicle types
may seem like a small number, a large
portion of the production volume in the
MY 2016 fleet have specifications that
are very similar, especially in highly
competitive segments (for instance,
many mid-sized sedans, many small
SUVs, and many large SUVs coalesce
around similar specifications,
respectively), and baseline simulations
have been aligned around these modal
specifications. The sequential addition
of these technologies generated more
than 100,000 unique technology
combinations per vehicle class. The
analysis included 10 technology classes,
so more than one million full-vehicle
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simulations were run. In addition,
simulation modeling was conducted to
determine the appropriate amount of
engine downsizing needed to maintain
baseline performance across all modeled
vehicle performance metrics when
advanced mass reduction technology or
advanced engine technology was
applied, so these simulations take into
account performance neutrality, given
logical engine down-sizing
opportunities associated with specific
technologies.
Some baseline vehicle assumptions
used in the simulation modeling were
updated based on public comment and
the assessment of the MY 2016
production fleet. The analysis included
updated assumptions about curb weight,
component inertia, as well as
technology properties like baseline
rolling resistance, aerodynamic drag
coefficients, and frontal areas. Many of
the assumptions are aligned with
published research from the Department
of Energy’s Vehicle Technologies Office
and other independent sources.124
124 Pannone, G. ‘‘Technical Analysis of Vehicle
Load Reduction Potential for Advanced Clear Cars,’’
April 29, 2015. Available at https://www.arb.ca.gov/
research/apr/past/13-313.pdf (last accessed June 21,
2018).
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Additional transmission technologies
and more levels of aerodynamic
technologies than NHTSA presented in
the Draft TAR analysis were also added
for today’s analysis. Having additional
technologies allowed the agencies to
assign baselines and estimate fuelsavings opportunities with more
precision.
The 10 vehicle types (referred to as
‘‘technology classes’’ in the modeling
documentation) are shown in Table II–
7. Each vehicle type (technology class)
represented a large segment of vehicles,
such as medium cars, small SUVs, and
medium performance SUVs.125 Baseline
parameters were defined with ANL for
each technology class, including
baseline curb weight, time required to
accelerate from stop to 60 miles per
hour, time required to accelerate from
50 miles per hour to 80 miles per hour,
ability of the vehicle to maintain
constant 65 miles per hour speed on a
six percent upgrade, and (for some
classes) assumptions about towing
capability.
125 Separate technology classes were created for
high performance and low performance vehicles to
better account for performance diversity across the
fleet.
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From these baseline specifications,
incremental combinations of fuel saving
technologies were applied. As the
combinations of technologies change, so
too may predicted performance.
The analysis attempts to maintain
performance by resizing engines at a few
specific incremental technology steps.
Steps from one technology to another
typically associated with a major
vehicle redesign, or engine redesign,
were identified, and engine resizing was
restricted only to these steps. The
analysis allowed engine resizing when
mass reduction of 10% or greater was
applied to the vehicle glider mass,126
and when one powertrain architecture
was replaced with another
architecture.127 The analysis resized
126 The
vehicle glider is defined here as the
vehicle without the engine, transmission, and
driveline. See PRIA Chapter 6.3 for further
information.
127 Some engine and accessory technologies may
be added to an engine without an engine
architecture change. For instance, manufacturers
may adapt, but not replace engine architectures to
include cylinder deactivation, variable valve lift,
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engines to the extent that performance
was maintained for the least capable
performance criteria to maintain vehicle
utility for that criteria; therefore,
sometimes other performance attributes
may improve. For instance, the amount
of engine resizing may be determined
based on its high speed acceleration
time if it is the least capable criteria, but
that resizing may also improve the low
speed acceleration time.128 The analysis
did not re-size the engine in response to
adding technologies that have small
effects on vehicle performance. For
instance, if a vehicle’s weight is reduced
by a small amount causing the 0–60
mile per hour time to improve slightly,
the analysis would not resize the
belt-integrated starter generators, and other basic
technologies. However, switching from a naturally
aspirated engine to a turbo-downsized engine is an
engine architecture change typically associated
with a major redesign and radical change in engine
displacement.
128 The simulation database, or summary of
simulation outputs, includes all of the estimated
performance metrics for each combination of
technology as modeled.
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engine. Manufacturers have repeatedly
told the agencies that the high costs for
redesign and the increased
manufacturing complexity that would
result from resizing engines for such
small changes in the vehicle preclude
doing so. The analysis should not, in
fact, include engine resizing with the
application of every technology or for
combinations of technologies that drive
small performance changes so that the
analysis better reflects what is feasible
for manufacturers to do.129
2. CAFE model
The CAFE model is designed to
simulate compliance with a given set of
CAFE or CO2 standards for each
manufacturer that sells vehicles in the
United States. The model begins with a
129 For instance, a vehicle would not get a
modestly bigger engine if the vehicle comes with
floor mats, nor would the vehicle get a modestly
smaller engine without floor mats. This example
demonstrates small levels of mass reduction. If
manufacturers resized engines for small changes,
manufacturers would have dramatically more part
complexity, potentially losing economies of scale.
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representation of the MY 2016 vehicle
model offerings for each manufacturer
that includes the specific engines and
transmissions on each model variant,
observed sales volumes, and all fuel
economy improving technology that is
already present on those vehicles. From
there the model adds technology, in
response to the standards being
considered, in a way that minimizes the
cost of compliance and reflects many
real-world constraints faced by
automobile manufacturers. The model
addresses fleet year-by-year compliance,
taking into consideration vehicle refresh
and redesign schedules and shared
platforms, engines, and transmissions
among vehicles.
As a result of simulating compliance,
the CAFE model provides the
technology pathways that manufacturers
could use to comply with regulations,
including how technologies could be
applied to each of their vehicle model/
configurations in response to a given set
of standards. The model calculates the
impacts of the simulated standard:
Technology costs, fuel savings (both in
gallons and dollars), CO2 reductions,
social costs and benefits, and safety
impacts.
The current analysis reflects several
changes made to the CAFE model since
2012, when NHTSA used the model to
estimate the effects, costs, and benefits
of final CAFE standards for light-duty
vehicles produced during MYs 2017–
2021 and augural standards for MYs
2022–2025. The changes are discussed
in Section II.A.1, above, and PRIA
Chapter 6.
3. Assumptions About Individual
Technology Cost and Effectiveness
Values
Cost and effectiveness values were
estimated for each technology included
in the analysis, with a summary list of
all technologies provided in Table II–1
(List of Technologies with Data Sources
for Technology Assignments) of
Preamble Chapter II.B, above. In all,
more than 50 technologies were
considered in today’s analysis, and the
analysis evaluated many combinations
of these technologies on many
applications. Potential issues in
assessing technology effectiveness and
cost were identified, including:
• Baseline (MY 2016) vehicle
technology level assessed as too low, or
too high. Compliance information was
extensively reviewed and supplemented
with available literature on many MY
2016 vehicle models. Manufacturers
could also review the baseline
technology assignments for their
vehicles, and the analysis incorporates
feedback received from manufacturers.
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• Technology costs too low or too
high. Tear down cost studies, CBI,
literature, and the 2015 NAS study
information were referenced to estimate
technology costs. In cases that one
technology appeared exemplary on cost
and effectiveness relative to all other
technologies, information was acquired
from additional sources to confirm or
reject assumptions. Cost assumptions
for emerging technologies are
continuously being evaluated.
• Technology effectiveness too high
or too low in combination with other
vehicle technologies. Technology
effectiveness was evaluated using the
Autonomie full-vehicle simulation
modeling, taking into account the
impact of other technologies on the
vehicle and the vehicle type. Inputs and
modeling for the analysis took into
account laboratory test data for
production and some pre-production
technologies, technical publications,
manufacturer and supplier CBI, and
simulation modeling of specific
technologies. Evaluating recently
introduced production products to
inform the technology effectiveness
models of emerging technologies was
preferred; however, some technologies
that are not yet in production were
considered, via CBI. Simulation
modeling used carefully chosen baseline
configurations to provide a consistent,
reasonable reference point for the
incremental effectiveness estimates.
• Vehicle performance not considered
or applied in an infeasible manner.
Performance criteria, including low
speed acceleration (0–60 mph time),
high speed acceleration (50–80 mph
time), towing, and gradeability (six
percent grade at 65 mph) were also
considered. In the simulation modeling,
resizing was applied to achieve the
same performance level as the baseline
for the least capable performance
criteria but only with significant design
changes. The analysis struck a balance
by employing a frequency of engine
downsizing that took product
complexity and economies of scale into
account.
• Availability of technologies for
production application too soon or too
late. A number of technologies were
evaluated that are not yet in production.
CBI was gathered on the maturity and
timing of these technologies and the
likely cadence at which manufacturers
might adopt these technologies.
• Product complexity and design
cadence constraints too low or too high.
Product platforms, refresh and redesign
cycles, shared engines, and shared
transmissions were also considered in
the analysis. Product complexity and
the cadence of product launches were
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matched to historical values for each
manufacturer.
• Customer acceptance under
estimated or over estimated. Resale
prices for hybrid vehicles, electric
vehicles, and internal combustion
engine vehicles were evaluated to assess
consumer willingness to pay for those
technologies. The analysis accounts for
the differential in the cost for those
technologies and the amount consumers
have actually paid for those
technologies. Separately, new dualclutch transmissions and manual
transmissions were applied to vehicles
already equipped with these
transmission architectures.
Please provide comments on all
assumptions for fuel economy and CO2
technology costs, effectiveness,
availability, and applicability to
vehicles in the fleet.
The technology effectiveness
modeling results show effectiveness of a
technology often varies with the type of
vehicle and the other technologies that
are on the vehicle. Figure II–1 and
Figure II–2 show the range of
effectiveness for each technology for the
range of vehicle types and technology
combinations included in this NPRM
analysis. The data reflect the change in
effectiveness for applying each
technology by itself while all other
technologies are held unchanged. The
data show the improvement in fuel
consumption (in gallons per mile) and
tailpipe CO2 over the combined 2-cycle
test procedures. For many technologies,
effectiveness values ranged widely; only
a few technologies for which
effectiveness may be reasonably
represented as a fixed offset were
identified.
For engine technologies, the
effectiveness improvement range is
relative to a comparably equipped
vehicle with only variable valve timing
(VVT) on the engine. For automatic
transmission technologies, the
effectiveness improvement range is over
a 5-speed automatic transmission. For
manual transmission technologies, the
effectiveness improvement range is over
a 5-speed manual transmission. For road
load technologies like aerodynamics,
rolling resistance, and mass reduction,
the effectiveness improvement ranges
are relative to the least advanced
technology state, respectively. For
hybrid and electric drive systems that
wholly replace an engine and
transmission, the effectiveness
improvement ranges are relative to a
comparably equipped vehicle with a
basic engine with VVT only and a 5speed automatic transmission. For
hybrid or electrification technologies
that complement other advanced engine
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instance, parallel strong hybrids and
belt integrated starter generators retain
engine technologies, such as a turbo
charged engine or an Atkinson cycle
engine). Many technologies have a wide
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range of estimated effectiveness values.
Figure II–3 below shows a hierarchy of
technologies discussed.
BILLING CODE 4910–59–P
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and transmission technologies, the
effectiveness improvement ranges are
relative to a comparably equipped
vehicle without the hybrid or
electrification technologies (for
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Figure 11-2- Example of Technology Effectiveness Variation by Application
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4. Engine Technologies
There are a number of engine
technologies that manufacturers can use
to improve fuel economy and CO2.
Some engine technologies can be
incorporated into existing engines with
minor or moderate changes to the
engines, but many engine technologies
require an entirely new engine
architecture.
In this section and for this analysis,
the terms ‘‘basic engine technologies’’
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and ‘‘advanced engine technologies’’ are
used only to define how the CAFE
model applies a specific engine
technology and handles incremental
costs and effectiveness improvements.
‘‘Basic engine technologies’’ refer to
technologies that, in many cases, can be
adapted to an existing engine with
minor or moderate changes to the
engine. ‘‘Advanced engine
technologies’’ refer to technologies that
generally require significant changes or
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43031
an entirely new engine architecture. In
the CAFE model, basic engine
technologies may be applied in
combination with other basic engine
technologies; advanced engine
technologies (defined by an engine map)
stand alone as an exclusive engine
technology. The words ‘‘basic’’ and
‘‘advanced’’ are not meant to confer any
information about the level of
sophistication of the technology. Also,
many advanced engine technology
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definitions include some basic engine
technologies, but these basic
technologies are already accounted for
in the costs and effectiveness values of
the advance engine. The ‘‘basic engine
technologies’’ need not be (and are not)
applied in addition to the ‘‘advanced
engine technologies’’ in the CAFE
model.
Engines come in a wide variety of
shapes, sizes, and configurations, and
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the incremental engine costs and
effectiveness values often depend on
engine architecture. The agencies
modeled single overhead cam (SOHC),
dual overhead cam (DOHC), and
overhead valve (OHV) engines
separately to account for differences in
engine architecture. The agencies
adjusted costs for some engine
technologies based on the number of
cylinders and number of banks in the
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engine, and the agencies evaluated
many production engines to better
understand how costs and capabilities
may vary with engine configuration.
Table II–8, Table II–9, Table II–10 below
shows the summary of absolute costs 130
for different technologies.
130 ‘‘Absolute’’ being in reference to cost above
the lowest level of technology considered in
simulations. For instance, an engine of the same
architecture with no VVT, VVL, SGDI, or DEAC.
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Name
VVT
VVL
Fmt 4701
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SGDI
DEAC
TURB01
Technology Pathway
Basic Engine
Basic Engine
Basic Engine
Basic Engine
Turbocharged Engine
C-2017
$
111.97
$
417.59
$
450.04
C-2021
$
10R.79
$
405.74
$
437.26
C-2025
$
106.24
$
396.22
$
427.00
$
153.95
$ U47.98
$
146.07
$ 1,044.43
TURB02
CEGR1
HCR1
HCR2
VCR
ADEAC
ADSL
DSLI
CNG
Turbocharged Engine
Turbocharged Engine
HCREngine
HCREngine
VCR Engine
Adv. DEAC Engine
Diesel Engine
Diesel Engine
Alt. Fuel Engine
$ 1,722.96
$ 2,138.49
$
735.65
$
980.78
not estimated
$ 1,370.86
$ 5,110.08
$
149.58
$ 1,078.90
$ 1,612.78
$ 2,001.73
$
692.23
$
980.78
not estimated
$ 1,237.93
$ 5,110.08
$ 5,661.68
$
156.22
$ 5,661.68
$
159.54
$ 1,490.01
$ 1,849.36
$
683.64
$
980.78
not estimated
$ 1,156.83
$ 5,110.08
$ 5,661.68
$
153.41
C-2029
$ 104.13
$ 388.34
$ 418.51
$ 143.17
$ 1,022.34
$ 1,403.80
$ 1,742.36
$ 681.67
$ 980.78
not estimated
$ 1,108.63
$ 5,110.08
$ 5,661.68
$ 150.72
24AUP2
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-8 - Summary of Absolute Engine Technology Cost vs. 14 Basic Engine, including Learning Effects and
Retail Price Eauival
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Name
VVT
VVL
SGDI
DEAC
TURB01
Technology Pathway
Basic Engine
Basic Engine
Basic Engine
Basic Engine
Turbocharged Engine
C-2017
$ 223.94
$ 682.38
$ 731.05
$ 265.92
$ 1253.70
TURB02
CEGR1
HCR1
HCR2
VCR
ADEAC
ADSL
DSLI
Turbocharged Engine
Turbocharged Engine
HCREngine
HCREngine
VCR Engine
Adv. DEAC Engine
Diesel Engine
Diesel Engine
Alt. Fuel Engine
$ 1,849.68
$ 2,265.21
$ 1,133.23
$ 1,490.32
not estimated
$ 2,115.07
$ 6,122.76
$ 6,841.17
$ 159.54
CNG
C-2021
$ 217.5R
$ 663.00
$ 710.29
C-2025
$ 212.4R
$ 647.45
$ 693.63
C-2029
$ 20R.25
$ 634.57
$ 679.83
$ 258.37
$ 1,178.26
$ 1,731.39
$ 2,12035
$ 1,066.34
$ 1,490.32
not estimated
$ 1,909.98
$ 6,122.76
$ 6,841.17
$ 156.22
$ 252.31
$ 1,140.61
$ 247.29
$ 1,116.49
$ 1,599.60
$ 1,958.95
$ 1,053.11
$ 1,490.32
not estimated
$ 1,784.85
$ 6,122.76
$ 1,507.05
$ 1,845.60
$ 1,050.09
$ 1,490.32
not estimated
$ 1,710.48
$ 6,122.76
$ 6,841.17
$ 150.72
$ 6,841.17
$ 153.41
24AUP2
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
EP24AU18.024
Table 11-9- Summary of Absolute Engine Technology Cost vs. V6 Basic Engine, including Learning Effects and Retail Price
Eauival
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24AUP2
Technology Pathway
Basic Engine
Basic Engine
Basic Engine
Basic Engine
Turbocharged Engine
C-2017
$ 223.94
$ 835.19
$ 900.08
C-2021
$ 217.5R
$ 811.47
$ 874.52
C-2025
$ 212.4R
$ 792.44
$ 854.01
C-2029
$ 20R.25
$ 776.68
$ 837.03
$ 265.92
$ L929.02
$ 252.31
$ 1,755.01
TURB02
CEGR1
HCR1
HCR2
VCR
ADEAC
ADSL
DSLI
Turbocharged Engine
Turbocharged Engine
HCREngine
HCREngine
VCR Engine
Adv. DEAC Engine
Diesel Engine
Diesel Engine
Alt. Fuel Engine
$ 2,897.03
$ 3,312.55
$ L480.31
$ 1,935.14
not estimated
$ 2,741.71
$ 6,502.61
$ 7,221.02
$ 159.54
$ 258.37
$ 1,812.94
$ 2,711.76
$ 3,100.71
$ 1,392.94
$ 1,935.14
not estimated
$ 2,475.87
$ 6,502.61
$ 7,221.02
$ 156.22
$ 247.29
$ 1,717.90
$ 2,360.38
$ 2,698.94
$ 1,371.71
$ 1,935.14
not estimated
$ 2,217.26
$ 6,502.61
$ 7,221.02
$ 150.72
CNG
$ 2,505.34
$ 2,864.69
$ 1,375.66
$ 1,935.14
not estimated
$ 2,313.66
$ 6,502.61
$ 7,221.02
$ 153.41
43035
analysis, and engine maps were
developed for each combination of
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Many types of production powertrains
were reviewed and tested for this
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sradovich on DSK3GMQ082PROD with PROPOSALS2
engine technologies. For a given engine
configuration, some production engines
may be less efficient than the engine
maps presented in the analysis, and
some may be more efficient. Developing
engine maps that reasonably
represented most vehicles equipped
with the engine technology, and that are
in production today, was the preferred
approach for this analysis. Additionally,
some advanced engines were included
in the simulation that are not yet in
production. The engine maps for these
engines were either based on CBI or
were theoretical. The most recently
released production engines are still
being reviewed, and the analysis may
include updated engine maps in the
future or add entirely new engine maps
to the analysis if either action could
improve the quality of the fleet-wide
analysis.
Stakeholders provided many
comments on the engine maps that were
presented in the Draft TAR. These
comments were considered, and today’s
analysis utilizes several engine maps
that were updated since the Draft TAR.
Most notably, for turbocharged and
downsized engines, the engine maps
were adjusted in high torque, low speed
operating conditions to address engine
knock with regular octane fuel to align
with the fuel octane that manufacturers
recommend be used for the majority of
vehicles. In the Draft TAR, NHTSA
assumed high octane fuel to develop
engine maps. See the discussion below
and in PRIA Chapter 6.3 for more
details. Please provide comment on the
appropriateness of assuming the use of
lower octane fuels.
(a) ‘‘Basic’’ Engine Technologies
The four ‘‘basic’’ engine technologies
in today’s model are Variable Valve
Timing (VVT), Variable Valve Lift
(VVL), Stoichiometric Gasoline Direct
Injection (SGDI), and basic Cylinder
Deactivation (DEAC). Over the last
decade, manufacturers upgraded many
engines with these engine technologies.
Implementing these technologies
involves changes to the cylinder head of
the engine, but the engine block,
crankshaft, pistons, and connecting rods
require few, if any, changes. In today’s
analysis, manufacturers may apply the
four basic engine technologies in
various combinations, just as
manufacturers have done recently.
(1) Variable Valve Timing (VVT)
Variable Valve Timing (VVT) is a
family of valve-train designs that
dynamically adjusts the timing of the
intake valves, exhaust valves, or both, in
relation to piston position. This family
of technologies reduces pumping losses.
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VVT is nearly universally used in the
MY 2016 fleet.
(2) Variable Valve Lift (VVL)
Variable Valve Lift (VVL) dynamically
adjusts the travel of the valves to
optimize airflow over a broad range of
engine operating conditions. The
technology increases effectiveness by
reducing pumping losses and may
improve efficiency by affecting incylinder charge (fuel and air mixture),
motion, and combustion.
(3) Stoichiometric Gasoline Direct
Injection (SGDI)
Stoichiometric Gasoline Direct
Injection (SGDI) sprays fuel at high
pressure directly into the combustion
chamber, which provides cooling of the
in-cylinder charge via in-cylinder fuel
vaporization to improve spark knock
tolerance and enable an increase in
compression ratio and/or more optimal
spark timing for improved efficiency.
SGDI appears in about half of basic
engines produced in MY 2016, and the
technology is used in many advanced
engines as well.
(4) Basic Cylinder Deactivation (DEAC)
Basic Cylinder Deactivation (DEAC)
disables intake and exhaust valves and
prevents fuel injection into some
cylinders during light-load operation.
The engine runs temporarily as though
it were a smaller engine, which reduces
pumping losses and improves
efficiency. Manufacturers typically
disable one-cylinder bank with basic
cylinder deactivation. In the MY 2016
fleet, manufacturers used DEAC on V6,
V8, V10, and V12 engines on OHV,
SOHC, and DOHC engine
configurations. With some engine
configurations in some operating
conditions, DEAC creates noisevibration-and-harshness (NVH)
challenges. NVH challenges are
significant for V6 and I4 DEAC
configurations. For I4 engine
configurations, manufacturers can
operate the DEAC function of an engine
in very few operating conditions, with
limited potential to save fuel. No
manufacturers sold I4 DEAC engines in
the MY 2016 fleet. Typically, the
smaller the engine displacement, the
less opportunity DEAC provides to
improve fuel consumption.
Manufacturers and suppliers continue
to evaluate more improved versions of
cylinder deactivation, including
advanced cylinder deactivation and
pairing basic cylinder deactivation with
turbo charged engines. No
manufacturers produced such
technologies in the MY 2016 fleet.
Advanced cylinder deactivation and
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turbo technologies were modeled and
considered separately in today’s
analysis.
(b) ‘‘Advanced’’ Engine Technologies
The analysis included ‘‘advanced’’
engine technologies that can deliver
high levels of effectiveness but often
require a significant engine design
change or a new engine architecture. In
the CAFE model, ‘‘basic’’ engine
technologies may be considered in
combination and applied before
advanced engine technologies.
‘‘Advanced’’ engine technologies
generally include one or more basic
engine technologies in the simulation,
without the need to layer on ‘‘basic’’
engine technologies on top of
‘‘advanced’’ engines. Once an advanced
engine technology is applied, the model
does not reconsider the basic engine
technologies. The characterization of
each advanced engine technology takes
into account the prerequisite
technologies.
Many of the newest advanced engine
technologies improve effectiveness over
their predecessors, but the engines may
also include sophisticated materials or
manufacturing processes that contribute
to efficiency improvements. For
instance, one recently introduced turbo
charged engine uses sodium filled valve
stems.131 Another recently introduced
high compression ratio engine uses a
sophisticated laser cladding process to
manufacture valve seats and improve
airflow.132 To fully consider these
advancements (and their potential
benefits), the incremental costs of these
technologies, as well as the effectiveness
improvements, must be accounted for.
(1) Turbocharged Engines
Turbo engines recover energy from
hot exhaust gas and compress intake air,
thereby increasing available airflow and
increasing specific power level. Due to
specific power improvements on turbo
engines, engine displacement can be
downsized. The downsizing reduces
pumping losses and improves fuel
economy at lower loads. For the NPRM
analysis, a level of downsizing is
assumed to be applied that achieves
performance similar to the baseline
naturally-aspirated engine. This
assumes manufacturers would apply the
benefits toward improved fuel economy
131 See Honda, ‘‘2018 Honda Accord Press Kit—
Powertrain,’’ Oct. 2, 2017. Available at https://
news.honda.com/newsandviews/article.aspx?g=
honda-automobiles&id=9932-en. (last accessed June
21, 2018).
132 Hakariya et al., ‘‘The New Toyota Inline 4Cylinder 2.5L Gasoline Engine,’’ SAE Technical
Paper 2017–01–1021 (Mar. 28, 2017), available at
https://www.sae.org/publications/technical-papers/
content/2017-01-1021/.
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sradovich on DSK3GMQ082PROD with PROPOSALS2
and not trade off fuel economy
improvements to increase overall
vehicle performance. In practice,
manufacturers have often also improved
some vehicle performance attributes at
the expense of not maximizing potential
fuel economy improvements.
Manufacturers may develop engines
to operate on varying levels of boost,133
with higher levels of boost achieving
higher engine specific power and
enabling greater levels of engine
downsizing and corresponding
reductions in pumping losses for
improved efficiency. However, engines
operating at higher boost levels are
generally more susceptible to engine
knock,134 especially at higher torques
and low engine speeds. Additionally,
engines with higher boost levels
typically require larger induction and
exhaust system components, dissipate
greater amounts of heat, and with
greater levels of engine downsizing have
increased challenges with turbo lag.135
For these reasons, three levels of turbo
downsizing technologies are separately
modeled in this analysis.
The analysis also modeled
turbocharged engines with parallel
hybrid technology. In simulations with
high stringencies, many manufacturers
produced turbo-hybrid electric vehicles.
In the MY 2016 fleet, of the vehicles that
use parallel hybrid technology, many
use turbocharged engines.
Since the Draft TAR, the turbo family
engine maps were updated to reflect
operation on 87 AKI regular octane
fuel.136 In the Draft TAR, turbo engine
maps were developed assuming
premium fuel. For this rulemaking
analyses, pathways to improving fuel
economy and CO2 are analyzed, while
also maintaining vehicle performance,
capability, and other attributes. This
includes assuming there is no change in
the fuel octane required to operate the
vehicle. Using 87 AKI regular octane
fuel is consistent with the fuel octane
that manufacturers specify for the
majority of vehicles, and enables the
modeling to account for important
design and calibration issues associated
133 Boost refers to the degree to which the
turbocharger compresses the intake air for the
engine, which may affect the specific power of the
engine.
134 Knock refers to rapid uncontrolled combustion
in the cylinder part way through the combustion
process, which can create an audible sound and can
damage the engine.
135 Turbo lag refers to the delay time between
power demanded and power delivered; it is
typically associated with rapid accelerations from a
stopped vehicle at idle.
136 Specifically, 87 Anti-Knock Index (AKI) Tier
3 certification fuel. 87 AKI is also known as 87
(R+M)/2 or 87 (Research Octane + Motor Octane)/
2.
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with regular octane fuel. Using the
updated criteria assures the NPRM
analysis reflects real-world constraints
faced by manufacturers to assure engine
durability, and acceptable drivability,
noise and harshness, and addresses the
over-estimation of potential fuel
economy improvements related to the
fuel octane assumptions, which did not
fully account for these constraints, in
the Draft TAR. Compared with the
NHTSA analysis in the Draft TAR, these
engine maps adjust the fuel use at high
torque and low speed operation and at
high speed operation to fully account
for knock limitations with regular
octane fuel.
The analysis assumes engine
downsizing with the addition of turbo
technology. For instance, in the
simulations, manufacturers may have
replaced a naturally-aspirated V8 engine
with a turbo V6 engine, and
manufacturers may have replaced a
naturally-aspirated V6 engine with a
turbo I4 engine. When manufacturers
reduced the number of banks or
cylinders of an engine, some cost
savings is projected due to fewer
cylinders and fewer valves. Such cost
savings is projected to help offset the
additional costs of turbo charger specific
hardware, making turbo downsizing a
very attractive technology progression
for some engines.137
(a) TURBO1
Level 1 Turbo Charging (TURBO1)
adds a turbo charger to a DOHC engine
with SGDI, VVT, and continuously VVL.
The engine operates at up to 18 bar
brake mean effective pressure (BMEP).
Manufacturers used Turbo1
technology in a little less than a quarter
of the MY 2016 fleet with particularly
high concentrations in premium
vehicles.
(b) TURBO2
Level 2 Turbo Charging (TURBO2)
operates at up to 24 bar BMEP. The step
from Turbo1 to Turbo2 is accompanied
with additional displacement
downsizing for reduced pumping losses.
Very few manufacturers have Turbo2
technology in the MY 2016 fleet.
(c) CEGR1
Turbo Charging with Cooled Exhaust
Gas Recirculation (CEGR1) improves the
knock resistance of Turbo2 engines by
mixing cooled inert exhaust gases into
the engine’s air intake. That allows
greater boost levels, more optimal spark
timing for improved fuel economy, and
137 In particular, the step from a naturallyaspirated V6 to a turbo I4 was particularly cost
effective in agency simulations.
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43037
performance and greater engine
downsizing for lower pumping losses.
CEGR1 technology is used in only a few
vehicles in the MY 2016 fleet, and many
of these vehicles include highperformance utility either for towing or
acceleration.
(a) Turbocharged Engine Technologies
Not Considered
Previous analyses considered turbo
charged engines with even higher BMEP
than today’s Turbo2 and CEGR1
technologies, but today’s analysis does
not present 27 bar BMEP turbo engines.
Turbo engines with very high BMEP
have demonstrated limited potential to
improve fuel economy due to practical
limitations on engine downsizing and
tradeoffs with launch performance and
drivability. Based on the analysis, and
based on CBI, CEGR2 turbo engine
technology was not included in this
NPRM analysis.
(2) High Compression Ratio Engines
(Atkinson Cycle Engines)
Atkinson cycle gasoline engines use
changes in valve timing (e.g., lateintake-valve-closing or LIVC) to reduce
the effective compression ratio while
maintaining the expansion ratio. This
approach allows a reduction in topdead-center (TDC) clearance ratio (e.g.,
increase in ‘‘mechanical’’ or ‘‘physical’’
compression ratio) to increase the
effective expansion ratio without
increasing the effective compression
ratio to a point that knock-limited
operation is encountered. Increasing the
expansion ratio in this manner improves
thermal efficiency but also lowers peak
BMEP, particularly at lower engine
speeds.
Often knock concerns for these
engines limit applications in high load,
low RPM conditions. Some
manufacturers have mitigated knock
concerns by lowering back pressure
with long, intricate exhaust systems, but
these systems must balance knock
performance with emissions tradeoffs,
and the increased size of the exhaust
manifold can pose packaging concerns,
particularly on V-engine
configurations.138
Only a few manufacturers produced
internal combustion engine vehicles
with Atkinson cycle engines in MY
138 Some HCR1 4-cylinder (I–4) engines use an
intricate 4–2–1 exhaust manifold to lower
backpressure and to improve engine efficiency.
Manufacturers sometimes fitted such an exhaust
system into a front-wheel-drive vehicle with an I–
4 engine by using a high underbody tunnel or
rearward dashpanel (trading off some interior
space), but packaging such systems on rear-wheeldrive vehicles may pose challenges, especially if the
engine has two banks and would therefore require
room for two such exhaust manifolds.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
2016; however, these engines are
commonly paired with hybrid electric
vehicle technologies due to the synergy
of peak efficiency of Atkinson cycle
engines and immediate torque from
electric motors in strong hybrids.
Atkinson cycle engines are very
common on power split hybrids and are
sometimes observed as part of a parallel
hybrid system or plug-in hybrid system.
Atkinson cycle engines played a
prominent role in EPA’s January 2017
final determination, which has since
been withdrawn. Today’s analysis
recognizes that the technology is not
suitable for many vehicles due to
performance, emissions and packaging
issues, and/or the extensive capital and
resources that would be required for
manufacturers to shift from other
powertrain technology pathways (such
as turbocharging and downsizing) to
standalone Atkinson cycle engine
technology.
(a) HCR1
A number of Asian manufacturers
have launched Atkinson cycle engines
in smaller vehicles that do not use
hybrid technologies. These production
engines have been benchmarked to
characterize HCR1 technology for
today’s analysis.
Today’s analysis restricted the
application of stand-alone Atkinson
cycle engines in the CAFE model in
some cases. The engines benchmarked
for today’s analysis were not suitable for
MY 2016 baseline vehicle models that
have 8-cylinder engines and in many
cases 6-cylinder engines.
(b) HCR2
sradovich on DSK3GMQ082PROD with PROPOSALS2
EPA conceptualized a ‘‘future’’
Atkinson cycle engine and published
the theoretical engine map in an SAE
paper.139 140 For this engine, EPA staff
began with a best-in-class 2.0L Atkinson
cycle engine and then increased the
efficiency of the engine map further,
through the theoretical application of
additional technologies in combination,
like cylinder deactivation, engine
friction reduction, and cooled exhaust
gas recirculation. This engine remains
entirely speculative, as no production
139 Ellies, B., Schenk, C., and Dekraker, P.,
‘‘Benchmarking and Hardware-in-the-Loop
Operation of a 2014 MAZDA SkyActiv 2.0L 13:1
Compression Ratio Engine,’’ SAE Technical Paper
2016–01–1007, 2016. Available at https://
www.sae.org/publications/technical-papers/
content/2016-01-1007/.
140 Lee, S., Schenk, C., and McDonald, J., ‘‘Air
Flow Optimization and Calibration in HighCompression-Ratio Naturally Aspirated SI Engines
with Cooled-EGR,’’ SAE Technical Paper 2016–01–
0565, 2016. Available at https://www.sae.org/
publications/technical-papers/content/2016-010565/.
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engine as outlined in the EPA SAE
paper has ever been commercially
produced or even produced as a
prototype in a lab setting. Furthermore,
the engine map has not been validated
with hardware and bench data, even on
a prototype level (as no such engine
exists to test to validate the engine
map).
Previously, EPA relied heavily on the
HCR2 (or sometimes referred to as ATK2
in previous EPA analysis) engine as a
cost effective pathway to compliance for
stringent alternatives, but many engine
experts questioned its technical
feasibility and near term commercial
practicability. Stakeholders asked for
the engine to be removed from
compliance simulations until the
performance could be validated with
engine hardware.141 142 While for the
Draft TAR, the agencies ran full-vehicle
simulations with the theoretical engine
map and made these available in the
CAFE model, HCR2 technology as
described in EPA’s SAE paper was not
included in today’s analysis because
there has been no observable physical
demonstration of the speculative
technology, and many questions remain
about its practicability as specified,
especially in high load, low engine
speed operating conditions. Simulations
with EPA’s HCR2 engine map produce
results that approach (and sometimes
exceed) diesel powertrain efficiency.143
Given the prominence of this unproven
technology in previous rule-makings,
the CAFE model may be configured to
consider the application of HCR2
technology for reference only.
As new engines emerge that achieve
high thermal efficiency, questions may
be raised as to whether the HCR2 engine
is a simulation proxy for the new engine
technology. It is important to conduct a
thorough evaluation of the actual new
production engines to measure the brake
specific fuel consumption and to
characterize the improvements
141 At NHTSA–2016–0068–0082, FCA
recommended, ‘‘Remove ATK2 from OMEGA
model until the performance is validated.’’, p. viii.
And FCA stated, ‘‘ATK2—High Compression
engines coupled with Cylinder Deactivation and
Cooled EGR are unlikely to deliver modeled results,
meet customer needs, or be ready for commercial
application.’’, p. 6–9.
142 At Docket ID No EPA–HQ–OAR–2015–0827–
6156, The Alliance of Automobile Manufacturers
commented, ‘‘[There] is no current example of
combined Atkinson, plus cooled EGR, plus cylinder
deactivation technology in the present fleet to verify
EPA’s modeled benefits and . . . EPA could not
provide physical test results replicating its modeled
benefits of these combined technologies,’’ p. 40.
143 Thomas, J. ‘‘Drive Cycle Powertrain
Efficiencies and Trends Derived from EPA Vehicle
Dynamometer Results,’’ SAE Int. J. Passeng. Cars—
Mech. Syst. 7(4):2014. Available at https://
www.sae.org/publications/technical-papers/
content/2014-01-2562/.
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attributable to friction and thermal
efficiency before drawing conclusions.
Using vehicle level data may
misrepresent or conflate complex
interactions between a high thermal
efficiency engine, engine friction
reduction, accessory load
improvements, transmission
technologies, mass reduction,
aerodynamics, rolling resistance, and
other vehicle technologies. For instance,
some of the newest high compression
ratio engines show improved thermal
efficiency, in large part due to improved
accessory loads or reduced parasitic
losses from accessory systems.144 The
CAFE model allows for incremental
improvement over existing HCR1
technologies with the addition of
improved accessory devices (IACC), a
technology that is available to be
applied on many baseline MY 2016
vehicles with HCR1 engines and may be
applied as part of a pathway of
compliance to further improve the
effectiveness of existing HCR1 engines.
(c) Emerging Gasoline Engine
Technologies
Manufacturers and suppliers continue
to invest in many emerging engine
technologies, and some of these
technologies are on the cusp of
commercialization. Often,
manufacturers submit information about
new engine technologies that they may
soon bring into production. When this
happens, a collaborative effort is
undertaken with suppliers and
manufacturers to learn as much as
possible and sometimes begin
simulation modeling efforts. Bench data,
or performance data for preproduction
vehicles and engines, is usually closely
held confidential business information.
To properly characterize the
technologies, it is often necessary to
wait until the engine technologies are in
production to study them.
(1) Advanced Cylinder Deactivation
(ADEAC)
Advanced cylinder deactivation
systems (or rolling or dynamic cylinder
deactivation systems) allows a further
degree of cylinder deactivation than
DEAC. The technology allows the
engine to vary the percentage of
cylinders deactivated and the sequence
in which cylinders are deactivated,
essentially providing ‘‘displacement on
demand’’ for low load operations, so
long as the calibration avoids certain
frequencies.
144 For instance, the MY 2018 2.5L Camry engine
that uses HCR technology also reduces parasitic
losses with a variable capacity oil pump.
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ADEAC systems may be integrated
into the valvetrains with moderate
modifications on OHV engines.
However, while the ADEAC operating
concept remains the same on DOHC
engines, the valvetrain hardware
configuration is very different, and
application on DOHC engines is
projected to be more costly per cylinder
due to the valvetrain differences.
Some preproduction 8-cylinder OHV
prototype vehicles were briefly
evaluated for this analysis, but no
production versions of the technology
have been studied.
Today’s analysis relied on CBI to
estimate costs and effectiveness values
of ADEAC. Since no engine map was
available at the time of the NPRM
analysis, ADEAC was estimated to
improve a basic engine with VVL, VVT,
SGDI, and DEAC by three percent (for 4
cylinder engines) six percent (for
engines with more than 4 cylinders).
ADEAC systems will continue to be
studied as production begins.
(2) Variable Compression Ratio Engines
(VCR)
Engines using variable compression
ratio (VCR) technology appear to be at
a production-intent stage of
development but also appear to be
targeted primarily towards limited
production, high performance and very
high BMEP (27–30 bar) applications.
Variable compression ratio engines
work by changing the length of the
piston stroke of the engine to operate at
a more optimal compression ratio and
improve thermal efficiency over the full
range of engine operating conditions.
A number of manufacturers and
suppliers provided information about
VCR technologies, and several design
concepts were reviewed that could
achieve a similar functional outcome. In
addition to design concept differences,
intellectual property ownership
complicates the ability of the agencies to
define a VCR hardware system that
could be widely adopted across the
industry.
For today’s analysis, VCR engines
have a spot on the technology
simulation tree, but VCR is not actively
used in the NPRM simulation.
Reasonable representations of costs and
technology characterizations remain
open questions for VCR engine
technology and the analysis.
NHTSA is sponsoring work to
develop engine maps for additional
combinations of technologies. Some of
these technologies being researched
presently, including VCR, may be used
in the analysis supporting the final rule.
Please provide comment on variable
compression ratio engine technology.
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Should VCR technology be employed in
the timeframe of this proposed
rulemaking? Why or why not? Do
commenters believe VCR technology
will see widespread adoption in the US
vehicle fleet? Why or why not? What
vehicle segments may it best be suited
for, and which segments would it not be
best suited for? Why or why not? What
cost and effectiveness values should be
used if VCR is modeled for analysis?
Please provide supporting data.
Additionally, please provide any
comments on the sponsored work
related to VCR, described further in
PRIA Chapter 6.3.
modeling for past rulemakings, and is
not included in this NPRM analysis,
primarily because effectiveness, cost,
and mass market implementation
readiness data are not available.
Please comment on the potential use
of HCCI technology in the timeframe
covered by this rule. More specifically,
should HCCI be included in the final
rulemaking analysis for this proposed
rulemaking? Why or why not? Please
provide supporting data, including
effectiveness values, costs in relation
varying engine types and applications,
and production timing that supports the
timeframe of this rulemaking.
(3) Compression Ignition Gasoline
Engines (SpCCI, HCCI)
For many years, engine developers,
researchers, manufacturers have
explored ways to achieve the inherent
efficiency of a diesel engine while
maintaining the operating
characteristics of a gasoline engine. A
potential pathway for striking this
balance is utilizing compression
ignition for gasoline fueled engines,
more commonly referred to as
Homogeneous Charge Compression
Ignition (HCCI).
Ongoing, periodic discussions with
manufacturers on future fuel saving
technologies and powertrain plans have,
generally, included HCCI as a long-term
strategy. The technology appears to
always be a strong consideration as, in
theory, it provides the ‘‘best of both
worlds,’’ meaning a way to provide
diesel engine efficiency with gasoline
engine performance and emissions
levels.
Developments in both the research
and the potential production
implementation of HCCI for the US
market is continually assessed. In 2017,
a significant, potentially production
breakthrough was announced by Mazda
regarding a gasoline-fueled engine
employing Spark Controlled
Compression Ignition (SpCCI), where
HCCI is employed for a portion of its
normal operation and spark ignition is
used at other times.145 Soon after,
Mazda publicly stated they plan to
introduce this engine as part of the
Skyactiv family of engines in 2019.146
However, HCCI was not included in
the simulation and vehicle fleet
(d) Diesel Engines
145 Mazda Next-Generation Technology—Press
Information, Mazda USA (Oct. 24, 2017), https://
insidemazda.mazdausa.com/press-release/mazdanext-generation-technology-press-information/ (last
visited Apr. 13, 2018).
146 Mazda introduces updated 2019 CX–3 at 2018
New York International Auto Show, Mazda USA
(Mar. 28, 2018), https://
insidemazda.mazdausa.com/press-release/mazdaintroduces-2019-cx-3-2018-new-york-auto-show/
(last visited Apr. 13, 2018).
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Diesel engines have several
characteristics that give superior fuel
efficiency, including reduced pumping
losses due to lack of (or greatly reduced)
throttling, high pressure direct injection
of fuel, a combustion cycle that operates
at a higher compression ratio, and a very
lean air/fuel mixture relative to an
equivalent-performance gasoline engine.
This technology requires additional
enablers, such as a NOX adsorption
catalyst system or a urea/ammonia
selective catalytic reduction system for
control of NOX emissions during lean
(excess air) operation.
(e) Alternative Fuel Engines
(1) Compressed Natural Gas (CNG)
Compressed Natural Gas (CNG)
engines use compressed natural gas as a
fuel source. The fuel storage and supply
systems for these engines differ
tremendously from gasoline, diesel, and
flex fuel vehicles.
(2) Flex Fuel Engines
Flex fuel engines can run on regular
gasoline and fuel blended with ethanol.
These vehicles may require additional
equipment in the fuel system to
effectively supply different blends of
fuel to the engine.
(f) Lubrication and Friction Reduction
Low-friction lubricants including low
viscosity and advanced low friction
lubricant oils are now available (and
widely used). If manufacturers choose to
make use of these lubricants, they may
need to make engine changes and
conduct durability testing to
accommodate the lubricants. The level
of low friction lubricants exceeded 85%
penetration in the MY 2016 fleet.
Reduction of engine friction can be
achieved through low-tension piston
rings, roller cam followers, improved
material coatings, more optimal thermal
management, piston surface treatments,
and other improvements in the design of
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engine components and subsystems that
improve efficient engine operation.
Manufacturers have already widely
adopted both lubrication and friction
reduction technologies. This analysis
includes advanced engine maps that
already assume application of lowfriction lubricants and engine friction
reduction technologies. Therefore,
additional friction reduction is not
considered in today’s analysis.
The use and commercial development
of improved lubricants and friction
reduction components will continue to
be monitored, including conical boring
and oblong cylinders, and future
analyses may be updated if new
information becomes available.
sradovich on DSK3GMQ082PROD with PROPOSALS2
5. Fuel Octane
(a) What is fuel octane level?
Gasoline octane levels are an integral
part of potential engine performance.
According the United States Energy
Information Administration (EIA),
octane ratings are measures of fuel
stability. These ratings are based on the
pressure at which a fuel will
spontaneously combust (auto-ignite) in
a testing engine.147 Spontaneous
combustion is an undesired condition
that will lead to serious engine damage
and costly repairs for consumers if not
properly managed. The higher an octane
number, the more stable the fuel,
mitigating the potential for spontaneous
combustion, also commonly known as
‘‘knock.’’ Modern engine control
systems are sophisticated and allow
manufacturers to detect when ‘‘knock’’
occurs during engine operation. These
control systems are designed to adjust
operating parameters to reduce or
eliminate ‘‘knock’’ once detected.
In the United States, consumers are
typically able to select from three
distinct grades of fuel, each of which
provides a different octane rating. The
octane levels can vary from region to
region, but on the majority, the octane
levels offered are regular (the lowest
octane fuel–generally 87 Anti-Knock
Index (AKI) also expressed as (the
average of Research Octane + Motor
Octane), midgrade (the middle range
octane fuel–generally 89–90 AKI), and
premium (the highest octane fuel–
generally 91–94 AKI).148 At higher
elevations, the lowest octane rating
available can drop to 85 AKI.149
147 U.S. Energy Information Administration, What
is Octane?, https://www.eia.gov/energyexplained/
index.cfm?page=gasoline_home#tab2 (last visited
Mar. 19, 2018).
148 Id.
149 See e.g., U.S. Department of Energy and U.S.
Environmental Protection Agency, What is 85
octane, and is it safe to use in my vehicle?, https://
www.fueleconomy.gov/feg/octane.shtml#85 (last
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Currently, throughout the United
States, pump fuel is a blend of 90%
gasoline and 10% ethanol. It is standard
practice for refiners to manufacture
gasoline and ship it, usually via
pipelines, to bulk fuel terminals across
the country. In many cases, refiners
supply lower octane fuels than the
minimum 87-octane required by law to
these terminals. The terminals then
perform blending operations to bring the
fuel octane level up to the minimum
required by law, and higher. In some
cases, typically to lowest fuel grade, the
‘‘base fuel’’ is blended with ethanol,
which has a typical octane rating of
approximately 113. For example, in
2013, the State of Nebraska Ethanol
Board defined requirements for refiners
to 84-octane gas for blending to achieve
87-octane prior to final dispensing to
consumers.150
(b) Fuel Octane Level and Engine
Performance
A typical, overarching goal of optimal
spark-ignited engine design and
operation is to maximize the greatest
amount of energy from the fuel
available, without manifesting
detrimental impacts to the engine over
its expected operating conditions.
Design factors, such as compression
ratio, intake and exhaust value control
specifications, combustion chamber and
piston characteristics, among others, are
all impacted by octane (stability) of the
fuel consumers are anticipated to use.151
Vehicle manufacturers typically
develop their engines and engine
control system calibrations based on the
fuel available to consumers. In many
cases, manufacturers may recommend a
fuel grade for best performance and to
prevent potential damage. In some
cases, manufacturers may require a
specific fuel grade for both best
performance and/or to prevent potential
engine damage.
Consumers, though, may or may not
choose to follow the recommendation or
requirement for a specific fuel grade.
Additionally, regional fuel availability
visited Mar. 19, 2018). 85 octane fuel is available
in high-elevation regions where the barometric
pressure is lower causing naturally-aspirated
engines to operate with less air and, therefore, at
lower torque and power. This creates less benefit
and need for higher octane fuels as compared to at
lower elevations where engine airflow, torque, and
power levels are higher.
150 Nebraska Ethanol Board, Oil Refiners Change
Nebraska Fuel Components, Nebraska.gov, https://
ethanol.nebraska.gov/wordpress/oil-refinerschange-nebraska-fuel-components/ (last visited
Mar. 19, 2018).
151 Additionally, PRIA Chapter 6 contains a brief
discussion of fuel properties, octane levels used for
engine simulation and in real-world testing, and
how octane levels can impact performance under
these test conditions.
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could also limit consumer choice, or, in
the case of higher elevation regions,
present an opportunity for consumers to
use a fuel grade that is below the
minimum recommended. As such,
vehicle manufacturers employ strategies
for scenarios where a lower than
recommended, or required, fuel grade is
used, mitigating engine damage over the
life of a vehicle.
When knock (also referred to as
detonation) is encountered during
engine operation, at the most basic
level, non-turbo charged engines can
reduce or eliminate knock by adjusting
the timing of the spark that ignites the
fuel, as well as the amounts of fuel
injected at each intake stroke
(‘‘fueling’’). In turbo-charged
applications, boost levels are typically
reduced along with spark timing and
fueling adjustments. Past rulemakings
have also discussed other techniques
that may be employed to allow higher
compression ratios, more optimal spark
timing to be used without knock, such
as the addition of cooled exhaust gas
recirculation (EGR). Regardless of the
type of spark-ignition engine or
technology employed, reducing or
preventing knock results in the loss of
potential power output, creating a
‘‘knock-limited’’ constraint on
performance and efficiency.
Despite limits imposed by available
fuel grades, manufacturers continue to
make progress in extracting more power
and efficiency from spark-ignited
engines. Production engines are safely
operating with regular 87 AKI fuel with
compression ratios and boost levels
once viewed as only possible with
premium fuel. According to the
Department of Energy, the average
gasoline octane level has remained
fundamentally flat starting in the early
1980’s and decreased slightly starting in
the early 2000s. During this time,
however, the average compression ratio
for the U.S. fleet has increased from 8.4
to 10.52, a more than 20% increase,
yielding the statement that, ‘‘There is
some concern that in the future, auto
manufacturers will reach the limit of
technological increases in compression
ratios without further increases in the
octane of the fuel.’’ 152
As such, manufacturers are still
limited by the available fuel grades to
consumers and the need to safeguard
the durability of their products for all of
the available fuels; thus, the potential
152 Fact of the Week, Fact #940: August 29, 2016
Diverging Trends of Engine Compression Ratio and
Gasoline Octane Rating, U.S. Department of Energy,
https://www.energy.gov/eere/vehicles/fact-940august-29-2016-diverging-trends-enginecompression-ratio-and-gasoline-octane (last visited
Mar. 21, 2018).
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improvement in the design of sparkignition engines continues to be
overshadowed by the fuel grades
available to consumers.
(c) Potential of Higher Octane Fuels
Automakers and advocacy groups
have expressed support for increases to
fuel octane levels for the U.S. market
and are actively participating in
Department of Energy research programs
on the potential of higher octane fuel
usage.153 154 Some positions for potential
future octane levels include advocacy
for today’s premium grade becoming the
base grade of fuel available, which
could enable low cost design changes
that would improve fuel economy and
CO2. Challenges associated with this
approach include the increased fuel cost
to consumers who drive vehicles
designed for current regular octane
grade fuel that would not benefit from
the use of the higher cost higher octane
fuel. The net costs for a shift to higher
octane fuel would persist well into the
future. Net benefits for the transition
would not be achieved until current
regular octane fuel is not available in
the North American market, causing
manufacturers to redesign all engines to
operate the higher octane fuel, and then
after those vehicles have been in
production a sufficient number of model
years to largely replace the current onroad vehicle fleet. The transition to net
positive benefits could take many years.
In anticipation of this proposed
rulemaking, organizations such as the
High Octane Low Carbon Alliance
(HOLC) and the Fuel Freedom
Foundation (FFA), have shared their
positions on the potential for making
higher octane fuels available for the U.S.
market. Other stakeholders also
commented to past NHTSA rulemakings
sradovich on DSK3GMQ082PROD with PROPOSALS2
153 Mark Phelan, High octane gas coming—but
you’ll pay more for it, Detroit Free Press (Apr. 25,
2017), https://www.freep.com/story/money/cars/
mark-phelan/2017/04/25/new-gasoline-promiseslower-emissions-higher-mpg-and-cost-octanesociety-of-automotive-engineers/100716174/.
154 The octane game: Auto industry lobbies for 95
as new regular, Automotive News (April 17, 2018),
https://www.autonews.com/article/20180417/
BLOG06/180419780/the-octane-game-autoindustry-lobbies-for-95-as-new-regular.
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and/or the Draft TAR regarding the
potential for increasing octane levels for
the U.S. market.
In the meetings with HOLC and the
FFA, the groups advocated for the
potential benefits high octane fuels
could provide via the blending of nonpetroleum feedstocks to increase octane
levels available at the pump. The
groups’ positions on benefits took both
a technical approach by suggesting an
octane level of 100 is desired for the
marketplace, as well as, the benefits
from potential increased national energy
security by reduced dependencies on
foreign petroleum.
(d) Fuel Octane—Request for Comments
Please comment on the potential
benefits, or dis-benefits, of considering
the impacts of increased fuel octane
levels available to consumers for
purposes of the model. More
specifically, please comment on how
increasing fuel octane levels would play
a role in product offerings and engine
technologies. Are there potential
improvements to fuel economy and CO2
reductions from higher octane fuels?
Why or why not? What is an ideal
octane level for mass-market
consumption balanced against cost and
potential benefits? What are the
negatives associated with increasing the
available octane levels and, potentially,
eliminating today’s lower octane fuel
blends? Please provide supporting data
for your position(s).
6. Transmission Technologies
Transmissions transmit torque from
the engine to the wheels. Transmissions
may improve fuel efficiency primarily
through two mechanisms: (1)
Transmissions with more gears allow
the engine to operate more regularly at
the most efficient speed-load points,
and (2) transmissions may have
improvements in friction (gears,
bearings, seals, and so on), or
improvements in shift efficiency that
help the transmission transfer torque
more efficiently, lowering parasitic
losses. These mechanisms are very
different, so full-vehicle simulation is
helpful to understand how a
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transmission may work with
complementary equipment to improve
fuel economy.
Today’s analysis significantly
increased the number of transmissions
modeled in full-vehicle simulations,
attempting to more closely align the
Department of Energy full-vehicle
simulations with existing vehicles.
Previously, EPA included just five
transmissions 155 by vehicle class in
their analysis, and often EPA
represented upgrades among manual,
automatic, continuously variable, and
dual clutch transmissions with the same
effectiveness 156 and cost values 157
within a vehicle class. Today’s analysis
simulated nearly 20 transmissions, with
explicit assumptions about gear ratios,
gear efficiencies, gear spans, shift logic,
and transmission architecture.158 159
This analysis improves transparency by
making clear the assumptions
underlying the transmissions in the fullvehicle simulations and by increasing
the number of transmissions simulated
since the Draft TAR. Methods will be
continuously evaluated to improve
transmission models in full-vehicle
simulations. For the box plots of
effectiveness values, as shown in the
PRIA Chapter 6, all automatic
transmissions are relative to a 5-speed
automatic, and all manual transmissions
are relative to a 5-speed manual. Table
II–11 below shows the absolute costs of
transmission used for this analysis
including learning and retail price
equivalent.
155 Null,
TRX11, TRX12, TRX21, TRX22.
TAR, p. 5–297 through 5–298
summarizes effectiveness values previously
assumed for stepping between transmission
technologies (Null, TRX11, TRX12, TRX21, TRX22).
157 Draft TAR, p. 5–299. ‘‘For future vehicles, it
was assumed that the costs for transitioning from
one technology level (TRX11–TRX22) to another
level is the same for each transmission type (AT,
AMT, DCT, and CVT).’’
158 See PRIA Chapter 6.3.
159 Ehsan, I.S., Moawad, A., Kim, N., & Rousseau,
A. ‘‘A Detailed Vehicle Simulation Process To
Support CAFE Standards.’’ ANL/ESD–18/6. Energy
Systems Division, Argonne National Laboratory.
2018.
156 Draft
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(a) Automatic Transmissions
Five-, six-, seven-, eight-, nine- and
ten-speed automatic transmissions are
optimized by changing the gear ratios to
enable the engine to operate in a more
efficient operating range over a broader
range of vehicle operating conditions.
While a six speed transmission
application was most prevalent for the
MYs 2012–2016 final rule, eight and
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higher speed transmissions were more
prevalent in the MY 2016 fleet.
‘‘L2’’ and ‘‘L3’’ transmissions
designate improved gear efficiency and
reduced parasitic losses. Few
transmissions in the MY 2016 fleet have
achieved ‘‘L2’’ efficiency, and the
highest level of transmission efficiencies
modeled are assumed to be available in
MY 2022.
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(1) Continuously Variable
Transmissions
Continuously variable transmission
(CVT) commonly uses V-shaped pulleys
connected by a metal belt rather than
gears to provide ratios for operation.
Unlike manual and automatic
transmissions with fixed transmission
ratios, continuously variable
transmissions can provide fully variable
and an infinite number of transmission
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ratios that enable the engine to operate
in a more efficient operating range over
a broader range of vehicle operating
conditions. In this NPRM, two levels of
CVTs are considered for future vehicles.
The second level CVT would have a
wider transmission ratio, increased
torque capacity, improvements in oil
pump efficiency, lubrication
improvements, and friction reduction.
While CVTs work well with light loads,
the technology as modeled is not
suitable for larger vehicles such as
trucks and large SUVs.
(2) Dual Clutch Transmissions
sradovich on DSK3GMQ082PROD with PROPOSALS2
Dual clutch or automated shift
manual transmissions (DCT) are similar
to manual transmissions except for the
vehicle controls shifting and launch
functions. A dual-clutch automated shift
manual transmission uses separate
clutches for even-numbered and oddnumbered gears, so the next expected
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gear is pre-selected, which allows for
faster and smoother shifting. The 2012–
2016 final rule limited DCT applications
to a maximum of 6-speeds. Both 6-speed
and 8-speed DCT transmissions are
considered in today’s proposal.
Dual clutch transmissions are very
effective transmission technologies, and
previous rule-making projected rapid,
and wide adoption into the fleet.
However, early DCT product launches
in the U.S. market experienced shift
harshness and poor launch
performance, resulting in customer
satisfaction issues—some so extreme as
to prompt vehicle buyback
campaigns.160 Most manufacturers are
not using DCTs in the U.S. market due
to the customer satisfaction issues.
Manufacturers used DCTs in about three
percent of the MY 2016 fleet. Today’s
160 Ford Powershift Transmission Settlement,
https://fordtransmissionsettlement.com/ (last visited
June 21, 2018).
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analysis limits the application of
improved DCTs to vehicles that already
use DCTs. Many of these vehicles are
imported performance products.
(b) Manual Transmissions
Manual 6- and 7-speed transmissions
offer an additional gear ratio, sometimes
with a higher overdrive gear ratio, over
a 5-speed manual transmission. Similar
to automatic transmissions, more gears
often means the engine may operate in
the efficient zone more frequently.
7. Vehicle Technologies
As discussed earlier in Section
II.D.1.b)(1), several technologies were
considered for this analysis, and Table
II–12, Table II–13, and Table II–14
below shows the full list of vehicle
technologies analyzed and the
associated absolute cost.161
161 Mass
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Name
Technology Pathway
C-2017
C-2021
C-2025
C-2029
LDB
DLR
$
88.32
$
81.14
$
75.14
$
70.94
SAX
DLR
$
93.43
$
83.15
$
77.05
$
72.87
ROLLO
ROLL
$
-
$
-
$
-
$
-
ROLLlO
ROLL
$
7.47
$
6.69
$
6.25
$
5.96
ROLL20
ROLL
$
58.32
$
47.14
$
42.24
$
39.54
MRO
MR
$
-
$
-
$
-
$
-
MRl
MR
$
0.42
$
0.37
$
0.34
$
0.32
MR2
MR
$
0.51
$
0.45
$
0.42
$
0.39
MR3
MR
$
0.78
$
0.71
$
0.66
$
0.62
MR4
MR
$
1.44
$
1.17
$
1.04
$
0.95
MRS
MR
$
2.62
$
2.11
$
1.87
$
1.70
AEROO
AERO
$
-
$
-
$
-
$
-
AER05
AERO
$
56.65
$
50.44
$
46.71
$
44.33
AEROlO
AERO
$ 115.82
$ 103.13
$
95.49
$
90.62
AER015
AERO
$ 163.66
$ 145.72
$ 134.93
$ 128.05
AER020
AERO
$ 289.56
$ 257.82
$ 238.72
$ 226.56
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Table 11-12 - Summary of Absolute Vehicle Technology Cost vs. Baseline for Cars,
I ncI ud.mg L earnmg
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. E;qmva
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Name
Technology Pathway
C-2017
C-2021
C-2025
C-2029
LDB
DLR
$
88.32
$
81.14
$
75.14
$
70.94
SAX
DLR
$
93.43
$
83.15
$
77.05
$
72.87
ROLLO
ROLL
$
-
$
-
$
-
$
-
ROLLlO
ROLL
$
7.47
$
6.69
$
6.25
$
5.96
ROLL20
ROLL
$
58.32
$
47.14
$
42.24
$
39.54
MRO
MR
$
-
$
-
$
-
$
-
MRl
MR
$
0.25
$
0.22
$
0.20
$
0.19
MR2
MR
$
0.34
$
0.30
$
0.28
$
0.27
MR3
MR
$
0.59
$
0.54
$
0.50
$
0.47
MR4
MR
$
1.37
$
1.11
$
0.99
$
0.90
MRS
MR
$
2.44
$
1.96
$
1.74
$
1.58
AEROO
AERO
$
-
$
-
$
-
$
-
AER05
AERO
$
56.65
$
50.44
$
46.71
$
44.33
AEROlO
AERO
$ 115.82
$ 103.13
$
95.49
$
90.62
AER015
AERO
$ 163.66
$ 145.72
$ 134.93
$ 128.05
AER020
AERO
$ 289.56
$ 257.82
$ 238.72
$ 226.56
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Table 11-13- Summary of Absolute Vehicle Technology Cost vs. Baseline for SUVs,
I ncI u d.mg L earnmg
. Enects an d R eta•·1 P nee
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
(a) Reduced Rolling Resistance
Lower-rolling-resistance tires have
characteristics that reduce frictional
losses associated with the energy
dissipated mainly in the deformation of
the tires under load, thereby improving
fuel economy and reducing CO2
emissions. New for this proposal, and
also marking an advance over low
rolling resistance tires considered
during the heavy duty greenhouse gas
rulemaking,162 is a second level of lower
rolling resistance tires that reduce
frictional losses even further. The first
level of low rolling resistance tires will
have 10% rolling resistance reduction
while the second level would have 20%
162 See 76 FR 57106, at 57207, 57229 (Sep. 15,
2011).
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rolling resistance reduction. In this
NPRM, baseline vehicle reference
rolling resistance values were
determined based on the MY 2016
vehicles rather than the MY 2008
vehicles used in the 2012 final rule.
Rolling resistance values were assigned
based on CBI shared by manufacturers.
In some cases, low rolling resistance
tires can affect traction, which may be
untenable for some high performance
vehicles. For cars and SUVs with more
than 405 horsepower, the analysis
restricted the application of the highest
levels of rolling resistance. For cars and
SUVs with more than 500 horsepower,
the analysis restricted the application of
any additional rolling resistance
technology.
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(b) Reduced Aerodynamic Drag
Coefficient
Aerodynamic drag reduction can be
achieved via two approaches, either by
reducing the drag coefficients or
reducing vehicle frontal area. To reduce
the drag coefficient, skirts, air dams,
underbody covers, and more
aerodynamic side view mirrors can be
applied. In the MY 2017–2025 final rule
and the 2016 Draft TAR, the analysis
included two levels of aerodynamic
technologies. The second level included
active grille shutters, rear visors, and
larger under body panels. This NPRM
expanded the aerodynamic drag
improvements from two levels to four to
provide more discrete levels. The NPRM
levels are 5%, 10%, 15%, and 20%
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
improvement relative to baseline
reference vehicles. The agencies relied
on the wind tunnel testing performed by
National Research Council (NRC),
Canada, Transport Canada (TC), and
Environment and Climate Change,
Canada (ECCC) to quantify the
aerodynamic drag impacts of various
OEM aerodynamic technologies and to
explore the improvement potential of
these technologies by expanding the
capability and/or improving the design
of MY 2016 state-of-the-art aerodynamic
treatments. The agencies estimated the
level of aerodynamic drag in each
vehicle model in the MY 2016 baseline
fleet and gathered CBI on aerodynamic
drag coefficients, so each vehicle has an
appropriate initial value for further
improvements.
Notably, today’s analysis assumes
aerodynamic drag reduction can only
come from reduction in the
aerodynamic drag coefficient and not
from reduction of frontal area.163 For
some bodystyles, the agencies have no
evidence that manufacturers may be
able to achieve 15% or 20%
aerodynamic drag coefficient reduction
relative to baseline for some bodystyles
(for instance, with pickup trucks) due to
form drag limitions. Previously, EPA
analysis assumed some vehicles from all
bodystyles could (and would) reduce
aerodynamic forces by 20%, which in
some cases led to future pickup trucks
having aerodynamic drag coefficients
better than some of today’s typical cars,
if frontal area were held constant. While
ANL created full-vehicle simulations for
trucks with 20% drag reduction, those
simulations were not used in the CAFE
previously assumed that manufacturers
could reduce frontal area as well as aerodynamic
drag coefficient to achieve 20% aerodynamic force
reduction relative to ‘‘Null’’ or initial aerodynamic
technology level; however, reducing frontal area
would likely degrade other utility features like
interior volume, or ingress/egress.
sradovich on DSK3GMQ082PROD with PROPOSALS2
163 EPA
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modeling. That level of drag reduction
is likely not technologically feasible
with today’s technology, and the
analysis accordingly restricted the
application of advanced levels of
aerodynamics in some instances, such
as in this case, due to bodystyle form
drag limitations. Separate from form
drag limitations, some high performance
vehicles already use advanced
aerodynamics technologies to generate
down force, and sometimes these
applications must trade-off between
aerodynamic drag coefficient reduction
and down force. Today’s analysis does
not apply 15% or 20% aerodynamic
drag coefficient reduction to cars and
SUVs with more than 405 horsepower.
(c) Mass Reduction
Mass Reduction can be achieved in
many ways, such as material
substitution, design optimization, part
consolidation, improving manufacturing
process, etc. The analysis utilizes mass
reduction levels of 5, 10, 15, and 20%
relative to a reference glider vehicle for
each vehicle subsegment. For HEV,
PHEV, and BEV vehicles, net mass
reduction was considered, including the
mass reduction applied to the glider and
the added mass of electrification
components. An extensive discussion of
mass reduction technologies as well as
the cost of mass reduction is located in
Chapter 6.3 of the PRIA. The analysis
included an estimated level of mass
reduction technology in each vehicle
model in the MY 2016 baseline fleet so
that each vehicle model has an
appropriate initial value for further
improvements.
(d) Low Drag Brakes (LDB)
Low-drag brakes reduce the sliding
friction of disc brake pads on rotors
when the brakes are not engaged
because the brake pads are pulled away
from the rotors.
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(e) Secondary Axle Disconnect (SAX)
Front or secondary axle disconnect for
all-wheel drive systems provides a
torque distribution disconnect between
front and rear axles when torque is not
required for the non-driving axle. This
results in the reduction of associated
parasitic energy losses.
8. Electrification Technologies
For this NPRM, the analysis of
electrification technologies relies
primarily on research published by the
Department of Energy, ANL.164 ANL’s
assumptions regarding all hybrid
systems, including belt-integrated
starter generators, strong parallel and
series hybrids, plug-in hybrids,165 and
battery electric vehicles, and most
projected technology costs were adopted
for this analysis. In addition, the most
recent ANL BatPaC model is used to
estimate battery costs. Table II–15 and
Table II–16 below show the absolute
costs of all electrification technologies
estimated for this NPRM analysis
relative to a basic internal combustion
engine vehicle with a 5-speed automatic
transmission.166
164 Moawad et al., Assessment of vehicle sizing,
energy consumption, and cost through large-scale
simulation of advanced engine technologies,
Argonne National Laboratory (March 2016),
available at https://www.autonomie.net/pdfs/
Report%20ANL%20ESD-1528%20-%20Assessment
%20of%20Vehicle%20Sizing,%20Energy%20
Consumption%20and%20Cost%20through
%20Large%20Scale%20Simulation%20
of%20Advanced%20Vehicle%20Technologies%20%201603.pdf.
165 Notably all power split hybrids, and all plugin hybrid vehicles were assumed to be paired with
a high compression ratio internal combustion
engine for this analysis.
166 Note: These costs do not include value loss for
HEVs, PHEVs, and BEVs. Powertrain hardware
between cars and small SUV’s is often similar,
especially if technology is used vehicles on the
same platform; however, battery pack sizes may
vary meaningfully to deliver similar range in
different applications.
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Table 11-15 - Summary of Car and Small SUV Absolute Electrification Technology Cost
Without Batteries vs. Baseline Internal Combustion Engine, Including Learning Effects
. E.qmva
. Ien t
an d R et a•·1 P nee
Name
Technology Pathway
C-2017
CONV
Electrification
$
SS12V
Electrification
$
BISG
C-2021
-
C-2025
C-2029
$
-
$
-
$
-
657.92
$
568.03
$
508.83
$
473.05
Electrification
$ 1,137.19
$
829.75
$
714.98
$
655.86
CISG
Electrification
$
$
781.09
$
691.89
$
651.54
SHEVP2
Hybrid/Electric
$ 2,206.07
$ 1,942.13
$ 1,732.29
$ 1,637.38
SHEVPS
Hybrid/Electric
$ 6,477.91
$ 5,664.33
$ 5,017.49
$ 4,724.85
PHEV30
Advanced Hybrid/Electric
$ 8,180.35
$ 6,956.06
$ 6,008.25
$ 5,587.55
PHEV50
Advanced Hybrid/Electric
$ 8,338.69
$ 7,011.23
$ 5,994.55
$ 5,546.75
BEV200
Advanced Hybrid/Electric
$ 2,976.02
$ 2,324.66
$ 1,859.67
$ 1,664.95
FCV
Advanced Hybrid/Electric
$19,673.32
$17,607.59
$16,485.05
$15,702.81
893.28
Name
Technology Pathway
C-2017
CONV
Electrification
$
-
$
-
$
SS12V
Electrification
$
735.31
$
634.85
$
568.69
$
528.70
BISG
Electrification
$
524.86
$
382.96
$
329.99
$
302.70
CISG
Electrification
$ 1,786.54
$ 1,562.17
$ 1,383.78
$ 1,303.07
SHEVP2
Hybrid/Electric
$ 1,924.68
$ 1,696.08
$ 1,514.34
$ 1,432.14
SHEVPS
Hybrid/Electric
$ 8,038.86
$ 7,029.24
$ 6,226.53
$ 5,863.38
PHEV30
Advanced Hybrid/Electric
$10,395.42
$ 8,839.62
$ 7,635.17
$ 7,100.55
PHEV50
Advanced Hybrid/Electric
$10,683.13
$ 8,982.46
$ 7,679.93
$ 7,106.23
BEV200
Advanced Hybrid/Electric
$ 4,351.27
$ 3,398.92
$ 2,719.04
$ 2,434.34
FCV
Advanced Hybrid/Electric
$25,969.16
$23,242.36
$21,760.59
$20,728.01
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Table 11-16- Summary of Truck and Medium SUV Absolute Electrification Technology
Cost Without Batteries vs. Baseline Internal Combustion Engine, Including Learning
Enect san d R et a•·1 P nee
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
(a) Hybrid Technologies
(1) 12-Volt Stop-Start
12-volt Stop-Start, sometimes referred
to as idle-stop or 12-volt micro hybrid,
is the most basic hybrid system that
facilitates idle-stop capability. These
systems typically incorporate an
enhanced performance battery and other
features such as electric transmission
pump and cooling pump to maintain
vehicle systems during idle-stop.
(2) Higher Voltage Stop-Start/Belt
Integrated Starter Generator
Higher Voltage Stop-Start/Belt
Integrated Starter Generator (BISG),
sometimes referred to as a mild hybrid
system, provides idle-stop capability
and uses a higher voltage battery with
increased energy capacity over typical
automotive batteries. The higher system
voltage allows the use of a smaller, more
powerful electric motor. This system
replaces a standard alternator with an
enhanced power, higher voltage, higher
efficiency starter-alternator, that is belt
driven and that can recover braking
energy while the vehicle slows down
(regenerative braking). Today’s analysis
assumes 48V systems on cars and small
SUVs and high voltage systems for large
SUVs and trucks. Future analysis may
reference the application and operation
of 48V systems on large SUVs and
trucks, if applicable.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(3) Integrated Motor Assist (IMA)/Crank
Integrated Starter Generator
Integrated Motor Assist (IMA)/Crank
integrated starter generator (CISG)
provides idle-stop capability and uses a
high voltage battery with increased
energy capacity over typical automotive
batteries. The higher system voltage
allows the use of a smaller, more
powerful electric motor and reduces the
weight of the wiring harness. This
system replaces a standard alternator
with an enhanced power, higher
voltage, higher efficiency starter
alternator that is crankshaft-mounted
and can recover braking energy while
the vehicle slows down (regenerative
braking).
(4) P2 Hybrid
P2 Hybrid (SHEVP2) is a newly
emerging hybrid technology that uses a
transmission-integrated electric motor
placed between the engine and a
gearbox or CVT, much like the IMA
system described above except with a
wet or dry separation clutch that is used
to decouple the motor/transmission
from the engine. In addition, a P2
hybrid would typically be equipped
with a larger electric machine.
Disengaging the clutch allows all-
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electric operation and more efficient
brake-energy recovery. Engaging the
clutch allows efficient coupling of the
engine and electric motor and, when
combined with a DCT transmission,
reduces gear-train losses relative to
power-split or 2-mode hybrid systems.
Battery costs are now considered
separately from other HEV hardware.
P2 Hybrid systems typically rely on
the internal combustion engine to
deliver high, sustained power levels.
While many vehicles may use HCR1
engines as part of a hybrid powertrain,
HCR1 engines may not be suitable for all
vehicles, especially high performance
vehicles, or vehicles designed to carry
or tow large loads. Many manufacturers
may prefer turbo engines (with high
specific power output) for P2 Hybrid
systems.
(5) Power-Split Hybrid
Power-split Hybrid (SHEVPS) is a
hybrid electric drive system that
replaces the traditional transmission
with a single planetary gearset and a
motor/generator. This motor/generator
uses the engine to either charge the
battery or supply additional power to
the drive motor. A second, more
powerful motor/generator is
permanently connected to the vehicle’s
final drive and always turns with the
wheels. The planetary gear splits engine
power between the first motor/generator
and the drive motor to either charge the
battery or supply power to the wheels.
The power-split hybrid technology is
included in this analysis as an enabling
technology supporting this proposal,
(the agencies evaluate the P2 hybrid
technology discussed above where
power-split hybrids might otherwise
have been appropriate). As stated above,
battery costs are now considered
separately from other HEV hardware.
Power-split hybrid technology as
modeled in this analysis is not suitable
for large vehicles that must handle high
loads.
The ANL Autonomie simulations
assumed all power-split hybrids use a
high compression ratio engine.
Therefore, all vehicles equipped with
SHEVPS technology in the CAFE model
inputs and simulations are assumed to
have high compression ratio engines.
(6) Plug-in Hybrid Electric
Plug-in hybrid electric vehicles
(PHEV) are hybrid electric vehicles with
the means to charge their battery packs
from an outside source of electricity
(usually the electric grid). These
vehicles have larger battery packs with
more energy storage and a greater
capability to be discharged than other
hybrid electric vehicles. They also use
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a control system that allows the battery
pack to be substantially depleted under
electric-only or blended mechanical/
electric operation and batteries that can
be cycled in charge sustaining operation
at a lower state of charge than is typical
of other hybrid electric vehicles. These
vehicles are sometimes referred to as
Range Extended Electric Vehicles
(REEV). In this NPRM analysis, PHEVs
with two all-electric ranges—both a 30
mile and a 50 mile all-electric range—
have been included as potential
technologies. Again, battery costs are
now considered separately from other
PHEV hardware.
The ANL Autonomie simulations
assumed all PHEVs use a high
compression ratio engine. Therefore, all
vehicles equipped with PHEV
technology in the CAFE model inputs
and simulations are assumed to have
high compression ratio engines. In
practice, many PHEVs recently
introduced in the marketplace use
turbo-charged engines in the PHEV
system, and this is particularly true for
PHEVs produced by European
manufacturers and for other PHEV
performance vehicle applications.
Please provide comment on the
modeling of PHEV systems. Should
turbo PHEVs be considered instead, or
in addition to high compression ratio
PHEVs? Why or why not? What vehicle
segments may turbo PHEVs best be
suited for, and which segments would it
not be best suited for? What vehicle
segments may high compression ratio
PHEVs best be suited for, and which
segments would it not be best suited
for? Similarly, the analysis currently
considers PHEVs with 30-mile and 50mile all-electric range, and should other
ranges be considered? For instance, a
20-mile all-electic range may decrease
the battery pack size, and hence the
battery pack cost relative to a 30-mile
all-electric range system, while still
providing electric-vehicle functionality
in many applications. Do commenters
believe PHEV technology will see
widespread adoption in the US vehicle
fleet? Why or why not? Please provide
supporting data.
(b) Full Electrification and Fuel Cell
Vehicles
(1) Battery Electric
Electric vehicles (EV) are equipped
with all-electric drive and with systems
powered by energy-optimized batteries
charged primarily from grid electricity.
EVs with range of 200 miles have been
included as a potential technology in
this NPRM. Battery costs are now
considered separately from other EV
hardware.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
(2) Fuel Cell Electric
Fuel cell electric vehicles (FCEVs)
utilize a full electric drive platform but
consume electricity generated by an
onboard fuel cell and hydrogen fuel.
Fuel cells are electrochemical devices
that directly convert reactants (hydrogen
and oxygen via air) into electricity, with
the potential of achieving more than
twice the efficiency of conventional
internal combustion engines. High
pressure gaseous hydrogen storage tanks
are used by most automakers for FCEVs.
The high pressure tanks are similar to
those used for compressed gas storage in
more than 10 million CNG vehicles
worldwide, except that they are
designed to operate at a higher pressure
(350 bar or 700 bar vs. 250 bar for CNG).
FCEVs are currently produced in
limited numbers and are available in
limited geographic areas.
(a) Electric Power Steering (EPS)
because it replaces a continuously
operated hydraulic pump, thereby
reducing parasitic losses from the
accessory drive. Manufacturers have
informed the agencies that full EPS
systems are being developed for all
and charge convenience is not taken
into account in the CAFE model. Also,
today’s analysis assumes HEVs, PHEVs,
and BEVs have the same survival rates
and mileage accumulation schedules as
vehicles with conventional powertrains,
and that HEVs, PHEVs, and BEVs never
receive replacement batteries before
being scrapped. The agencies invite
comment on these assumptions and on
data and practicable methods to
implement any alternatives.
9. Accessory Technologies
Two accessory technologies, electric
power steering (EPS) and improved
accessories (IACC) (accessory
technologies categorized for the 2012
rule) were considered in this analysis,
and are described below.167 Table II–17
and Table II–18 below shows the
estimated absolute costs including
learning effects and retail price
equivalent utilized in today’s analysis.
types of light-duty vehicles, including
large trucks. However, this analysis
applies the EHPS technology to large
trucks and the EPS technology to all
other light-duty vehicles.
EP24AU18.033
167 For further discussion of accessory
technologies, see Chapter 6 of the PRIA
accompanying this NPRM.
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Electric power steering (EPS)/
Electrohydraulic power steering (EHPS)
is an electrically-assisted steering
system that has advantages over
traditional hydraulic power steering
(c) Electric Vehicle Infrastructure
BEVs and PHEVs may be charged at
home or elsewhere. Home chargers may
access electricity from a regular wall
outlet, or they may require special
equipment to be installed at the home.
Commercial chargers may sometimes be
found at businesses or other travel
locations. These chargers often may
supply power to the vehicle at a faster
rate of charge but often require
significant capital investment to install.
Time to charge, and availability and
convenience of charging are significant
factors for plug-in vehicle operators. For
many consumers, accessible charging
stations present inconveniences that
may deter the adoption of battery
electric and plug-in hybrid vehicles.
More detail about charging and
charging infrastructure, including a
discussion of potential electric vehicle
impacts on the electric grid, is available
in the PRIA, Chapter 6. For today’s
analysis, costs for installing chargers
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
(b) Improved Accessories (IACC)
Improved accessories (IACC) may
include high efficiency alternators,
electrically driven (i.e., on-demand)
water pumps, variable geometry oil
pumps, cooling fans, a mild
regeneration strategy, and high
efficiency alternators. It excludes other
electrical accessories such as electric oil
pumps and electrically driven air
conditioner compressors. In the MY
2017–2025 final rule, two levels of IACC
were offered as a technology path (a low
improvement level and a high
improvement level). Since much of the
market has incorporated some of these
technologies in the MY 2016 fleet, the
analysis assumes all vehicles have
incorporated what was previously the
low level, so only the high level remains
as an option for some vehicles.
sradovich on DSK3GMQ082PROD with PROPOSALS2
10. Other Technologies Considered but
Not Included in This Aanalysis
Manufacturers, suppliers, and
researchers continue to create a diverse
set of fuel economy technologies. Many
high potential technologies that are still
in the early stages of the development
and commercialization process are still
being evaluated for any final analysis.
Due to uncertainties in the cost and
capabilities of emerging technologies,
some new and pre-production
technologies are not yet a part of the
CAFE model simulation. Evaluating and
benchmarking promising fuel economy
technologies continues to be a priority
as commercial development matures.
(a) Engine Technologies
• Variable compression ratio (VCR)—
varies the compression ratio and swept
volume by changing the piston stroke on
all cylinders. Manufacturers accomplish
this by changing the effective length of
the piston connecting rod, with some
prototypes having a range of 8:1 to 14:1
compression ratio. In turbocharged
form, early publications suggest VCR
may be possible to deliver up to 35%
improved efficiency over the existing
equivalent-output naturally-aspirated
engine.168
• Opposed-piston engine—sometimes
known as opposed-piston opposedcylinder (OPOC), operates with two
pistons per cylinder working in
opposite reciprocal motion and running
on a two-stroke combustion cycle. It has
no cylinder head or valvetrain but
requires a turbocharger and
168 See e.g., VC—Turbo—The world’s first
production-ready variable compression ratio
engine, Nissan Motor Corporation (Dec. 13, 2017),
https://newsroom.nissan-global.com/releases/
release-917079cb4af478a2d26bf8e5ac00ae49-vcturbo-the-worlds-first-production-ready-variablecompression-ratio-engine.
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supercharger for engine breathing. The
efficiency may be significantly higher
than MY 2016 turbocharged gasoline
engines with competitive costs. This
engine architecture could run on many
fuels, including gasoline and diesel.
Packaging constraints, emissions
compliance, and performance across a
wide range of operating conditions
remain as open considerations. No
production vehicles have been publicly
announced, and multiple manufacturers
continue to evaluate the
technology.169 170
• Dual-fuel—engine concepts such as
reactivity controlled compression
ignition (RCCI) combine multiple fuels
(e.g. gasoline and diesel) in cylinder to
improve brake thermal efficiency while
reducing NOX and particulate
emissions. This technology is still in the
research phase.171
• Smart accessory technologies—can
improve fuel efficiency through smarter
controls of existing systems given
imminent or expected controls inputs in
real world driving conditions. For
instance, a vehicle could adjust the use
of accessory systems to conserve energy
and fuel as a vehicle approaches a red
light. Vehicle connectivity and sensors
can further refine the operation for more
benefit and smoother operation.172
• High Compression Miller Cycle
Engine with Variable Geometry
Turbocharger or Electric Supercharger—
Atkinson cycle gasoline engines with
sophisticated forced induction system
that requires advanced controls. The
benefits of these technologies provide
better control of EGR rates and boost
which is achieved with electronically
controlled turbocharger or supercharger.
The electric version of this technology
which incorporates 48V is called Eboost.173 174
169 Murphy,
T. Achates: Opposed-Piston Engine
makers tooling up, Wards Auto (Jan. 23, 2017),
https://wardsauto.com/engines/achates-opposedpiston-engine-makers-tooling.
170 Our Formula, Achates Power, https://
achatespower.com/our-formula/opposed-piston/
(last visited June 21, 2018).
171 Robert Wagner, Enabling the Next Generation
of High Efficiency Engines, Oak Ridge National
Laboratory, U.S. Department of Energy (2012),
available at https://www.energy.gov/sites/prod/
files/2014/03/f8/deer12_wagner_0.pdf.
172 EfficientDynamics—The intelligent route to
lower emissions, BMW Group (2007), https://
www.bmwgroup.com/content/dam/bmw-groupwebsites/bmwgroup_com/responsibility/downloads/
en/2007/Alex_ED__englische_Version.pdf.
173 Volkswagen at the 37th Vienna Motor
Symposium, Volkswagen (Apr. 28, 2016), https://
www.volkswagen-media-services.com/en/
detailpage/-/detail/Volkswagen-at-the-37th-ViennaMotor-Symposium/view/3451577/
5f5a4dcc90111ee56bcca439f2dcc518?p_p_
auth=M2yfP3Ze.
174 These engines may be considered in the
analysis supporting the final rule, but these engine
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(b) Electrified Vehicle Powertrain
• Advanced battery chemistries—
many emerging battery technologies
promise to eventually improve the cost,
safety, charging time, and durability in
comparison to the MY 2016 automotive
lithium-ion batteries. For instance,
many view solid state batteries as a
promising medium-term automotive
technology. Solid state batteries replace
the battery’s liquid electrolyte with a
solid electrolyte to potentially improve
safety, power and energy density,
durability, and cost. Some variations
use ceramic, polymer, or sulfide-based
solid electrolytes. Multiple automakers
and suppliers are exploring the
technology and possible
commercialization that may occur in the
early 2020s.175 176 177
• Supercapacitors/Ultracapacitors—
An electrical energy storage device with
higher power density but lower energy
density than batteries. Advanced
capacitors may reduce battery
degradation associated with charge and
discharge cycles, with some tradeoffs to
cost and engineering complexity.
Supercapacitors/Ultracapacitors are
currently not used in parallel or as a
standalone traction motor energy storage
device.178
• Motor/Drivetrain:
Æ Lower-cost magnets for Brushless
Direct Current (BLDC) motors—BLDC
motor technology, common in hybrid
and battery electric vehicles, uses rare
earth magnets. By substituting and
eliminating rare earths from the
magnets, motor cost can be significantly
reduced. This technology is announced,
but not yet in production. The
capability and material configuration of
these systems remains a closely guarded
trade secret.179
maps were not available in time for the NPRM
analysis. Please see Chapter 6.3 of the PRIA
accompanying this proposal for more information.
175 Schmitt, B. Ultrafast-Charging Solid-State EV
Batteries Around The Corner, Toyota Confirms,
Forbes (Jul. 25, 2017), https://www.forbes.com/
sites/bertelschmitt/2017/07/25/ultrafast-chargingsolid-state-ev-batteries-around-the-corner-toyotaconfirms/#5736630244bb.
176 Moving toward clean mobility, Robert Bosch
GmbH, https://www.bosch.com/explore-andexperience/moving-toward-clean-mobility/ (last
visited June 21, 2018).
177 Reuters Staff, Honda considers developing all
solid-state EV batteries, Reuters (Dec. 21, 2017),
https://www.reuters.com/article/us-honda-nissan/
honda-considers-developing-all-solid-state-evbatteries-idUSKBN1EF0FM.
178 Burke, A. & Zhao,H. Applications of
Supercapacitors in Electric and Hybrid Vehicles,
Institute of Transportation Studies University of
California, Davis (Apr. 2015), available at https://
steps.ucdavis.edu/wp-content/uploads/2017/05/
2015-UCD-ITS-RR-15-09-1.pdf.
179 Buckland, K. & Sano, N. Toyota Readies
Cheaper Electric Motor by Halving Rare Earth Use,
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Æ Integrated multi-phase integrated
electric vehicle drivetrains. Research
has been conducted on 6-phase and 9phase integrated systems to potentially
reduce cost and improve power density.
Manufacturers may improve system
power density through integration of the
motor, inverter, control, and gearing.
These systems are in the research
phase.180 181
(c) Transmission Technologies
• Beltless CVT—Most MY 2016,
commercially available CVTs rely on
belt technology. A new architecture of
CVT replaces belts or pulleys with a
continuously variable variator, which is
a special type of planetary set with balls
and rings instead of gears. The
technology promises to improve
efficiency, handle higher torques, and
change modes more quickly. This
technology may be commercially
available as early as 2020.182
• Multi-speed electric motor
transmission—MY 2016 battery electric
vehicle transmissions are single-speed.
Multiple gears can allow for more
torque multiplication at lower speeds or
a downsized electric machine, increased
efficiency, and higher top speed. Twospeed transmission designs are available
but not currently in production.183
(d) Energy-Harvesting Technology
sradovich on DSK3GMQ082PROD with PROPOSALS2
• Vehicle waste heat recovery
systems—Internal combustion engines
convert the majority of the fuel’s energy
to heat. Thermoelectric generators and
heat pipes can convert this heat to
electricity.184 Thermoelectric
generators, often made of
semiconductors, have been tested by
automakers but have traditionally not
been implemented due to low efficiency
Bloomberg (Feb, 20, 2018), https://
www.bloomberg.com/news/articles/2018-02-20/
toyota-readies-cheaper-electric-motor-by-halvingrare-earth-use.
180 Burkhardt, Y., Spagnolo, A., Lucas, P.,
Zavesky, M., & Brockerhoff, P. ‘‘Design and analysis
of a highly integrated 9-phase drivetrain for EV
applications ’’ 20 November 2014. DOI. 10.1109/
ICELMACH.2014.6960219. IEEE xplore.
181 Patel, V., Wang, J., Nugraha, D., Vuletic, R., &
Tousen, J. ‘‘Enhanced Availability of Drivetrain
Through Novel Multi-Phase Permanent Magnet
Machine Drive’’ 2016. IEEE Transactions on
Industrial Electronics Pages. 469–480.
182 Murphy, T. Planets Aligning for Dana’s
VariGlide Beltless CVT, Wards Auto (Aug. 22,
2017), https://wardsauto.com/technology/planetsaligning-dana-s-variglide-beltless-cvt.
183 Faid, S. A Highly Efficient Two Speed
Transmission for Electric Vehicles (May 2015),
available at https://www.evs28.org/event_file/event_
file/1/pfile/EVS28_Saphir_Faid.pdf.
184 Orr et al., A review of car waste heat recovery
systems utilising thermoelectric generators and heat
pipes, 101 Applied Thermal Engineering 490–495
(May 25, 2016).
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and high cost.185 These systems are not
yet in production.
• Suspension energy recovery—
Multiple electromechanical and
electrohydraulic suspension
technologies exist that can convert
motion from uneven roads into
electricity.186 187 These technologies are
limited to luxury vehicles with limited
production volumes. This technology is
not produced in 2016 but planned for
production as early as 2018.188
11. Air Conditioning Efficiency and OffCycle Technologies
(a) Air Conditioning Efficiency
Technologies
Air conditioning (A/C) is a virtually
standard automotive accessory, with
more than 95% of new cars and light
trucks sold in the United States
equipped with mobile air conditioning
(MAC) systems. Most of the additional
air conditioning related load on an
engine is due to the compressor, which
pumps the refrigerant around the system
loop. The less the compressor operates
or the more efficiently it operates, the
less load the compressor places on the
engine, and the better fuel consumption
will be. This high penetration means A/
C systems can significantly impact
energy consumed by the light duty
vehicle fleet.
Vehicle manufacturers can generate
credits for improved A/C systems under
EPA’s GHG program and receive a fuel
consumption improvement value (FCIV)
equal to the value of the benefit not
captured on the 2-cycle test under
NHTSA’s CAFE program.189 Table II–19
provides a ‘‘menu’’ of qualifying A/C
technologies, with the magnitude of
each improvement value or credit
estimated based on the expected
reduction in CO2 emissions from the
technology.190 NHTSA converts the
improvement in grams per mile to a
FCIV for each vehicle for purposes of
measuring CAFE compliance. As part of
a manufacturer’s compliance data,
manufacturers will provide information
185 Patel, P. Powering Your Car with Waste Heat,
MIT Technology Review (May 25, 2011), https://
www.technologyreview.com/s/424092/poweringyour-car-with-waste-heat/.
186 Baeuml, B. et al., The Chassis of the Future,
Schaeffler, https://www.schaeffler.com/
remotemedien/media/_shared_media/08_media_
library/01_publications/schaeffler_2/symposia_1/
downloads_11/Schaeffler_Kolloquium_2014_27_
en.pdf (last visited June 21, 2018).
187 Advanced Suspension, Tenneco, https://
www.tenneco.com/overview/rc_advanced_
suspension/ (last visited June 21, 2018).
188 Audi A8 Active Chassis, Audi, https://
www.audi.com/en/innovation/design/more_
personal_comfort_a8_active_chassis.html (last
visited June 21, 2018).
189 77 FR 62624, 62720 (Oct. 15, 2012).
190 40 CFR 86.1868–12 (2016).
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about which off-cycle technologies are
present on which vehicles (see Section
X for further discussion of reporting offcycle technology information).
The 2012 final rule for MYs 2017 and
later outlined two test procedures to
determine credit or FCIV eligibility for
A/C efficiency menu credits, the idle
test, and the AC17 test. The idle test,
performed while the vehicle is at idle,
determined the additional CO2
generated at idle when the A/C system
is operated.191 The AC17 test is a fourpart performance test that combines the
existing SC03 driving cycle, the fuel
economy highway test cycle, and a preconditioning cycle, and solar soak
period.192 Manufacturers could use the
idle test or AC17 test to determine
improvement values for MYs 2014–
2016, while for MYs 2017 and later, the
AC17 test is the exclusive test that
manufacturers can use to demonstrate
eligibility for menu A/C improvement
values.
In MYs 2020 and later, manufacturers
will use the AC17 test to demonstrate
eligibility for A/C credits and to
partially quantify the amount of the
credit earned. AC17 test results equal to
or greater than the menu value will
allow manufacturers to claim the full
menu value for the credit. A test result
less than the menu value will limit the
amount of credit to that demonstrated
on the AC17 test. In addition, for MYs
2017 and beyond, A/C fuel consumption
improvement values will be available
for CAFE calculations, whereas
efficiency credits were previously only
available for GHG compliance. The
agencies proposed these changes in the
2012 final rule for MYs 2017 and later
largely as a result of new data collected,
as well as the extensive technical
comments submitted on the proposal.193
The pre-defined technology menu and
associated car and light truck credit
value is shown in Table II–19 below.
The regulations include a definition of
each technology that must be met to be
eligible for the menu credit.194
Manufacturers are not required to
submit any other emissions data or
information beyond meeting the
definition and useful life
requirements 195 to use the pre-defined
191 75 FR 25324, 25431 (May 7, 2010). The A/C
CO2 Idle Test is run with and without the A/C
system cooling the interior cabin while the vehicle’s
engine is operating at idle and with the system
under complete control of the engine and climate
control system.
192 77 FR 62624, 62723 (Oct. 15, 2012).
193 Id.
194 Id. at 62725.
195 Lifetime vehicle miles travelled (VMT) for MY
2017–2025 are 195,264 miles and 225,865 miles for
passenger cars and light trucks, respectively. The
manufacturer must also demonstrate that the off-
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credit value. Manufacturers’ use of
menu-based credits for A/C efficiency is
subject to a regulatory cap: 5.7 g/mi for
cars and trucks through MY 2016 and
separate caps of 5.0 g/mi for cars and
7.2g/mi for trucks for later MYs.196
In the 2012 final rule for MYs 2017
and later, the agencies estimated that
manufacturers would employ significant
advanced A/C technologies throughout
their fleets to improve fuel economy,
and this was reflected in the stringency
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cycle technology is effective for the full useful life
of the vehicle. Unless the manufacturer
demonstrates that the technology is not subject to
in-use deterioration, the manufacturer must account
for the deterioration in their analysis.
196 40 CFR 86.1868–12(b)(2) (2016).
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of the standards.197 Many manufacturers
have since incorporated A/C technology
throughout their fleets, and the
utilization of advanced A/C
technologies has become a significant
contributor to industry compliance
plans. As summarized in the EPA
Manufacturer Performance Report for
the 2016 model year,198 15 auto
manufacturers included A/C efficiency
credits as part of their compliance
demonstration in the 2016 MY. These
197 See e.g., 77 FR 62623, 62803–62806 (Oct. 15,
2012).
198 See Greenhouse Gas Emission Standards for
Light-Duty Vehicles: Manufacturer Performance
Report for the 2016 Model Year (EPA Report 420–
R18–002), U.S. EPA (Jan. 2018), available at https://
nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=
P100TGIA.pdf.
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amounted to more than 12 million Mg
of fuel consumption improvement
values of the total net fuel consumption
improvement values reported. This is
equivalent to approximately four grams
per mile across the 2016 fleet.
Accordingly, a significant amount of
new information about A/C technology
and the efficacy of test procedures has
become available since the 2012 final
rule.
The sections below provide a brief
history of the AC17 test procedure for
evaluating A/C efficiency improving
technology and discuss stakeholder
comments on the AC17 test procedure
approach and discuss A/C efficiency
technology valuation through the offcycle program.
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(1) Evaluation of the AC17 Test
Procedure Since the Draft TAR
In developing the AC17 test
procedure, the agencies sought to
develop a test procedure that could
more reliably generate an appropriate
fuel consumption improvement value
based on an ‘‘A’’ to ‘‘B’’ comparison,
that is, a comparison of substantially
similar vehicles in which one has the
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technology and the other does not.199
The agencies believe that the AC17 test
procedure is more capable of detecting
the effect of more efficient A/C
components and controls strategies
during a transient drive cycle rather
199 For
an explanation of how the agencies, in
collaboration with stakeholders, developed the
AC17 test procedure, see the 2017 and later final
rule at 77 FR 62624, 62723 (Oct. 15, 2012).
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than during just idle (as measured in the
old idle test procedure). As described
above and in the 2012 final rule,200 the
AC17 test is a four-part performance test
that combines the existing SC03 driving
200 See 77 FR 62624, 62723 (Oct. 15, 2012); Joint
Technical Support Document: Final Rulemaking for
2017–2025 Light-Duty Vehicle Greenhouse Gas
Emission and Corporate Average Fuel Economy
Standards, U.S. EPA, National Highway Traffic
Safety Administration at 5–40 (August 2012) .
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cycle, the fuel economy highway cycle,
as well as a pre-conditioning cycle, and
a solar soak period.
The agencies received several
comments on the Draft TAR evaluation
of the AC17 test procedure. FCA
commented generally that A/C
efficiency technologies ‘‘are not
showing their full effect on this AC17
test as most technologies provide benefit
at different temperatures and humidity
conditions in comparison to a standard
test conditions. All of these technologies
are effective at different levels at
different conditions. So there is not one
size fits all in this very complex testing
approach. Selecting one test that
captures benefits of all of these
conditions has not been possible.’’ 201
The agencies acknowledge that any
single test procedure is unlikely to
equally capture the real-world effect of
every potential technology in every
potential use case. Both the agencies
and stakeholders understood this
difficulty when developing the AC17
test procedure. While no test is perfect,
the AC17 test procedure represents an
industry best effort at identifying a test
that would greatly improve upon the
idle test by capturing a greater range of
operating conditions. General industry
evaluation of the AC17 test procedure is
in agreement that the test achieves this
objective.
FCA also noted that ‘‘[i]t is a major
problem to find a baseline vehicle that
is identical to the new vehicle but
without the new A/C technology. This
alone makes the test unworkable.’’ 202
The agencies disagree this makes the
test unworkable. The regulation
describes the baseline vehicle as a
‘‘similar’’ vehicle, selected with good
engineering judgment (such that the test
comparison is not unduly affected by
other differences). Also, OEMs
expressed confidence in using A-to-B
testing to qualify for fuel consumption
improvement values for software-based
A/C efficiency technologies. While
hardware technologies may pose a
greater challenge in locating a
sufficiently similar ‘‘A’’ baseline
vehicle, the engineering analysis
provision under 40 CFR 86.1868–
12(g)(2) provides an alternative to
locating and performing an AC17 test on
such a vehicle. Further, as the USCAR
program in general and the GM Denso
SAS compressor application specifically
have shown, the test is able to resolve
small differences in CO2 effectiveness
(1.3 grams in the latter case) when
carefully conducted.
Commenters on the Draft TAR also
expressed a desire for improvements in
the process by which manufacturers
without an ‘‘A’’ vehicle (for the A-to-B
comparison) could apply under the
engineering analysis provision, such as
development of standardized
engineering analysis and bench testing
procedures that could support such
applications. For example, Toyota
requested that ‘‘EPA consider an
optional method for validation via an
engineering analysis, as is currently
being developed by industry.’’ 203
Similarly, the Alliance commented that,
‘‘[t]he future success of the MAC credit
program in generating emissions
reductions will depend to a large extent
on the manner in which it is
administered by EPA, especially with
respect to making the AC17 A-to-B
provisions function smoothly, without
becoming a prohibitive obstacle to fully
achieving the MAC indirect credits.’’ 204
As described in the Draft TAR, in
2016, USCAR members initiated a
Cooperative Research Program (CRP)
through the Society of Automotive
Engineers (SAE) to develop bench
testing standards for the four hardware
technologies in the fuel consumption
improvement value menu (blower motor
control, internal heat exchanger,
improved evaporators and condensers,
and oil separator). The intent of the
program is to streamline the process of
conducting bench testing and
engineering analysis in support of an
application for A/C credits under 40
CFR part 86.1868–12(g)(2), by creating
uniform standards for bench testing and
for establishing the expected GHG effect
of the technology in a vehicle
application.
An update to the list of SAE standards
under development originally presented
in the Draft TAR is listed in Table II–
20. Since completion of the Draft TAR,
work has continued on these standards,
which appear to be nearing completion.
The agencies seek comment with the
latest completion of these SAE
standards.
(2) A/C Efficiency Technology Valuation
Through the Off-Cycle Program
by utilizing technologies on the menu;
however, the agencies recognize that
manufacturers will develop additional
technologies that are not currently listed
on the menu. These additional A/C
efficiency-improving technologies are
eligible for fuel consumption
improvement values on a case-by-case
basis under the off-cycle program.
Approval under the off-cycle program
also requires ‘‘A-to-B’’ comparison
testing under the AC17 test, that is,
testing substantially similar vehicles in
which one has the technology and the
other does not.
To date, the agencies have received
one type off-cycle application for an A/
C efficiency technology. In December
2014, General Motors submitted an offcycle application for the Denso SAS A/
203 See Comment by Toyota (revised), Docket ID
NHTSA–2016–0068–0088, at 23.
204 See Comment by Alliance of Automobile
Manufacturers, Docket ID EPA–HQ–OAR–2015–
0827–4089 and NHTSA–2016–0068–0072, at 160.
The A/C technology menu, discussed
at length above, includes several A/C
efficiency-improving technologies that
were well defined and had been
quantified for effectiveness at the time
of the 2012 final rule for MYs 2017 and
beyond. Manufacturers claimed the vast
majority of A/C efficiency credits to date
201 See Comment by FCA US LLC, Docket ID
NHTSA 2016–0068–0082, at 123–124.
202 Id. at 124.
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C compressor with variable crankcase
suction valve technology, requesting an
off-cycle GHG credit of 1.1 grams CO2
per mile. In December 2017, BMW of
North America, Ford Motor Company,
Hyundai Motor Company, and Toyota
petitioned and received approval to
receive the off-cycle improvement value
for the same A/C efficiency
technology.205 206 EPA, in consultation
with NHTSA, evaluated the applications
and found methodologies described
therein were sound and appropriate.207
Accordingly, the agencies approved the
fuel economy improvement value
applications.
The agencies received additional
stakeholder comments on the off-cycle
approval process as an alternate route to
receiving A/C technology credit values.
The Alliance requested that EPA
‘‘simplify and standardize the
procedures for claiming off-cycle credits
for the new MAC technologies that have
been developed since the creation of the
MAC indirect credit menu.’’ 208 Other
commenters noted the importance of
continuing to incentivize further
innovation in A/C efficiency
technologies as new technologies
emerge that are not listed on the menu
or when manufacturers begin to reach
regulatory caps. The commenters
suggested that EPA should consider
adding new A/C efficiency technologies
to the menu and/or update the fuel
consumption improvement values for
technology already listed on the menu,
particularly in cases where
manufacturers can show through an offcycle application that the technology
actually deserves more credit than that
listed on the menu. For example, Toyota
commented that ‘‘the incentive values
for A/C efficiency should be updated
along with including new technologies
being deployed.’’ 209
The agencies note that some of these
comments are directed towards the offcycle technology approval process
generally, which is described in more
detail in Section X of this preamble.
Regarding the A/C technology menu
specifically, the agencies do anticipate
205 EPA Decision Document: Off-Cycle Credits for
BMW Group, Ford Motor Company, and Hyundai
Motor Company, U.S. EPA (Dec. 2017), available at
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=
P100TF06.pdf.
206 Alternative Method for Calculating Off-cycle
Credits under the Light-Duty Vehicle Greenhouse
Gas Emissions Program: Applications from General
Motors and Toyota Motor North America, 83 FR
8262 (Feb. 26, 2018).
207 Id.
208 Comment by Alliance of Automobile
Manufacturers, Docket ID EPA–HQ–OAR–2015–
0827–4089 and NHTSA–2016–0068–0072, at 152.
209 Comment by Toyota (revised), Docket ID
NHTSA–2016–0068–0088, at 23.
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that new A/C technologies not currently
on the menu will emerge over the time
frame of the MY 2021–2026 standards.
This proposal requests comment on
adding one additional A/C technology
to the menu—the A/C compressor with
variable crankcase suction valve
technology, discussed below (and also
one off-cycle technology, discussed
below). The agencies also request
comment on whether to change any fuel
economy improvement values currently
assigned to technologies on the menu.
Next, as mentioned above, the menubased improvement values for A/C
efficiency established in the 2012 final
rule for MYs 2017 and by end are
subject to a regulatory cap. The rule set
a cap of 5.7 g/mi for cars and trucks
through MY 2016 and separate caps of
5.0 g/mi for cars and 7.2g/mi for trucks
for later MYs.210 Several commenters
asked EPA to reconsider the
applicability of the cap to non-menu A/
C efficiency technologies claimed
through the off-cycle process and
questioned the applicability of this cap
on several different grounds. These
comments appear to be in response to a
Draft TAR passage that stated:
‘‘Applications for A/C efficiency credits
made under the off-cycle credit program
rather than the A/C credit program will
continue to be subject to the A/C
efficiency credit cap’’ (Draft TAR, p. 5–
210). The agencies considered these
comments and present clarification
below. As additional context, the 2012
TSD states:
‘‘. . . air conditioner efficiency is an offcycle technology. It is thus appropriate [. . .]
to employ the standard off-cycle credit
approval process [to pursue a larger credit
than the menu value]. Utilization of bench
tests in combination with dynamometer tests
and simulations [. . .] would be an
appropriate alternate method of
demonstrating and quantifying technology
credits (up to the maximum level of credits
allowed for A/C efficiency) [emphasis added].
A manufacturer can choose this method even
for technologies that are not currently
included in the menu.’’ 211
This suggests the concept of placing a
limit on total A/C fuel consumption
improvement values, even when some
are granted under the off-cycle program,
is not entirely new and that EPA
considered the menu cap as being
appropriate at the time.
A/C regulatory caps specified under
40 CFR 86.1868–12(b)(2) apply to A/C
efficiency menu-based improvement
210 40
C.F.R § 86.1868–12(b)(2) (2016).
Technical Support Document: Final
Rulemaking for 2017–2025 Light-Duty Vehicle
Greenhouse Gas Emission and Corporate Average
Fuel Economy Standards, U.S. EPA, National
Highway Traffic Safety Administration at 5–58
(August 2012).
211 Joint
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values and are not part of the off-cycle
regulation (40 CFR 86.1869–12).
However, it should be noted that offcycle applications submitted via the
public process pathway are decided
individually on merits through a
process involving public notice and
opportunity for comment. In deciding
whether to approve or deny a request,
the agencies may take into account any
factors deemed relevant, including such
issues as the realization of claimed fuel
consumption improvement value in
real-world use. Such considerations
could include synergies or interactions
among applied technologies, which
could potentially be addressed by
application of some form of cap or other
applicable limit, if warranted.
Therefore, applying for A/C efficiency
fuel consumption improvement values
through the off-cycle provisions in 40
CFR 86.1869–12 should not be seen as
a route to unlimited A/C fuel
consumption improvement values. The
agencies discuss air conditioning
efficiency improvement values further
in Section X of this NPRM.
(b) Off-Cycle Technologies
‘‘Off-cycle’’ emission reductions and
fuel consumption improvements can be
achieved by employing off-cycle
technologies resulting in real-world
benefits but where that benefit is not
adequately captured on the test
procedures used to demonstrate
compliance with fuel economy emission
standards. EPA initially included offcycle technology credits in the MY
2012–2016 rule and revised the program
in the MY 2017–2025 rule.212 NHTSA
adopted equivalent off-cycle fuel
consumption improvement values for
MYs 2017 and later in the MY 2017–
2025 rule.213
Manufacturers can demonstrate the
value of off-cycle technologies in three
ways: First, they may select fuel
economy improvement values and CO2
credit values from a pre-defined
‘‘menu’’ for off-cycle technologies that
meet certain regulatory specifications.
As part of a manufacturer’s compliance
data, manufacturers will provide
information about which off-cycle
technologies are present on which
vehicles.
The pre-defined list of technologies
and associated off-cycle light-duty
vehicle fuel economy improvement
values and GHG credits is shown in
Table II–21 and Table II–22 below.214 A
212 77
FR 62624, 62832 (Oct. 15, 2012).
at 62839.
214 For a description of each technology and the
derivation of the pre-defined credit levels, see
Chapter 5 of the Joint Technical Support Document:
213 Id.
E:\FR\FM\24AUP2.SGM
24AUP2
43057
definition of each technology equipment
must meet to be eligible for the menu
credit is included at 40 CFR 86.1869–
12(b)(4). Manufacturers are not required
to submit any other emissions data or
information beyond meeting the
definition and useful life requirements
to use the pre-defined credit value.
Credits based on the pre-defined list are
subject to an annual manufacturer fleetwide cap of 10 g/mile.
Manufacturers can also perform their
own 5-cycle testing and submit test
results to the agencies with a request
explaining the off-cycle technology. The
additional three test cycles have
different operating conditions including
high speeds, rapid accelerations, high
temperature with A/C operation and
cold temperature, enabling
improvements to be measured for
technologies that do not impact
operation on the 2-cycle tests. Credits
determined according to this
methodology do not undergo public
review.
The third pathway allows
manufacturers to seek EPA approval to
use an alternative methodology for
determining the value of an off-cycle
technology. This option is only
available if the benefit of the technology
cannot be adequately demonstrated
using the 5-cycle methodology.
Manufacturers may also use this option
to demonstrate reductions that exceed
Final Rulemaking for 2017–2025 Light-Duty Vehicle
Greenhouse Gas Emission and Corporate Average
Fuel Economy Standards, U.S. EPA, National
Highway Traffic Safety Administration (August
2012).
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
those available via use of the
predetermined menu list. The
manufacturer must also demonstrate
that the off-cycle technology is effective
for the full useful life of the vehicle.
Unless the manufacturer demonstrates
that the technology is not subject to inuse deterioration, the manufacturer
must account for the deterioration in
their analysis.
Manufacturers must develop a
methodology for demonstrating the
benefit of the off-cycle technology, and
EPA makes the methodology available
for public comment prior to an EPA
determination, in consultation with
NHTSA, on whether to allow the use of
the methodology to measure
improvements. The data needed for this
demonstration may be extensive.
Several manufacturers have requested
and been granted use of alternative test
methodologies for measuring
improvements. In 2013, Mercedes
requested off-cycle credits for the
following off-cycle technologies in use
or planned for implementation in the
2012–2016 model years: Stop-start
systems, high-efficiency lighting,
infrared glass glazing, and active seat
ventilation. EPA approved
methodologies for Mercedes to
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
determine these off-cycle credits in
September 2014.215 Subsequently, FCA,
Ford, and GM requested off-cycle
credits using this same methodology.
FCA and Ford submitted applications
for off-cycle credits from high efficiency
exterior lighting, solar reflective glass/
glazing, solar reflective paint, and active
seat ventilation. Ford’s application also
demonstrated off-cycle benefits from
active aerodynamic improvements
(grille shutters), active transmission
warm-up, active engine warm-up
technologies, and engine idle stop-start.
GM’s application described real-world
benefits of an air conditioning
compressor with variable crankcase
suction valve technology. EPA approved
the credits for FCA, Ford, and GM in
September 2015.216 Note, however, that
although EPA granted the use of
alternative methodologies to determine
215 EPA Decision Document: Mercedes-Benz Offcycle Credits for MYs 2012–2016, U.S. EPA (Sept.
2014), available at https://nepis.epa.gov/Exe/
ZyPDF.cgi/P100KB8U.PDF?Dockey=
P100KB8U.PDF.
216 EPA Decision Document: Off-cycle Credits for
Fiat Chrysler Automobiles, Ford Motor Company,
and General Motors Corporation, U.S. EPA (Sept.
2015), available at https://nepis.epa.gov/Exe/
ZyPDF.cgi/P100N19E.PDF?Dockey=P100N19E.PDF.
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credit values, manufacturers have yet to
report credits to EPA based on those
alternative methodologies.
As discussed below, all three methods
have been used by manufacturers to
generate off-cycle improvement values
and credits.
(1) Use of Off-Cycle Technologies to
Date
Manufacturers used a wide array of
off-cycle technologies in MY 2016 to
generate off-cycle GHG credits using the
pre-defined menu. Table II–23 below
shows the percent of each
manufacturer’s production volume
using each menu technology reported to
EPA for MY 2016 by manufacturer.
Table II–24 shows the g/mile benefit
each manufacturer reported across its
fleet from each off-cycle technology.
Like Table II–23, Table II–24 provides
the mix of technologies used in MY
2016 by manufacturer and the extent to
which each technology benefits each
manufacturer’s fleet. Fuel consumption
improvement values for off-cycle
technologies were not available in the
CAFE program until MY 2017; therefore,
only GHG off-cycle credits have been
generated by manufacturers thus far.
E:\FR\FM\24AUP2.SGM
24AUP2
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VerDate Sep<11>2014
anufacturer
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Hyundai
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0.8
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Nissan
Subaru
Toyota
FCA
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0.0
26.9
33.6
3.6
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
17.2
5.3
0.0
0.0
4.6
0.0
0.0
0.0
0.0
16.9
0.0
0.0
0.0
16.5
0.0
19.7
0.0
70.9
0.0
0.0
81.1
0.6
0.0
9.2
81.5
65.7
48.1
59.0
0.0
0.2
0.0
0.0
27.7
2.4
91.8
0.0
10.8
98.6
3.1
51.5
22.7
11.9
69.0
0.0
14.6
0.4
23.5
2.3
12.2
51.9
13.2
20.7
28.2
5.8
49.1
0.0
d
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(.)
VJ
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-23- Percent of2016 Model Year Vehicle Production Volume with Credits from the Menu, by Manufacturer &
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43060
-.-----
Manufacturer
Active
Aerodynamics
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24AUP2
Rover generated the most off-cycle
credits on a fleet-wide basis, reporting
credits equivalent to approximately 6 g/
mile and 5 g/mile, respectively. Several
other manufacturers report fleet-wide
credits in the range of approximately 1
to 4 g/mile. In MY 2016, the fleet total
across manufacturers equaled
approximately 2.5 g/mile. The agencies
E:\FR\FM\24AUP2.SGM
was the first year that manufacturers
could generate credits using pre-defined
menu values, manufacturers have acted
quickly to generate substantial off-cycle
improvements. FCA and Jaguar Land
Frm 00076
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-
6.4
3.2
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2.3
2.0
15.7
0.0
2.2
0.0
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0.
0
Note: "0.0" indicates the manufacturer implemented that technology, but the overall penetration rate was not high
enough to round to 0.1 g/mi whereas a dash indicates no use of a given technology by a manufacturer.
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Jkt 244001
In 2016, manufacturers generated the
vast majority of credits using the predefined menu.217 Although MY 2014
23:42 Aug 23, 2018
217 Thus far, the agencies have only granted one
manufacturer (GM) off-cycle credits for technology
based on 5-cycle testing. These credits are for an
off-cycle technology used on certain GM gasolineelectric hybrid vehicles, an auxiliary electric pump,
which keeps engine coolant circulating in cold
VerDate Sep<11>2014
Table 11-24- Model Year 2016 Off-Cycle Technology Fuel Consumption Improvement Value from the Menu, by
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
expect that as manufacturers continue
expanding their use of off-cycle
technologies, the fleet-wide effects will
continue to grow with some
manufacturers potentially approaching
the 10 g/mile fleet-wide cap.
E. Development of Economic
Assumptions and Information Used as
Inputs to the Analysis
1. Purpose of Developing Economic
Assumptions for Use in Modeling
Analysis
sradovich on DSK3GMQ082PROD with PROPOSALS2
(a) Overall Framework of Costs and
Benefits
It is important to report the benefits
and costs of this proposed action in a
format that conveys useful information
about how those impacts are generated
and that also distinguishes the impacts
of those economic consequences for
private businesses and households from
the effects on the remainder of the U.S.
economy. A reporting format will
accomplish the first objective to the
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
extent that it clarifies the benefits and
costs of the proposed action’s impacts
on car and light truck producers,
illustrates how these are transmitted to
buyers of new vehicles, shows the
action’s collateral economic effects on
owners of used cars and light trucks,
and identifies how these impacts create
costs and benefits for the remainder of
the U.S. economy. It will achieve the
second objective by showing clearly
how the economy-wide or ‘‘social’’
benefits and costs of the proposed
action are composed of its direct effects
on vehicle producers, buyers, and users,
plus the indirect or ‘‘external’’ benefits
and costs it creates for the general
public.
Table II–25 through Table II–28
present the economic benefits and costs
of the proposed action to reduce CAFE
and CO2 emissions standards for model
years 2021–26 at three percent and
seven percent discount rates in a format
that is intended to meet these objectives.
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43061
Note: They include costs which are
transfers between different economic
actors—these will appear as both a cost
and a benefit in equal amounts (to
separate affected parties). Societal cost
and benefit values shown elsewhere in
this document do not show costs which
are transfers for the sake of simplicity
but report the same net societal costs
and benefits. As it indicates, the
proposed action first reduces costs to
manufacturers for adding technology
necessary to enable new cars and light
trucks to comply with fuel economy and
emission regulations (line 1). It may also
reduce fine payments by manufacturers
who would have failed to comply with
the more demanding baseline standards.
Manufacturers are assumed to transfer
these cost savings on to buyers by
charging lower prices (line 5); although
this reduces their revenues (line 3), on
balance, the reduction in compliance
costs and lower sales revenue leaves
them financially unaffected (line 4).
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VerDate Sep<11>2014
Table 11-25 - Benefits and Costs Resulting from the Proposed CAFE Standards
Jkt 244001
PO 00000
Private Benefits and (Costs)
Amount
Savings in technology costs to increase fuel economy
$252.6
Reduced fine payments for non-compliance
$3.0
assumed = -(1 + 2)
Net loss in revenue from lower vehicle prices
($255.6)
4
net= 1+2+3
Net benefits to manufacturers
$0.0
5
assumed= 3
Lower purchase prices for new vehicles
$255.6
Reduced injuries and fatalities from higher vehicle weight
$2.4
Higher fuel costs from lower fuel economy (at retail
prices)*
($152.6)
Inconvenience from more frequent refueling
($8.5)
Lost mobility benefits from reduced driving
($61.0)
net= 5+6+7+8+9
Net benefits to new vehicle buyers
$35.9
1
2
3
Source
CAFE model
Vehicle
Manufacturers
6
Frm 00078
7
Fmt 4701
9
8
New Vehicle
Buyers
Sfmt 4725
10
CAFE model
E:\FR\FM\24AUP2.SGM
11
Used Vehicle
Owners
CAFE model
Reduced costs for injuries and property damage costs from
driving in used vehicles
$88.3
12
All Private
Parties
net = 4+ 10+ 11
Net private benefits
$124.2
Line
Affected Party
Source
External Benefits and (Costs)
Amount
24AUP2
13
14
15
EP24AU18.039
Affected Party
Rest of U.S.
Economy
CAFE Model
Increase in climate damages from added GHG
Emissions**
Increase in health damages from added emissions of air
pollutants**
Increase in economic externalities from added petroleum
use**
($4.3)
($1.2)
($10.9)
16
Reduction in civil penalty revenue
($3.0)
17
Reduction in external costs from lower vehicle use***
$51.9
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Line
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Affected Party
Frm 00079
18
19
Fmt 4701
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Line
20
21
22
Affected Party
Entire U.S.
Economy
Source
Private Benefits and (Costs)
Amount
net= 13+ 14+ 15+ 16+ 17+ 18
Increase in Fuel Tax Revenues
Net external benefits
$19.7
$52.1
Source
total= 1+2+5+6+ 11 + 17+ 18
total= 3+7+8+9+ 13+ 14+ 15+ 16
net=20+21 (also=l2+19)
Economy-Wide Benefits and (Costs)
Total benefits
Total costs
Net Benefits
Amount
$673.5
($497.2)
$176.3
E:\FR\FM\24AUP2.SGM
*Value represents lost fuel savings from lowered fuel economy of MY's 2017-2029 and gained fuel savings from more quickly replacing
MY's 1977 to 2029 with newer vehicles.
**Value represents lost external benefits from lowered fuel economy of MY's 2017-2029 and lowered external costs from
more quickly replacing MY's 1977 to 2029 with newer vehicles.
*** Value includes lower external costs from reducing rebound effect and any change in overall fleet usage from more
quickly replacing MY's 1977 to 2029 with newer vehicles.
24AUP2
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23:42 Aug 23, 2018
Line
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Table 11-26 - Benefits and Costs Resulting from the Proposed CAFE Standards
(present values discounted at 7%)
Line
Affected Party
Source
Private Benefits and (Costs)
Amount
$192.2
CAFE model
Savings in technology costs to increase fuel
economy
Reduced fine payments for non-compliance
$2.1
assumed= -(1 +2)
Net loss in revenue from lower vehicle prices
($194.3)
4
net= 1+2+3
Net benefits to manufacturers
$0.0
5
assumed = 3
Lower purchase prices for new vehicles
$194.3
$1.3
CAFE model
Reduced injuries and fatalities from higher
vehicle weight
Higher fuel costs from lower fuel economy (at
retail prices)*
8
Inconvenience from more frequent refueling
($5.4)
9
Lost mobility benefits from reduced driving
($37.1)
Net benefits to new vehicle buyers
$56.2
$45.9
1
2
3
Vehicle
Manufacturers
6
7
New Vehicle
Buyers
net= 5+6+7+8+9
10
12
Used Vehicle
Owners
All Private Parties
net = 4+1 0+ 11
Reduced costs for injuries and property damage
costs from driving in used vehicles
Net private benefits
Line
Affected Party
Source
External Benefits and (Costs)
Amount
($2.7)
CAFE Model
h1crease in climate damages from added GHG
Emissions**
Increase in health damages from added
emissions of air pollutants**
Increase in economic externalities from added
petroleUlll use**
11
CAFE model
13
14
15
RestofU.S.
Economy
$102.1
($1.1)
($6.9)
Reduction in civil penalty revenue
($2.1)
17
Reduction in external costs from lower vehicle
use***
$29.6
18
Increase in Fuel Tax Revenues
$12.7
net= 13+14+15+16+17+18
Net external benefits
$29.4
Source
total= 1+2+5+6+11+17+18
total= 3+7+8+9+13+14+15+16
net= 20+21 (also =12+19)
Economy-Wide Benefits and (Costs)
Total benefits
Total costs
Net Benefits
Amount
$478.1
($346.6)
$131.5
16
19
Line
20
21
22
Affected Party
Entire U.S.
Economy
*Value represents lost fuel savings from lowered fuel economy of MY's 2017-2029 and gained fuel savings from more quickly
replacing MY's 1977 to 2029 with newer vehicles.
**Value represents lost external benefits from lowered fuel economy of MY's 2017-2029 and lowered external costs
from more quickly replacing MY's 1977 to 2029 with newer vehicles.
*** Value includes lower external costs from reducing rebound effect and any change in overall fleet usage from
more quickly replacing MY's 1977 to 2029 with newer vehicles.
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
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EP24AU18.041
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($96.9)
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
43065
Table 11-27- Benefits and Costs Resulting from the Proposed GHG Standards
(present values discounted at 3%)
Line
Affected Party
1
2
3
4
5
Vehicle
Manufacturers
Private Benefits and (Costs)
Source
Savings in technology costs to increase fuel
economy
Reduced fine payments for non-compliance
Net loss in revenue from lower vehicle prices
Net benefits to manufacturers
Lower purchase prices for new vehicles
Reduced injuries and fatalities from higher
vehicle weight
Higher fuel costs from lower fuel economy (at
retail prices)*
CAFE model
assumed= -(1 +2)
net= 1+2+3
assumed = 3
6
7
8
New Vehicle
Buyers
CAFE model
9
net= 5+6+7+8+9
10
$259.8
$0.0
($259.8)
$0.0
$259.8
$7.5
($165.2)
h1cmwenience from more frequent refueling
($9.4)
Lost mobility benefits from reduced driving
($69.5)
Net benefits to new vehicle buyers
$23.2
12
Used Vehicle
Owners
All Private Parties
net = 4+1 0+ 11
Reduced costs for injuries and property damage
costs from driving in used vehicles
Net private benefits
Line
Affected Party
Source
External Benefits and (Costs)
($0.8)
CAFE Model
mcrease in climate damages from added GHG
Emissions**
mcrease in health damages from added
emissions of air pollutants**
mcrease in economic externalities from added
petrolemn use**
Reduction in civil penalty revenue
$0.0
17
Reduction in external costs from lower vehicle
use***
$62.4
18
mcrease in Fuel Tax Revenues
$21.5
net= 13+14+15+16+17+18
Net external benefits
$66.5
11
CAFE model
13
14
15
16
Rest of U.S.
Economy
19
$111.0
$134.2
Amount
($4.7)
($11.9)
Line
Affected Party
Source
Economy-Wide Benefits and (Costs)
Amount
20
21
22
Entire U.S.
Economy
total= 1+2+5+6+11+17+18
total= 3+7+8+9+13+14+15+16
net= 20+21 (also =12+19)
Total benefits
Total costs
Net Benefits
$722.0
($521.3)
$200.7
*Value represents lost fuel savings from lowered fuel economy of MY's 2017-2029 and gained fuel savings from more quickly
replacing MY's 1977 to 2029 with newer vehicles.
**Value represents lost external benefits from lowered fuel economy of MY's 2017-2029 and lowered external costs
from more quickly replacing MY's 1977 to 2029 with newer vehicles.
***Value includes lower external costs from reducing rebound effect and any change in overall fleet usage from
more quickly replacing MY's 1977 to 2029 with newer vehicles.
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Table 11-28- Benefits and Costs Resulting from the Proposed GHG Standards
(present values discounted at 7%)
Line
Affected Party
1
2
Vehicle
Manufacturers
Source
Private Benefits and (Costs)
CAFE model
Savings in technology costs to increase fuel
economy
Reduced fine payments for non-compliance
$195.6
$0.0
assumed= -(1 +2)
Net loss in revenue from lower vehicle prices
($195.6)
4
net= 1+2+3
Net benefits to manufacturers
$0.0
5
assumed= 3
Lower purchase prices for new vehicles
$195.6
CAFE model
Reduced injuries and fatalities from higher
vehicle weight
Higher fuel costs from lower fuel economy (at
retail prices)*
3
6
7
New Vehicle
Buyers
$4.4
($105.3)
8
Inconvenience from more frequent refueling
($6.0)
9
Lost mobility benefits from reduced driving
($42.0)
net= 5+6+7+8+9
Net benefits to new vehicle buyers
$46.7
10
11
Used Vehicle
Owners
CAFE model
Reduced costs for injuries and property damage
costs from driving in used vehicles
$56.7
12
All Private Parties
net = 4+1 0+ 11
Net private benefits
$103.4
Line
Affected Party
Source
External Benefits and (Costs)
Amount
($1.0)
CAFE Model
Increase in climate damages from added GHG
Emissions**
Increase in health damages from added
emissions of air pollutants**
Increase in economic externalities from added
petroleum use**
Reduction in civil penalty revenue
$0.0
Reduction in external costs from lower vehicle
use***
$35.0
13
14
15
16
RcstofU.S.
Economy
17
18
Line
20
21
22
($3.0)
($7.6)
Increase in Fuel Tax Revenues
$13.8
net= 13+14+15+16+17+18
Net external benefits
$37.2
Affected Party
Source
Economy-Wide Benefits and (Costs)
Amount
Entire U.S.
Economy
total= 1+2+5+6+11+17+18
total= 3+7+8+9+13+14+15+16
net= 20+21 (also= 12+ 19)
Total benefits
Total costs
Net Benefits
$501.1
($360.5)
$140.6
19
*Value represents lost fuel savings from lowered fuel economy of MY's 2017-2029 and gained fuel savings from more quickly
replacing MY's 1977 to 2029 with newer vehicles.
**Value represents lost external benefits from lowered fuel economy of MY's 2017-2029 and lowered external costs
from more quickly replacing MY's 1977 to 2029 with newer vehicles.
***Value includes lower external costs from reducing rebound effect and any change in overall fleet usage from
more quickly replacing MY's 1977 to 2029 with newer vehicles.
As the tables show, most impacts of
the proposed action will fall on the
businesses and individuals who design,
manufacture, and sell (at retail and
wholesale) cars and light trucks, the
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consumers who purchase, drive, and
subsequently sell or trade-in new
models (and ultimately bear the cost of
fuel economy technology), and owners
of used cars and light trucks produced
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during model years prior to those
covered by this action. Compared to the
baseline standards, if the preferred
alternative is finalized, buyers of new
cars and light trucks will benefit from
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their lower purchase prices and
financing costs (line 5). They will also
avoid the increased risks of being
injured in crashes that would have
resulted from manufacturers’ efforts to
reduce the weight of new models to
comply with the baseline standards,
which represents another benefit from
reducing stringency vis-a`-vis the
baseline (line 6).
At the same time, new cars and light
trucks will offer lower fuel economy
with more lenient standards in place,
and this imposes various costs on their
buyers and users. Drivers will
experience higher costs as a
consequence of new vehicles’ increased
fuel consumption (line 7), and from the
added inconvenience of more frequent
refueling stops required by their
reduced driving range (line 8). They will
also forego some mobility benefits as
they use newly-purchased cars and light
trucks less in response to their higher
fueling costs, although this loss will be
almost fully offset by the fuel and other
costs they save by driving less (line 9).
On balance, consumers of new cars and
light trucks produced during the model
years subject to this proposed action
will experience significant economic
benefits (line 10).
By lowering prices for new cars and
light trucks, this proposed action will
cause some owners of used vehicles to
retire them from service earlier than
they would otherwise have done, and
replace them with new models. In
effect, it will transfer some driving that
would have been done in used cars and
light trucks under the baseline scenario
to newer and safer models, thus
reducing costs for injuries (both fatal
and less severe) and property damages
sustained in motor vehicle crashes. This
improvement in safety results from the
fact that cars and light trucks have
become progressively more protective in
crashes over time (and also slightly less
prone to certain types of crashes, such
as rollovers). Thus, shifting some travel
from older to newer models reduces
injuries and damages sustained by
drivers and passengers because they are
traveling in inherently safer vehicles
and not because it changes the risk
profiles of drivers themselves. This
reduction in injury risks and other
damage costs produces benefits to
owners and drivers of older cars and
light trucks. This also results in benefits
in terms of improved fuel economy and
significant reductions of emissions from
newer vehicles (line 11).
Table II–27 through Table II–28 also
show that the changes in fuel
consumption and vehicle use resulting
from this proposed action will in turn
generate both benefits and costs to the
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remainder of the U.S. economy. These
impacts are ‘‘external,’’ in the sense that
they are by-products of decisions by
private firms and individuals that alter
vehicle use and fuel consumption but
are experienced broadly throughout the
U.S. economy rather than by the firms
and individuals who indirectly cause
them. Increased refining and
consumption of petroleum-based fuel
will increase emissions of carbon
dioxide and other greenhouse gases that
theoretically contribute to climate
change, and some of the resulting (albeit
uncertain) increase in economic
damages from future changes in the
global climate will be borne throughout
the U.S. economy (line 13). Similarly,
added fuel production and use will
increase emissions of more localized air
pollutants (or their chemical
precursors), and the resulting increase
in the U.S. population’s exposure to
harmful levels of these pollutants will
lead to somewhat higher costs from its
adverse effects on health (line 14). On
the other hand, it is expected that the
proposed standards, by reducing new
vehicle prices relative to the baseline,
will accelerate fleet turnover to cleaner,
safer, more efficient vehicles (as
compared to used vehicles that might
otherwise continue to be driven or
purchased).
As discussed in PRIA Section 9.8,
increased consumption and imports of
crude petroleum for refining higher
volumes of gasoline and diesel will also
impose some external costs throughout
the U.S. economy, in the form of
potential losses in production and costs
for businesses and households to adjust
rapidly to sudden changes in energy
prices (line 15 of the table), although
these costs should be tempered by
increasing U.S. oil production.218
Reductions in driving by buyers of new
cars and light trucks in response to their
higher operating costs will also reduce
the external costs associated with their
contributions to traffic delays and noise
levels in urban areas, and these
additional benefits will be experienced
throughout much of the U.S. economy
(line 17). Finally, some of the higher
fuel costs to buyers of new cars and
light trucks will consist of increased
fuel taxes; this increase in revenue will
enable Federal and State government
agencies to provide higher levels of road
capacity or maintenance, producing
benefits for all road and transit users
(line 18).
On balance, Table II–27 through Table
II–28 show that the U.S. economy as a
whole will experience large net
economic benefits from the proposed
action (line 22). While the proposal to
establish less stringent CAFE and GHG
emission standards will produce net
external economic costs, as the increase
in environmental and energy security
externalities outweighs external benefits
from reduced driving and higher fuel
tax revenue (line 19), the table also
shows that combined benefits to vehicle
manufacturers, buyers, and users of cars
and light trucks, and the general public
(line 20), including the value of the lives
saved and injuries avoided, will greatly
outweigh the combined economic costs
they experience as a consequence of this
proposed action (line 21).
The finding that this action to reduce
the stringency of previously-established
CAFE and GHG standards will create
significant net economic benefits—
when it was initially claimed that
establishing those standards would also
generate large economic benefits to
vehicle buyers and others throughout
the economy—is notable. This contrast
with the earlier finding is explained by
the availability of updated information
on the costs and effectiveness of
technologies that will remain available
to improve fuel economy in model years
2021 and beyond, the fleet-wide
consequences for vehicle use, fuel
consumption, and safety from requiring
higher fuel economy (that is,
considering these consequences for used
cars and light trucks as well as new
ones), and new estimates of some
external costs of fuel in petroleum use.
218 Note: This output was based upon the EIA
Annual Energy Outlook from 2017. The 2018
Annual Energy Outlook projects the U.S. will be a
net exporter by around 2029, with net exports
peaking at around 0.5 mbd circa 2040. See Annual
Energy Outlook 2018, U.S. Energy Information
Administration, at 53 (Feb, 6, 2018), https://
www.eia.gov/outlooks/aeo/pdf/AEO2018.pdf.
Furthermore, pursuant to Executive Order 13783
(Promoting Energy Independence and Economy
Growth), agencies are expected to review and revise
or rescind policies that unduly burden the
development of domestic energy resources beyond
what is necessary to protect the public interest or
otherwise comply with the law. Therefore, it is
reasonable to anticipate further increases in
domestic production of petroleum. The agencies
may update the analysis and table to account for
this revised information.
2. Macroeconomic Assumptions That
Affect the Benefit Cost Analysis
Unlike previous CAFE and GHG
rulemaking analyses, the economic
context in which the alternatives are
simulated is more explicit. While both
this analysis and previous analyses
contained fuel price projections from
the Annual Energy Outlook, which has
embedded assumptions about future
macroeconomic conditions, this
analysis requires explicit assumptions
about future GDP growth, labor force
participation, and interest rates in order
to evaluate the alternatives.
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.
Table-11-29 - M acroeconomic
Calendar
Real
Year
Interest
Rate
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
The analysis simulates compliance
through MY 2032 explicitly and must
consider the full useful lives of those
vehicles, approximately 40 years, in
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2.70
1.00
-0.30
-0.30
1.10
1.70
2.00
2.20
2.40
2.40
2.60
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
2.70
p ro.tec
. f IOns th rougJh CY 2050
Real
Labor Force
GDP
Participation
Growth (thousands)
Rate
2.60
1.60
2.90
3.00
3.00
2.90
2.70
2.40
2.20
2.20
2.20
2.10
2.20
2.20
2.20
2.10
2.10
2.10
2.10
2.10
2.10
2.10
2.10
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
2.20
122,700
124,248
125,739
127,625
129,284
130,577
131,752
132,674
133,471
134,271
135,077
135,887
136,703
137,386
138,073
138,764
139,457
140,155
140,855
141,560
142,268
142,979
143,694
144,556
145,423
146,296
147,174
148,057
148,945
149,839
150,738
151,642
152,552
153,467
154,388
155,314
order to estimate their lifetime mileage
accumulation and fuel consumption.
This means that any macroeconomic
forecast influencing those factors must
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cover a similar span of years. Due to the
long time horizon, a source that
regularly produces such lengthy
forecasts of these factors was selected:
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the 2017 OASDI Trustees Report from
the U.S. Social Security Administration.
While Table–II–29 only displays
assumptions through CY 2050, the
remaining years merely continue the
trends present in the table.
The analysis once again uses fuel
price projections from the 2017 Annual
Energy Outlook.219 The projections by
central analysis supporting today’s
proposal uses reference case estimates of fuel prices
reported in the Energy Information
Administration’s (EIA’s) Annual Energy Outlook
2017 (AEO 2017). Today’s proposal also examines
the sensitivity of this analysis to changes in key
inputs, including fuel prices, and includes cases
that apply fuel prices from the AEO 2017 low oil
price and high oil price cases. The reference case
prices are considerably lower than AEO 2011-based
reference cases prices applied in the 2012
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219 The
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rulemaking, and this is one of several important
changes in circumstances supporting revision of
previously-issued standards.
After significant portions of today’s analysis had
already been completed, EIA released AEO 2018,
which reports reference case fuel prices about 10%
higher than reported in AEO 2017, though still well
below the above-mentioned prices from AEO 2011.
The sensitivity analysis therefore includes a case
that applies fuel prices from the AEO 2018
reference case. The AEO 2018 low oil price case
reports fuel prices somewhat higher than the AEO
2017 low oil price case, and the AEO 2018 high oil
price case reports fuel prices very similar to the
AEO 2017 high oil price case. Adding the AEO 2018
low and high oil price cases to the sensitivity
analysis would thus have provided little, if any,
additional insight into the sensitivity of the analysis
to fuel prices. As shown in the summary of the
sensitivity analysis, results obtained applying AEO
2018-based fuel prices are similar to those obtained
applying AEO 2017-based fuel prices. For example,
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fuel calendar year and fuel type are
presented in Table–II–30, in real 2016
dollars. Fuel prices in this analysis
affect not only the value of each gallon
of fuel consumed but relative valuation
of fuel-saving technologies demanded
by the market as a result of their
associated fuel savings.
net benefits between the two are about five percent
different, especially considering that decisions
regarding future standards are not single-factor
decisions, but rather reflect a balancing of factors,
applying AEO 2018-based fuel prices would not
materially change the extent to which today’s
analysis supports the selection of the preferred
alternative.
Like other inputs to the analysis, fuel prices will
be updated for the analysis supporting the final rule
after consideration of related new information and
public comment.
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Calendar
Year
Gasoline
($/gallon)
Diesel
($/gallon)
Electricity
($/kwh)
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
2049
2050
2.55
2.21
2.30
2.28
2.48
2.59
2.71
2.83
2.86
2.88
2.93
2.98
2.99
2.98
3.01
3.06
3.10
3.14
3.13
3.17
3.19
3.25
3.26
3.27
3.32
3.35
3.37
3.37
3.36
3.37
3.38
3.39
3.41
3.41
3.42
3.46
2.76
2.31
2.63
2.90
3.08
3.19
3.27
3.35
3.41
3.45
3.51
3.57
3.59
3.60
3.64
3.71
3.76
3.82
3.82
3.86
3.88
3.95
3.97
3.97
4.02
4.05
4.07
4.07
4.07
4.09
4.10
4.13
4.17
4.16
4.18
4.24
0.11
0.10
0.10
0.10
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.11
0.12
0.12
3. New Vehicle Sales and Employment
Assumptions
In all previous CAFE and GHG
rulemaking analyses, static fleet
forecasts that were based on a
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combination of manufacturer
compliance data, public data sources,
and proprietary forecasts were used.
When simulating compliance with
regulatory alternatives, the analysis
projected identical sales across the
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alternatives, for each manufacturer
down to the make/model level where
the exact same number of each model
variant was simulated to be sold in a
given model year under both the least
stringent alternative (typically the
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baseline) and the most stringent
alternative considered. To the extent
that an alternative matched the
assumptions made in the production of
the proprietary forecast, using a static
fleet based upon those assumptions may
have been warranted. However, it seems
intuitive that any sufficiently large span
of regulatory alternatives would contain
alternatives for which that static forecast
was unrepresentative. A number of
commenters have encouraged
consideration of the potential impact of
CAFE/GHG standards on new vehicle
prices and sales, and the changes to
compliance strategies that those shifts
could necessitate.220 In particular, the
continued growth of the utility vehicle
segment creates compliance challenges
within some manufacturers’ fleets as
sales volumes shift from one region of
the footprint curve to another.
Any model of sales response must
satisfy two requirements: It must be
appropriate for use in the CAFE model,
and it must be econometrically
reasonable. The first of these
requirements implies that any variable
used in the estimation of the
econometric model, must also be
available as a forecast throughout the
duration of the years covered by the
simulations (this analysis explicitly
simulates compliance through MY
2032). Some values the model calculates
endogenously, making them available in
future years for sales estimation, but
others must be known in advance of the
simulation. As the CAFE model
simulates compliance, it accumulates
technology costs across the industry and
over time. By starting with the last
known transaction price and adding the
accumulated technology cost to that
value, the model is able to represent the
average selling price in each future
model year assuming that manufacturers
are able to pass all of their compliance
costs on to buyers of new vehicles.
Other variables used in the estimation
must enter the model as inputs prior to
the start of the compliance simulation.
(a) How do car and light truck buyers
value improved fuel economy?
How potential buyers value
improvements in the fuel economy of
new cars and light trucks is an
important issue in assessing the benefits
and costs of government regulation. If
buyers fully value the savings in fuel
costs that result from higher fuel
economy, manufacturers will
presumably supply any improvements
that buyers demand, and vehicle prices
220 See e.g., Comment by Alliance of Automobile
Manufacturers, Docket ID EPA–HQ–OAR–2015–
0827–4089 and NHTSA–2016–0068–0072.
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will fully reflect future fuel cost savings
consumers would realize from owning—
and potentially re-selling—more fuelefficient models. In this case, more
stringent fuel economy standards will
impose net costs on vehicle owners and
can only result in social benefits by
correcting externalities, since
consumers would already fully
incorporate private savings into their
purchase decisions. If instead
consumers systematically undervalue
the cost savings generated by
improvements in fuel economy when
choosing among competing models,
more stringent fuel economy standards
will also lead manufacturers to adopt
improvements in fuel economy that
buyers might not choose despite the cost
savings they offer.
The potential for car buyers to forego
improvements in fuel economy that
offer savings exceeding their initial
costs is one example of what is often
termed the ‘‘energy-efficiency gap.’’
This appearance of such a gap, between
the level of energy efficiency that would
minimize consumers’ overall expenses
and what they actually purchase, is
typically based on engineering
calculations that compare the initial
cost for providing higher energy
efficiency to the discounted present
value of the resulting savings in future
energy costs.
There has long been an active debate
about why such a gap might arise and
whether it actually exists. Economic
theory predicts that individuals will
purchase more energy-efficient products
only if the savings in future energy costs
they offer promise to offset their higher
initial costs. However, the additional
cost of a more energy-efficient product
includes more than just the cost of the
technology necessary to improve its
efficiency; it also includes the
opportunity cost of any other desirable
features that consumers give up when
they choose the more efficient
alternative. In the context of vehicles,
whether the expected fuel savings
outweigh the opportunity cost of
purchasing a model offering higher fuel
economy will depend on how much its
buyer expects to drive, his or her
expectations about future fuel prices,
the discount rate he or she uses to value
future expenses, the expected effect on
resale value, and whether more efficient
models offer equivalent attributes such
as performance, carrying capacity,
reliability, quality, or other
characteristics.
Published literature has offered little
consensus about consumers’
willingness-to-pay for greater fuel
economy, and whether it implies over, under- or full-valuation of the expected
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fuel savings from purchasing a model
with higher fuel economy. Most studies
have relied on car buyers’ purchasing
behavior to estimate their willingnessto-pay for future fuel savings; a typical
approach has been to use ‘‘discrete
choice’’ models that relate individual
buyers’ choices among competing
vehicles to their purchase prices, fuel
economy, and other attributes (such as
performance, carrying capacity, and
reliability), and to infer buyers’
valuation of higher fuel economy from
the relative importance of purchase
prices and fuel economy.221 Empirical
estimates using this approach span a
wide range, extending from substantial
undervaluation of fuel savings to
significant overvaluation, thus making it
difficult to draw solid conclusions about
the influence of fuel economy on
vehicle buyers’ choices (see Helfand &
Wolverton, 2011; Green (2010) for
detailed reviews of these cross-sectional
studies). Because a vehicle’s price is
often correlated with its other attributes
(both measured and unobserved),
analysts have often used instrumental
variables or other approaches to address
endogeneity and other resulting
concerns (e.g., Barry, et al. 1995).
Despite these efforts, more recent
research has criticized these crosssectional studies; some have questioned
the effectiveness of the instruments they
use (Allcott & Greenstone, 2012), while
others have observed that coefficients
estimated using non-linear statistical
methods can be sensitive to the
optimization algorithm and starting
values (Knittel & Metaxoglou, 2014).
Collinearity (i.e., high correlations)
among vehicle attributes—most notably
among fuel economy, performance or
power, and vehicle size—and between
vehicles’ measured and unobserved
features also raises questions about the
reliability and interpretation of
coefficients that may conflate the value
of fuel economy with other attributes
(Sallee, et al., 2016; Busse, et al., 2013;
Allcott & Wozny, 2014; Allcott &
Greenstone, 2012; Helfand & Wolverton,
2011).
In an effort to overcome shortcomings
of past analyses, three recently
published studies rely on panel data
from sales of individual vehicle models
to improve their reliability in
identifying the association between
vehicles’ prices and their fuel economy
(Sallee, et al. 2016; Allcott & Wozny,
2014; Busse, et al., 2013). Although they
differ in certain details, each of these
221 In a typical vehicle choice model, the ratio of
estimated coefficients on fuel economy—or more
commonly, fuel cost per mile driven—and purchase
price is used to infer the dollar value buyers attach
to slightly higher fuel economy.
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analyses relates changes over time in
individual models’ selling prices to
fluctuations in fuel prices, differences in
their fuel economy, and increases in
their age and accumulated use, which
affects their expected remaining life,
and thus their market value. Because a
vehicle’s future fuel costs are a function
of both its fuel economy and expected
gasoline prices, changes in fuel prices
have different effects on the market
values of vehicles with different fuel
economy; comparing these effects over
time and among vehicle models reveals
the fraction of changes in fuel costs that
is reflected in changes in their selling
prices (Allcott & Wozny, 2014). Using
very large samples of sales enables these
studies to define vehicle models at an
extremely disaggregated level, which
enables their authors to isolate
differences in their fuel economy from
the many other attributes, including
those that are difficult to observe or
measure, that affect their sale prices.222
These studies point to a somewhat
narrower range of estimates than
suggested by previous cross-sectional
studies; more importantly, they
consistently suggest that buyers value a
sradovich on DSK3GMQ082PROD with PROPOSALS2
222 These studies rely on individual vehicle
transaction data from dealer sales and wholesale
auctions, which includes actual sale prices and
allows their authors to define vehicle models at a
highly disaggregated level. For instance, Allcott &
Wozny (2014) differentiate vehicles by
manufacturer, model or nameplate, trim level, body
type, fuel economy, engine displacement, number
of cylinders, and ‘‘generation’’ (a group of
successive model years during which a model’s
design remains largely unchanged). All three
studies include transactions only through mid-2008
to limit the effect of the recession on vehicle prices.
To ensure that the vehicle choice set consists of true
substitutes, Allcott & Wozny (2014) define the
choice set as all gasoline-fueled light-duty cars,
trucks, SUVs, and minivans that are less than 25
years old (i.e., they exclude vehicles where the
substitution elasticity is expected to be small).
Sallee et al. (2016) exclude diesels, hybrids, and
used vehicles with less than 10,000 or more than
100,000 miles.
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large proportion—and perhaps even
all—of the future savings that models
with higher fuel economy offer.223
Because they rely on estimates of fuel
costs over vehicles’ expected remaining
lifetimes, these studies’ estimates of
how buyers value fuel economy are
sensitive to the strategies they use to
isolate differences among individual
models’ fuel economy, as well as to
their assumptions about buyers’
discount rates and gasoline price
expectations, among others. Since
Anderson et al. (2013) find evidence
that consumers expect future gasoline
prices to resemble current prices, we
use this assumption to compare the
findings of the three studies and
examine how their findings vary with
the discount rates buyers apply to future
fuel savings.224
223 Killian & Sims (2006) and Sawhill (2008) rely
on similar longitudinal approaches to examine
consumer valuation of fuel economy except that
they use average values or list prices instead of
actual transaction prices. Since these studies
remain unpublished, their empirical results are
subject to change, and they are excluded from this
discussion.
224 Each of the studies makes slightly different
assumptions about appropriate discount rates.
Sallee et al. (2016) use five percent in their base
specification, while Allcott & Wozny (2014) rely on
six percent. As some authors note, a five to six
percent discount rate is consistent with current
interest rates on car loans, but they also
acknowledge that borrowing rates could be higher
in some cases, which could be justify higher
discount rates. Rather than assuming a specific
discount rate, Busse et al. (2013) directly estimate
implicit discount rates at which future fuel costs
would be fully internalized; they find discount rates
of six to 21% for used cars and one to 13% for new
cars at assumed demand elasticities ranging from
¥2 to ¥3. Their estimates can be translated into
the percent of fuel costs internalized by consumers,
assuming a particular discount rate. To make these
results more directly comparable to the other two
studies, we assume a range of discount rates and
uses the authors’ spreadsheet tool to translate their
results into the percent of fuel costs internalized
into the purchase price at each rate. Because Busse
et al. (2013) estimate the effects of future fuel costs
on vehicle prices separately by fuel economy
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As Table 1 indicates, Allcott & Wozny
(2014) find that consumers incorporate
55% of future fuel costs into vehicle
purchase decisions at a six percent
discount rate, when their expectations
for future gasoline prices are assumed to
reflect prevailing prices at the time of
their purchases. With the same
expectation about future fuel prices, the
authors report that consumers would
fully value fuel costs only if they apply
discount rates of 24% or higher.
However, these authors’ estimates are
closer to full valuation when using
gasoline price forecasts that mirror oil
futures markets because the petroleum
market expected prices to fall during
this period (this outlook reduces the
discounted value of a vehicle’s expected
remaining lifetime fuel costs). With this
expectation, Allcott & Wozny (2014)
find that buyers value 76% of future
cost savings (discounted at six percent)
from choosing a model that offers higher
fuel economy, and that a discount rate
of 15% would imply that they fully
value future cost savings. Sallee et al.
(2016) begin with the perspective that
buyers fully internalize future fuel costs
into vehicles’ purchase prices and
cannot reliably reject that hypothesis;
their base specification suggests that
changes in vehicle prices incorporate
slightly more than 100% of changes in
future fuel costs. For discount rates of
five to six percent, the Busse et al.
(2013) results imply that vehicle prices
reflect 60 to 100% of future fuel costs.
As Table II–31 suggests, higher private
discount rates move all of the estimates
closer to full valuation or to overvaluation, while lower discount rates
imply less complete valuation in all
three studies.
quartile, these results depend on which quartiles of
the fuel economy distribution are compared; our
summary shows results using the full range of
quartile comparisons.
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The studies also explore the
sensitivity of the results to other
parameters that could influence their
results. Busse et al. (2013) and Allcott
& Wozny (2014) find that relying on
data that suggest lower annual vehicle
use or survival probabilities, which
imply that vehicles will not last as long,
moves their estimates closer to full
valuation, an unsurprising result
because both reduce the changes in
expected future fuel costs caused by fuel
price fluctuations. Allcott & Wozny’s
(2014) base results rely on an
instrumental variables estimator that
groups miles-per-gallon (MPG) into two
quantiles to mitigate potential
attenuation bias due to measurement
error in fuel economy, but they find that
greater disaggregation of the MPG
groups implies greater undervaluation
(for example, it reduces the 55%
estimated reported in Table 1 to 49%).
Busse et al. (2013) allow gasoline prices
to vary across local markets in their
main specification; using national
average gasoline prices, an approach
more directly comparable to the other
studies, results in estimates that are
closer to or above full valuation. Sallee
et al. (2016) find modest undervaluation
by vehicle fleet operators or
manufacturers making large-scale
purchases, compared to retail dealer
sales (i.e., 70 to 86%).
Since they rely predominantly on
changes in vehicles’ prices between
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repeat sales, most of the valuation
estimates reported in these studies
apply most directly to buyers of used
vehicles. Only Busse et al. (2013)
examine new vehicle sales; they find
that consumers value between 75 to
133% of future fuel costs for new
vehicles, a higher range than they
estimate for used vehicles. Allcott &
Wozny (2014) examine how their
estimates vary by vehicle age and find
that fluctuations in purchase prices of
younger vehicles imply that buyers
whose fuel price expectations mirror the
petroleum futures market value a higher
fraction of future fuel costs: 93% for
one- to three-year-old vehicles,
compared to their estimate of 76% for
all used vehicles assuming the same
price expectation.225
Accounting for differences in their
data and estimation procedures, the
three studies described here suggest that
car buyers who use discount rates of
five to six percent value at least half—
and perhaps all—of the savings in future
fuel costs they expect from choosing
models that offer higher fuel economy.
225 Allcott & Wozny (2014) and Sallee, et al.
(2016) also find that future fuel costs for older
vehicles are substantially undervalued (26–30%).
The pattern of Allcott and Wozny’s results for
different vehicle ages is similar when they use retail
transaction prices (adjusted for customer cash
rebates and trade-in values) instead of wholesale
auction prices, although the degree of valuation
falls substantially in all age cohorts with the
smaller, retail price based sample.
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Perhaps more important in assessing the
case for regulating fuel economy, one
study suggests that buyers of new cars
and light trucks value three-quarters or
more of the savings in future fuel costs
they anticipate from purchasing highermpg models, although this result is
based on more limited information.
In contrast, previous regulatory
analyses of fuel economy standards
implicitly assumed that buyers
undervalue even more of the benefits
they would experience from purchasing
models with higher fuel economy so
that without increases in fuel economy
standards little improvement would
occur, and the entire value of fuel
savings from raising CAFE standards
represented private benefits to car and
light truck buyers themselves. For
instance, in the EPA analysis of the
2017–2025 model year greenhouse gas
emission standards, fuel savings alone
added up to $475 billion (at three
percent discount rate) over the lifetime
of the vehicles, far outweighing the
compliance costs: $150 billion). The
assertion that buyers were unwilling to
take voluntary advantage of this
opportunity implies that collectively,
they must have valued less than a third
($150 billion/$475 billion = 32%) of the
fuel savings that would have resulted
from those standards.226 The evidence
226 In fact, those earlier analyses assumed that
new car and light truck buyers attach relatively
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
reviewed here makes that perspective
extremely difficult to justify and would
call into question any analysis that
claims to show large private net benefits
for vehicle buyers.
What analysts assume about
consumers’ vehicle purchasing
behavior, particularly about potential
buyers’ perspectives on the value of
increased fuel economy, clearly matters
a great deal in the context of benefit-cost
analysis for fuel economy regulation. In
light of recent evidence on this
question, a more nuanced approach
than assuming that buyers drastically
undervalue benefits from higher fuel
economy, and that as a consequence,
these benefits are unlikely to be realized
without stringent fuel economy
standards, seems warranted. One
possible approach would be to use a
baseline scenario where fuel economy
levels of new cars and light trucks
reflected full (or nearly so) valuation of
fuel savings by potential buyers in order
to reveal whether setting fuel economy
standards above market-determined
levels could produce net social benefits.
Another might be to assume that, unlike
in the agencies’ previous analyses,
where buyers were assumed to greatly
undervalue higher fuel economy under
the baseline but to value it fully under
the proposed standards, buyers value
improved fuel economy identically
under both the baseline scenario and
with stricter CAFE standards in place.
The agencies ask for comment on these
and any alternative approaches they
should consider for valuing fuel savings,
new peer-reviewed evidence on vehicle
buyers’ behavior that casts light on how
they value improved fuel economy, the
appropriate private discount rate to
apply to future fuel savings, and thus
the degree to which private fuel savings
should be considered as private benefits
of increasing fuel economy standards.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(b) Sales Data and Relevant
Macroeconomic Factors
Developing a procedure to predict the
effects of changes in prices and
attributes of new vehicles is
complicated by the fact that their sales
are highly pro-cyclical—that is, they are
very sensitive to changes in
macroeconomic conditions—and also
statistically ‘‘noisy,’’ because they
reflect the transient effects of other
factors such as consumers’ confidence
in the future, which can be difficult to
observe and measure accurately. At the
same time, their average sales price
little value to higher fuel economy, since their
baseline scenarios assumed that fuel economy
levels would not increase in the absence of
progressively tighter standards.
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tends to move in parallel with changes
in economic growth; that is, average
new vehicle prices tend to be higher
when the total number of new vehicles
sold is increasing and lower when the
total number of new sales decreases
(typically during periods of low
economic growth or recessions). Finally,
counts of the total number of new cars
and light trucks that are sold do not
capture shifts in demand among vehicle
size classes or body styles (‘‘market
segments’’); nor do they measure
changes in the durability, safety, fuel
economy, carrying capacity, comfort, or
other aspects of vehicles’ quality.
The historical series of new light-duty
vehicle sales exhibits cyclic behavior
over time that is most responsive to
larger cycles in the macro economy—
but has not increased over time in the
same way the population, for example,
has. While U.S. population has grown
over 35 percent since 1980, the
registered vehicle population has grown
at an even faster pace—nearly doubling
between 1980 and 2015.227 But annual
vehicle sales did not grow at a similar
pace –even accounting for the cyclical
nature of the industry. Total new lightduty sales prior to the 2008 recession
climbed as high as 16 million, though
similarly high sales years occurred in
the 1980’s and 1990’s as well. In fact,
when considering a 10-year moving
average to smooth out the effect of
cycles, most 10-year averages between
1992 and 2015 are within a few percent
of the 10-year average in 1992. And
although average transaction prices for
new vehicles have been rising steadily
since the recession ended, prices are not
yet at historical highs when adjusted for
inflation. The period of highest
inflation-adjusted transaction prices
occurred from 1996–2006, when the
average transaction price for a new
light-duty vehicle was consistently
higher than the price in 2015.
In an attempt to overcome these
analytical challenges, various
approaches were experimented with to
predict the response of new vehicle
sales to the changes in prices, fuel
economy, and other features. These
included treating new vehicle demand
as a product of changes in total demand
for vehicle ownership and demand
necessary to replace used vehicles that
are retired, analyzing total expenditures
227 There are two measurements of the size of the
registered vehicle population that are considered to
be authoritative. One is produced by the Federal
Highway Adminstration, and the other by R.L. Polk
(now part of IHS). The Polk measurement shows
fleet growth between 1980 and 2015 of about 85%,
while the FHWA measurement shows a slower
growth rate over that period; only about 60%. Both
are still considerably larger than the growth in new
vehicle sales over the same period.
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to purchase new cars and light trucks in
conjunction with the total number sold,
and other approaches. However, none of
these methods offered a significant
improvement over estimating the total
number of vehicles sold directly from its
historical relationship to directly
measurable factors such as their average
sales price, macroeconomic variables
such as GDP or Personal Disposable
Income, U.S. labor force participation,
and regularly published surveys of
consumer sentiment or confidence.
Quarterly, rather than annual data on
total sales of new cars and light trucks,
their average selling price, and
macroeconomic variables was used to
develop an econometric model of sales,
in order to increase the number of
observations and more accurately
capture the causal effects of individual
explanatory variables. Applying
conventional data diagnostics for timeseries economic data revealed that most
variables were non-stationary (i.e., they
reflected strong underlying time trends)
and displayed unit roots, and statistical
tests revealed co-integration between
the total vehicle sales—the model’s
dependent variable—and most
candidate explanatory variables.
(c) Current Estimation of Sales Impacts
To address the complications of the
time series data, the analysis estimated
an autoregressive distributed-lag (ARDL)
model that employs a combination of
lagged values of its dependent
variable—in this case, last year’s and the
prior year’s vehicle sales—and the
change in average vehicle price,
quarterly changes in the U.S. GDP
growth rate, as well as current and
lagged values of quarterly estimates of
U.S. labor force participation. The
number of lagged values of each
explanatory variable to include was
determined empirically (using the
Bayesian information criterion), by
examining the effects of including
different combinations of their lagged
values on how well the model
‘‘explained’’ historical variation in car
and light truck sales.
The results of this approach were
encouraging: The model’s predictions fit
the historical data on sales well, each of
its explanatory variables displayed the
expected effect on sales, and analysis of
its unexplained residual terms revealed
little evidence of autocorrelation or
other indications of statistical problems.
The model coefficients suggest that
positive GDP growth rates and increases
in labor force participation are both
indicators of increases in new vehicle
sales, while positive changes in average
new vehicle price reduce new sales.
However, the magnitude of the
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coefficient on change in average price is
not as determinative of total sales as the
other variables.
Based on the model, a $1,000 increase
in the average new vehicle price causes
approximately 170,000 lost units in the
first year, followed by a reduction of
another 600,000 units over the next ten
years as the initial sales decrease
propagates over time through the lagged
variables and their coefficients. The
price elasticity of new car and light
truck sales implied by alternative
estimates of the model’s coefficients
ranged from ¥0.2 to ¥0.3—meaning
that changes in their prices have
moderate effects on total sales—which
contrasts with estimates of higher
sensitivity to prices implied by some
models.228 The analysis was unable to
incorporate any measure of new car and
light truck fuel economy in the model
that added to its ability to explain
historical variation in sales, even after
experimenting with alternative
measures of such as the unweighted and
sales-weighted averages fuel economy of
models sold in each quarter, the level of
fuel economy they were required to
achieve, and the change in their fuel
economy from previous periods.
Despite the evidence in the literature,
summarized above, that consumers
value most, if not all, of the fuel
economy improvements when
purchasing new vehicles, the model
described here operates at too high a
level of aggregation to capture these
preferences. By modeling the total
number of new vehicles sold in a given
year, it is necessary to quantify
important measures, like sales price or
fuel economy, by averages. Our model
operates at a high level of aggregation,
where the average fuel economy
represents an average across many
vehicle types, usage profiles, and fuel
economy levels. In this context, the
average fuel economy was not a
meaningful value with respect to its
influence on the total number of new
vehicles sold. A number of recent
studies have indeed shown that
consumers value fuel savings (almost)
fully. Those studies are frequently based
on large datasets that are able to control
for all other vehicle attributes through a
variety of econometric techniques. They
represent micro-level decisions, where a
228 Effects on the used car market are accounted
for separately.
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buyer is (at least theoretically) choosing
between a more or less efficient version
of a pickup truck (for example) that is
otherwise identical. In an aggregate
sense, the average is not comparable to
the decision an individual consumer
faces.
Estimating the sales response at the
level of total new vehicle sales likely
fails to address valid concerns about
changes to the quality or attributes of
new vehicles sold—both over time and
in response to price increases resulting
from CAFE standards. However,
attempts to address such concerns
would require significant additional
data, new statistical approaches, and
structural changes to the CAFE model
over several years. It is also the case that
using absolute changes in the average
price may be more limited than another
characterization of price that relies on
distributions of household income over
time or percentage change in the new
vehicle price. The former would require
forecasting a deeply uncertain quantity
many years into the future, and the
latter only become relevant once the
simulation moves beyond the
magnitude of observed price changes in
the historical series. Future versions of
this model may use a different
characterization of cost that accounts for
some of these factors if their inclusion
improves the model estimation and
corresponding forecast projections are
available.
The changes in selling prices, fuel
economy, and other features of cars and
light trucks produced during future
model years that result from
manufacturers’ responses to lower CAFE
and GHG emission standards are likely
to affect both sales of individual models
and the total number of new vehicles
sold. Because the values of changes in
fuel economy and other features to
potential buyers are not completely
understood; however, the magnitude,
and possibly even the direction, of their
effect on sales of new vehicles is
difficult to anticipate. On balance, it is
reasonable to assume that the changes in
prices, fuel economy, and other
attributes expected to result from their
proposed action to amend and establish
fuel economy and GHG emission
standards are likely to increase total
sales of new cars and light trucks during
future model years. Please provide
comment on the relationship between
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price increases, fuel economy, and new
vehicle sales, as well as methods to
appropriately account for these
relationships.
(d) Projecting New Vehicle Sales and
Comparisons to Other Forecasts
The purpose of the sales response
model is to allow the CAFE model to
simulate new vehicle sales in a given
future model year, accounting for the
impact of a regulatory alternative’s
stringency on new vehicle prices (in a
macro-economic context that is
identical across alternatives). In order to
accomplish this, it is important that the
model of sales response be dynamically
stable, meaning that it responds to
shocks not by ‘‘exploding,’’ increasing
or decreasing in a way that is
unbounded, but rather returns to a
stable path, allowing the shock to
dissipate. The CAFE model uses the
sales model described above to
dynamically project future sales; after
the first year of the simulation, lagged
values of new vehicle sales are those
that were produced by the model itself
rather than observed. The sales response
model constructed here uses two lagged
dependent variables and simple
econometric conditions determine if the
model is dynamically stable. The
coefficients of the one-year lag and the
two-year lag, b1 and b2, respectively
must satisfy three conditions. Their sum
must be less than one, b2 ¥ b1 <1, and
the absolute value of b2 must be less
than one. The coefficients of this model
satisfy all three conditions.
Using the Augural CAFE standards as
the baseline, it is possible to produce a
series of future total sales as shown in
Table–II–32. For comparison, the table
includes the calculated total light-duty
sales of a proprietary forecast purchased
to support the 2016 Draft TAR analysis,
the total new light-duty sales in EIA’s
2017 Annual Energy Outlook, and a
(short) forecast published in the Center
for Automotive Research’s Q4 2017
Automotive Outlook. All of the forecasts
in Table–II–32 assume the Augural
Standards are in place through MY
2025, though assumptions about the
costs required to comply with them
likely differ. As the table shows, despite
differences among them, the
dynamically produced sales projection
from the CAFE model is not
qualitatively different from the others.
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While this forecast projects a
relatively high, but flat, level of new
vehicle sales into the future, it is worth
noting that it continues another trend
observed in the historical data. The time
series of annual new vehicle sales is
volatile from year to year, but multi-year
averages are less so being sufficient to
wash out the variation associated with
them peaks and valleys of the series.
Despite the fact that the moving average
annual new vehicle sales has been
growing over the last four decades, it
has not kept pace with U.S. population
growth. Data from the Federal Reserve
Bank of St. Louis shows that the percapita sales of new vehicles peaked in
1986 and has declined more than 25%
from this peak to today’s level.231 While
the sales projection in Table–II–32
would represent a historically high
average of new vehicle sales over the
analysis period, it would not be
sufficient to reverse the trend of
declining per-capita sales of new
229 Out of necessity, the analysis in today’s rule
conflates production year (or ‘‘model year’’) and
calendar year. The volumes cited in the CAFE
model forecast represent forecasted production
volumes for those model years, while the other
represent calendar year sales (rather than
production)—during which two, or possibly three,
different model year vehicles are sold. In the long
run, the difference is not important. In the early
years, there are likely to be discrepancies.
230 U.S. Total Sales by Make, Automotive News,
https://www.autonews.com/section/datalist18 (last
visited June 22, 2018).
231 Mislinski, J. Light Vehicle Sales Per Capita:
Our Latest Look at the Long-Term Trend, Advisor
Perspectives (June 1, 2018), https://
www.advisorperspectives.com/dshort/updates/
2018/05/01/light-vehicle-sales-per-capita-our-latestlook-at-the-long-term-trend.
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vehicles during the analysis period,
though it would continue the trend at a
slower rate.
In addition to the statistical model
that estimates the response of total new
vehicle sales to changes in the average
new vehicle price, the CAFE model
incorporates a dynamic fleet share
model that modifies the light truck (and,
symmetrically, passenger car) share of
the new vehicle market. A version of
this model first appeared in the 2012
final rule, when this fleet share
component was introduced to ensure
greater internal consistency within
inputs in the uncertainty analysis. For
today’s analysis, this dynamic fleet
share is enabled throughout the analysis
of alternatives.
The dynamic fleet share model is a
series of difference equations that
determine the relative share of light
trucks and passenger cars based on the
average fuel economy of each, the fuel
price, and average vehicle attributes like
horsepower and vehicle mass (the latter
of which explicitly evolves as a result of
the compliance simulation). While this
model was taken from EIA’s National
Energy Modeling System (NEMS), it is
applied at a different level. Rather than
apply the shares based on the regulatory
class distinction, the CAFE model
applies the shares to body-style. This is
done to account for the large-scale shift
in recent years to crossover utility
vehicles that have model variants in
both the passenger car and light truck
regulatory fleets. The agencies have
always modified their static forecasts of
new vehicle sales to reflect the PC/LT
split present in the Annual Energy
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Outlook; this integration continues that
approach in a way that ensures greater
internal consistency when simulating
multiple regulatory alternatives (and
conducting sensitivity analysis on any
of the factors that influence fleet share).
(e) Vehicle Choice Models as an
Alternative Method To Estimate New
Vehicle Sales
Another potential option to estimate
future new vehicle sales would be to use
a full consumer choice model. The
agencies simulate compliance with
CAFE and CO2 standards for each
manufacturer using a disaggregated
representation of its regulated vehicle
fleets. This means that each
manufacturer may have hundreds of
vehicle model variants (e.g., the Honda
Civic with the 6-cylinder engine, and
the Honda Civic with the 4-cylinder
engine would each be treated as
different, in some ways, during the
compliance simulation).232 While the
analysis accounts for a wide variety of
attributes across these vehicles, only a
few of them change during the
compliance simulation. However, all of
those attributes are relevant in the
context of consumer choice models.
Aside from the computational
intensity of simulating new vehicle
sales at the level of individual models—
for all manufacturers, under each
regulatory alternative, over the next
decade or more—it would be necessary
to include additional relationships
232 For more detail about the compliance
simulation and manufacturer fleet representation,
see Section II.G.
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about how consumers trade off among
vehicle attributes, which types of
consumers prefer which types of
attributes (and how much), and how
manufacturers might strategically price
these modified vehicles. This requires a
strategic pricing model, which each
manufacturer has and would likely be
unwilling to share. Some of this
strategic pricing behavior occurs on
small time-scale through the use of
dealer incentives, rebates on specific
models, and creative financing offers.
When simulating compliance at the
annual scale, it is effectively impossible
to account for these types of strategic
decisions.
It is also true consumers have
heterogeneous preferences that change
over time and determine willingness-topay for a variety of vehicle attributes.
These preferences change in response to
marketing, distribution, pricing, and
product strategies that manufacturers
may change over time. With enough
data, a consumer choice model could
stratify new vehicle buyers into types
and attempt to measure the strength of
each type’s preference for fuel economy,
acceleration, safety rating, perceived
quality and reliability, interior volume,
or comfort. However, other factors also
influence customers’ purchase decision,
and some of these can be challenging to
model. Consumer proximity to
dealerships, quality of service and
customer experience at dealerships,
availability and terms of financing, and
basic product awareness may
significantly factor into sales success.
Manufacturers’ marketing choices
may significantly and unpredictably
affect sales. Ad campaigns may increase
awareness in the market, and campaigns
may reposition consumers’ perception
of the brands and products. For
example, in 2011 the Volkswagen Passat
featured an ad with a child in a Darth
Vader costume (and showcased remote
start technology on the Passat). In MY
2012, Kia established the Kia Soul with
party rocking, hip-hop hamster
commercials showcasing push-button
ignition, a roomy interior, and design
features in the brake lights. Both
commercials raised awareness and
highlighted basic product features. Each
commercial also impressed
demographic groups with pop culture
references, product placement, and co-
branding. While the marketing budget of
individual manufacturers may help a
consumer choice model estimate market
share for a given brand, estimating the
impact of a given campaign on new
sales is more challenging as consumers
make purchasing decisions based upon
their own needs and desires.
Modelers must understand how
consumers and commercial buyers
select vehicles in order to effectively
develop and implement a consumer
choice model in a compliance
simulation. Consumers purchase
vehicles for a variety of reasons such as
family need, need for more space, new
technology, changes to income and
affordability of a new vehicle, improved
fuel economy, operating costs of current
vehicles, and others. Once committed to
buying a vehicle, consumers use
different processes to narrow down their
shopping list. Consumer choice decision
attributes include factors both related
and not related to the vehicle design.
The vehicle’s utility for those attributes
is researched across many different
information sources as listed in the table
below.
An objective, attribute-based
consumer choice model could lead to
projected swings in manufacturer
market shares and individual model
volumes. The current approach
simulates compliance for each
manufacturer assuming that it produces
the same set of vehicles that it produced
in the initial year of the simulation (MY
2016 in today’s analysis). If a consumer
choice model were to drive projected
sales of a given vehicle model below
some threshold, as consumers have
done in the real market, the simulation
currently has no way to generate a new
vehicle model to take its place. As
demand changes across specific market
segments and models, manufacturers
adapt by supplying new vehicle
nameplates and models (e.g., the
proliferation of crossover utility
vehicles in recent years). Absent that
flexibility in the compliance simulation,
even the more accurate consumer choice
model may produce unrealistic
projections of future sales volumes at
the model, segment, or manufacturer
level.
Comment is sought on the
development and use of potential
consumer choice model in compliance
simulations. Comment is also sought on
the appropriate breadth, depth, and
complexity of considerations in a
consumer choice model.
not so stringent as to’’ lead to ‘‘adverse
economic consequences, such as a
significant loss of jobs or unreasonable
elimination of consumer choice.’’ 233
EPA similarly conducted an industry
employment analysis under the broad
authority granted to the agency under
the Clean Air Act.234 Both agencies
recognized the uncertainties inherent in
estimating industry employment
impacts; in fact, both agencies dedicated
a substantial amount of discussion to
uncertainty in industry employment
analyses in the 2012 final rule for MYs
2017 and beyond.235 Notwithstanding
these uncertainties, CAFE and CO2
standards do impact industry labor
hours, and providing the best analysis
practicable better informs stakeholders
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(f) Industry Employment Baseline
(Including Multiplier Effect) and Data
Description
In the first two joint CAFE/CO2
rulemakings, the agencies considered an
analysis of industry employment
impacts in some form in setting both
CAFE and emissions standards; NHTSA
conducted an industry employment
analysis in part to determine whether
the standards the agency set were
economically practicable, that is,
whether the standards were ‘‘within the
financial capability of the industry, but
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233 67
FR 77015, 77021 (Dec. 16, 2002).
George E. Warren Corp. v. EPA, 159 F.3d
616, 623–624 (D.C. Cir. 1998) (ordinarily
permissible for EPA to consider factors not
specifically enumerated in the Act).
235 See 77 FR 62624, 62952, 63102 (Oct. 15, 2012).
234 See
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and the public about the standards’
impact than would omitting any
estimates of potential labor impacts.
Today many of the effects that were
previously qualitatively identified, but
not considered, are quantified. For
instance, in the PRIA for the 2017–2025
rule EPA identified ‘‘demand effects,’’
‘‘cost effects,’’ and ‘‘factor shift effects’’
as important considerations for industry
labor, but the analysis did not attempt
to quantify either the demand effect or
the factor shift effect.236 Today’s
industry labor analysis quantifies direct
labor changes that were qualitatively
discussed previously.
Previous analyses and new
methodologies to consider direct labor
effects on the automotive sector in the
United States were improved upon and
developed. Potential changes that were
evaluated include (1) dealership labor
related to new light duty vehicle unit
sales; (2) changes in assembly labor for
vehicles, for engines and for
transmissions related to new vehicle
unit sales; and (3) changes in industry
labor related to additional fuel savings
technologies, accounting for new
vehicle unit sales. All automotive labor
effects were estimated and reported at a
national level,237 in job-years, assuming
2,000 hours of labor per job-year.
The analysis estimated labor effects
from the forecasted CAFE model
technology costs and from review of
automotive labor for the MY 2016 fleet.
For each vehicle in the CAFE model
analysis, the locations for vehicle
assembly, engine assembly, and
transmission assembly and estimated
labor in MY 2016 were recorded. The
percent U.S. content for each vehicle
was also recorded. Not all parts are
made in the United States, so the
analysis also took into account the
percent U.S. content for each vehicle as
manufacturers add fuel-savings
technologies. As manufacturers added
fuel-economy technologies in the CAFE
model simulations, the analysis
assumed percent U.S. content would
remain constant in the future, and that
the U.S. labor added would be
proportional to U.S. content. From this
foundation, the analysis forecasted
automotive labor effects as the CAFE
model added fuel economy technology
and adjusted future sales for each
vehicle.
236 Regulatory Impact Analysis: Final Rulemaking
for 2017–2025 Light-Duty Vehicle Greenhouse Gas
Emission Standards and Corporate Average Fuel
Economy Standards, U.S. EPA at 8–24 to 8–32
(Aug. 2012).
237 The agencies recognize a few local production
facilities may contribute meaningfully to local
economies, but the analysis reported only on
national effects.
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The analysis also accounts for sales
projections in response to the different
regulatory alternatives; the labor
analysis considers changes in new
vehicle prices and new vehicle sales (for
further discussion of the sales model,
see Section 2.E). As vehicle prices rise,
the analysis expected consumers to
purchase fewer vehicles than they
would have at lower prices. As
manufacturers sell fewer vehicles, the
manufacturers may need less labor to
produce the vehicles and less labor to
sell the vehicles. However, as
manufacturers add equipment to each
new vehicle, the manufacturers will
require human resources to develop,
sell, and produce additional fuel-saving
technologies. The analysis also accounts
for the potential that new standards
could shift the relative shares of
passenger cars and light trucks in the
overall fleet (see Section 2.E); insofar as
different vehicles involved different
amounts of labor, this shifting impacts
the quantity of estimated labor. The
CAFE model automotive labor analysis
takes into account reduction in vehicle
sales, shifts in the mix of passenger cars
and light trucks, and addition of fuelsavings technologies.
For today’s analysis, it was assumed
that some observations about the
production of MY 2016 vehicles would
carry forward, unchanged into the
future. For instance, assembly plants
would remain the same as MY 2016 for
all products now, and in the future. The
analysis assumed percent U.S. content
would remain constant, even as
manufacturers updated vehicles and
introduced new fuel-saving
technologies. It was assumed that
assembly labor hours per unit would
remain at estimated MY 2016 levels for
vehicles, engines, and transmissions,
and the factor between direct assembly
labor and parts production jobs would
remain the same. When considering
shifts from one technology to another,
the analysis assumed revenue per
employee at suppliers and original
equipment manufacturers would remain
in line with MY 2016 levels, even as
manufacturers added fuel-saving
technologies and realized cost
reductions from learning.
The analysis focused on automotive
labor because adjacent employment
factors and consumer spending factors
for other goods and services are
uncertain and difficult to predict. The
analysis did not consider how direct
labor changes may affect the macro
economy and possibly change
employment in adjacent industries. For
instance, the analysis did not consider
possible labor changes in vehicle
maintenance and repair, nor did it
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consider changes in labor at retail gas
stations. The analysis did not consider
possible labor changes due to raw
material production, such as production
of aluminum, steel, copper and lithium,
nor did the agencies consider possible
labor impacts due to changes in
production of oil and gas, ethanol, and
electricity. The analysis did not analyze
effects of how consumers could spend
money saved due to improved fuel
economy, nor did the analysis assess the
effects of how consumers would pay for
more expensive fuel savings
technologies at the time of purchase;
either could affect consumption of other
goods and services, and hence affect
labor in other industries. The effects of
increased usage of car-sharing, ridesharing, and automated vehicles were
not analyzed. The analysis did not
estimate how changes in labor from any
industry could affect gross domestic
product and possibly affect other
industries as a result.
Finally, no assumptions were made
about full-employment or not fullemployment and the availability of
human resources to fill positions. When
the economy is at full employment, a
fuel economy regulation is unlikely to
have much impact on net overall U.S.
employment; instead, labor would
primarily be shifted from one sector to
another. These shifts in employment
impose an opportunity cost on society,
approximated by the wages of the
employees, as regulation diverts
workers from other activities in the
economy. In this situation, any effects
on net employment are likely to be
transitory as workers change jobs (e.g.,
some workers may need to be retrained
or require time to search for new jobs,
while shortages in some sectors or
regions could bid up wages to attract
workers). On the other hand, if a
regulation comes into effect during a
period of high unemployment, a change
in labor demand due to regulation may
affect net overall U.S. employment
because the labor market is not in
equilibrium. Schmalansee and Stavins
point out that net positive employment
effects are possible in the near term
when the economy is at less than full
employment due to the potential hiring
of idle labor resources by the regulated
sector to meet new requirements (e.g., to
install new equipment) and new
economic activity in sectors related to
the regulated sector longer run, the net
effect on employment is more difficult
to predict and will depend on the way
in which the related industries respond
to the regulatory requirements. For that
reason, this analysis does not include
multiplier effects but instead focuses on
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labor impacts in the most directly
affected industries. Those sectors are
likely to face the most concentrated
labor impacts.
Comment is sought on these
assumptions and approaches in the
labor analysis.
4. Estimating Labor for Fuel Economy
Technologies, Vehicle Components,
Final Assembly, and Retailers
The following sections discuss the
approaches to estimating factors related
to dealership labor, final assembly labor
and parts production, and fuel economy
technology labor.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(a) Dealership Labor
The analysis evaluated dealership
labor related to new light-duty vehicle
sales, and estimated the labor hours per
new vehicle sold at dealerships,
including labor from sales, finance,
insurance, and management. The effect
of new car sales on the maintenance,
repair, and parts department labor is
expected to be limited, as this need is
based on the vehicle miles traveled of
the total fleet. To estimate the labor
hours at dealerships per new vehicle
sold, the National Automobile Dealers
Association 2016 Annual Report, which
provides franchise dealer employment
by department and function, was
referenced.238 The analysis estimated
that slightly less than 20% of dealership
employees’ work relates to new car sales
(versus approximately 80% in service,
parts, and used car sales), and that on
average dealership employees working
on new vehicle sales labor for 27.8
hours per new vehicle sold.
(b) Final Assembly Labor and Parts
Production
How the quantity of assembly labor
and parts production labor for MY 2016
vehicles would increase or decrease in
the future as new vehicle unit sales
increased or decreased was estimated.
Specific assembly locations for final
vehicle assembly, engine assembly, and
transmission assembly for each MY
2016 vehicle were identified. In some
cases, manufacturers assembled
products in more than one location, and
the analysis identified such products
and considered parallel production in
the labor analysis.
The analysis estimated industry
average direct assembly labor per
vehicle (30 hours), per engine (four
hours), and per transmission (five
hours) based on a sample of U.S.
238 NADA Data 2016: Annaul Financial Profile of
America’s Franchised New-Car Dealerships,
National Automobile Dealers Association, https://
www.nada.org/2016NADAdata/ (last visited June
22, 2018).
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assembly plant employment and
production statistics and other publicly
available information. The analysis
recognizes that some plants may use
less labor than the analysis estimates to
produce the vehicle, the engine, or the
transmission, and other plants may have
used more labor. The analysis used the
assembly locations and industry
averages for labor per unit to estimate
U.S. assembly labor hours for each
vehicle. U.S. assembly labor hours per
vehicle ranged from as high as 39 hours
if the manufacturer assembled the
vehicle, engine, and transmission at
U.S. plants, to as low as zero hours if
the manufacturer imported the vehicle,
engine, and transmission.
The analysis also considered labor for
part production in addition to labor for
final assembly. Motor vehicle and
equipment manufacturing labor
statistics from the U.S. Census Bureau,
the Bureau of Labor Statistics,239 and
other publicly available sources were
surveyed. Based on these sources, the
analysis noted that the historical
average ratio of vehicle assembly
manufacturing employment to
employment for total motor vehicle and
equipment manufacturing for new
vehicles remained roughly constant over
the period from 2001 through 2013, at
a ratio of 5.26. Observations from 2001–
2013 spanned many years, many
combinations of technologies and
technology trends, and many economic
conditions, yet the ratio remained about
the same. Accordingly, the analysis
scaled up estimated U.S. assembly labor
hours by a factor of 5.26 to consider U.S.
parts production labor in addition to
assembly labor for each vehicle.
The industry estimates for vehicle
assembly labor and parts production
labor for each vehicle scaled up or down
as unit sales scaled up or down over
time in the CAFE model.
(c) Fuel Economy Technology Labor
As manufacturers spend additional
dollars on fuel-saving technologies,
parts suppliers and manufacturers
require human resources to bring those
technologies to market. Manufacturers
may add, shift, or replace employees in
ways that are difficult for the agencies
to predict in response to adding fuelsavings technologies; however, it is
expected that the revenue per labor hour
at original equipment manufacturers
(OEMs) and suppliers will remain about
the same as in MY 2016 even as
industry includes additional fuel-saving
technology.
To estimate the average revenue per
labor hour at OEMs and suppliers, the
239 NAICS
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analysis looked at financial reports from
publicly traded automotive
businesses.240 Based on recent figures, it
was estimated that OEMs would add
one labor year per $633,066 revenue 241
and that suppliers would add one labor
year per $247,648 in revenue.242 These
global estimates are applied to all
revenues, and U.S. content is applied as
a later adjustment. In today’s analysis, it
was assumed these ratios would remain
constant for all technologies rather than
that the increased labor costs would be
shifted toward foreign countries.
Comment is sought on the realism of
this assumption.
(d) Labor Calculations
The analysis estimated the total labor
as the sum of three components:
Dealership hours, final assembly and
parts production, and labor for fueleconomy technologies (at OEM’s and
suppliers). The CAFE model calculated
additional labor hours for each vehicle,
based on current vehicle manufacturing
locations and simulation outputs for
additional technologies, and sales
changes. The analysis applied some
constants to all vehicles,243 but other
constants were vehicle specific,244 or
year specific for a vehicle.245
While a multiplier effect of all U.S.
automotive related jobs on non-auto
related U.S. jobs was not considered for
today’s analysis, the analysis did
program a ‘‘global multiplier’’ that can
be used to scale up or scale down the
total labor hours. This multiplier exists
in the parameters file, and for today’s
analysis the analysis set the value at
1.00.
5. Additional Costs and Benefits
Incurred by New Vehicle Buyers
Some costs of purchasing and owning
a new or used vehicle scale with the
240 The analysis considered suppliers that won
the Automotive News ‘‘PACE Award’’ from 2013–
2017, covering more than 40 suppliers, more than
30 of which are publicly traded companies.
Automotive News gives ‘‘PACE Awards’’ to
innovative manufacturers, with most recent
winners earning awards for new fuel-savings
technologies.
241 The analysis assumed incremental OEM
revenue as the retail price equivalent for
technologies, adjusting for changes in sales volume.
242 The analysis assumed incremental supplier
revenue as the technology cost for technologies
before retail price equivalent mark-up, adjusting for
changes in sales volume.
243 The analysis applied the same assumptions to
all manufacturers for annual labor hours per
employee, dealership hours per unit sold, OEM
revenue per employee, supplier revenue per
employee, and factor for the jobs multiplier.
244 The analysis made vehicle specific
assumptions about percent U.S. content and U.S.
assembly employment hours.
245 The analysis estimated technology cost for
each vehicle, for each year based on the technology
content applied in the CAFE model, year-by-year.
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value of the vehicle. Where fuel
economy standards increase the
transaction price of vehicles, they will
affect both the absolute amount paid in
sales tax and the average amount of
financing required to purchase the
vehicle. Further, where they increase
the MSRP, they increase the appraised
value upon which both value-related
registration fees and a portion of
insurance premiums are based. The
analysis assumes that the transaction
price is a set share of the MSRP, which
allows calculation of these factors as
shares of MSRP. Below the assumptions
made about how each of these
additional costs of vehicle purchase and
ownership scale with the MSRP and
how the analysis arrived at these
assumptions are discussed.
national weighted-average sales tax rate
almost identical to that resulting from
the use of Census population estimates
as weights, just slightly above 5.5%. The
analysis opted to utilize Census
population rather than the registrationbased proxy of new vehicle sales as the
basis for computing this weighted
average, as the end results were
negligibly different and the analytical
approach involving new vehicle
registrations had not been as thoroughly
reviewed. Note: Sales taxes and
registration fees are transfer payments
between consumers and the Federal
government and are therefore not
considered a cost in the societal
perspective. However, these costs are
considered as additional costs in the
private consumer perspective.
(a) Sales Taxes
The analysis took auto sales taxes by
state 246 and weighted them by
population by state to determine a
national weighted-average sales tax of
5.46%. The analysis sought to weight
sales taxes by new vehicle sales by state;
however, such data were unavailable. It
is recognized that for this purpose, new
vehicle sales by state is a superior
weighting mechanism to Census
population; in effort to approximate
new vehicle sales by state, a study of the
change in new vehicle registrations
(using R.L. Polk data) by state across
recent years was conducted, resulting in
a corresponding set of weights. Use of
the weights derived from the study of
vehicle registration data resulted in a
(b) Financing Costs
The analysis assumes 85% of
automobiles are financed based on
Experian’s quarter 4, 2016 ‘‘State of the
Automotive Finance Market,’’ which
notes that 85.2% of 2016 new vehicles
were financed, as were 85.9% of 2015
new vehicle purchases.247 The analysis
used data from Wards Automotive and
JD Power on the average transaction
price of new vehicle purchases, average
financed new auto beginning principal,
and the average incentive as a percent
of MSRP to compute the ratio of the
average financed new auto principal to
the average new vehicle MSRP for
calendar years 2011–2016. Table–II–34
shows that the average financed auto
principal is between 82 and 84% of the
average new vehicle MSRP. Using the
assumption that 85% of new vehicle
purchases involve some financing, the
average share of the MSRP financed for
all vehicles purchased, including nonfinanced transactions, rather than only
those that are financed, was computed.
Table–II–34 shows that this share ranges
between 70 and 72%. From this, the
analysis assumed that on an aggregate
level, including all new vehicle
purchases, 70% of the value of all
vehicles’ MSRP is financed. It is likely
that the share financed is correlated
with the MSRP of the new vehicle
purchased, but for simplification
purposes, it is assumed that 70% of all
vehicle costs are financed, regardless of
the MSRP of the vehicle. In
measurements of the impacts on the
average consumer, this assumption will
not affect the outcome of our
calculation, though this assumption will
matter for any discussions about how
many, or which, consumers bear the
brunt of the additional cost of owning
more expensive new vehicles. For sake
of simplicity, the model also assumes
that increasing the cost of new vehicles
will not change the share of new vehicle
MSRP that is financed; the relatively
constant share from 2011–2016 when
the average MSRP of a vehicle increased
10% supports this assumption. It is
recognized that this is not indicative of
average individual consumer
transactions but provides a useful tool
to analyze the aggregate marketplace.
From Wards Auto data, the average
48- and 60-month new auto interest
rates were 4.25% in 2016, and the
average finance term length for new
autos was 68 months. It is recognized
that longer financing terms generally
include higher interest rates. The share
financed, interest rate, and finance term
length are added as inputs in the
246 See Car Tax by State,
FactoryWarrantyList.com, https://www.factory
warrantylist.com/car-tax-by-state.html (last visited
June 22, 2018). Note: County, city, and other
municipality-specific taxes were excluded from
weighted averages, as the variation in locality taxes
within states, lack of accessible documentation of
locality rates, and lack of availability of weights to
apply to locality taxes complicate the ability to
reliably analyze the subject at this level of detail.
Localities with relatively high automobile sales
taxes may have relatively fewer auto dealerships, as
consumers would endeavor to purchase vehicles in
areas with lower locality taxes, therefore reducing
the effect of the exclusion of municipality-specific
taxes from this analysis.
247 Zabritski, M. State of the Automotive Finance
Market: A look at loans and leases in Q4 2016,
Experian, https://www.experian.com/assets/
automotive/quarterly-webinars/2016-Q4-SAFMrevised.pdf (last visited June 22, 2018).
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parameters file so that they are easier to
update in the future. Using these inputs
the model computes the stream of
financing payments paid for the average
financed purchases as the following:
Note: The above assumes the interest
is distributed evenly over the period,
when in reality more of the interest is
paid during the beginning of the term.
However, the incremental amount
calculated as attributable to the standard
will represent the difference in the
annual payments at the time that they
are paid, assuming that a consumer does
not repay early. This will represent the
expected change in the stream of
financing payments at the time of
financing.
The above stream does not equate to
the average amount paid to finance the
purchase of a new vehicle. In order to
compute this amount, the share of
financed transactions at each interest
rate and term combination would have
to be known. Without having
projections of the full distribution of the
auto finance market into the future, the
above methodology reasonably accounts
for the increased amount of financing
costs due to the purchase of a more
expensive vehicle, on an average basis
taking into account non-financed
transactions. Financing payments are
also assumed to be an intertemporal
transfer of wealth for a consumer; for
this reason, it is not included in the
societal cost and benefit analysis.
However, because it is an additional
cost paid by the consumer, it is
calculated as a part of the private
consumer welfare analysis.
It is recognized that increased finance
terms, combined with rising interest
rates, lead to a longer period of time
before a consumer will have positive
equity in the vehicle to trade in toward
the purchase of a newer vehicle. This
has impacts in terms of consumers
either trading vehicles with negative
equity (thereby increasing the amount
financed and potentially subjecting the
consumer to higher interest rates and/or
rendering the consumer unable to
obtaining financing) or delaying the
replacement of the vehicle until they
achieve suitably positive equity to allow
for a trade. Comment is sought on the
effect these developments will have on
the new vehicle market, both in general,
and in light of increased stringency of
fuel economy and GHG emission
standards. Comment is also sought on
whether and how the model should
account for consumer decisions to
purchase a used vehicle instead of a
new vehicle based upon increased new
vehicle prices in response to increased
CAFE standard stringency.
To utilize the above framework,
estimates of the share of MSRP paid on
collision and comprehensive insurance
and of annual vehicle depreciations are
needed to implement the above
equation. Wards has data on the average
annual amount paid by model year for
new light trucks and passenger cars on
collision, comprehensive and damage
and liability insurance for model years
1992–2003; for model years 2004–2016,
they only offer the total amount paid for
insurance premiums. The share of total
insurance premiums paid for collision
and comprehensive coverage was
computed for 1979–2003. For cars the
share ranges from 49 to 55%, with the
share tending to be largest towards the
end of the series. For trucks the share
ranges from 43 to 61%, again, with the
share increasing towards the end of the
series. It is assumed that for model years
2004–2016, 60% of insurance premiums
for trucks, and 55% for cars, is paid for
collision and comprehensive. Using
these shares the absolute amount paid
for collision and comprehensive
coverage for cars and trucks is
computed. Then each regulatory class in
the fleet is weighted by share to estimate
the overall average amount paid for
collision and comprehensive insurance
by model year as shown in Table–II–35.
The average share of the initial MSRP
paid in collision and comprehensive
insurance by model year is then
computed. The average share paid for
model years 2010–2016 is 1.83% of the
initial MSRP. This is used as the share
of the value of a new vehicle paid for
collision and comprehensive in the
future.
(c) Insurance Costs
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More expensive vehicles will require
more expensive collision and
comprehensive (e.g., fire and theft) car
insurance. Actuarially fair insurance
premiums for these components of
value-based insurance will be the
amount an insurance company will pay
out in the case of an incident type
weighted by the risk of that type of
incident occurring. It is expected that
the same driver in the same vehicle type
will have the same risk of occurrence for
the entirety of a vehicle’s life so that the
share of the value of a vehicle paid out
should be constant over the life of a
vehicle. However, the value of vehicles
will decline at some depreciation rate so
that the absolute amount paid in valuerelated insurance will decline as the
vehicle depreciates. This is represented
in the model as the following stream of
expected collision and comprehensive
insurance payments:
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2017 data from Fitch Black Book was
used as a source for vehicle depreciation
rates; two- to six-year-old vehicles in
2016 had an average annual
depreciation rate of 17.3%.248 It is
assumed that future depreciation rates
will be like recent depreciation, and the
analysis used the same assumed
depreciation. Table–II–36 shows the
cumulative share of the initial MSRP of
a vehicle assumed to be paid in
collision and comprehensive insurance
in five-year age increments under this
depreciation assumption, conditional on
a vehicle surviving to that age—that is,
the expected insurance payments at the
time of purchase will be weighted by
the probability of surviving to that age.
If a vehicle lives to 10 years, 9.9% of the
initial MSRP is expected to be paid in
collision and comprehensive payments;
by 20 years 11.9% of the initial MSRP;
finally, if a vehicle lives to age 40,
12.4% of the initial MSRP. As can be
seen, the majority of collision and
comprehensive payments are paid by
the time the vehicle is 10 years old.
The increase in insurance premiums
resulting from an increase in the average
value of a vehicle is a result of an
increase in the expected amount
insurance companies will have to pay
out in the case of damage occurring to
the driver’s vehicle. In this way, it is a
cost to the private consumer,
attributable to the CAFE standard that
caused the price increase.
In previous rulemaking analyses,
NHTSA imposed an economic cost of
lost welfare to buyers of advanced
electric vehicles. NHTSA chose to
model a 75-mile EV for early adopters,
who we assume would not be concerned
with the lower range, and a 150-mile EV
for the broader market. The initial five
percent of EV sales were assumed to go
to early adopters, with the remainder
being 150-mile EVs. The broader market
was assumed to have some lower utility
for the 150-mile EV, due to the lower
driving range between refueling events
relative to a conventional vehicle. Thus,
an additional social cost of about $3,500
per vehicle was assigned to the EV150
to capture the lost utility to
consumers.249 Additionally, NHTSA
imposed a ‘‘relative value loss’’ of
1.94% of the vehicle’s MSRP to reflect
the economic value of the difference
between the useful life of a conventional
ICE and the 150-mile EV when it
reaches a 55% battery capacity (as a
result of battery deteroriation).250 In
subsequent analyses (the 2016 Draft
TAR analysis and today’s analysis),
NHTSA removed the low-range EVs
from its technology set due to both weak
consumer demand for low-range EVs in
the marketplace and subsequent
technology advances that make 200-mile
EVs a more practical option for new EVs
produced in future model years. The
exclusion of low-range EVs in the
technology set reduced the need to
account for consumer welfare losses
248 Fitch Ratings Vehicle Depreciation Report
February 2017, Black Book, https://
www.blackbook.com/wp-content/uploads/2017/02/
Final-February-Fitch-Report.pdf (last visited June
22, 2018).
249 Based on Michael K. Hidrue, George R.
Parsons, Willett Kempton, Meryl P. Gardner,
Willingness to pay for electric vehicles and their
attributes, Resource and Energy Economics,Volume
33, Issue 3, 2011, Pages 686–705.
250 The vehicle was assumed to be retired once
the capacity reached 55 percent of its initial
capacity, and the residual lifetime miles from that
point forward were valued, discounted, and
expressed as a fraction of initial MSRP.
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(d) Consumer Acceptance of Specific
Technologies
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attributable to reduced driving range.
While the sensitivity analysis explores
some potential for continuing consumer
value loss, even in the improved
electrified powertrain vehicles, the
central analysis assumes that no value
loss exists for electrified powertrains.
However, ongoing low sales volumes
and a growing body of literature suggest
that consumer welfare losses may still
exist if manufacturers are forced to
produce electric vehicles in place of
vehicles with internal combustion
engines (forcing sacrifices to cargo
capacity or driving range) in order to
comply with standards. This topic will
receive ongoing investigation and
revision before the publication of the
final rule. Please provide comments and
any relevant data that would help to
inform the estimation of
implementation of any value loss
related to sacrificed attributes in electric
vehicles.
One reason it was necessary to
account for welfare losses from reduced
driving range in this way is that, in
previous rulemakings, the agencies
implicitly assumed that every vehicle in
the forecast would be produced and
purchased and that manufacturers
would pass on the entire incremental
cost of fuel-saving technologies to new
car (and truck) buyers. However, many
stakeholders commented that
consumers are not willing to pay the full
incremental costs for hybrids, plug-in
hybrids, and battery electric vehicles.251
For this analysis, consumer willingness
to pay for HEVs, PHEVs, BEVs relative
to comparable ICE vehicles was
investigated. The analysis compared the
estimated price premium the electrified
vehicles command in the used car
market and estimated the willingness to
pay premium for new vehicles with
electrification technologies at age zero
relative to their internal combustion
engine counterparts. For the analysis,
the willingness to pay was compared
with the expected incremental cost to
produce electrification technologies.
Manufacturers also contributed
confidential business information about
the costs, revenues, and profitability of
their electrified vehicle lines. The CBI
provided a valuable check on the
empirical work described below. As a
result of this examination, we no longer
assume manufacturers can pass on the
entire incremental cost of hybrid, plugin hybrid, and battery electric vehicles
to buyers of those vehicles. The
difference between the buyer’s
willingness-to-pay for those
technologies, and the cost to produce
them, must be recovered from buyers of
other vehicles in a manufacturer’s
product portfolio or sacrificed from its
profits, or sacrificed from dealership
profits, or supplemented with State or
Federal incentives (or, some
combination of the four).
Using data from the used vehicle
market, statistical models were fit to
estimate consumer willingness to pay
for new vehicles with varying levels of
electrification relative to comparable
internal combustion engine vehicles
was evaluated in four steps. The
analysis (1) gathered used car fair
market value for select vehicles; (2)
developed regression models to estimate
the portion of vehicle depreciation rate
attributable to the vehicle nameplate
and the portion attributable to the
vehicle’s technology content at each age
(using fixed effects for nameplates and
specific electrification technologies); (3)
estimated the value of vehicles at age
zero (i.e., when the vehicles were new);
and (4) compared new vehicle values for
comparable vehicles across different
electrification levels (i.e., internal
combustion, HEV, PHEV, and BEV) to
estimate willingness-to-pay for the
electric technology relative to an ICE.
The dataset used for estimation
consisted of vehicle attribute data from
Edmunds and transaction data from
Kelley Blue Book published online in
June and July of 2017 for select vehicles
of interest.252 253 The dataset was
constructed to contain pairs of vehicles
that were nearly the same, except for
type of powertrain (internal combustion
versus some amount of electrification).
For instance, the dataset contained used
vehicle prices for the Honda Accord and
Honda Accord Hybrid, Toyota Camry
and Toyota Camry Hybrid, Ford Fusion
and Ford Fusion Hybrid, Kia Soul and
Kia Soul EV, and so on for several
model years. In some cases, the
manufacturer produced no identically
equivalent internal combustion engine
vehicle, so a similar internal
combustion vehicle produced by the
same manufacturer was used as the
point of comparison. For example, the
Nissan Leaf was paired with the Nissan
Versa, as well as the Toyota Prius and
Toyota Corolla. Only vehicles available
for private sale, and in good vehicle
condition were included in the
analysis.254 The dataset contains fewer
observations for PHEVs and BEVs
because manufacturers have produced
fewer examples of vehicles with these
technologies, compared to HEV and ICE
vehicles. In all of these cases, trim level
and options packages were matched
between ICE and electric powertrains to
minimize the degree of non-powertrain
difference between vehicle pairs. The
resale price data spanned many model
years, but most observations in the
dataset represent MY 2013 through MY
2016.
The regression models used to
estimate the transaction price (or
‘‘Value’’) as a function of age, control for
the type of powertrain (ICE, HEV, PHEV,
and BEV) and nameplate to account for
their impact on the value of the vehicle
as it ages.255 The regression takes the
following form, with ICE, HEV, PHEV,
and BEV binary variables (0, or 1), and
age defined as 2017 minus the model
year was used:
1n(Value = ,b1(ICE * Age) + b2(HEV *
Age) + b3(PHEV * Age) + b4(BEV *
Age) + b5(HEV) + b6(PHEV) +
b7(BEV) + FENameplate
For each observation in the dataset,
the ‘‘Value’’ at age zero is determined by
setting the age variable to zero and
solving.
251 See e.g., Comment by Alliance of Automobile
Manufacturers, Docket ID EPA–HQ–OAR–2015–
0827–4089 and NHTSA–2016–0068–0072.
252 See Edmunds, https://www.edmunds.com/
(last visited June 22, 2018). Edmunds publishes
automotive data, reviews, and advice.
253 See Kelley Blue Book, https://www.kbb.com/
(last visited June 22, 2018). Kelley Blue Book, part
of Cox Automotive’s Autotrader brand, provides
automotive research, reviews, and advice, including
estimated market values of new and used vehicles.
254 It is possible ‘‘good’’ vehicles for all ages may
have inadvertently introduced a small bias in the
sample, as a ‘‘good’’ conditioning rating on a
vehicle just a year or two old may not be in average
condition relative to other vehicles of the vintage,
but a ‘‘good’’ rating for a much older car may reflect
an impeccably maintained vehicle.
255 In the case of electrified vehicles with no
internal combustion engine equivalent, the analysis
grouped like vehicle pairs together under the same
nameplate fixed effects (or FENameplate). Tesla
vehicles have no internal combustion engine
equivalent, and the used vehicle market for Tesla
has not cleared in the same way because of a variety
of unique business factors (previously, Tesla
guaranteed resale value prices for their products,
which was a factory incentive program that only
recently ended, no longer applying to vehicles sold
after July 1, 2016). These two factors impaired the
quality of used Tesla data for the purposes of the
analysis, so the agencies excluded Tesla vehicles
from today’s analysis on customer willingness-topay for electrified vehicles.
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The estimated willingness-to-pay for
electrified powertrain packages over an
internal combustion engine in an
otherwise similar vehicle is computed
as the difference between their
estimated initial values, using the
functions above. These pair-wise
differences are averaged to estimate a
price premium for new vehicles with
HEV, PHEV, and BEV technologies. This
analysis suggests that consumers are
willing to pay more for new electrified
vehicles than their new internal engine
combustion counterparts, but only a
little more, and not necessarily enough
to cover the relatively large projected
incremental cost to produce these
vehicles. Specifically, the analysis
estimated consumers are willing to pay
between $2,000 and $3,000 more for the
electrified powertrains considered here
than their internal combustion engine
counterparts.
Table–II–37 illustrates the variation in
willingness-to-pay by electrification
level (although the statistical model did
not distinguish between PHEV30 and
PHEV50 due to the small number of
available operations for plug-in
hybrids). As the table demonstrates, the
difference between the median and
mean predicted price premium for
PHEVs is significant. The limited
number of PHEV observations were not
uniformly distributed among the
nameplates present, and some of the
luxury vehicles in the set retained value
in a way that skewed the average. The
CBI acquired from manufacturers was
more consistent with the mean than
median value (except for the PHEVs).
Additionally, the Kelley Blue Book
data suggest that the used electrified
vehicles were often worth less than their
used internal combustion engine
counterpart vehicles after a few years of
use.256 As Table–II–38 illustrates, the
value of the price premium shrinks as
the vehicles age and depreciate. Using
the statistical model, we estimate that
strong hybrids hold less than $100 of
the initial price premium by age eight
(on average). While the battery electric
vehicles appear to be worth less than
their ICE counterparts by age eight,
there is limited data about this emerging
segment of the new vehicle market.
These independently-produced results
using publicly available data were in
line with manufacturers’ reported
confidential business information.
The ‘‘technology cost burden’’
numbers used in today’s analysis
represent the amount of a given
technology’s incremental cost that
manufacturers are unable to pass along
to the buyer of a given vehicle at the
time of purchase. The burden is defined
as the difference between estimated
willingness-to-pay, itself a combination
of the estimated values and confidential
business information received from
manufacturers any tax credits that can
be passed through in the price, and the
cost of the technology. In general, the
incremental willingness-to-pay falls
well short of the costs currently
projected for HEVs, PHEVs, and BEVs;
for example, BEV technology can add
roughly $18,000 in equipment costs to
the vehicle after standard retail price
equivalent markups (with a large
portion of those costs being batteries),
but the estimated willingness-to-pay is
only about $3,000. While tax credits
offset some, if not most of that
difference for PHEVs and BEVs, there is
some residual amount that buyers of
new electrified vehicles are currently
unwilling to cover, and that must either
come from forgone profits or be passed
256 The analysis did not identify an underlying
reason for this observation, but the agencies posit
for discussion purposes there could be some
interaction between maintenance costs and batteries
or maintenance costs and low volume vehicles.
Alternatively, new electrified vehicles may be
superior to previous generation vehicles, and new
electrified vehicles may be offered at lower prices
still because of a variety of market conditions.
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along to buyers of other vehicles in a
manufacturer’s portfolio.
Manufacturers may be able to recover
some or all of these costs by charging
higher prices for their other models, in
which case it will represent a welfare
loss to buyers of other vehicles (even if
not to buyers of HEVs, PHEVs, or BEVs
themselves). To the extent that they are
unable to do so and must absorb part or
all of these costs, their profits will
decline, and in effect this cost will be
borne by their investors. In practice, the
analysis estimates benefits and costs to
car and light truck manufacturers and
buyers under the assumption that each
manufacturer recovers all technology
costs and civil penalties it incurs from
buyers via higher average prices for the
models it produces and sells, although
sufficient information to support
specific assumptions about price
increases for individual models is not
present. In effect, this means that any
part of a manufacturer’s costs to convert
specific models to electric drive
technologies that it cannot recover by
charging higher prices to their buyers
will be borne collectively by buyers of
the other models they produce. Each of
those buyers is in effect assumed to pay
a slight premium (or ‘‘markup’’) over the
manufacturer’s cost to produce the
models they purchase (including the
cost of any technology used to improve
its fuel economy), this premium on
average is modeled to recover the full
cost of technology applied to all
vehicles to improve the fuel economy of
the fleet. So, even though electrified
vehicles are modeled as if their buyers
are unwilling to pay the full cost of the
technology associated with their fuel
economy improvement, the price borne
by the average new vehicle buyer
represents the average incremental
technology cost for all applied
technology, the sum of all technology
costs divided by the number of units
sold, across all classes, for each
manufacturer.
The willingness-to-pay analysis
described above relies on used vehicle
data that is widely available to the
public. Market tracking services update
used vehicle price estimates regularly as
fuel prices and other market conditions
change, making the data easy to update
in the future as market conditions
change. The used vehicle data also
account for consumer willingness-topay absent State and Federal rebates at
the time of sale, which are reflected in
both the initial purchase price of the
vehicle and its later value in the used
vehicle market. As such, the analysis
would continue to be relevant even if
incentive programs for vehicle
electrification change or phase out in
the future. By considering a variety of
nameplates and body styles produced
by several manufacturers, this analysis
produces average willingness-to-pay
estimates that can be applied to the
whole industry. By evaluating matched
pairs of vehicles from the same
manufacturer, the analysis accounts for
many additional factors that may be tied
to the brand, rather than the technology,
and influence the fair market price of
vehicles. In particular, the data
inherently include customer valuations
for fuel-savings and vehicle
maintenance schedules, as well as other
factors like noise-vibration-andharshness, interior space,257 and fueling
convenience in the context of the
vehicles considered.
There are some limitations to this
approach. There are currently few
observations of PHEV and BEV
technologies in the data, and most of the
observations for BEVs are sedans and
small cars, the values for which are
extrapolated to other market segments.
Additionally, the used vehicle data
supporting these estimates inherently
includes both older and newer
generations of technology, so the
historical regression may be slow to
react to rapid changes in the new
vehicle marketplace. As new vehicle
nameplates emerge, and existing
nameplates improve their
implementation of electrification
technologies, this model will require reestimation to determine how these new
entrants impact the estimated industry
average willingness-to-pay.
Additionally, the willingness-to-pay
analysis does not consider electric
vehicles with no direct ICE counterpart.
For example, today’s evaluation does
not consider Tesla because the Tesla
brand has no ICE equivalent, and
because the free-market prices for used
Tesla vehicles have been difficult (if not
impossible) to obtain, primarily due to
factory guaranteed resale values (which
is a program that still affects the used
market for many Tesla vehicles). Still,
Tesla vehicles have a large share of the
BEV market by both unit sales and
dollar sales, it may be possible to
include Tesla data in a future update to
this analysis. Similarly, the analysis did
257 Often HEVs and PHEVs place batteries in
functional storage space, such as the trunk or floor
storage bins, thereby forcing consumers to trade-off
fuel-savings with other functional vehicle
attributes.
258 See https://www.transportation.gov/sites/
dot.gov/files/docs/ValueofTravelTime
Memorandum.pdf (last accessed July 3, 2018).
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not include ICE vehicles with no similar
HEV, PHEV, or BEV nameplate or
counterpart, so the analysis presented
here looks at a small portion of all
transactions and is more likely to
include fuel efficient models where
market demand for hybrid (or higher)
versions may exist. One possible
alternative is to rely on new vehicle
transaction prices to estimate consumer
willingness-to-pay for new vehicles
with certain attributes. However, new
vehicle transaction data is highly
proprietary and difficult to obtain in a
form that may be disclosed to the
public.
While estimating willingness-to-pay
for electrification technologies from
depreciation and MSRP data is
appealing, many manufacturers handle
MSRP and pricing strategies differently,
with some preferring to deviate only a
little from sticker price and others
preferring to offer high discounts. There
is evidence of large differences between
MSRP and effective market prices to
consumers for many vehicles, especially
BEVs.
Please provide comments on methods
and data used to evaluate consumer
willingness-to-pay for electrification
technologies.
(e) Refueling Surplus
Direct estimates of the value of
extended vehicle range are not available
in the literature, so the reduction in the
required annual number of refueling
cycles due to improved fuel economy
was calculated and the economic value
of the resulting benefits assessed. Chief
among these benefits is the time that
owners save by spending less time both
in search of fueling stations and in the
act of pumping and paying for fuel.
The economic value of refueling time
savings was calculated by applying
DOT-recommended valuations for travel
time savings to estimates of how much
time is saved.258 The value of travel
time depends on average hourly
valuations of personal and business
time, which are functions of total hourly
compensation costs to employers. The
total hourly compensation cost to
employers, inclusive of benefits, in
2010$ is $29.68.259 Table–II–39 below
demonstrates the approach to estimating
the value of travel time ($/hour) for both
urban and rural (intercity) driving. This
approach relies on the use of DOTrecommended weights that assign a
lesser valuation to personal travel time
than to business travel time, as well as
259 Total hourly employer compensation costs for
2010 (average of quarterly observations across all
occupations for all civilians). See https://
www.bls.gov/ncs/ect/tables.htm (last accessed July
3, 2018).
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weights that adjust for the distribution
between personal and business travel.
260 Time spent on personal travel during rural
(intercity) travel is valued at a greater rate than that
of urban travel. There are several reasons behind
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time—independent of urban or rural
status—may be produced.
Note: The calculations above assume only
one adult occupant per vehicle. To fully
estimate the average value of vehicle travel
time, the presence of additional adult
passengers during refueling trips must be
accounted for. The analysis applies such an
adjustment as shown in Table–II–40; this
the divergence in these values: (1) Time is scarcer
on a long trip; (2) a long trip involves
complementary expenditures on travel, lodging,
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adjustment is performed separately for
passenger cars and for light trucks, yielding
occupancy-adjusted valuations of vehicle
travel time during refueling trips for each
fleet.
Note: Children (persons under age 16) are
excluded from average vehicle occupancy
counts, as it is assumed that the opportunity
cost of children’s time is zero.
food, and entertainment because time at the
destination is worth such high costs.
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The estimates of the hourly value of
urban and rural travel time ($15.67 and
$21.93, respectively) shown in Table–II–
39 above must be adjusted to account
for the nationwide ratio of urban to rural
driving. By applying this adjustment (as
shown in Table–II–40 below), an overall
estimate of the hourly value of travel
The analysis estimated the amount of
refueling time saved using (preliminary)
survey data gathered as part of our
2010–2011 National Automotive
Sampling System’s Tire Pressure
Monitoring System (TPMS) study.263
The study was conducted at fueling
stations nationwide, and researchers
made observations regarding a variety of
characteristics of thousands of
individual fueling station visits from
August 2010 through April 2011.264
Among these characteristics of fueling
station visits is the total amount of time
spent pumping and paying for fuel.
From a separate sample (also part of the
TPMS study), researchers conducted
interviews at the pump to gauge the
distances that drivers travel in transit to
and from fueling stations, how long that
transit takes, and how many gallons of
fuel are being purchased.
This analysis of refueling benefits
considers only those refueling trips
which interview respondents indicated
the primary reason was due to a low
reading on the gas gauge.265 This
restriction was imposed so as to exclude
drivers who refuel on a fixed (e.g.,
weekly) schedule and may be unlikely
to alter refueling patterns as a result of
increased driving range. The relevant
TPMS survey data on average refueling
trip characteristics are presented below
in Table–II–41.
As an illustration of how the value of
extended refueling range was estimated,
assume a small light truck model has an
average fuel tank size of approximately
20 gallons and a baseline actual on-road
fuel economy of 24 mpg (its assumed
level in the absence of a higher CAFE
standard for the given model year).
TPMS survey data indicate that drivers
who indicated the primary reason for
their refueling trips was a low reading
on the gas gauge typically refuel when
their tanks are 35% full (i.e. as shown
in Table–II–41, with 7.0 gallons in
reserve, and the consumer purchases 13
gallons). By this measure, a typical
driver would have an effective driving
range of 312 miles (= 13.0 gallons × 24
261 See Travel Monitoring, Traffic Volume Trends,
U.S. Department of Transportation Federal Highway
Administration, https://www.fhwa.dot.gov/policy
information/travellmonitoring/tvt.cfm (last visited
June 22, 2018). Weights used for urban versus rural
travel are computed using cumulative 2011
estimates of urban versus rural miles driven
provided by the Federal Highway Administration.
262 Source: National Automotive Sampling
System 2010–2011 Tire Pressure Monitoring System
(TPMS) study. See next page for further background
on the TPMS study. TPMS data are preliminary at
this time, and rates are subject to change pending
availability of finalized TPMS data. Average
occupancy rates shown here are specific to
refueling trips and do not include children under
16 years of age.
263 TPMS data are preliminary and not yet
published. Estimates derived from TPMS data are
therefore preliminary and subject to change.
Observational and interview data are from distinct
subsamples, each consisting of approximately 7,000
vehicles. For more information on the National
Automotive Sampling System and to access TPMS
data when they are made available, see https://
www.nhtsa.gov/NASS.
264 The data collection period for the TPMS study
ranged from October 10, 2010, through April 15,
2011.
265 Approximately 60% of respondents indicated
‘‘gas tank low’’ as the primary reason for the
refueling trip in question.
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mpg) before he or she is likely to refuel.
Increasing this model’s actual on-road
fuel economy from 24 to 25 mpg would
therefore extend its effective driving
range to 325 miles (= 13.0 gallons × 25
mpg). Assuming that the truck is driven
12,000 miles/year,266 this one mpg
improvement in actual on-road fuel
economy reduces the expected number
of refueling trips per year from 38.5 (=
12,000 miles per year/312 miles per
refueling) to 36.9 (= 12,000 miles per
year/325 miles per refueling), or by 1.6
refuelings per year. If a typical fueling
cycle for a light truck requires a total of
6.83 minutes, then the annual value of
time saved due to that one mpg
improvement would amount to $3.97 (=
(6.83/60) × $21.81 × 1.6).
In the central analysis, this
calculation was repeated for each future
calendar year that light-duty vehicles of
each model year affected by the
standards considered in this rule would
remain in service. The resulting
cumulative lifetime valuations of time
savings account for both the reduction
over time in the number of vehicles of
a given model year that remain in
service and the reduction in the number
of miles (VMT) driven by those that stay
in service. The analysis also adjusts the
value of time savings that will occur in
future years both to account for
expected annual growth in real
wages 267 and to apply a discount rate to
determine the net present value of time
saved.268 A further adjustment is made
to account for evidence from the
interview-based portion of the TPMS
study which suggests that 40% of
refueling trips are for reasons other than
a low reading on the gas gauge. It is
therefore assumed that only 60% of the
theoretical refueling time savings will
be realized, as it was assumed that
owners who refuel on a fixed schedule
266 2009 National Household Travel Survey
(NHTS), U.S Department of Transportation Federal
Highway Administration at 48 (June 2011),
available at https://nhts.ornl.gov/2009/pub/stt.pdf.
12,000 miles/year is an approximation of a light
duty vehicle’s annual mileage during its initial
decade of use (the period in which the bulk of
benefits are realized). The CAFE model estimates
VMT by model year and vehicle age, taking into
account the rebound effect, secular growth rates in
VMT, and fleet survivability; these complexities are
omitted in the above example for simplicity.
267 See The Economics Daily, The compensationproductivity gap, U.S. Department of Labor Bureau
of Labor Statistics (Feb. 24, 2011), https://
www.bls.gov/opub/ted/2011/ted_20110224.htm. A
1.1% annual rate of growth in real wages is used
to adjust the value of travel time per vehicle
($/hour) for future years for which a given model
is expected to remain in service. This rate is
supported by a BLS analysis of growth in real wages
from 2000–2009.
268 Note: Here, as elsewhere in the analysis,
discounting is applied on an annual basis from CY
2017.
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will continue to do. Based on peer
reviewer comments to NHTSA’s initial
implementation of refueling time
savings (subsequent to the CAFE NPRM
issued in 2011), the analysis of refueling
time savings was updated for the final
rule to reflect peer reviewer
suggestions.269 Beyond updating time
values to current dollars, that analysis
has been used, unchanged, in today’s
analysis as well.
Because a reduction in the expected
number of annual refueling trips leads
to a decrease in miles driven to and
from fueling stations, the value of
consumers’ fuel savings associated with
this decrease can also be calculated. As
shown in Table–II–41, the typical
incremental round-trip mileage per
refueling cycle is 1.08 miles for light
trucks and 0.97 miles for passenger cars.
Going back to the earlier example of a
light truck model, a decrease of 1.6 in
the number of refuelings per year leads
to a reduction of 1.73 miles driven per
year (= 1.6 refuelings × 1.08 miles
driven per refueling). Again, if this
model’s actual on-road fuel economy
was 24 mpg, the reduction in miles
driven yields an annual savings of
approximately 0.07 gallons of fuel (=
1.73 miles/24 mpg), which at $3.25/
gallon 270 results in a savings of $0.23
per year to the owner.
Note: This example is illustrative only of
the approach used to quantify this benefit. In
practice, the societal value of this benefit
excludes fuel taxes (as they are transfer
payments) from the calculation and is
modeled using fuel price forecasts specific to
each year the given fleet will remain in
service.
The annual savings to each consumer
shown in the above example may seem
like a small amount, but the reader
should recognize that the valuation of
the cumulative lifetime benefit of this
savings to owners is determined
separately for passenger car and light
truck fleets and then aggregated to show
the net benefit across all light-duty
vehicles, which is much more
significant at the macro level.
Calculations of benefits realized in
future years are adjusted for expected
real growth in the price of gasoline, for
the decline in the number of vehicles of
a given model year that remain in
service as they age, for the decrease in
269 Peer review materials, peer reviewer
backgrounds, comments, and NHTSA responses for
this prior assessment are available at Docket
NHTSA–2012–0001.
270 Estimate of $3.25/gallon is the forecasted cost
per gallon (including taxes, as individual
consumers consider reduced tax expenditures to be
savings) for motor gasoline in 2025. Source of price
projections: U.S. Energy Information
Administration, Annual Energy Outlook Early 2018.
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the number of miles (VMT) driven by
those that stay in service, and for the
percentage of refueling trips that occur
for reasons other than a low reading on
the gas gauge; a discount rate is also
applied in the valuation of future
benefits. Using this direct estimation
approach to quantify the value of this
benefit by model year was considered;
however, it was concluded that the
value of this benefit is implicitly
captured in the separate measure of
overall valuation of fuel savings.
Therefore, direct estimates of this
benefit are not added to net benefits
calculations. It is noted that there are
other benefits resulting from the
reduction in miles driven to and from
fueling stations, such as a reduction in
greenhouse gas emissions—CO2 in
particular—which, as per the case of
fuel savings discussed in the preceding
paragraph, are implicitly accounted for
elsewhere.
Special mention must be made with
regard to the value of refueling time
savings benefits to owners of electric
and plug-in electric (both referred to
here as EV) vehicles. EV owners who
routinely drive daily distances that do
not require recharging on-the-go may
eliminate the need for trips to fueling or
charging stations. It is likely that early
adopters of EVs will factor this benefit
into their purchasing decisions and
maintain driving patterns that require
once-daily at-home recharging (a
process which generally takes five to
eleven hours for a full charge) 271 for
those EV owners who have purchased
and installed a Level Two charging
station to a high-voltage outlet at their
home or parking place. However, EV
owners who regularly or periodically
need to drive distances further than the
fully-charged EV range may need to
recharge at fixed locations. A
distributed network of charging stations
(e.g., in parking lots, at parking meters)
may allow some EV owners to recharge
their vehicles while at work or while
shopping, yet the lengthy charging
cycles of current charging technology
may pose a cost to owners due to the
value of time spent waiting for EVs to
charge and potential EV shoppers who
do not have access to charging at home
(e.g., because they live in an apartment
without a vehicle charging station, only
271 See generally All-New Nissan Leaf Range &
Charging, Nissan USA, https://www.nissanusa.com/
vehicles/electric-cars/leaf/range-charging.html (last
visited June 22, 2018); Home Charging Calculator,
Tesla, https://www.tesla.com/support/homecharging-calculator (last visited June 22, 2018);
2018 Chevrolet Bolt EV, GM, https://media.gm.com/
content/media/us/en/chevrolet/vehicles/bolt-ev/
2018/_jcr_content/iconrow/textfile/file.res/2018Chevrolet-Bolt-EV-Product-Guide.pdf (last visited
June 22, 2018).
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have street parking, or have garages with
insufficient voltage). Moreover, EV
owners who primarily recharge their
vehicles at home will still experience
some level of inconvenience due to their
vehicle being either unavailable for
unplanned use or to its range being
limited during this time should they
interrupt the charging process.
Therefore, at present EVs hold potential
in offering significant time savings but
only to owners with driving patterns
optimally suited for EV characteristics.
If fast-charging technologies emerge and
a widespread network of fast-charging
stations is established, it is expected
that a larger segment of EV vehicle
owners will fully realize the potential
refueling time savings benefits that EVs
offer. This is an area of significant
uncertainty.
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6. Vehicle Use and Survival
To properly account for the average
value of consumer and societal costs
and benefits associated with vehicle
usage under various CAFE and GHG
alternatives, it is necessary to estimate
the portion of these costs and benefits
that will occur at each age (or calendar
year) for each model year cohort. Doing
so requires some estimate of how many
miles the average vehicle of a given
type 272 is expected to drive at each age
and what share of the initial model year
cohort is expected to remain at each age.
The first estimates are referred to as the
vehicle miles travelled (VMT) schedules
and the second as the survival rate
schedules. In this section the data
sources and general methodologies used
to develop these two essential inputs are
briefly discussed. More complete
discussions of the development of both
the VMT schedules and the survival rate
schedules are present in the PRIA
Chapter 8.
(a) Updates to Vehicle Miles Traveled
Schedules Since 2012 FR
The MY 2017–2021 FRM built
estimates of average lifetime mileage
accumulation by body style and age
using the 2009 National Household
Travel Survey (NHTS), which surveys
odometer readings of the vehicles
present from the approximately 113,000
households sampled. Approximately
210,000 vehicles were in the sample of
self-reported odometer readings
collected between April 2008 and April
2009. This represents a sample size of
less than one percent of the more than
250 million light-duty vehicles
registered in 2008 and 2009. The NHTS
sample is now 10 years old and taken
272 Type here refers to the following body styles:
Pickups, vans/SUVs, and other cars.
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during the Great Recession. The 2017
NHTS was not available at the time of
this rulemaking. Because of the age of
the last available NHTS and the unusual
economic conditions under which it
was collected, NHTSA built the new
schedule using a similar method from a
proprietary dataset collected in the fall
of 2015. This new data source has the
advantages of both being newer, a larger
sample, and collected by a third party.
(1) Data Sources and Estimation (Polk
Odometer Data)
To develop new mileage
accumulation schedules for vehicles
regulated under the CAFE program
(classes 1–3), NHTSA purchased a data
set of vehicle odometer readings from
IHS/Polk (Polk). Polk collects odometer
readings from registered vehicles when
they encounter maintenance facilities,
state inspection programs, or
interactions with dealerships and
OEMs—these readings are more likely to
be precise than the self-reported
odometer readings collected in the
NHTS. The average odometer readings
in the data set NHTSA purchased are
based on more than 74 million unique
odometer readings across 16 model
years (2000–2015) and vehicle classes
present in the data purchase (all
registered vehicles less than 14,000 lbs.
GVW). This sample represents
approximately 28% of the light-duty
vehicles registered in 2015, and thus has
the benefit of not only being a newer,
but also, a larger, sample.
Comparably to the NHTS, the Polk
data provide a measure of the
cumulative lifetime vehicle miles
traveled (VMT) for vehicles, at the time
of measurement, aggregated by the
following parameters: Make, model,
model year, fuel type, drive type, door
count, and ownership type (commercial
or personal). Within each of these
subcategories they provide the average
odometer reading, the number of
odometer readings in the sample from
which Polk calculated the averages, and
the total number of that subcategory of
vehicles in operation.
In estimating the VMT models, each
data point was weighted (make/model
classification) by the share of each
make/model in the total population of
the corresponding vehicle body style.
This weighting ensures that the
predicted odometer readings, by body
style and model year, represent each
vehicle classification among observed
vehicles (i.e., the vehicles for which
Polk has odometer readings), based on
each vehicles’ representation in the
registered vehicle population of its body
style. Implicit in this weighting scheme
is the assumption that the samples used
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to calculate each average odometer
reading by make, model, and model year
are representative of the total
population of vehicles of that type.
Several indicators suggest that this is a
reasonable assumption.
First, the majority of vehicle make/
models is well-represented in the
sample. For more than 85% of make/
model combinations, the average
odometer readings are collected for 20%
or more of the total population. Most
make/model observations have
sufficient sample sizes, relative to their
representation in the vehicle
population, to produce meaningful
average odometer totals at that level.
Second, we considered whether the
representativeness of the odometer
sample varies by vehicle age because
VMT schedules in the CAFE model are
specific to each age. It is possible that,
for some of those models, an insufficient
number of odometer readings is
recorded to create an average that is
likely to be representative of all of those
models in operation for a given year. For
all model years other than 2015,
approximately 95% or more of vehicles
types are represented by at least five
percent of their population. For this
reason, observations from all model
years, other than 2015, were included in
the estimation of the new VMT
schedules.
Because model years are sold in in the
Fall of the previous calendar year,
throughout the same calendar year, and
even into the following calendar year—
not all registered vehicles of a make/
model/model year will have been
registered for at least a year (or more)
until age three. The result is that some
MY 2014 vehicles may have been driven
for longer than one year, and some less,
at the time the odometer was observed.
In order to consider this in the
definition of age, an age of a vehicle is
assigned to be the difference between
the average reading date of a make/
model and the average first registration
date of that make/model. The result is
that the continuous age variable reflects
the amount of time that a car has been
registered at the time of odometer
reading and presumably the time span
that the car has accumulated the miles.
After creating the ‘‘age’’ variable, the
analysis fits the make/model lifetime
VMT data points to a weighted quartic
polynomial regression of the age of the
vehicle (stratified by vehicle body
styles). The predicted values of the
quartic regressions are used to calculate
the marginal annual VMT by age for
each body style by calculating
differences in estimated lifetime mileage
accumulation by age. However, the Polk
data acquired by NHTSA only contains
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observations for vehicles newer than 16
years of age. In order to estimate the
schedule for vehicles older than the age
15 vehicles in the Polk data, information
about that portion of the schedule from
the VMT schedules used in both the
2017–2021 Final Light Duty Rule and
2019–2025 Medium-Duty NPRM was
combined. The light-duty schedules
were derived from the survey data
contained in the 2009 National
Household Travel Survey (NHTS).
From the old schedules, the annual
VMT is expected to be decreasing for all
ages. Towards the end of the sample, the
predictions for annual VMT increase. In
order to force the expected
monotonicity, a triangular smoothing
algorithm is performed until the
schedule is monotonic. This performs a
weighted average which weights the
observations close to the observation
more than those farther from it. The
result is a monotonic function, that
predicts similar lifetime VMT for the
sample span as the original function.
Because the analysis does not have data
beyond 15 years of age, it is not able to
correctly capture that part of the annual
VMT curve using only the new dataset.
For this reason, trends in the old data
to extrapolate the new schedule for ages
beyond the sample range are used.
To use the VMT information from the
newer data source for ages outside of the
sample, final in-sample age (15 years)
are used as a seed and then applied to
the proportional trend from the old
schedules to extrapolate the new
schedules out to age 40. To do this, the
annual percentage difference in VMT of
the old schedule for ages 15–40 is
calculated. The same annual percentage
difference in VMT is applied to the new
schedule to extend beyond the final insample value. This assumes that the
overall proportional trend in the outer
years is correctly modeled in the old
VMT schedule and imposes this same
trend for the outer years of the new
schedule. The extrapolated schedules
are the final input for the VMT
schedules in the CAFE model. PRIA
Chapter 8 contains a lengthier
discussion of both the data source and
the methodology used to create the new
schedules.
273 Though not included in today’s analysis,
corresponding schedules for heavy-duty pickups
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(2) Using New Schedules in the CAFE
Model/Analysis
While the Polk registration data set
contains odometer readings for
individual vehicles, the CAFE model
tabulates ‘‘mileage accumulation’’
schedules, which relate average annual
miles driven to vehicle age, based on
vehicles’ body style. For the purposes of
VMT accounting, the CAFE model
classifies vehicles in the analysis fleet as
being one of the following: Passenger
car, SUV, pickup truck, passenger van,
or medium-duty pickup/van.273 In order
to use the Polk data to develop VMT
schedules for each of these vehicle
classes in the CAFE model, a mapping
between the classification of each model
in the Polk data and the classes in the
CAFE model was first constructed. This
mapping enabled separate tabulations of
average annual miles driven at each age
for each of the vehicle classes included
in the CAFE model.
The only revision made to the
mappings used to construct the new
VMT schedules was to merge the SUV
and passenger van body styles into a
single class. These body styles were
merged because there were very few
examples of vans—only 38 models were
in use during 2014, where every other
body style had at least three times as
many models. Further, as shown in the
PRIA Chapter 8, there was not a
significant difference between the 2009
NHTS van and SUV mileage schedules,
nor was there a significant difference
between the schedules built with the
two body styles merged or kept separate
using the 2015 Polk data. Merging these
body styles does not change the
workings of the CAFE model in any
way, and the merged schedule is simply
entered as an input for both vans and
SUVs.
Although there is a single VMT by age
schedule used as an input for each body
style, the assumptions about the
rebound effect require that this schedule
be scaled for future analysis years to
reflect changes in the cost of travel from
the time the Polk sample was originally
collected. These changes result from
both changes in fuel prices between the
time the sample was collected and any
future analysis year and differences in
fuel economy between the vehicles
included in the sample used to build the
mileage schedules and the future-year
vehicles analyzed within the CAFE
Model simulation.
As discussed in Section 0, recent
literature supports a 20% ‘‘rebound
effect’’ for light-duty vehicle use, which
represents an elasticity of annual use
with respect to fuel cost per mile of
¥0.2. Because fuel cost per mile is
calculated as fuel price per gallon
divided by fuel economy (in miles per
gallon), this same elasticity applies to
changes in fuel cost per mile that result
from variation in fuel prices or
differences in fuel economy. It suggests
that a five percent reduction in the cost
per mile of travel for vehicles of a
certain body style will result in a one
percent increase in the average number
of miles they are driven annually.
The average cost per mile (CPM) of a
vehicle of a given age and vehicle style
in CY 2016 (the first analysis year of the
simulation) was used as the reference
point to calculate the rebound effect
within the CAFE model. However, this
does not perfectly align with the time of
the collection of the Polk dataset. The
Polk data were collected in 2015 (so that
2014 fuel prices were the last to
influence sampled vehicles’ odometer
readings), and represents the average
odometer reading at a single point in
time for age (model year) included in
the cross-section. We use the difference
in the average odometer reading for each
vintage during 2014 to calculate the
number of miles vehicles are driven at
each age (see PRIA Chapter 8 for
specific details on the analysis). For
example, we interpret the difference in
the average odometer reading between
the five- and six-year-old vehicles of a
given body style as the average number
of miles they are driven during the year
when they were five years old.
However, vehicles produced during
different model years do not have the
same average fuel economy, so it is
important to consider the average fuel
economy of each vintage (or model year)
used to measure mileage accumulation
at a given age when scaling VMT for the
rebound calculation.
The first step in doing so is to adjust
for any change in average annual use
that would have been caused by
differences in fuel prices between CYs
2014 and 2016. This is done by scaling
the original schedules of annual VMT
by age tabulated from the Polk sample
using the following equation:
and vans were developed using the same
methodology.
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Here, the average fuel economy for
vehicles of a given body style and age
refers to a different MY in 2016 than it
did in 2014; for example, a MY 2014
vehicle had reached age two vehicle
during CY 2016, whereas a 2012 model
year vehicle was age two during CY
2014.
To estimate the average annual use of
vehicles of a specified body type and
age during future calendar years under
a specific regulatory alternative, the
CAFE model adjusts the resulting
estimates of vehicle use by age for that
body type during CY 2016 to reflect (1)
the projected change in fuel prices from
2016 to each future calendar year; and
(2) the difference between the average
fuel economy for vehicles of that body
type and age during a future calendar
year and the average fuel economy for
vehicles of that same body type and age
during 2016. These two factors combine
to determine the average fuel cost per
mile for vehicles of that body type and
age during each future calendar year
and the average fuel cost per mile for
vehicles of that same body type and age
during 2016.
The elasticity of annual vehicle use
with respect to fuel cost per mile is
applied to the difference between these
two values because vehicle use is
assumed to respond identically to
differences in fuel cost per mile that
result from changes in fuel prices or
from differences in fuel economy. The
model then repeats this calculation for
each calendar year during the lifetimes
of vehicles of other body types, and
subsequently repeats this entire set of
calculations for each regulatory
alternative under consideration. The
resulting differences in average annual
use of vehicles of each body type at each
age interact with the number estimated
to remain in use at that age to determine
total annual VMT by vehicles of each
body type.
This adjustment is defined by the
equation below:
This equation uses the observed cost
per mile of a vehicle of each age and
style in CY 2016 as the reference point
for all future calendar years. That is, the
reference fuel price is fixed at 2016
levels, and the reference fuel economy
of vehicles of each age is fixed to the
average fuel economy of the vintage that
had reached that age in 2016. For
example, the reference CPM for a oneyear-old SUV is always the CPM of the
average MY 2015 SUV in CY 2016, and
the CPM for a two-year-old SUV is
always the CPM of the average
MYv2014 SUV in CY 2016.
This referencing ensures that the
model’s estimates of annual mileage
accumulation for future calendar years
reflect differences in the CPM of
vehicles of each given type and age
relative to CPM resulting from the
average fuel economy of vehicles of that
type and age and observed fuel prices
during the year when the mileage
accumulation schedules were originally
measured. This is consistent with a
definition of the rebound effect as the
elasticity of annual vehicle use with
respect to changes in the fuel cost per
mile of travel, regardless of the source
of changes in fuel cost per mile.
Alternative forms of referencing are
possible, but none can guarantee that
projected future vehicle use will
respond to both projected changes in
fuel prices and differences in individual
models’ fuel economy among regulatory
alternatives.
The mileage estimates described
above are a crucial input in the CAFE
model’s calculation of fuel consumption
and savings, energy security benefits,
consumer surplus from cheaper travel,
recovered refueling time, tailpipe
emissions, and changes in crashes,
fatalities, noise and congestion.
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Across all body styles and ages, the
previous VMT schedules estimate
higher average annual VMT than the
updated schedules. Table–II—42
compares the lifetime VMT under the
2009 NHTS and the 2015 Polk dataset.
The 40-year lifetime VMT gives the
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(3) Comparison to other VMT
projections (2012 FR, AEO average
lifetime miles, totals?)
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expected lifetime VMT of a vehicle
conditional on surviving to age 40. The
new schedules predict between 24 and
31% fewer miles for a 40-year old
vehicle depending on the body style.
The new schedules predict that the
average 40-year old vehicle will drive
between approximately 260k and 280k
miles depending on the body style
versus between approximately 350k and
380k for the previous schedules.
The static survival-weighted lifetime
VMT represents the expected number of
miles the average vehicle of each body
style will drive, weighting by the
likelihood it survives to each age using
the previous static scrappage schedules.
The dynamic survival-weighted lifetime
VMT represents the expected number of
miles driven by each body style,
weighting by the dynamic survival
schedules under baseline
assumptions.274 There is a similar
proportional reduction in expected
lifetime VMT under both survival
assumptions, with the dynamic
scrappage model predicting lifetime
mileage accumulation within 10,000
miles of the previous static model under
both VMT schedules. The expected
lifetime mileage accumulation reduces
between 13 and 15% under the current
VMT schedules when compared to the
previous schedules—a smaller
proportional reduction than the
unweighted lifetime assumptions. Using
the updated schedules, the expected
lifetime mileage accumulation is
between approximately 150k and 170k
miles depending on the body style,
rather than the approximately 180k to
210k miles under the previous
schedules. For more detail on when the
mileage and survival rates occur,
chapter 8 of the PRIA gives the full VMT
schedules by age. The section below
gives further estimates of how lifetime
VMT estimates vary under different
assumptions within the dynamic
scrappage model.
We have several reasons for preferring
the new VMT schedules over the prior
iterations. Before discussing these
reasons, it is important to note that
NHTSA uses the same general
methodology in developing both
schedules. We consider data on average
odometer readings by age and body style
collected once during a given window
of time; we then estimate a weighted
polynomial function between vehicle
age and lifetime accumulation for a
given vehicle style. As with the
previous schedules, we use the interannual differences as the estimate of
annual miles traveled for a given age.
The primary advantage of the current
schedules is the data source. The
previous schedules are based on data
that is outdated and self-reported, while
the observations from Polk are between
five and seven years newer than those
in the NHTS and represent valid
odometer readings (rather than self-
reported information). Further, the 2009
NHTS represents approximately one
percent of the sample of vehicles
registered in 2008/2009, while the 2015
Polk dataset represents approximately
30% of all registered light-duty vehicles;
it is a much larger dataset, and less
likely to oversample certain vehicles.
Additionally, while the NHTS may be a
representative sample of households, it
is less likely to be a representative
sample of vehicles. However, by
properly accounting for vehicle
population weights in the new averages
and models, we corrected for this issue
in the derivation of the new schedules.
Importantly, this methodology treats
the cross-section of ages in a single
calendar year as a panel of the same
model year vehicle, when in reality each
age represents a single model year, and
not a true panel. We have some concern
that where the most heavily driven
vehicles drop out of the sample that the
lifetime odometer readings will be lower
than they would be if the scrapped
vehicles had been left in the dataset
without additional mileage
accumulation. This would bias our
estimates of inter-annual mileage
accumulation downward and may result
in an undervaluation of costs and
benefits associated with additional
travel for vehicles of older ages. For the
next VMT schedule iteration, NHTSA
intends to use panel data to test the
magnitude of any attrition effect that
may exist. While this caveat is
important, all previous iterations were
also built from a single calendar year
cross-section and contain the same
inherent bias.
274 In estimating the dynamic survival rate to
weight the annual VMT schedules, we make the
following input assumptions: The reference vehicle
is MY 2016, GDP growth rates and fuel prices are
our central estimates, and the future average new
vehicle fuel economies by body style and overall
average new vehicle prices are those simulated by
the CAFE model when CAFE standards are omitted
(by setting standards at 1 mpg), such that only
technologies that pay back within 30 months are
applied.
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(b) How does CAFE affect vehicle
retirement rates?
Lightly used vehicles are a close
substitute for new vehicles; thus, there
is relationship between the two markets.
As the price for new vehicles increases,
there is an upward shift in the demand
for used vehicles. As a result of the
upward shift in the demand curve, the
equilibrium price and quantity of used
vehicles both increase; the value of used
vehicles increases as a result. The
decision to scrap or maintain a used
vehicle is closely linked with the value
of the vehicle; when the value is lesser
than the cost to maintain the vehicle, it
will be scrapped. In general, as a result
of new vehicle price increases, the
scrappage rate, or the proportion of
vehicles remaining on the road
unregistered in a given year, of used
vehicles will decline. Because older
vehicles are on average less efficient and
less safe, this will have important
implications for the evaluations of costs
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and benefits of fuel economy standards,
which increase the cost of new vehicles
and reduce the average cost per mile of
fuel costs.
Fuel economy standards result in the
application of more fuel saving
technologies for at least some models,
which result in a higher cost for
manufacturers to produce otherwise
identical vehicles. This increase in
production cost amounts to an upward
shift in the supply curve for new
vehicles. This increases the equilibrium
price and reduces the quantity of
vehicles demanded. While the cost of
new vehicles increases under increased
fuel economy standards, the fuel cost
per mile of travel declines. Consumers
will place some value on the fuel
savings associated with the additional
technology, to the extent that they value
reduced operating expenses against the
increased price of a new vehicle,
increased financing costs (and
impediments to obtaining financing),
and increased insurance costs.
There is a trade-off between fuel
economy and other attributes that
consumers value such as: Vehicle
performance, interior volume, etc.
Where the additional value of fuel
savings associated with a technology is
greater than any loss of value from
trade-offs with other attributes, the
demand for new vehicles will also shift
upwards. Where the additional
evaluation of fuel savings is lesser than
any loss of value from changes to other
attributes, the demand will shift
downwards. Thus, the direction of the
demand shift is unknown. However, if
we assume that manufacturers pass all
costs associated with a model off to the
consumer of that vehicle, then the per
vehicle profit remains constant. If we
also assume that manufacturers are good
predictors of the valuation and elasticity
of certain vehicle attributes, then we can
assume that even if there is some
positive demand shift, it is not enough
to increase demand above the original
equilibrium levels, or manufacturers
would apply those technologies even in
the absence of regulation.
As noted above, the increase in the
price of new vehicles will result in
increased demand for used vehicles as
substitutes, extending the expected age
and lifetime vehicle miles travelled of
less efficient, and generally, less safe
vehicles. The additional usage of older
vehicles will result in fewer gallons
saved and more total on-road fatalities
under more stringent CAFE alternatives.
For more on the topic of safety, the
relative safety of specific model year
vehicles is discussed in Section 0 of the
preamble and PRIA Chapter 11. Both the
erosion of fuel savings and the increase
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in incremental fatalities will decrease
the societal net benefits of increasing
new vehicle fuel economy standards.
Our previous estimates of vehicle
scrappage did not include a dynamic
response to new vehicle price, but
recent literature has continued to
illustrate that this an omission which
could rival the rebound effect in
magnitude (Jacobsen & van Bentham,
2015). For this reason, we worked to
develop an econometric survival model
which captures the effect of increasing
the price of new vehicles on the survival
rate of used vehicles discussed in the
following sections and in more detail in
the PRIA Chapter 8. We discuss the
literature on vehicle scrappage rate and
discuss in the succeeding section. A
brief explanation of why we develop our
own models and the data sources and
econometric estimations we use to do
so, follows. We conclude the discussion
of the updates to vehicle survival
estimates with a summary of the results,
a description of how we use them in the
CAFE model, and finally, how the
updated schedules compare with the
previous static scrappage schedules.
(1) What does the literature say about
the relationship?
(a) How Fuel Economy Standards
Impact Vehicle Scrappage
The effects of differentiated
regulation 275 in the context of fuel
economy (particularly, emission
standards only affecting new vehicles)
was discussed in detail in Gruenspecht
(1981) and (1982), and has since been
coined the ‘‘Gruenspecht effect.’’
Gruenspecht recognized that because
fuel economy standards affect only new
vehicles, any increase in price (net of
the portion of reduced fuel savings
valued by consumers) will increase the
expected life of used vehicles and
reduce the number of new vehicles
entering the fleet. In this way, increased
fuel economy standards slow the
turnover of the fleet and the entrance of
any regulated attributes tied only to new
vehicles. Although Gruenspecht
acknowledges that a structural model
which allows new vehicle prices to
affect used vehicle scrappage only
through their effect on used vehicle
prices would be preferable, the data
available on used vehicle prices was
(and still is) limited. Instead he tested
his hypothesis in his 1981 dissertation
using new vehicle price and other
determinants of used car prices as a
275 Differentiated regulations are regulations
affecting segments of the market differently; here,
it references the fact that emission and fuel
economy standards have largely only applied to
new and not used vehicles.
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reduced form to approximate used car
scrappage in response to increasing fuel
economy standards.
Greenspan & Cohen (1996) offer
additional foundations from which to
think about vehicle stock and scrappage.
Their work identifies two types of
scrappage: Engineering scrappage and
cyclical scrappage. Engineering
scrappage represents the physical wear
on vehicles, which results in their being
scrapped. Cyclical scrappage represents
the effects of macroeconomic conditions
on the relative value of new and used
vehicles; under economic growth the
demand for new vehicles increases and
the value of used vehicles declines,
resulting in increased scrappage. In
addition to allowing new vehicle prices
to affect cyclical vehicle scrappage a` la
the Gruenspecht effect, Greenspan and
Cohen also note that engineering
scrappage seems to increase where EPA
emission standards also increase; as
more costs goes towards compliance
technologies, it becomes more
expensive to maintain and repair more
complicated parts, and scrappage
increases. In this way, Greenspan and
Cohen identify two ways that fuel
economy standards could affect vehicle
scrappage: (1) Through increasing new
vehicle prices, thereby increasing used
vehicle prices, and finally, reducing onroad vehicle scrappage, and (2) by
shifting resources towards fuel-saving
technologies—potentially reducing the
durability of new vehicles by making
them more complex.
(b) Aggregate vs. Atomic Data Source in
the Literature
One important distinction between
the literatures on vehicles scrappage is
between those that use atomic vehicle
data, data following specific individual
vehicles, and those that use some level
of aggregated data, data that counts the
total number of vehicles of a given type.
The decision to scrap a vehicle is an
atomic one—that is, made on an
individual vehicle basis. The decision
relates to the cost of maintaining a
vehicle, and the value of the vehicle
both on the used car market, and as
scrap metal. Generally, a used car owner
will decide to scrap a vehicle where the
value of the vehicle is less than the
value of the vehicle as scrap metal plus
the cost to maintain or repair the
vehicle. In other words, the owner gets
more value from scrapping the vehicle
than continuing to drive it or from
selling it.
Recent work is able to model
scrappage as an atomic decision due to
the availability of a large database of
used vehicle transactions. Following
works by other authors including:
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Busse, Knittel, & Zettelmeyer (2013);
Sallee, West, & Fan (2010); Alcott &
Wozny (2013); and Li, Timmins, & von
Haefen (2009)—Jacobsen & van Benthem
(2015) considers the impact of changes
in gasoline prices on used vehicle
values and scrappage rates. In turn, they
consider the impact of an increase in
used vehicle values on the scrappage
rate of those vehicles. They find that
increases in gasoline price result in a
reduction in the scrappage rate of the
most fuel efficient vehicles and an
increase in the scrappage rate of the
least fuel efficient vehicles. This has
important implications for the validity
of the average fuel economy values
linked to model years and assumed to
be constant over the life of that model
year fleet within this study. Future
iterations of this study could further
investigate the relationship between fuel
economy, vehicle usage, and scrappage,
as noted in other places in this
discussion.
While the decision to scrap a vehicle
is made atomically, the data available to
NHTSA on scrappage rates and
variables that influence these scrappage
rates are aggregate measures. This
influences the best available methods to
measure the impacts of new vehicle
prices on existing vehicle scrappage.
The result is that this study models
aggregate trends in vehicle scrappage
and not the atomic decisions that make
up these trends. Many other works
within the literature use the same data
source and general scrappage construct,
such as: Walker (1968); Park (1977),
Greene & Chen (1981); Gruenspecht
(1981); Gruenspecht (1982); Feeney &
Cardebring (1988); Greenspan & Cohen
(1996); Jacobsen & van Bentham (2015);
and Bento, Roth, & Zhuo (2016) all use
the same aggregate vehicle registration
data as the source to compute vehicle
scrappage.
Walker (1968) and Bento, Roth, &
Zhuo (2016) use aggregate data to
directly compute the elasticity of
scrappage from measures of used
vehicle prices. Walker (1968) uses the
ratio of used vehicle Consumer Price
Index (CPI) to repair and maintenance
CPI. Bento, Roth, & Zhuo (2016) use
used vehicle prices directly. While the
direct measurement of the elasticity of
scrappage is preferable in a theoretical
sense, the CAFE model does not predict
future values of used vehicles, only
future prices of new vehicles. For this
reason, any model compatible with the
current CAFE model must estimate a
reduced form similar to Park (1977);
Gruenspecht (1981); Greenspan & Cohen
(1996), who use some form of new
vehicle prices or the ratio of new
vehicle prices to maintenance and
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repair prices to impute some measure of
the effect of new vehicle prices on
vehicle scrappage.
(c) Historical Trends in Vehicle
Durability
Waker (1968); Park (1977); Feeney &
Cardebring (1988); Hamilton &
Macauley (1999); and Bento, Ruth, &
Zhuo (2016) all note that vehicles
change in durability over time. Walker
(1968) simply notes a significant
distinction in expected vehicle lifetimes
pre- and post-World War I. Park (1977)
discusses a ‘durability factor’ set by the
producer for each year so that different
vintages and makes will have varying
expected lifecycles. Feeney &
Cardebring (1988) show that durability
of vehicles appears to have generally
increased over time both in the U.S. and
Swedish fleets using registration data
from each country. They also note that
the changes in median lifetime between
the Swedish and U.S. fleet track well,
with a 1.5 year lag in the U.S. fleet. This
lag is likely due to variation in how the
data is collected—the Swedish vehicle
registry requires a title to unregister a
vehicle, and therefore gets immediate
responses, where the U.S. vehicle
registry requires re-registration, which
creates a lag in reporting.
Hamilton & Macauley (1999) argue for
a clear distinction between embodied
versus disembodied impacts on vehicle
longevity. They define embodied
impacts as inherent durability similar to
Park’s producer supplied ‘durability
factor’ and Greenspan’s ‘engineering
scrappage’ and disembodied effects
those which are environmental, not
unlike Greenspan and Cohen’s ‘cyclical
scrappage.’ They use calendar year and
vintage dummy variables to isolate the
effects—concluding that the
environmental factors are greater than
any pre-defined ‘durability factor.’ Some
of their results could be due to some
inflexibility of assuming model year
coefficients are constant over the life of
a vehicle, and there may be some
correlation between the observed life of
the later model years of their sample
and the ‘stagflation’ 276 of the 1970’s.
Bento, Ruth, & Zhuo (2016) find that the
average vehicle lifetime has increased
27% from 1969 to 2014 by sub-setting
their data into three model year cohorts.
To implement these findings in the
scrappage model incorporated into the
CAFE model, this study takes pains to
estimate the effect of durability changes
in such a way that the historical
durability trend can be projected into
the future; for this reason, a continuous
276 Continued high inflation combined with high
unemployment and slow economic growth.
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‘durability’ factor as a function of model
year vintage is included.
(d) Models of the Gruenspecht Effect
Used in Other Policy Analyses
This is not the first estimation of the
‘Gruenspecht Effect’ for policy
considerations. In their Technical
Support Document (TSD) for the 2004
proposal to reduce greenhouse gas
emissions from motor vehicles,
California Air Resources Board (CARB)
outlines how they utilized the CARBITS
vehicle transaction choice model in an
attempt to capture the effect of
increasing new vehicle prices on vehicle
replacement rates. They consider data
from the National Personal
Transportation Survey (NPTS) as a
source of revealed preferences and a
University of California (UC) study as a
source of stated preferences for the
purchase and sale of household fleets
under different prices and attributes
(including fuel economy) of new
vehicles.
The transaction choice model
represents the addition and deletion of
a vehicle from a household fleet within
a short period of time as a
‘‘replacement’’ of a vehicle, rather than
as two separate actions. Their final data
set consists of 790 vehicle replacements,
292 additions, and 213 deletions; they
do not include the deletions, but assume
any vehicle over 19 years old that is
sold is scrapped. This allows them to
capture a slowing of vehicle
replacement under higher new vehicle
prices, but because their model does not
include deletions, does not explicitly
model vehicle scrappage, but assumes
all vehicles aged 20 and older are
scrapped rather than resold. They
calibrate the model so that the overall
fleet size is benchmarked to Emissions
FACtors (EMFAC) fleet predictions for
the starting year; the simulation then
produces estimates that match the
EMFAC predictions without further
calibration.
The CARB study captures the effect
on new vehicle prices on the fleet
replacement rates and offers some
precedence for including some estimate
of the Gruenspecht Effect. One
important thing to note is that because
vehicles that exited the fleet without
replacement were excluded, the effect of
new vehicle prices on scrappage rates
where the scrapped vehicle is not
replaced is not captured. Because new
and used vehicles are substitutes, it is
expected that used vehicle prices will
increase with new vehicle prices.
Because higher used vehicle prices will
lower the number of vehicles whose
cost of maintenance is higher than their
value, it is expected that not only will
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replacements of used vehicles slow, but
also, that some vehicles that would have
been scrapped without replacement
under lower new vehicle prices will
now remain on the road because their
value will have increased. Aggregate
measures of the Gruenspecht effect will
include changes to scrappage rates both
from slower replacement rates, and
slower non-replacement scrappage rates.
(2) Description of Data Sources
NHTSA purchases proprietary data on
the registered vehicle population from
IHS/Polk for safety analyses. IHS/Polk
has annual snapshots of registered
vehicle counts beginning in calendar
year (CY) 1975 and continuing until
calendar year 2015. The data includes
the following regulatory classes as
defined by NHTSA: Passenger cars, light
trucks (classes 1 and 2a), and medium
and heavy-duty trucks (classes 2b and
3). Polk separates these vehicles into
another classification scheme: Cars and
trucks. Under their schema, pickups,
vans, and SUVs are treated as trucks,
and all other body styles are included as
cars. In order to build scrappage models
to support the model year (MY) 2021–
2026 light duty vehicle (LDV) standards,
it was important to separate these
vehicle types in a way compatible with
the existing CAFE model.
There were two compatible choices to
aggregate scrappage rates: (1) By
regulatory class or (2) by body style.
Because for NHTSA’s purposes vans/
SUVs are sometimes classified as
passenger cars and sometimes as light
trucks, and there was no quick way to
reclassify some SUVs as passenger cars
within the Polk dataset, NHTSA chose
to aggregate survival schedules by body
style. This approach is also preferable
because NHTSA uses body style specific
lifetime VMT schedules. Vehicles
experience increased wear with use;
many maintenance and repair events are
closely tied to the number of miles on
a vehicle. The current version of the
CAFE model considers separate lifetime
VMT schedules for cars, vans/SUVs,
pickups and classes 2b and 3 vehicles.
These vehicles are assumed to serve
different purposes and, as a result, are
modelled to have different average
lifetime VMT patterns. These different
uses likely also result in different
lifetime scrappage patterns.
Once stratified into body style level
buckets, the data can be aggregated into
population counts by vintage and age.
These counts represent the population
of vehicles of a given body style and
vintage in a given calendar year. The
difference between the counts of a given
vintage and vehicle type from one
calendar year to the next is assumed to
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represent the number of vehicles of that
vintage and type scrapped in a given
year. There were a couple other
important data considerations for the
calculations of the historical scrappage
rates not discussed here but discussed
in detail in the PRIA Chapter 8.277
For historical data on vehicle
transaction prices, the models use data
from the National Automobile Dealers
Association (NADA), which records the
average transaction price of all lightduty vehicles. These transaction prices
represent the prices consumers paid for
new vehicles but do not include any
value of vehicles that may have been
traded in to dealers. Importantly, these
transaction prices were not available by
vehicle body styles; thus, the models
will miss any unique trends that may
have occurred for a particular vehicle
body style. This may be particularly
relevant for pickup trucks, which
observed considerable average price
increases as luxury and high option
pickups entered the market. Future
models will further consider
incorporating price series that consider
the price trends for cars, SUVs and vans,
and pickups separately.278
The models use the NADA price
series rather than the Bureau of Labor
Statistics (BLS) New Vehicle Consumer
Price Index (CPI), used by Park (1977)
and Greenspan & Cohen (1997), because
the BLS New Vehicle CPI makes quality
adjustments to the new vehicle prices.
BLS assumes that additions of safety
and fuel economy equipment are a
quality adjustment to a vehicle model,
which changes the good and should not
be represented as an increase in its
price. While this is good for some
purposes, it presumes consumers fully
value technologies that improve fuel
economy. Because it is the purpose to
this study to measure whether this is
true, it is important that vehicle prices
adjusted to fully value fuel economy
improving technologies, which would
obscure the ability to measure the
277 The first is any discontinuity caused by a
change in how Polk collected their data beginning
in calendar year 2010, and the second is the use of
the adjustment described in Greenspan & Cohen
(1996).
278 Note: Using historical data aggregated by body
styles to capture differences in price trends by body
style does not require the assertion technology costs
are or are not borne by the body style to which they
are applied. If the body-style level average price
change is used, then the assumption is
manufacturers do not cross-subsidize across body
styles, whereas if the average price change is used
then the assumption is they would proportion costs
equally for each vehicle. These are implementation
questions to be worked out once NHTSA has a
historical data source separating price series by
body styles, but these do not matter in the current
model which only considers the average price of all
light-duty vehicles.
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preference for more fuel efficient and
expensive new vehicles, are not used.
As further justification for using the
NADA price series over the BLS New
Vehicle CPI, Park (1977) cites a
discontinuity found in the amount of
quality adjustments made to the series
so that more adjustments are made over
time. This could further limit the ability
for the BLS New Vehicle CPI to predict
changes in vehicle scrappage.
Vehicle scrappage rates are also
influenced by fuel economy and fuel
prices. Historical data on the fuel
economy by vehicle style from model
years 1979–2016 was obtained from the
2016 EPA Motor Trends Report.279 The
van/SUV fuel economy values represent
a sales-weighted harmonic average of
the individual body styles. Fuel prices
were obtained from Department of
Energy (DOE) historical values, and
future fuel prices within the CAFE
model use the Annual Energy Outlook
(AEO) future oil price projections.280
From these values the average cost per
100 miles of travel for the cohort of new
vehicles in a given calendar year and
the average cost per 100 miles of travel
for each used model year cohort in that
same calendar year are computed.281 It
is expected that as the new vehicle fleet
becomes more efficient (holding all
other attributes constant) that it will be
more desirable, and the demand for
used vehicles should decrease
(increasing their scrappage). As a given
model year cohort becomes more
expensive to operate due to increases in
fuel prices, it is expected the scrappage
of that model year will increase. It is
perhaps worth noting that more efficient
model year vintages will be less
susceptible to changes in fuel prices, as
279 Light-Duty Automotive Technology, Carbon
Dioxide Emissions, and Fuel Economy Trends: 1975
Through 2016, U.S. EPA (Nov. 2016), available at
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=
P100PKK8.pdf.
280 Note: The central analysis uses the AEO
reference fuel price case, but sensitivity analysis
also considers the possibility of AEO’s low and high
fuel price cases.
281 Work by Jacobsen and van Bentham suggests
that these initial average fuel economy values may
not represent the average fuel economy of a model
year cohort as it ages—mainly, they find that the
most fuel efficient vehicles scrap earlier than the
least fuel efficient models in a given cohort. This
may be an important consideration in future
endeavors that work to link fuel economy, vehicle
miles travelled (VMT), and scrappage. Studies on
‘‘the rebound effect’’ suggest that lowering the fuel
cost per driven mile increases the demand for VMT.
With more miles, a vehicle will be worth less as its
perceived remaining useful life will be shorter; this
will result in the vehicle being more likely to be
scrapped. A rebound effect is included in the CAFE
model, but because reliable data on how average
VMT by age has varied over calendar year and
model year vintage is not available, expected
lifetime VMT is not included within the current
dynamic scrappage model.
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(3) Summary of Model Estimation
The most predictive element of
vehicle scrappage is what Greenspan
and Cohen deem ‘engineering
scrappage.’ This source of scrappage is
largely determined by the age of a
vehicle and the durability of a specific
model year vintage. Vehicle scrappage
typically follows a roughly logistic
function with age—that is,
instantaneous scrappage increases to
some peak, and then declines, with age
as noted in Walker (1968); Park (1977);
Greene & Chen (1981); Gruenspecht
(1981); Feeney & Cardebring (1988);
Greenspan & Cohen (1996); Hamilton &
Macauley (1999); and Bento, Roth, &
Zhuo (2016). Thus, this analysis also
uses a logistic function to capture this
trend of vehicle scrappage with age but
allows non-linear terms to capture any
skew to the logistic relationship.
Specific details about the final and
considered forms of engineering
scrappage by body styles is presented in
the PRIA Chapter 8.
The final and considered independent
variables intended to capture cyclical
elements of vehicle scrappage and the
considered forms of each are discussed
in PRIA Chapter 8; here only inclusion
of the GDP growth rate is discussed. The
GDP growth rate is not a single-period
effect; both the current and previous
GDP growth rates will affect vehicle
scrappage rates. A single year increase
will affect scrappage differently than a
multi-period trend. For this reason, an
optimal number of lagged terms are
included: The within-period GDP
growth rate, the previous period GDP
growth rate, and the growth rate from
two prior years for the car model, while
for vans/SUVs, and pickups, the current
and previous period GDP growth rate
are sufficient.
Similarly, the considered model
allows that one-period changes in new
vehicle prices will affect the used
vehicle market differently than a
consistent trend in new vehicle prices.
The optimal number of lags is three so
that the price trend from the current
year and the three prior years influences
the demand for and scrappage of used
vehicles. Note: The average lease length
is three years 283 so that the price of an
average vehicle coming off lease is
estimated to affect the scrappage rate of
used vehicles—this is a major source of
the newest used vehicles that enter the
used car fleet. Further, because
increases in new vehicle prices due to
increased stringency of CAFE standards
is the primary mechanism through
which CAFE standards influence
vehicle scrappage and the CAFE Model
assumes that usage, efficiency, and
safety vary with the age of the vehicle,
particular attention is paid to the form
of this effect. It is important to know the
likelihood of scrappage by the age of the
vehicle to correctly account for the
additional costs of additional fatalities
and increased fuel consumption from
deferred scrappage. Thus, the influence
of increasing new vehicle prices is
allowed to influence the demand for
used vehicles (and reduce their
scrappage) differently for different ages
of vehicles in the scrappage model. We
discuss both how we determined the
correct form and number of lags for each
body style in PRIA Chapter 8.
The final cyclical factor affecting
vehicle scrappage in the preferred
model is the cost per 100 miles of travel
both of new vehicles and of the vehicle
which is the subject of the decision to
scrap or not to scrap. The new vehicle
cost per 100 miles is defined as the ratio
of the average fuel price faced by new
vehicles in a given calendar year and
the average new vehicle fuel economy
for 100 miles in the same calendar year,
and varies only with calendar year:
The cost per 100 miles of the
potentially scrapped vehicle is
described as the ratio of the average fuel
price faced by that model year vintage
in a given calendar year and the average
fuel economy for 100 miles of travel for
that model year when it was new, and
varies both with calendar year and
model year:
282 The 2017 Annual Report of the Board of
Trustees of the Federal Old-Age and Survivors
Insurance and Federal Disability Insurance Trust
Funds, Social Security Administration (2017),
available at https://www.ssa.gov/oact/tr/2017/
tr2017.pdf.
283 See e.g., Edmunds January 2017 Lease Market
Report, Edmunds (Jan. 2017), https://
dealers.edmunds.com/static/assets/articles/leasereport-jan-2017.pdf.
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absolute changes in their cost per mile
will be smaller. The functional forms of
the cost per mile measures are further
discussed in the model specification
subsection 3 below.
Aggregate measures that cyclically
affect the value of used vehicles include
macroeconomic factors like the real
interest rate, the GDP growth rate,
unemployment rates, cost of
maintenance and repairs, and the value
of a vehicle as scrap metal or as parts.
Here only the GDP growth rate is
discussed, as this is the only measure
included in the final model. Extended
reasoning as to why other variables are
not included in the final model in the
PRIA Chapter 8 is offered, but the
discussion was omitted here for brevity
in describing only the final model.
Generally economic growth will result
in a higher demand for new vehicles—
cars in aggregate are normal goods—and
a reduction in the value of used
vehicles. The result should be an
increase in the scrappage rate of existing
vehicles so that we expect the GDP
growth rate to be an important predictor
of vehicle scrappage rates.
NHTSA sourced the GDP growth rate
from the 2017 OASDI Trustees
Report.282 The Trustees Report offers
credible projections beyond 2032.
Because the purpose of building this
scrappage model is to project vehicle
survival rates under different fuel
economy alternatives and the current
fuel economy projections go as far
forward as calendar year 2032, using a
data set that encompasses projections at
least through 2032 is an essential
characteristic of any source used for this
analysis.
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The average per-gallon fuel price
faced by a model year vintage in a given
calendar year is the annual average fuel
price of all fuel types present in that
model year fleet for the given calendar
year, weighted by the share of each fuel
type in that model year fleet. Or the
following, where FT represents the set
of fuel types present in a given model
year vintage:
For these variables, the best fit model
includes the cost per mile of both the
new and the used vehicle for the current
and prior year. This is congruent with
research that suggests consumers
respond to current fuel prices and fuel
price changes. The selection process of
this form for the cost per mile and the
implications is discussed in PRIA
Chapter 8.
There are a couple other controlling
factors considered in our final model.
The 2009 Car Allowance Rebate System
(CARS) is not outlined here but is
outlined in PRIA Chapter 8. This
program aimed to accelerate the
retirement of less fuel efficient vehicles
and replace them with more fuel
efficient vehicles. Further discussion of
how this is controlled for is located in
PRIA Chapter 8. Finally, evidence of
autocorrelation was found, and
including three lagged values of the
dependent variable addresses the
concern. Treatment of autocorrelation is
discussed in PRIA Chapter 8.
One additional issue encountered in
the estimations of scrappage rates is that
the models predict too many vehicles
remain on the road in the later years.
This issue occurs because the data
beyond age 15 are progressively more
sparsely populated; vehicles over 15
years were not captured in the Polk data
until 1994, when each successive
collection year added an additional age
of vehicles until 2005 when all ages
began to be collected. This means that
for vehicles over the age of 25 there are
only 10 years of data. In order to correct
for this issue the fact that the final fleet
share converges to roughly the same
share for most model years for a given
vehicle type is used. The predicted
versus historical relationships seem to
deviate beginning around age 20; thus,
for scrappage rates for vehicles beyond
age 20 an exponential decay function
which guarantees that by age 40 the
final fleet share reaches the convergence
level observed in the historical data is
applied. The application of the decay
function and mathematical definition is
further defended in PRIA Chapter 8.
A sensitivity case is also developed to
isolate the magnitude of the
Greunspecht effect. The impacts on
costs and benefits are presented in
section VII.H.1 of this document. In
order to isolate the effect, the price of
new vehicles is held constant at CY
2016 levels. The specific methodology
used to do so is described in detail in
PRIA Chapter 8, as is the leakage
implied by comparing the reference and
no Gruenspecht effect sensitivity cases.
It is important to note here that the
leakage calculated ranges between 12
and 18% across regulatory alternatives.
This is in line with Jacobsen & van
Bentham (2015) estimates which put
leakage for their central case between 13
and 16%. Their high gasoline price case
is more in line this analysis’ central
case—with fuel prices of $3/gallon—and
predicts leakage of 21%. This further
validates the scrappage model effects
against examples in the literature.
The models used for this analysis are
able to capture the relationship for
vehicle scrappage as it varies with age
and how this relationship changes with
increases to new vehicle price, the cost
per mile of travel of new and used
vehicles, and how the rate varies
cyclically with the GDP growth rate. It
also controls for the CARS program and
checks the influence of a change in
Polk’s data collection procedures. The
goodness of fit measures and the
plausibility of the predictions of the
model are discussed at some length in
PRIA Chapter 8. In the next section, the
impacts of updating the static scrappage
models to the dynamic models on
average vehicle age and usage, by body
styles, and across different regulatory
assumptions are discussed.
increase. However, given the
distribution of the mileage
accumulation schedule by age, this
amounts only to a two percent increase
in the expected lifetime mileage
accumulation of an individual vehicle.
This range is consistent with DOT
expectations in terms of direction and
magnitude.
The use of a static retirement
schedule, while deemed a reasonable
approach in the past, is a limited
representation of scrappage behavior. It
fails to account for increasing vehicle
durability—occurring for the last several
decades—and the resulting increase in
average vehicle age in the on-road fleet,
which has nearly doubled since 1980.284
Thus, turning off the dynamic scrappage
model described above would not
impose a perspective on the analysis
that is neutral with respect to observed
scrappage behavior but would instead
represent a strong assumption that
asserts important trends in the historical
record will abruptly cease or change
direction.
As discussed above, the dynamic
scrappage model implemented to
support this proposal affects total fleet
size through several mechanisms.
Although the model accounts for the
influence of changes to average new
vehicle price and U.S. GDP growth, the
most influential mechanism, by far, is
the observed trend of increasing vehicle
durability over successive model years.
This phenomenon is prominently
discussed in the academic literature
related to vehicle retirement, where
there is no disagreement about its
existence or direction.285 In fact, when
the CAFE model is exercised in a way
that keeps average new vehicle prices at
(approximately) MY 2016 levels, the onroad fleet grows from an initial level of
228 million in 2016 to 340 million in
2050, an increase of 49% over the 35year period from 2016 to 2050.
The historical data show the size of
the registered vehicle population (i.e.,
the on-road fleet) growing by about 60%
in the 35 years between 1980 and
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(c) What is the estimated effect on
vehicle retirement and how do results
compare to previously estimated fleets
and VMT?
The expected lifetime of a car
estimated using the static scrappage
schedule from the 2012 final rule, both
in years and miles, is between the
expected lifetime of the dynamic
scrappage model in the absence of CAFE
standards and under the baseline
standards. Estimated by the dynamic
scrappage model, the average vehicle is
expected to live 15.1 years under the
influence of only market demand for
new technology, and 15.6 years under
the baseline scenario, a four percent
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284 Based
on data from FHWA and IHS/Polk.
(1968); Park (1977); Feeney &
Cardebring (1988); Hamilton & Macauley (1999);
and Bento, Ruth, & Zhuo (2016) note that vehicles
change in durability over time.
285 Waker
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2015.286 In the 35 years between 2016
and 2050, our simulation shows the onroad fleet growing from about 230
million vehicles to about 345 million
vehicles when the market adopts only
the amount of fuel economy, which it
naturally demands. The simulated
growth over this period is about 50%
from today’s level, rather than the 60%
observed in the historical data over the
last 35 years. Under the baseline
regulatory scenario, the growth over the
next 35 years is simulated to be about
54%—still short of the observed growth
over a comparable period of time. In
fact, the simulated annual growth rate in
the size of the on-road fleet in this
analysis, about 1.3%, is lower than the
long-term average annual growth rate of
about two percent dating back to the
1970s.287
Additionally, there are inherent
precision limitations in measuring
something as vast and complex as the
registered vehicle population. For
decades, the two authoritative sources
for the size of the on-road fleet have
been R.L. Polk (now IHS/Polk) and
FHWA. For two decades these two
sources differed by more than 10% each
year, only lately converging to within a
few percent of each other. These
discrepancies over the correct
interpretation of the data by each source
have consistently represented
differences of more than 10 million
vehicles.
The total number of new vehicles
projected to enter the fleet is slightly
higher than the historical trend (though
the impact of the great recession makes
it hard to say by how much). More
generally, the projections used in the
analysis cover long periods of time
without exhibiting the kinds of
fluctuation that are present in the
historical record. For example, the
forecast of GDP growth in our analysis
posits a world in which the United
States sees uninterrupted positive
annual growth in real GDP for four
decades. The longest such period in the
historical record is 17 years and still
included several years of low (but
positive) growth during that interval.
Over such a long period of time, in
the absence of deep insight into the
future of the U.S. auto industry, it is
sensible to assume that the trends
286 There are two measurements of the size of the
registered vehicle population that are considered to
be authoritative. One is produced by the Federal
Highway Administration, and the other by R.L. Polk
(now part of IHS). The Polk measurement shows
fleet growth between 1980 and 2015 of about 85%,
while the FHWA measurement shows a slower
growth rate over that period, only about 60%.
287 Based on calculations using Polk’s National
Vehicle Population Profile (NVPP).
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observed over the course of decades are
likely to persist. Analyzing fuel
economy standards requires an
understanding of the mechanisms that
influence new vehicle sales, the size of
the on-road fleet, and vehicle miles
traveled. It is upon these mechanisms
that the policy acts: Increasing/
decreasing new vehicle prices changes
the rate at which new vehicles are sold,
changing the attributes and prices of
these vehicles influences the rates at
which all used vehicles are retired, the
overall size of the on-road fleet
determines the total amount of VMT,
which in turn affects total fuel
consumption, fatalities, and other
externalities. The fact that DOT’s
bottom-up approach produces results in
line with historical trends is both
expected and intended.
This is not to say that all details of
this new approach will be immediately
intuitive for reviewers accustomed to
results that do not include a dynamic
sales model or dynamic scrappage
model, much less results that combine
the two. For example, some reviewers
may observe that today’s analysis shows
that, compared to the baseline
standards, the proposed standards
produce a somewhat smaller on-road
fleet (i.e., fewer vehicles in service)
despite somewhat increased sales of
new vehicles (consistent with reduced
new vehicle prices) and decreased
prices for used vehicles. While it might
be natural to assume that reduced prices
of new vehicles and increased sales
should lead to a larger on-road fleet, in
our modelling, the increased sales are
more than offset by the somewhat
accelerated scrappage that accompanies
the estimated decrease in new vehicle
prices. This outcome represents an onroad fleet that is both smaller and a little
younger on average (relative to the
baseline) and ‘‘turns over’’ more
quickly.
To further test the validity of the
scrappage model, a dynamic forecast
was constructed for calendar years 2005
through 2015 to see how well it predicts
the fleet size for this period. The last
true population the scrappage model
‘‘sees’’ is the 2005 registered vehicle
population. It then takes in known
production volumes for the new model
year vehicles and dynamically estimates
instantaneous scrappage rates for all
registered vehicles at each age for CYs
2006–2015, based only on the observed
exogenous values that inform the model
(GDP growth rate, observed new vehicle
prices, and cost per mile of operation),
fleet attributes of the vehicles (body
style, age, cost per mile of operation),
and estimated scrappage rates at earlier
ages. Within this exercise, the scrappage
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model relies on its own estimated
values as the previous scrappage rates at
earlier ages, forcing any estimation
errors to propagate through to future
years. This exercise is discussed further
in PRIA Chapter VII. While the years of
the recession represent a significant
shock to the size of the fleet, briefly
reversing many years of annual growth,
the model recovers quickly and
produces results within one percent of
the actual fleet size, as it did prior to the
recession.
In order to compare the magnitudes of
the sales and scrappage effects across
different fuel economy standards
considered it is important to define
comparable measures. The sales effect
in a single calendar year is simply the
difference in new vehicle sales across
alternatives. However, the scrappage
effect in a single calendar year is not
simply the change in fleet size across
regulatory alternatives. The scrappage
model predicts the probability that a
vehicle will be scrapped in the next year
conditional on surviving to that age; the
absolute probability that a vehicle
survives to a given age is conditional on
the scrappage effect for all previous
analysis years. In other words, if
successive calendar years observe lower
average new vehicle prices, the effect of
increased scrappage on fleet size will
accumulate with each successive
calendar year—because fewer vehicles
survived to previous ages, the same
probability of scrappage would result in
a smaller fleet size for the following year
as well, though fewer vehicles will have
been scrapped than in the previous year.
To isolate the number of vehicles not
scrapped in a single calendar year
because of the change in standards, the
first step is to calculate the number of
vehicles scrapped in every calendar year
for both the proposed standards and the
baseline; this is calculated by the interannual change in the size of the used
vehicle fleet (vehicles ages 1–39) for
each alternative. The difference in this
measure across regulatory alternatives
represents the change in vehicle
scrappage because of a change in the
standards. The resulting scrappage
effect for a single calendar year can be
compared to the difference across
regulatory alternatives in new vehicle
sales for the same calendar year as a
comparison of the relative magnitudes
of the two effects. In most years, under
the proposed standards relative to the
baseline standards, the analysis shows
that for each additional new vehicles
sold, two to four used vehicles are
removed from the fleet. Over the time
period of the analysis these predicted
differences in the numbers of vehicles
accumulate, resulting in a maximum of
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seven million fewer vehicles by CY
2033 for the proposed CAFE standards
relative to the augural standards, and
nine million fewer vehicles by CY 2035
for the proposed GHG standards relative
to the current GHG standards. Tables
11–29 and 11–30 in the PRIA show the
difference in the fleet size by calendar
year for the proposed standards relative
to the augural standards for the CAFE
and GHG programs, respectively.
To understand why the sales and
scrappage effects do not perfectly offset
each other to produce a constant fleet
size across regulatory alternatives it is
important to remember that the decision
to buy a new vehicle and the decision
to scrap a used vehicle are often not
made by the same household as a joint
decision. The average length of initial
ownership for new vehicles is
approximately 6.5 years (and increasing
over time). Cumulative scrappage up to
age seven is typically less than 10%of
the initial fleet. This suggests that most
vehicles belong to more than one
household over the course of their
lifetimes. The household that is
deciding whether or not to purchase a
new vehicle is rarely the same
household deciding whether or not to
scrap a vehicle. So a vehicle not
scrapped in a given year is seldom the
direct substitute for a new vehicle
purchased by that household.
Considering this, it is not expected that
for every additional vehicle scrapped,
there is also an additional new one sold,
under the proposed standards relative to
the baseline standards.
Further, while sales and scrappage
decisions are both influenced by
changes in new vehicle prices, the
mechanism through which these
decisions change are different for the
two effects. A decrease in average new
vehicle prices will directly increase the
demand for new vehicles along the same
demand curve. This decrease in new
vehicle prices will cause a substitution
towards new vehicles and away from
used vehicles, shifting the entire
demand curve for used vehicles
downwards. This will decrease both the
equilibrium prices of used vehicles, as
shown in Figure 8–16 of the PRIA. Since
the decision to scrap a vehicle in a given
year is closely related to the difference
between the vehicle’s value and the cost
to maintain it, if the value of a vehicle
is lower than the cost to maintain it, the
current owner will not choose to
maintain the vehicle for their own use
or for resale in the used car market, and
the vehicle will be scrapped. That is, a
current owner will only supply a
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vehicle to the used car market if the
price of the vehicle is greater than the
cost of supplying it. Lowering the
equilibrium price of used vehicles will
lower the increase the number of
scrapped vehicles, lowering the supply
of used vehicles, and decreasing the
equilibrium quantity. The change in
new vehicle sales is related to demand
of new vehicles at a given price, but the
change in used vehicle scrappage is
related to the shift in the demand curve
for used vehicles, and the resulting
change in the quantity current owners
will supply; these effects are likely not
exactly offsetting.
Our models indicate that the ratio of
the magnitude of the scrappage effect to
the sales effect is greater than one so
that the fleet grows under more
stringent scenarios. However, it is
important to remember that not all
vehicles are driven equally; used
vehicles are estimated to deliver
considerably less annual travel than
new vehicles. Further, used vehicles
only have a portion of their original life
left so that it will take more than one
used vehicle to replace the full lifetime
of a new vehicle, at least in the longrun. The result of the lower annual VMT
and shorter remaining lifetimes of used
vehicles, is that although the fleet is
1.5% bigger in CY 2050 for the augural
baseline than it is for the proposed
standards, the total non-rebound VMT
for CY 2050 is 0.4% larger in the
augural baseline than in the proposed
standards. This small increase in VMT
is consistent with a larger fleet size; if
more used vehicles are supplied, there
likely is some small resulting increase
in VMT.
Our models face some limitations,
and work will continue toward
developing methods for estimating
vehicle sales, scrappage, and mileage
accumulation. For example, our
scrappage model assumes that the
average VMT for a vehicle of a
particular vintage is fixed—that is, aside
from rebound effects, vehicles of a
particular vintage drive the same
amount annually, regardless of changes
to the average expected lifetimes. The
agencies seek comment on ways to
further integrate the survival and
mileage accumulation schedules. Also,
our analysis uses sales and scrappage
models that do not dynamically interact
(though they are based on similar sets of
underlying factors); while both models
are informed by new vehicle prices, the
model of vehicle sales does not respond
to the size and age profile of the on-road
fleet, and the model of vehicle
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scrappage rates does not respond to the
quantity of new vehicles sold. As one
potential option for development, the
potential for an integrated model of
sales and scrappage, or for a dynamic
connection between the two models will
be considered. Comment is sought on
both the sales and scrappage models, on
potential alternatives, and on data and
methods that may enable practicable
integration of any alternative models
into the CAFE model.
7. Accounting for the Rebound Effect
Caused by Higher Fuel Economy
(a) What is the rebound effect and how
is it measured?
Amending and establishing fuel
economy and GHG standards at a lesser
stringency than the augural standards
for future model years will lead to
comparatively lower fuel economy for
new cars and light trucks, thus
increasing the amount of fuel they
consume in traveling each mile than
they would under the augural standard.
The resulting increase in their per-mile
fuel and total driving costs will lead to
a reduction in the number of miles they
are driven each year over their lifetimes,
and example of the rebound effect that
is usually associated with energy
efficiency improvements working in
reverse. The fuel economy rebound
effect—a specific example of the energy
efficiency rebound effect for the case of
motor vehicles—refers to the welldocumented tendency of vehicles’ use
to increase when their fuel economy is
improved and the cost of driving each
mile declines as a result.
(b) What does the literature say about
the magnitude of this effect?
Table–II–43 summarizes estimates of
the fuel economy rebound effect for
light-duty vehicles from studies
conducted through 2008, when the
agencies originally surveyed research on
this subject.288 After summarizing all of
the estimates reported in published and
other publicly-available research
available at that time, it distinguishes
among estimates based on the type of
data used to develop them. As the table
reports, estimates of the rebound effect
ranged from 6% to as high as 75%, and
the range spanned by published
estimates was nearly as wide (7–75%).
288 Complete references to the studies
summarized in Table 8–2 are included in the PRIA,
and many of the unpublished studies are available
in the docket for this rulemaking.
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Most studies reported more than one
empirical estimate, and the authors of
published studies typically identified
the single estimate in which they were
most confident; these preferred
estimates spanned only a slightly
narrower range (9–75%).
Despite their wide range, these
estimates displayed a strong central
tendency, as Table–II–43 also shows.
The average values of all estimates,
those that were published, and authors’
preferred estimates from published
studies were 22–23%, and the median
estimates in each category were close to
these values, indicating nearly
symmetric distributions. The estimates
in each category also clustered fairly
tightly around their respective average
values, as shown by their standard
deviations in the table’s last column.
When classified by the type of data they
relied on, U.S. aggregate time-series data
produced slightly smaller values
(averaging 18%) than did panel-type
data for individual states (23%) or
household survey data (25%). In each
category, the median estimate was again
quite close to the average reported
value, and comparing the standard
deviations of estimates based on each
type of data again suggests a fairly tight
scatter around their respective means.
Of these studies, a then recentlypublished analysis by Small & Van
Dender (2007), which reported that the
rebound effect appeared to be declining
over time in response to increasing
income of drivers, was singled out.
These authors theorized that rising
income increased the opportunity cost
of drivers’ time, leading them to be less
responsive over time to reductions in
the fuel cost of driving each mile. Small
and Van Dender reported that while the
rebound effect averaged 22% over the
entire time period they analyzed (1967–
2001), its value had declined by half—
or to 11%—during the last five years
they studied (1997–2001). Relying
primarily on forecasts of its continued
decline over time, the analysis reduced
the 20% rebound effect that NHTSA
used to analyze the effects of CAFE
standards for light trucks produced
during model years 2005–07 and 2008–
11 to 10% for their analysis of CAFE
and GHG standards for MY 2012–16
passenger cars and light trucks.
Table–II–44 summarizes estimates of
the rebound effect reported in research
that has become available since the
agencies’ original survey, which
extended through 2008, and the
following discussion briefly summarizes
the approaches used by these more
recent studies. Bento et al. (2009)
combined demographic characteristics
of more than 20,000 U.S. households,
the manufacturer and model of each
vehicle they owned, and their annual
usage of each vehicle from the 2001
National Household Travel Survey with
detailed data on fuel economy and other
attributes for each vehicle model
obtained from commercial publications.
The authors aggregated vehicle models
into 350 categories representing
combinations of manufacturer, vehicle
type, and age, and use the resulting data
to estimate the parameters of a complex
model of households’ joint choices of
the number and types of vehicles to
own, and their annual use of each
vehicle.
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Bento et al. estimate the effect of
vehicles’ operating costs per mile,
including fuel costs, which depend in
part on each vehicle’s fuel economy, as
well as maintenance and insurance
expenses, on households’ annual use of
each vehicle they own. Combining the
authors’ estimates of the elasticity of
vehicle use with respect to per-mile
operating costs with the reported
fraction of total operating costs
accounted for by fuel (slightly less than
one-half) yields estimates of the
rebound effect. The resulting values
vary by household composition, vehicle
size and type, and vehicle age, ranging
from 21 to 38%, with a composite
estimate of 34% for all households,
vehicle models, and ages. The smallest
values apply to new luxury cars, while
the largest estimates are for light trucks
and households with children, but the
implied rebound effects differ little by
vehicle age.
Barla et al. (2009) analyzed the
responses of car and light truck
ownership, vehicle travel, and average
fuel efficiency to variation in fuel prices
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and aggregate economic activity
(measured by gross product) using
panel-type data for the 10 Canadian
provinces over the period from 1990
through 2004. The authors estimated a
system of equations for these three
variables using statistical procedures
appropriate for models where the
variables of interest are simultaneously
determined (that is, where each variable
is one of the factors explaining variation
in the others). This procedure enabled
them to control for the potential
‘‘reverse influence’’ of households’
demand for vehicle travel on their
choices of how many vehicles to own
and their fuel efficiency levels when
estimating the effect of variation in fuel
efficiency on vehicle use.
Their analysis found that provinciallevel aggregate economic activity had
moderately strong effects on car and
light truck ownership and use but that
fuel prices had only modest effects on
driving and the average fuel efficiency
of the light-duty vehicle fleet. Each of
these effects became considerably
stronger over the long term than in the
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year when changes in economic activity
and fuel prices initially occurred, with
three to five years typically required for
behavioral adjustments to stabilize.
After controlling for the joint
relationship among vehicle ownership,
driving demand, and the fuel efficiency
of cars and light trucks, Barla et al.
estimated elasticities of average vehicle
use with respect to fuel efficiency that
corresponded to a rebound effect of
eight percent in the short run, rising to
nearly 20% within five years. A notable
feature of their analysis was that
variation in average fuel efficiency
among the individual Canadian
provinces and over the time period they
studied was adequate to identify its
effect on vehicle use, without the need
to combine it with variation in fuel
prices in order to identify its effect.
Wadud et al. (2009) combine data on
U.S. households’ demographic
characteristics and expenditures on
gasoline over the period 1984–2003
from the Consumer Expenditure Survey
with data on gasoline prices and an
estimate of the average fuel economy of
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vehicles owned by individual
households (constructed from a variety
of sources). They employ these data to
explore variation in the sensitivity of
individual households’ gasoline
consumption to differences in income,
gasoline prices, the number of vehicles
owned by each household, and their
average fuel economy. Using an
estimation procedure intended to
account for correlation among
unmeasured characteristics of
households and among estimation errors
for successive years, the authors explore
variation in the response of fuel
consumption to fuel economy and other
variables among households in different
income categories and between those
residing in urban and rural areas.
Dividing U.S. households into five
equally-sized income categories, Wadud
et al. estimate rebound effects ranging
from 1–25%, with the smallest estimates
(8% and 1%) for the two lowest income
categories, and significantly larger
estimates for the middle (18%) and two
highest income groups (18 and 25%). In
a separate analysis, the authors estimate
rebound effects of seven percent for
households of all income levels residing
in U.S. urban areas and 21% for rural
households.
West & Pickrell (2011) analyzed data
on more than 100,000 households and
300,000 vehicles from the 2009
Nationwide Household Transportation
Survey to explore how households
owning multiple vehicles chose which
of them to use and how much to drive
each one on the day the household was
surveyed. Their study focused on how
the type and fuel economy of each
vehicle a household owned, as well as
its demographic characteristics and
location, influenced household
members’ decisions about whether and
how much to drive each vehicle. They
also investigated whether fuel economy
and fuel prices exerted similar
influences on vehicle use, and whether
households owning more than one
vehicle tended to substitute use of one
for another—or vary their use of all of
them similarly—in response to
fluctuations in fuel prices and
differences in their vehicles’ fuel
economy.
Their estimates of the fuel economy
rebound effect ranged from as low as
nine percent to as high as 34%, with
their lowest estimates typically applying
to single-vehicle households and their
highest values to households owning
three or more vehicles. They generally
found that differences in fuel prices
faced by households who were surveyed
on different dates or who lived in
different regions of the U.S. explained
more of the observed variation in daily
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vehicle use than did differences in
vehicles’ fuel economy. West and
Pickrell also found that while the
rebound effect for households’ use of
passenger cars appeared to be quite
large—ranging from 17% to nearly twice
that value—it was difficult to detect a
consistent rebound effect for SUVs.
Anjovic & Haas (2012) examined
variation in vehicle use and fuel
efficiency among six European nations
over an extended period (1970–2006),
using an elaborate model and estimation
procedure intended to account for the
existence of common underlying trends
among the variables analyzed and thus
avoid identifying spurious or
misleading relationships among them.
The six nations included in their
analysis were Austria, Germany,
Denmark, France, Italy, and Sweden; the
authors also conducted similar analyses
for the six nations combined. The
authors focused on the effects of average
income levels, fuel prices, and the fuel
efficiency of each nation’s fleet of cars
on the total distance they were driven
each year and their total fuel energy
consumption. They also tested whether
the responses of energy consumption to
rising and falling fuel prices appeared to
be symmetric in the different nations.
Anjovic and Haas report a long-run
aggregate rebound effect of 44% for the
six nations their study included, with
corresponding values for individual
nations ranging from a low of 19% (for
Austria) to as high as 56% (Italy). These
estimates are based on the estimated
response of vehicle use to variation in
average fuel cost per kilometer driven in
each of the six nations and for their
combined total. Other information
reported in their study, however,
suggests lower rebound effects; their
estimates of the response of total fuel
energy consumption to fuel efficiency
appear to imply an aggregate rebound
effect of 24% for the six nations, with
values ranging from as low as 0–3% (for
Austria and Denmark) to as high as 70%
(Sweden), although the latter is very
uncertain. These results suggest that
vehicle use in European nations may be
somewhat less sensitive to variation in
driving costs caused by changes in fuel
efficiency than to changes in driving
costs arising from variation in fuel
prices, but they find no evidence of
asymmetric responses of total fuel
consumption to rising and falling prices.
Using data on household characteristics
and vehicle use from the 2009
Nationwide Household Transportation
Survey (NHTS), Su (2012) analyzes the
effects of locational and demographic
factors on household vehicle use and
investigates how the magnitude of the
rebound effect varies with vehicles’
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annual use. Using variation in the fuel
economy and per-mile cost of and
detailed controls for the demographic,
economic, and locational characteristics
of the households that owned them (e.g.,
road and population density) and each
vehicle’s main driver (as identified by
survey respondents), the author
employs specialized regression methods
to capture the variation in the rebound
effect across 10 different categories of
vehicle use.
Su estimated the overall rebound
effect for all vehicles in the sample
averaged 13%, and that its magnitude
varied from 11–19% among the 10
different categories of annual vehicle
use. The smallest rebound effects were
estimated for vehicles at the two
extremes of the distribution of annual
use—those driven comparatively little,
and those used most intensively—while
the largest estimated effects applied to
vehicles that were driven slightly more
than average. Controlling for the
possibility that high-mileage drivers
respond to the increased importance of
fuel costs by choosing vehicles that offer
higher fuel economy narrowed the range
of Su’s estimated rebound effects
slightly (to 11–17%), but did not alter
the finding that they are smallest for
lightly- and heavily-driven vehicles and
largest for those with slightly above
average use.
Linn (2013) also uses the 2009 NHTS
to develop a linear regression approach
to estimate the relationship between the
VMT of vehicles belonging to each
household and a variety of different
factors: Fuel costs, vehicle
characteristics other than fuel economy
(e.g., horsepower, the overall ‘‘quality’’
of the vehicle), and household
characteristics (e.g., age, income). Linn
reports a fuel economy rebound effect
with respect to VMT of between 20–
40%.
One interesting result of the study is
that when the fuel efficiency of all
vehicles increases, which would be the
long-run effect of rising fuel efficiency
standards, two factors have opposing
effects on the VMT of a particular
vehicle. First, VMT increases when that
vehicle’s fuel efficiency increases. But
the increase in the fuel efficiency of the
household’s other vehicles causes the
vehicle’s own VMT to decrease. Because
the effect of a vehicle’s own fuel
efficiency is larger than the other
vehicles’ fuel efficiency, VMT increases
if the fuel efficiency of all vehicles
increases proportionately. Linn also
finds that VMT responds much more
strongly to vehicle fuel economy than to
gasoline prices, which is at variance
with the Hymel et al. and Greene results
discussed above.
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Like Su and Linn, Liu et al. (2014)
employed the 2009 NHTS to develop an
elaborate model of an individual
household’s choices about how many
vehicles to own, what types and ages of
vehicles to purchase, and how much
combined driving to do using all of
them. Their analysis used a complex
mathematical formulation and statistical
methods to represent and measure the
interdependence among households’
choices of the number, types, and ages
of vehicles to purchase, as well as how
intensively to use them.
Liu et al. employed their model to
simulate variation in households’ total
vehicle use to changes in their income
levels, neighborhood characteristics,
and the per-mile fuel cost of driving
averaged over all vehicles each
household owns. The complexity of the
relationships among the number of
vehicles owned, their specific types and
ages, fuel economy levels, and use
incorporated in their model required
them to measure these effects by
introducing variation in income,
neighborhood attributes, and fuel costs,
and observing the response of
households’ annual driving. Their
results imply a rebound effect of
approximately 40% in response to
significant (25–50%) variation in fuel
costs, with almost exactly symmetrical
responses to increases and declines.
A study of the rebound effect by
Frondel et al. (2012) used data from
travel diaries recorded by more than
2,000 German households from 1997
through 2009 to estimate alternative
measures of the rebound effect, and to
explore variation in their magnitude
among households. Each household
participating in the survey recorded its
automobile travel and fuel purchases
over a period of one to three years and
supplied information on its composition
and the personal characteristics of each
of its members. The authors converted
households’ travel and fuel
consumption to a monthly basis, and
used specialized estimation procedures
(quantile and random-effects panel
regression) to analyze monthly variation
in their travel and fuel use in relation
to differences in fuel prices, the fuel
efficiency of each vehicle a household
owned, and the fuel cost per mile of
driving each vehicle.
Frondel et al. estimate four separate
measures of the rebound effect, three of
which capture the response of vehicle
use to variation in fuel efficiency, fuel
price, and fuel cost per mile traveled,
and a fourth capturing the response of
fuel consumption to changes in fuel
price. Their first three estimates range
from 42% to 57%, while their fourth
estimate corresponds to a rebound effect
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of 90%. Although their analysis finds no
significant variation of the rebound
effect with household income, vehicle
ownership, or urban versus rural
location, it concludes that the rebound
effect is substantially larger for
households that drive less (90%) than
for those who use their vehicles most
intensively (56%).
Gillingham (2014) analyzed variation
in the use of approximately five million
new vehicles sold in California from
2001 to 2003 during the first several
years after their purchase, focusing
particularly on how their use responded
to geographic and temporal variation in
fuel prices. His sample consisted
primarily of personal or household
vehicles (87%) but also included some
that were purchased by businesses,
rental car companies, and government
agencies. Using county-level data, he
analyzed the effect of differences in the
monthly average fuel price paid by their
drivers on variation in their monthly
use and explored how that effect varied
with drivers’ demographic
characteristics and household incomes.
Gillingham’s analysis did not include
a measure of vehicles’ fuel economy or
fuel cost per mile driven, so he could
not measure the rebound effect directly,
but his estimates of the effect of fuel
prices on vehicle use correspond to a
rebound effect of 22–23% (depending
on whether he controlled for the
potential effect of gasoline demand on
its retail price). His estimation
procedure and results imply that vehicle
use requires nearly two years to adjust
fully to changes in fuel prices. He found
little variation in the sensitivity of
vehicle use to fuel prices among car
buyers with different demographic
characteristics, although his results
suggested that it increases with their
income levels.
Weber & Farsi (2014) analyzed
variation in the use of more than 70,000
individual cars owned by Swiss
households who were included in a
2010 survey of travel behavior. Their
analysis focuses on the simultaneous
relationships among households’
choices of the fuel efficiency and size
(weight) of the vehicles they own, and
how much they drive each one,
although they recognize that fuel
efficiency cannot be chosen
independently of vehicle weight. The
authors employ a model specification
and statistical estimation procedures
that account for the likelihood that
households intending to drive more will
purchase more fuel-efficient cars but
may also choose more spacious and
comfortable—and thus heavier—
models, which affects their fuel
efficiency indirectly, since heavier
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vehicles are generally less fuel-efficient.
The survey data they rely on includes
both owners’ estimates of their annual
use of each car and the distance it was
actually driven on a specific day;
because they are not closely correlated,
the authors employ them as alternative
measures of vehicle use to estimate the
rebound effect, but this restricts their
sample to the roughly 8,100 cars for
which both measures are available.
Weber and Farsi’s estimates of the
rebound effect are extremely large: 75%
using estimated annual driving and 81%
when they measure vehicle use by
actual daily driving. Excluding vehicle
size (weight) and limiting the choices
that households are assumed to consider
simultaneously to just vehicles’ fuel
efficiency and how much to drive
approximately reverses these estimates,
but both are still very large. Using a
simpler procedure that does not account
for the potential effect of driving
demand on households’ choices among
vehicle models of different size and fuel
efficiency produces much smaller
values for the rebound effect: 37% using
annual driving and 19% using daily
travel. The authors interpret these latter
estimates as likely to be too low because
actual on-road fuel efficiency has not
improved as rapidly as suggested by the
manufacturer-reported measure they
employ. This introduces an error in
their measure that may be related to a
vehicle’s age, and their more complex
estimation procedure may reduce its
effect on their estimates. Nevertheless,
even their lower estimates exceed those
from many other studies of the rebound
effect, as Table 8–2 shows.
Hymel, Small, & Van Dender (2010)—
and more recently, Hymel & Small
(2015)—extended the simultaneous
equations analysis of time-series and
state-level variation in vehicle use
originally reported in Small & Van
Dender (2007) and to test the effect of
including more recent data. As in the
original 2007 study, both subsequent
extensions found that the fuel economy
rebound effect had declined over time
in response to increasing personal
income and urbanization but had risen
during periods when fuel prices
increased. Because they rely on the
response of vehicle use to fuel cost per
mile to estimate the rebound effect,
however, none of these three studies is
able to detect whether its apparent
decline in response to rising income
levels over time truly reflects its effect
on drivers’ responses to changing fuel
economy—the rebound effect itself—or
simply captures the effect of rising
income on their sensitivity to fuel
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prices.289 These updated studies each
revised Small and Van Dender’s original
estimate of an 11% rebound effect for
1997–2011 upward when they included
more recent experience: To 13% for the
period 2001–04, and subsequently to
18% for 2000–2009.
In their 2015 update, Hymel and
Small hypothesized that the recent
increase in the rebound effect could be
traced to a combination of expanded
media coverage of changing fuel prices,
increased price volatility, and an
asymmetric response by drivers to
variation in fuel costs. The authors
estimated that about half of the apparent
increase in the rebound effect for recent
years could be attributed to greater
volatility in fuel prices and more media
coverage of sudden price changes. Their
results also suggest that households
curtail their vehicle use within the first
year following an increase in fuel prices
and driving costs, while the increase in
driving that occurs in response to
declining fuel prices—and by
implication, to improvements in fuel
economy—occurs more slowly.
West et al. (2015) attempted to infer
the fuel economy rebound effect using
data from Texas households who
replaced their vehicles with more fuelefficient models under the 2009 ‘‘Cash
for Clunkers’’ program, which offered
sizeable financial incentives to do so.
Under the program, households that
retired older vehicles with fuel economy
levels of 18 miles per gallon (MPG) or
less were eligible for cash incentives
ranging from $3,500–4,000, while those
retiring vehicles with higher fuel
economy were ineligible for such
rebates. The authors examined the fuel
economy, other features, and
subsequent use of new vehicles
households in Texas purchased to
replace older models that narrowly
qualified for the program’s financial
incentives because their fuel economy
was only slightly below the 18 MPG
threshold. They then compared these to
the fuel economy, features, and use of
new vehicles that demographically
comparable households bought to
replace older models, but whose slightly
higher fuel economy—19 MPG or
289 DeBorger et al. (2016) analyze the separate
effects of variation in household income on the
sensitivity of their vehicle use to fuel prices and the
fuel economy of vehicles they own. Their results
imply the decline in the fuel economy rebound
effect with income reported in Small & Van Dender
(2007) and its subsequent extensions appears to
result entirely from a reduction in drivers’
sensitivity to fuel prices as their incomes rise,
rather than from any effect of rising income on the
sensitivity of vehicle use to improving fuel
economy; i.e., on the fuel economy rebound effect
itself.
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above—made them barely ineligible for
the program.
The authors reported that the higher
fuel economy of new models that
eligible households purchased in
response to the generous financial
incentives offered under the ‘‘Cash for
Clunkers’’ did not prompt their buyers
to use them more than the older, lowMPG vehicles they replaced. They
attributed this apparent absence of a
fuel economy rebound effect—which
they described as an ‘‘attributeadjusted’’ measure of its magnitude—to
the fact that eligible households chose
to buy less expensive, smaller, and
lower-performing models to replace
those they retired. Because these
replacements offered lower-quality
transportation service, their buyers did
not drive them more than the vehicles
they replaced.
The applicability of this result to the
proposal’s analysis is doubtful because
previous regulatory analyses assumed
that manufacturers could achieve
required improvements in fuel economy
without compromising the performance,
carrying and towing capacity, comfort,
or safety of cars and light trucks from
recent model years.290 While this may
be technically true, doing so would
come at a combined greater cost. If this
argument is correct, then amending
future standards at a reduced stringency
from their previously-adopted levels
would lead to less driving attributable to
rebound, and should therefore not lead
to artificial constraints in new vehicles’
other features that offset the reduction
in their use stemming from lower fuel
economy.
Most recently, De Borger et al. (2017)
analyze the response of vehicle use to
changes in fuel economy among a
sample of nearly 350,000 Danish
households owning the same model
vehicle, of which almost one-third
replaced it with a different model
sometime during the period from 2001
to 2011. By comparing the changes in
households’ driving from the early years
of this period to its later years among
those who replaced their vehicles
during the intervening period to the
changes in driving among households
who kept their original vehicles, the
authors attempted to isolate the effect of
changes in fuel economy on vehicle use
from those of other factors. They
measured the rebound effect as the
290 As discussed, this does not mean attributes of
future cars and light trucks will be anything close
to those manufacturers could have offered if lower
standards had remained in effect. Instead, the
agencies asserted features other than fuel economy
could be maintained at the levels offered in recent
model years—that features will not likely be
removed, but may not be improved.
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change in households’ vehicle use in
response to differences in the fuel
economy between vehicles they had
owned previously and the new models
they purchased to replace them, over
and above any change in vehicle use
among households who did not buy
new cars (and thus saw no change in
fuel economy).
These authors’ data enabled them to
control for the effects of changes over
time in household characteristics and
vehicle features other than fuel
economy that were likely to have
contributed to observed changes in
vehicle use. They also employed
complex statistical methods to account
for the fact that some households
replacing their vehicles may have done
so in anticipation of changes in their
driving demands (rather than the
reverse), as well as for the possibility
that some households who replaced
their cars may have done so because
their driving behavior was more
sensitive to fuel prices than other
households. Their estimates ranged
from 8–10%, varying only minimally
among alternative model specifications
and statistical estimation procedures or
in response to whether their sample was
restricted to households that replaced
their vehicles or also included
households that kept their original
vehicles throughout the period.291
Finally, De Borger et al. found no
evidence that the rebound effect is
smaller among lower-income
households than among their higherincome counterparts.
(c) What value have the agencies
assumed in this rule?
On the basis of all of the evidence
summarized here, a fuel economy
rebound effect of 20% has been chosen
to analyze the effects of the proposed
action. This is a departure from the 10%
value used in regulatory analyses for
MYs 2012–2016 and previous analyses
for MYs 2017–2025 CAFE and GHG
standards and represents a return to the
value employed in the analyses for MYs
2005–2011 CAFE standards. There are
several reasons the estimate of the fuel
economy rebound effect for this analysis
has been increased.
First, the 10% value is inconsistent
with nearly all research on the
magnitude of the rebound effect, as
Table–II–43 and Table–II–44 indicate.
Instead, it is based almost exclusively
291 This latter result suggests their estimates were
not biased by any tendency for households whose
demographic characteristics, economic
circumstances, or driving demands changed over
the period in ways that prompted them to replace
their vehicles with models offering different fuel
economy.
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on the finding of the 2007 study by
Small and Van Dender that the rebound
effect had been declining over time in
response to drivers’ rising incomes and
on extending that decline through future
years using an assumption of steady
income growth. As indicated above,
however, subsequent extensions of
Small and Van Dender’s original
research have produced larger estimates
of the rebound effect for recent years:
While their original study estimated the
rebound effect at 11% for 1997–2001,
the 2010 update by Hymel, Small, and
Van Dender reported a value of 13% for
2004, and Hymel and Small’s 2015
update estimated the rebound effect at
18% for 2003–09. Further, the issues
with state-level measures of vehicle use,
fuel consumption, and fuel economy
identified previously raise some doubt
about the reliability of these studies’
estimates of the rebound effect.
At the same time, the continued
increases in income that were
anticipated to produce a continued
decline in the rebound effect have not
materialized. The income measure (real
personal income per Capita) used in
these analyses has grown only
approximately one percent annually
over the past two decades and is
projected to grow at approximately
1.5% for the next 30 years, in contrast
to the two to three percent annual
growth assumed by the agencies when
developing earlier forecasts of the future
rebound effect. Further, another recent
study by DeBorger et al. (2016) analyzed
the separate effects of variation in
household income on the sensitivity of
their vehicle use to fuel prices and the
fuel economy of vehicles they own.
These authors’ results indicate that the
decline in the fuel economy rebound
effect with income reported in Small &
Van Dender (2007) and subsequent
research results entirely from a
reduction in drivers’ sensitivity to fuel
prices as their incomes rise rather than
from any effect of rising income on the
sensitivity of vehicle use to fuel
economy itself. This latter measure,
which DeBorger et al. find has not
changed significantly as incomes have
risen over time, is the correct measure
of the fuel economy rebound effect, so
their analysis calls into question its
assumed sensitivity to income.
Some studies of households’ use of
individual vehicles also find that the
fuel economy rebound effect increases
with the number of vehicles they own.
Because vehicle ownership is strongly
associated with household income, this
common finding suggests that the
overall value of the rebound effect is
unlikely to decline with rising incomes
as the agencies had previously assumed.
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In addition, buyers of new cars and light
trucks belong disproportionately to
higher-income households that already
own multiple vehicles, which further
suggests that the higher values of the
rebound effect estimated by many
studies for such households are more
relevant for analyzing use of newlypurchased cars and light trucks.
Finally, research on the rebound
effect conducted since the agencies’
original 2008 review of evidence almost
universally reports estimates in the 10–
40% (and larger) range, as Table–II–43
shows. Thus, the 20% rebound effect
used in this analysis more accurately
represents the findings from both the
studies considered in 2008 review and
the more recent analyses.
(1) What are the implications of the
rebound effect for VMT?
The assumed rebound effect not only
influences the use of new vehicles in
today’s analysis but also affects the
response of the initial registered vehicle
population to changes in fuel price
throughout their remaining useful lives.
The fuel prices used in this analysis are
lower than the projections used to
inform the 2012 Final Rule but generally
increase from today’s level over time. As
they do so, the rebound effect acts as a
price elasticity of demand for travel—as
the cost-per-mile of travel increases,
owners of all vehicles in the registered
population respond by driving less. In
particular, they drive 20% less than the
difference between the cost-per-mile of
travel when they were observed in
calendar year 2016 and the relevant
cost-per-mile at any future age. For the
new vehicles subject to this proposal
(and explicitly simulated by the CAFE
model), fuel economies increase relative
to MY 2016 levels, and generally
improve enough to offset the effect of
rising fuel prices—at least during the
years covered by the proposal. For those
vehicles, the difference between the
initial cost-per-mile of travel and future
travel costs is negative. As the vehicles
become less expensive to operate, they
are driven more (20% more than the
difference between initial and present
travel costs, precisely). Of course, each
of the regulatory alternatives considered
in the analysis would result in lower
fuel economy levels for vehicles
produced in model year 2020 and later
than if the baseline standards remained
in effect, so total VMT is lower under
these alternatives than under the
baseline.
(2) What is the mobility benefit that
accrues to vehicle owners?
The increase in travel associated with
the rebound effect produces additional
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benefits to vehicle owners, which reflect
the value to drivers and other vehicle
occupants of the added (or more
desirable) social and economic
opportunities that become accessible
with additional travel. As evidenced by
the fact that they elect to make more
frequent or longer trips when the cost of
driving declines, the benefits from this
added travel exceed drivers’ added
outlays for the fuel it consumes
(measured at the improved level of fuel
economy resulting from stricter CAFE
standards). The amount by which the
benefits from this increased driving
travel exceed its increased fuel costs
measures the net benefits they receive
from the additional travel, usually are
referred to as increased consumer
surplus.
NHTSA’s analysis estimates the
economic value of the decreased
consumer surplus provided by reduced
driving using the conventional
approximation, which is one half of the
product of the increase in vehicle
operating costs per vehicle-mile and the
resulting decrease in the annual number
of miles driven. Because it depends on
the extent of the change in fuel
economy, the value of economic
impacts from decreased vehicle use
changes by model year and varies
among alternative CAFE standards.
(d) Societal Externalities Associated
With CAFE Alternatives
(1) Energy Security Externalities
Higher U.S. fuel consumption will
produce a corresponding increase in the
nation’s demand for crude petroleum,
which is traded actively in a worldwide
market. The U.S. accounts for a large
enough share of global oil consumption
that the resulting boost in global
demand will raise its worldwide price.
The increase in global petroleum prices
that results from higher U.S. demand
causes a transfer of revenue to oil
producers worldwide from not only
buyers of new cars and light trucks, but
also other consumers of petroleum
products in the U.S. and throughout the
world, all of whom pay the higher price
that results.
Although these effects will be
tempered by growing U.S. oil
production, uncertainty in the long-term
import-export balance makes it difficult
to precisely project how these effects
might change in response to that
increased production. Growing U.S.
petroleum consumption will also
increase potential costs to all U.S.
petroleum users from possible
interruptions in the global supply of
petroleum or rapid increases in global
oil prices, not all of which are borne by
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the households or businesses who
increase their petroleum consumption
(that is, they are partly ‘‘external’’ to
petroleum users). If U.S. demand for
imported petroleum increases, it is also
possible that increased military
spending to secure larger oil supplies
from unstable regions of the globe will
be necessary.
These three effects are often referred
to collectively as ‘‘energy security
externalities’’ resulting from U.S.
petroleum consumption, and increases
in their magnitude are sometimes cited
as potential social costs of increased
U.S. demand for oil. To the extent that
they represent real economic costs that
would rise incrementally with increases
in U.S. petroleum consumption of the
magnitude likely to result from less
stringent CAFE and GHG standards,
these effects represent potential
additional costs of this proposed action.
Chapter 7 of the Regulatory Impact
Analysis for this proposed action
defines each of these energy security
externalities in detail, assesses whether
its magnitude is likely to change as a
consequence of this action, and
identifies whether that change
represents a real economic cost or
benefit of this action.
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(2) Environmental Externalities
The change in criteria pollutant
emissions that result from changes in
vehicle usage and fuel consumption is
estimated as part of this analysis.
Criteria air pollutants include carbon
monoxide (CO), hydrocarbon
compounds (usually referred to as
‘‘volatile organic compounds,’’ or VOC),
nitrogen oxides (NOX), fine particulate
matter (PM2.5), and sulfur oxides (SOX).
These pollutants are emitted during
vehicle storage and use, as well as
throughout the fuel production and
distribution system. While increases in
domestic fuel refining, storage, and
distribution that result from higher fuel
consumption will increase emissions of
these pollutants, reduced vehicle use
associated with the fuel economy
rebound effect will decrease their
emissions. The net effect of less
stringent CAFE standards on total
emissions of each criteria pollutant
depends on the relative magnitudes of
increases in its emissions during fuel
refining and distribution, and decreases
in its emissions resulting from
additional vehicle use. Because the
relationship between emissions in fuel
refining and vehicle use is different for
each criteria pollutant, the net effect of
increased fuel consumption from the
proposed standards on total emissions
of each pollutant is likely to differ.
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The social damage costs associated
with changes in the emissions of criteria
pollutants and CO2 was calculated,
attributing benefits and costs to the
regulatory alternatives considered based
on the sign of the change in each
pollutant. In previous rulemakings, the
agencies have considered the social cost
of CO2 emissions from a global
perspective, accumulating social costs
for CO2 emissions based on adverse
outcomes attributable to climate change
in any country. In this analysis,
however, the costs of CO2 emissions and
resulting climate damages from both
domestic and global perspectives were
considered. Chapter 9 of the Regulatory
Impact Analysis provides a detailed
discussion of how the agencies estimate
changes in emissions of criteria air
pollutants and CO2 and reports the
values the agencies use to estimate
benefits or costs associated with those
changes in emissions.
(3) Traffic Externalities (Congestion,
Noise)
Increased vehicle use associated with
the rebound effect also contributes to
increased traffic congestion and
highway noise. To estimate the
economic costs associated with these
consequences of added driving, the
estimates of per-mile congestion and
noise costs caused by increased use of
automobiles and light trucks developed
previously by the Federal Highway
Administration (FHWA) were applied.
These values are intended to measure
the increased costs resulting from added
congestion and the delays it causes to
other drivers and passengers and noise
levels contributed by automobiles and
light trucks. NHTSA previously
employed these estimates in its analysis
accompanying the MY 2011 final CAFE
rule as well as in its analysis of the
effects of higher CAFE standards for MY
2012–16 and MY 2017–2021. After
reviewing the procedures used by
FHWA to develop them and considering
other available estimates of these values
and recognizing that no commenters
have addressed these costs directly in
their comments on previous rules, the
values continue to be appropriate for
use in this proposal. For this analysis,
FHWA’s estimates of per-mile costs are
multiplied by the annual increases in
automobile and light truck use from the
rebound effect to yield the estimated
increases in total congestion and noise
externality costs during each year over
the lifetimes of the cars and light trucks
in the on-road fleet. Due to the fact that
this proposal represents a decrease in
stringency, the fuel economy rebound
effect results in fewer miles driven
under the action alternatives relative to
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the baseline, which generates savings in
congestion and road noise relative to the
baseline.
F. Impact of CAFE Standards on Vehicle
Safety
In past CAFE rulemakings, NHTSA
has examined the effect of CAFE
standards on vehicle mass and the
subsequent effect mass changes will
have on vehicle safety. While setting
standards based on vehicle footprint
helps reduce potential safety impacts
associated with CAFE standards as
compared to setting standards based on
some other vehicle attribute, footprintbased standards cannot entirely
eliminate those impacts. Although prior
analyses noted that there could also be
impacts because of other factors besides
mass changes, those impacts were not
estimated quantitatively.292 In this
current analysis, the safety analysis has
been expanded to include a broader and
more comprehensive measure of safety
impacts, as discussed below. A number
of factors can influence motor vehicle
fatalities directly by influencing vehicle
design or indirectly by influencing
consumer behavior. These factors
include:
(1) Changes, which affect the
crashworthiness of vehicles impact
other vehicles or roadside objects, in
vehicle mass made to reduce fuel
consumption. NHTSA’s statistical
analysis of historical crash data to
understand effects of vehicle mass and
size on safety indicates reducing mass
in light trucks generally improves
safety, while reducing mass in
passenger cars generally reduces safety.
NHTSA’s crash simulation modeling of
vehicle design concepts for reducing
mass revealed similar trends.293
(2) The delay in the pace of consumer
acquisition of newer safer vehicles that
results from higher vehicle prices
associated with technologies needed to
meet higher CAFE standards. Because of
a combination of safety regulations and
voluntary safety improvements,
passenger vehicles have become safer
over time. Compared to prior decades,
fatality rates have declined significantly
292 NHTSA included a quantification of reboundassociated safety impacts in its Draft TAR analysis,
but because the scrappage model is new for this
rulemaking, did not include safety impacts
associated with the effect of standards on new
vehicle prices and thus on fleet turnover. The fact
that the scrappage model did not exist previously
does not mean that the effects that it aims to show
were not important considerations, simply that the
agency was unable to account for them
quantitatively prior to the current analysis.
293 DOT HS 812051a—Methodology for
evaluating fleet protection of new vehicle designs
Application to lightweight vehicle designs, DOT HS
812051b Methodology for evaluating fleet
protection of new vehicle designs_Appendices.
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because of technological safety
improvements as well as behavioral
shifts such as increased seat belt use.
The results of this analysis project that
vehicle prices will be nearly $1,900
higher under the augural CAFE
standards compared to the preferred
alternative that would hold stringency
at MY 2020 levels in MYs 2021–2026.
This will induce some consumers to
delay or forgo the purchase of newer
safer vehicles and slow the transition of
the on-road fleet to one with the
improved safety available in newer
vehicles. This same factor can also shift
the mix of passenger cars and light
trucks.
(3) Increased driving because of better
fuel economy. The ‘‘rebound effect’’
predicts consumers will drive more
when the cost of driving declines. More
stringent CAFE standards reduce
vehicle operating costs, and in response,
some consumers may choose to drive
more. Driving more increases exposure
to risks associated with on-road
transportation, and this added exposure
translates into higher fatalities.
Although all three factors influence
predicted fatality levels that may occur,
only two of them, the changes in vehicle
mass and the changes in the acquisition
of safer vehicles—are actually imposed
on consumers by CAFE standards. The
safety of vehicles has improved over
time and is expected to continue
improving in the future commensurate
with the pace of safety technology
innovation and implementation and
motor vehicle safety regulation. Safety
improvements will likely continue
regardless of changes to CAFE
standards. However, its pace may be
modified if manufacturers choose to
delay or forgo investments in safety
technology because of the demand
CAFE standards impose on research,
development, and manufacturing
budgets. Increased driving associated
with rebound is a consumer choice.
Improved CAFE will reduce driving
costs, but nothing in the higher CAFE
standards compels consumers to drive
additional miles. If consumers choose to
do so, they are making a decision that
the utility of more driving exceeds the
marginal operating costs as well as the
added crash risk it entails. Thus, while
the predicted fatality impacts with all
three factors embedded into the model
are measured, the fatalities associated
with consumer choice decisions are
accounted for separately from those
resulting from technologies
implemented in response to CAFE
regulations or economic limitations
resulting from CAFE regulation. Only
those safety impacts associated with
mass reduction and those resulting from
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higher vehicle prices are directly
attributed to CAFE standards.294 This is
reflected monetarily by valuing extra
rebound miles at the full value of their
added driving cost plus the added safety
risk consumers experience, which
completely offsets the societal impact of
any added fatalities from this voluntary
consumer choice.
The safety component of CAFE
analysis has evolved over time. In the
2012 final rule, the analysis accounted
for the change in projected fatalities
attributable to mass reduction of new
vehicles. The model assumed that
manufacturers would choose mass
reduction as a compliance method
across vehicle classes such that the net
effect of mass reduction on fatalities was
zero. However, in the 2016 draft
Technical Assessment Report, DOT
made two consequential changes to the
analysis of fatalities associated with the
CAFE standards. In particular, first, the
modelling assumed that mass reduction
technology was available to all vehicles,
regardless of net safety impact, and
second, it accounted for the incremental
safety costs associated with additional
miles traveled due to the rebound effect.
The current analysis extends the
analysis to report incremental fatality
impacts associated with additional
miles traveled due to the rebound effect,
and identifies the increase in fatalities
associated with additional driving
separately from changes in fatalities
attributable other sources.295
The current analysis adds another
element: The effect that higher new
vehicle prices have on new vehicle sales
and on used vehicle scrappage, which
influences total expected fatalities
294 It could be argued fatalities resulting from
consumer’s decision to delay the purchase of newer
safer vehicles is also a market decision implying
consumers fully accept the added safety risk
associated with this delay and value the time value
of money saved by the delayed purchase more than
this risk. This scenario is likely accurate for some
purchasers. For others, the added cost may
represent a threshold price increase effectively
preventing them from being financially able to
purchase a new vehicle. Presently there is no way
to determine the proportion of lost sales reflected
by these two scenarios. The added driving from the
rebound effect results from a positive benefit of
CAFE, which reduces the cost of driving. By
contrast, the effect of retaining older vehicles longer
results from costs imposed on consumers, which
potentially limit their purchase options. Thus,
fatalities are attributed to retaining older vehicles
due to CAFE but not those resulting from decisions
to drive more. Comments are sought on this
assumption.
295 Drivers who travel additional miles are
assumed to experience benefits that at least offset
the costs they incur in doing so, including the
increased safety risks they face. Thus while the
number of additional fatalities resulting from
increased driving is reported, the associated costs
are not included among the social costs of the
proposal.
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because older vehicle vintages are
associated with higher rates of
involvement in fatal crashes than newer
vehicles. Finally, a dynamic fleet share
model also predicts the effects of
changes in the standards on the share of
light trucks and passenger cars in future
model year light-duty vehicle fleets.
Vehicles of different body styles have
different rates of involvement in fatal
crashes, so that changing the share of
each in the projected future fleet has
safety impacts; the implied safety effects
are captured in the current modelling.
The agencies seek comment on changes
to the safety analysis made in this
proposal, they seek particular comment
on the following changes:
(1) The sales scrappage models as
independent models: Two separate models
capture the effects of new vehicle prices on
new vehicle demand and used vehicle
retirement rates—the sales model and the
scrappage model, respectively. We seek
public comment on the methods used for
each of these models, in particular we seek
comment on:
• The assumptions and variables included in
the independent models
• The techniques and data used to estimate
the independent models
• The structure and implementation of the
independent models
(2) Integration of the sales and scrappage
models: The new sales and scrappage models
use many of the same predictors, but are not
directly integrated. We seek public comment
on, and data supporting whether integrating
the two models is appropriate.
(3) Integration of the scrappage rates and
mileage accumulation: The current model
assumes that annual mileage accumulation
and scrappage rates are independent of one
another. We seek public comment on the
appropriateness of this assumption, and data
that would support developing an interaction
between scrappage rates and mileage
accumulation, or testing whether such an
interaction is important to include.
(4) Increased risk of older vehicles: The
observed increase in crash and injury risk
associated with older vehicles is likely due
to a combination of vehicle factors and driver
factors. For example, older vehicles are less
crashworthy because in general they’re
equipped with fewer or less modern safety
features, and drivers of older cars are on
average younger and may be less skilled
drivers or less risk-averse than drivers of new
vehicles. We fit a model which includes both
an age and vintage affect, but assume that the
age effect is entirely a result of changes in
average driver demographics, and not
impacted by changes in CAFE or GHG
standards. We seek comment on this
approach for attributing increased older
vehicle risk. Is the analysis likely to
overestimate or underestimate the safety
benefits under the proposed alternative?
(5) Changes in the mix of light trucks and
passenger cars: The dynamic fleet share
model predicts changes in the future share of
light truck and passenger car vehicles.
Changes in the mix of vehicles may result in
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increased or decreased fatalities. Does the
dynamic fleet share model reasonably
capture consumers’ decisions about how they
substitute between different types and sizes
of vehicles depending on changes in fuel
economy, relative and absolute prices, and
other vehicle attributes? We seek comment
on whether our safety analysis provides a
reasonable estimate of the effects of changes
in fleet mix on future fatalities.
1. Impact of Weight Reduction on Safety
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The primary goals of CAFE and CO2
standards are reducing fuel
consumption and CO2 emissions from
the on-road light-duty vehicle fleet; in
addition to these intended effects, the
potential of the standards to affect
vehicle safety is also considered.296 As
a safety agency, NHTSA has long
considered the potential for adverse
safety consequences when establishing
CAFE standards, and under the CAA,
EPA considers factors related to public
health and human welfare, including
safety, in regulating emissions of air
pollutants from mobile sources.
Safety trade-offs associated with fuel
economy increases have occurred in the
past, particularly before NHTSA CAFE
standards were attribute-based; past
safety trade-offs may have occurred
because manufacturers chose at the
time, in response to CAFE standards, to
build smaller and lighter vehicles.
Although the agency now uses attributebased standards, in part to protect
against excessive vehicle downsizing,
the agency must be mindful of the
possibility of related safety trade-offs in
the future. In cases where fuel economy
improvements were achieved through
reductions in vehicle size and mass, the
smaller, lighter vehicles did not fare as
well in crashes as larger, heavier
vehicles, on average.
Historically, as shown in FARS data
analyzed by NHTSA, the safest cars
generally have been heavy and large,
while cars with the highest fatal-crash
rates have been light and small. The
question, then, is whether past is
necessarily a prologue when it comes to
potential changes in vehicle size (both
footprint and ‘‘overhang’’) and mass in
296 In this rulemaking document, ‘‘vehicle safety’’
is defined as societal fatality rates per vehicle mile
of travel (VMT), including fatalities to occupants of
all vehicles involved in collisions, plus any
pedestrians. Injuries and property damage are not
within the scope of the statistical models discussed
in this section because of data limitations (e.g.,
limited information on observed or potential
relationships between safety standards and injury
and property damage outcomes, consistency of
reported injury severity levels). Rather, injuries and
property damage are represented within the CAFE
model through adjustment factors based on
observed relationships between societal costs of
fatalities and societal injury and property damage
costs.
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response to the more stringent future
CAFE and GHG standards.
Manufacturers stated they will reduce
vehicle mass as one of the cost-effective
means of increasing fuel economy and
reducing CO2 to meet standards, and
this approach is incorporated this
expectation into the modeling analysis
supporting the standards. Because the
analysis discerns a historical
relationship between vehicle mass, size,
and safety, it is reasonable to assume
these relationships will continue in the
future.
(a) Historical Analyses of Vehicle Mass
and Safety
Researchers have been using
statistical analysis to examine the
relationship of vehicle mass and safety
in historical crash data for many years
and continue to refine their techniques.
In the MY 2012–2016 final rule, the
agencies stated we would conduct
further study and research into the
interaction of mass, size, and safety to
assist future rulemakings and start to
work collaboratively by developing an
interagency working group between
NHTSA, EPA, DOE, and CARB to
evaluate all aspects of mass, size, and
safety. The team would seek to
coordinate government-supported
studies and independent research to the
greatest extent possible to ensure the
work is complementary to previous and
ongoing research and to guide further
research in this area.
The agencies also identified three
specific areas to direct research in
preparation for future CAFE/CO2
rulemaking regarding statistical analysis
of historical data. First, NHTSA would
contract with an independent
institution to review statistical methods
NHTSA and DRI used to analyze
historical data related to mass, size, and
safety, and to provide recommendations
on whether existing or other methods
should be used for future statistical
analysis of historical data. This study
would include a consideration of
potential near multicollinearity in the
historical data and how best to address
it in a regression analysis. The 2010
NHTSA report (hereinafter 2010 Kahane
report) was also peer reviewed by two
other experts in the safety field—Farmer
(Insurance Institute for Highway Safety)
and Lie (Swedish Transport
Administration).297
Second, NHTSA and EPA, in
consultation with DOE, would update
the MY 1991–1999 database where
297 All three peer reviews are available in Docket
No. NHTSA–2010–0152, Relationships Between
Fatality Risk, Mass, and Footprint, https://
www.regulations.gov/docket?D=NHTSA-2010-0152.
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safety analyses in the NPRM and final
rule are based with newer vehicle data
and create a common database that
could be made publicly available to
address concerns that differences in
data were leading to different results in
statistical analyses by different
researchers.
And third, to assess if the design of
recent model year vehicles
incorporating various mass reduction
methods affect relationships among
vehicle mass, size, and safety, the
agencies sought to identify vehicles
using material substitution and smart
design and to assess if there is sufficient
crash data involving those vehicles for
statistical analysis. If sufficient data
exists, statistical analysis would be
conducted to compare the relationship
among mass, size, and safety of these
smart design vehicles to vehicles of
similar size and mass with more
traditional designs.
By the time of the MY 2017–2025
final rule, significant progress was made
on these tasks: The independent review
of recent and updated statistical
analyses of the relationship between
vehicle mass, size, and crash fatality
rates had been completed. NHTSA
contracted with the University of
Michigan Transportation Research
Institute (UMTRI) to conduct this
review, and the UMTRI team led by
Green evaluated more than 20 papers,
including studies done by NHTSA’s
Kahane, Wenzel of the U.S. Department
of Energy’s Lawrence Berkeley National
Laboratory, Dynamic Research, Inc., and
others. UMTRI’s basic findings are
discussed in Chapter 11 of the PRIA
accompanying this NPRM.
Some commenters in recent CAFE
rulemakings, including some vehicle
manufacturers, suggested designs and
materials of more recent model year
vehicles may have weakened the
historical statistical relationships
between mass, size, and safety. It was
agreed that the statistical analysis would
be improved by using an updated
database reflecting more recent safety
technologies, vehicle designs and
materials, and reflecting changes in the
vehicle fleet. An updated database was
created and employed for assessing
safety effects for that final rule. The
agencies also believed, as UMTRI found,
different statistical analyses may have
produced different results because they
used slightly different datasets for their
analyses.
To try to mitigate this issue and to
support the current rulemaking, NHTSA
created a common, updated database for
statistical analysis consisting of crash
data of model years 2000–2007 vehicles
in calendar years 2002–2008, as
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compared to the database used in prior
NHTSA analyses, which was based on
model years 1991–1999 vehicles in
calendar years 1995–2000. The new
database was the most up-to-date
possible, given the processing lead time
for crash data and the need for enough
crash cases to permit statistically
meaningful analyses. NHTSA made the
preliminary version of the new
database, which was the basis for
NHTSA’s 2011 preliminary report
(hereinafter 2011 Kahane report),
available to the public in May 2011, and
an updated version in April 2012 (used
in NHTSA’s 2012 final report,
hereinafter 2012 Kahane report),298
enabling other researchers to analyze
the same data and hopefully minimize
discrepancies in results because of
inconsistencies across databases.299
Since the publication of the MYs
2017–2025 final rule, NHTSA has
sponsored, and is sponsoring, new
studies and research to inform the
current CAFE and CO2 rulemaking. In
addition, the National Academy of
Sciences published a new report in this
area.300 Throughout the rulemaking
process, NHTSA’s goal is to publish as
much of our research as possible. In
establishing standards, all available
data, studies, and information
objectively without regard to whether
they were sponsored by the agencies,
will be considered.
Undertaking these tasks has helped
come closer to resolving ongoing
debates in statistical analysis research of
historical crash data. It is intended that
these conclusions will be applied going
forward in future rulemakings, and it is
believed the research will assist the
public discussion of the issues. Specific
historical analyses (in addition to
NHTSA’s own analysis) on vehicle mass
and safety used to support this
rulemaking include:
• The 2011 and 2013 NHTSA
Workshops on Vehicle Mass, Size, and
Safety;
• the University of Michigan
Transportation Research Institute
(UMTRI) independent review of a set of
statistical relationships between vehicle
curb weight, footprint variables (track
width, wheelbase), and fatality rates
from vehicle crashes;
• the 2012 Lawrence Berkeley
National Laboratory (LBNL) Phase 1 and
Phase 2 reports on the sensitivity of
298 Those databases are available at ftp://
ftp.nhtsa.dot.gov/CAFE/.
299 See 75 FR 25324, 25395–25396 (May 7, 2010)
(for a discussion of planned statistical analyses).
300 Cost, Effectiveness and Deployment of Fuel
Economy Technologies for Light-Duty Vehicles,
National Academy of Sciences (2015).
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NHTSA’s baseline results and casualty
risk per VMT;
• the 2012 DRI reports on, among
other things, the effects of mass
reduction on crash frequency and
fatality risk per crash;
• LBNL’s subsequent review of DRI’s
study;
• the 2015 National Academy of
Sciences Report; and
• the 2017 NBER working paper
analyzing the relationships among
traffic fatalities, CAFE standards, and
distributions of MY 1989–2005 lightduty vehicle curb weights.
A detailed discussion of each analysis
is discussed in Chapter 11 of the PRIA
accompanying this proposed rule.
(b) Recent NHTSA Analysis Supporting
CAFE Rulemaking
As mentioned previously, NHTSA
and EPA’s 2012 joint final rule for MYs
2017 and beyond set ‘‘footprint-based’’
standards, with footprint being defined
as roughly equal to the wheelbase
multiplied by the average of the front
and rear track widths. Basing standards
on vehicle footprint ideally helps to
discourage vehicle manufacturers from
downsizing their vehicles; the agencies
set higher (more stringent) mile per
gallon (mpg) targets for smaller-footprint
vehicles but would not similarly
discourage mass reduction that
maintains footprint while potentially
improving fuel economy. Several
technologies, such as substitution of
light, high-strength materials for
conventional materials during vehicle
redesigns, have the potential to reduce
weight and conserve fuel while
maintaining a vehicle’s footprint and
maintaining or possibly improving the
vehicle’s structural strength and
handling.
In considering what technologies are
available for improving fuel economy,
including mass reduction, an important
corollary issue for NHTSA to consider is
the potential effect those technologies
may have on safety. NHTSA has thus far
specifically considered the likely effect
of mass reduction that maintains
footprint on fatal crashes. The
relationship between a vehicle’s mass,
size, and fatality risk is complex, and it
varies in different types of crashes. As
mentioned above, NHTSA, along with
others, has been examining this
relationship for more than a decade.301
The safety chapter of NHTSA’s April
2012 final regulatory impact analysis
(FRIA) of CAFE standards for MY 2017–
301 A complete discussion of the historical
analysis of vehicle mass and safety is located in
Chapter 10 of the PRIA accompanying this
proposed rulemaking.
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2021 passenger cars and light trucks
included a statistical analysis of
relationships between fatality risk,
mass, and footprint in MY 2000–2007
passenger cars and LTVs (light trucks
and vans), based on calendar year (CY)
2002–2008 crash and vehicleregistration data; 302 this analysis was
also detailed in the 2012 Kahane report.
The principal findings and
conclusions of the 2012 Kahane report
were mass reduction in the lighter cars,
even while holding footprint constant,
would significantly increase fatality
risk, whereas mass reduction in the
heavier LTVs would reduce societal
fatality risk by reducing the fatality risk
of occupants of lighter vehicles
colliding with those heavier LTVs.
NHTSA concluded, as a result, any
reasonable combination of mass
reductions that held footprint constant
in MY 2017–2021 vehicles—
concentrated, at least to some extent, in
the heavier LTVs and limited in the
lighter cars—would likely be
approximately safety-neutral; it would
not significantly increase fatalities and
might well decrease them.
NHTSA released a preliminary report
(2016 Puckett and Kindelberger report)
on the relationship between fatality risk,
mass, and footprint in June 2016 in
advance of the Draft TAR. The
preliminary report covered the same
scope as the 2012 Kahane report,
offering a detailed description of the
databases, modeling approach, and
analytical results on relationships
among vehicle size, mass, and fatalities
that informed the Draft TAR. Results in
the Draft TAR and the 2016 Puckett and
Kindelberger report are consistent with
results in the 2012 Kahane report;
chiefly, societal effects of mass
reduction are small, and mass reduction
concentrated in larger vehicles is likely
to have a beneficial effect on fatalities,
while mass reduction concentrated in
smaller vehicles is likely to have a
detrimental effect on fatalities.
For the 2016 Puckett and
Kindelberger report and Draft TAR,
NHTSA, working closely with EPA and
the DOE, performed an updated
statistical analysis of relationships
between fatality rates, mass and
footprint, updating the crash and
exposure databases to the latest
available model years. The agencies
analyzed updated databases that
included MY 2003–2010 vehicles in CY
2005–2011 crashes. For this proposed
302 Kahane, C.J. Relationships Between Fatality
Risk, Mass, and Footprint in Model Year 2000–2007
Passenger Cars and LTVs—Final Report, National
Highway Traffic Safety Administration (Aug. 2012),
available at https://crashstats.nhtsa.dot.gov/Api/
Public/ViewPublication/811665.
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rule, databases are the most up-to-date
possible (MY 2004–2011 vehicles in CY
2006–2012), given the processing time
for crash data and the need for enough
crash cases to permit statistically
meaningful analyses. As in previous
analyses, NHTSA has made the new
databases available to the public on its
website, enabling other researchers to
analyze the same data and hopefully
minimizing discrepancies in results that
would have been because of
inconsistencies across databases.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(c) Updated Analysis for This
Rulemaking
The basic analytical method used to
analyze the impacts of weight reduction
on safety in this proposed rule is the
same as in NHTSA’s 2012 Kahane
report, 2016 Puckett and Kindelberger
report, and the Draft TAR: The agency
analyzed cross sections of the societal
fatality rate per billion vehicle miles of
travel (VMT) by mass and footprint,
while controlling for driver age, gender,
and other factors, in separate logistic
regressions by vehicle class and crash
type. ‘‘Societal’’ fatality rates include
fatalities to occupants of all the vehicles
involved in the collisions, plus any
pedestrians.
The temporal range of the data is now
MY 2004–2011 vehicles in CY 2006–
2012, updated from previous databases
of MY 2000–2007 vehicles in CY 2002–
2008 (2012 Kahane Report) and MY
2003–2010 vehicles in CY 2005–2011
(2016 Puckett and Kindelberger report
and Draft TAR). NHTSA purchased a
file of odometer readings by make,
model, and model year from Polk that
helped inform the agency’s improved
VMT estimates. As in the 2012 Kahane
report, 2016 Puckett and Kindelberger
report, and the Draft TAR, the vehicles
are grouped into three classes: Passenger
cars (including both two-door and fourdoor cars); CUVs and minivans; and
truck-based LTVs.
There are nine types of crashes
specified in the analysis. Single-vehicle
crashes include first-event rollovers,
collisions with fixed objects, and
collisions with pedestrians, bicycles and
motorcycles. Two-vehicle crashes
include collisions with: heavy-duty
vehicles; car, CUV, or minivan < 3,187
pounds (the median curb weight of
other, non-case, cars, CUVs and
303 Kahane, C. J. Relationships Between Fatality
Risk, Mass, and Footprint in Model Year 1991–1999
and Other Passenger Cars and LTVs (Mar. 24,
2010), in Final Regulatory Impact Analysis:
Corporate Average Fuel Economy for MY 2012–MY
2016 Passenger Cars and Light Trucks, National
Highway Traffic Safety Administration (Mar. 2010)
at 464–542.
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minivans in fatal crashes in the
database); car, CUV, or minivan ≥ 3,187
pounds; truck-based LTV < 4,360
pounds (the median curb weight of
other truck-based LTVs in fatal crashes
in the database); and truck-based LTV ≥
4,360 pounds. An additional crash type
includes all other fatal crash types (e.g.,
collisions involving more than two
vehicles, animals, or trains). Splitting
the ‘‘other’’ vehicles into a lighter and
a heavier group permits more accurate
analyses of the mass effect in collisions
of two light vehicles. Grouping partnervehicle CUVs and minivans with cars
rather than LTVs is more appropriate
because their front-end profile and
rigidity more closely resembles a car
than a typical truck-based LTV.
The curb weight of passenger cars is
formulated, as in the 2012 Kahane
report, 2016 Puckett and Kindelberger
report, and Draft TAR, as a two-piece
linear variable to estimate one effect of
mass reduction in the lighter cars and
another effect in the heavier cars. The
boundary between ‘‘lighter’’ and
‘‘heavier’’ cars is 3,201 pounds (which
is the median mass of MY 2004–2011
cars in fatal crashes in CY 2006–2012,
up from 3,106 for MY 2000–2007 cars in
CY 2002–2008 in the 2012 NHTSA
safety database, and up from 3,197 for
MY 2003–2010 cars in CY 2005–2011 in
the 2016 NHTSA safety database).
Likewise, for truck-based LTVs, curb
weight is a two-piece linear variable
with the boundary at 5,014 pounds
(again, the MY 2004–2011 median,
higher than the median of 4,594 for MY
2000–2007 LTVs in CY 2002–2008 and
the median of 4,947 for MY 2003–2010
LTVs in CY 2005–2011). Curb weight is
formulated as a simple linear variable
for CUVs and minivans. Historically,
CUVs and minivans have accounted for
a relatively small share of new-vehicle
sales over the range of the data,
resulting in less crash data available
than for cars or truck-based LTVs.
For a given vehicle class and weight
range (if applicable), regression
coefficients for mass (while holding
footprint constant) in the nine types of
crashes are averaged, weighted by the
number of baseline fatalities that would
have occurred for the subgroup MY
2008–2011 vehicles in CY 2008–2012 if
these vehicles had all been equipped
with electronic stability control (ESC).
The adjustment for ESC, a feature of the
analysis added in 2012, takes into
account results will be used to analyze
effects of mass reduction in future
vehicles, which will all be ESCequipped, as required by NHTSA’s
regulations.
Techniques developed in the 2011
(preliminary) and 2012 (final) Kahane
reports have been retained to test
statistical significance and to estimate
95 percent confidence bounds (sampling
error) for mass effects and to estimate
the combined annual effect of removing
100 pounds of mass from every vehicle
(or of removing different amounts of
mass from the various classes of
vehicles), while holding footprint
constant.
NHTSA considered the near
multicollinearity of mass and footprint
to be a major issue in the 2010 Kahane
report 303 and voiced concern about
inaccurately estimated regression
coefficients.304 High correlations
between mass and footprint and
variance inflation factors (VIF) have not
changed from MY 1991–1999 to MY
2004–2011; large vehicles continued to
be, on the average, heavier than small
vehicles to the same extent as in the
previous decade.305
Nevertheless, multicollinearity
appears to have become less of a
problem in the 2012 Kahane, 2016
Puckett and Kindelberger/Draft TAR,
and current NHTSA analyses.
Ultimately, only three of the 27 core
models of fatality risk by vehicle type in
the current analysis indicate the
potential presence of effects of
multicollinearity, with estimated effects
of mass and footprint reduction greater
than two percent per 100-pound mass
reduction and one-square-foot footprint
reduction, respectively; these three
models include passenger cars and
CUVs in first-event rollovers, and CUVs
in collisions with LTVs greater than
4,360 pounds. This result is consistent
with the 2016 Puckett and Kindelberger
report, which also found only three
cases out of 27 models with estimated
effects of mass and footprint reduction
greater than two percent per 100-pound
mass reduction and one-square-foot
footprint reduction.
Table II–45 presents the estimated
percent increase in U.S. societal fatality
risk per 10 billion VMT for each 100-
304 Van Auken and Green also discussed the issue
in their presentations at the NHTSA Workshop on
Vehicle Mass-Size-Safety in Washington, DC
February 25, 2011. More information on the NHTSA
Workshop on Vehicle Mass-Size-Safety is available
at https://one.nhtsa.gov/Laws-&-Regulations/CAFE%E2%80%93-Fuel-Economy/NHTSA-Workshopon-Vehicle-Mass%E2%80%93Size%E2%80%93
Safety.
305 Greene, W. H. Econometric Analysis 266–68
(Macmillan Publishing Company 2d ed. 1993); Paul
D. Allison, Logistic Regression Using the SAS
System 48–51 (SAS Institute Inc. 2001). VIF scores
are in the 6–9 range for curb weight and footprint
in NHTSA’s new database—i.e., in the somewhat
unfavorable 2.5–10 range where near
multicollinearity begins to become a concern in
logistic regression analyses.
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pound reduction in vehicle mass, while
holding footprint constant, for each of
the five vehicle classes:
None of the estimated effects have 95percent confidence bounds that exclude
zero, and thus are not statistically
significant at the 95-percent confidence
level. Two estimated effects are
statistically significant at the 85-percent
level. Societal fatality risk is estimated
to: (1) Increase by 1.2 percent if mass is
reduced by 100 pounds in the lighter
cars; and (2) decrease by 0.61 percent if
mass is reduced by 100 pounds in the
heavier truck-based LTVs. The
estimated increases in societal fatality
risk for mass reduction in the heavier
cars and the lighter truck-based LTVs,
and the estimated decrease in societal
fatality risk for mass reduction in CUVs
and minivans are not significant, even at
the 85-percent confidence level.
Confidence bounds estimate only the
sampling error internal to the data used
in the specific analysis that generated
the point estimate. Point estimates are
also sensitive to the modification of
components of the analysis, as
discussed at the end of this section.
However, this degree of uncertainty is
methodological in nature rather than
statistical.
It is useful to compare the new results
in Table II–45 to results in the 2012
Kahane report (MY 2000–2007 vehicles
in CY 2002–2008) and the 2016 Puckett
and Kindelberger report and Draft TAR
(MY 2003–2010 vehicles in CY 2005–
2011), presented in Table II–46 below:
New results are directionally the same
as in 2012; in the 2016 analysis, the
estimate for lighter LTVs was of
opposite sign (but small magnitude).
Consistent with the 2012 Kahane and
2016 Puckett and Kindelberger reports,
mass reductions in lighter cars are
estimated to lead to increases in
fatalities, and mass reductions in
heavier LTVs are estimated to lead to
decreases in fatalities. However, NHTSA
does not consider this conclusion to be
definitive because of the relatively wide
confidence bounds of the estimates. The
estimated mass effects are similar
among analyses for both classes of
passenger cars; for all reports, the
estimate for lighter passenger cars is
statistically significant at the 85-percent
confidence level, while the estimate for
heavier passenger cars is insignificant.
The estimated mass effect for heavier
truck-based LTVs is stronger in this
analysis and in the 2016 Puckett and
Kindelberger report than in the 2012
Kahane report; both estimates are
statistically significant at the 85-percent
confidence level, unlike the
corresponding insignificant estimate in
the 2012 Kahane report. The estimated
mass effect for lighter truck-based LTVs
is insignificant and positive in this
analysis and the 2012 Kahane report,
while the corresponding estimate in the
2016 Puckett and Kindelberger report
was insignificant and negative.
Vehicle mass continued an historical
upward trend across the MYs in the
newest databases. The average (VMTweighted) masses of passenger cars and
CUVs both increased by approximately
three percent from MYs 2004 to 2011
(3,184 pounds to 3,289 pounds for
passenger cars, and 3,821 pounds to
3,924 pounds for CUVs). Over the same
period, the average mass of minivans
increased by six percent (from 4,204
pounds to 4,462 pounds), and the
average mass of LTVs increased by 10%
(from 4,819 pounds to 5,311 pounds).
306 Median curb weights in the 2012 Kahane
report: 3,106 pounds for cars, 4,594 pounds for
truck-based LTVs. Median curb weights in the 2016
Puckett and Kindelberger report: 3,197 pounds for
cars, 4,947 pounds for truck-based LTVs.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Historical reasons for mass increases
within vehicle classes include:
Manufacturers discontinuing lighter
models; manufacturers re-designing
models to be heavier and larger; and
shifting consumer preferences with
respect to cabin size and overall vehicle
size.
The principal difference between
heavier vehicles, especially truck-based
LTVs, and lighter vehicles, especially
passenger cars, is mass reduction has a
different effect in collisions with
another car or LTV. When two vehicles
of unequal mass collide, the change in
velocity (delta V) is greater in the lighter
vehicle. Through conservation of
momentum, the degree to which the
delta V in the lighter vehicle is greater
than in the heavier vehicle is
proportional to the ratio of mass in the
heavier vehicle to mass in the lighter
vehicle:
Because fatality risk is a positive
function of delta V, the fatality risk in
the lighter vehicle in two-vehicle
collisions is also higher. Removing some
mass from the heavy vehicle reduces
delta V in the lighter vehicle, where
fatality risk is higher, resulting in a large
benefit, offset by a small penalty
because delta V increases in the heavy
vehicle where fatality risk is low—
adding up to a net societal benefit.
Removing some mass from the lighter
vehicle results in a large penalty offset
by a small benefit—adding up to net
harm.
These considerations drive the overall
result: Mass reduction is associated with
an increase in fatality risk in lighter
cars, a decrease in fatality risk in
heavier LTVs, CUVs, and minivans, and
has smaller effects in the intermediate
groups. Mass reduction may also be
harmful in a crash with a movable
object such as a small tree, which may
break if hit by a high mass vehicle
resulting in a lower delta V than may
occur if hit by a lower mass vehicle
which does not break the tree and
therefore has a higher delta V. However,
in some types of crashes not involving
collisions between cars and LTVs,
especially first-event rollovers and
impacts with fixed objects, mass
reduction may not be harmful and may
be beneficial. To the extent lighter
vehicles may respond more quickly to
braking and steering, or may be more
stable because their center of gravity is
lower, they may more successfully
avoid crashes or reduce the severity of
crashes.
Farmer, Green, and Lie, who reviewed
the 2010 Kahane report, again peerreviewed the 2011 Kahane report.307 In
preparing his 2012 report (along with
the 2016 Puckett and Kindelberger
report and Draft TAR), Kahane also took
into account Wenzel’s 308 assessment of
the preliminary report and its peer
reviews, DRI’s analyses published early
in 2012, and public comments such as
the International Council on Clean
Transportation’s comments submitted
on NHTSA and EPA’s 2010 notice of
joint rulemaking.309 These comments
prompted supplementary analyses,
especially sensitivity tests, discussed at
the end of this section.
The regression results are best suited
to predict the effect of a small change in
mass, leaving all other factors, including
footprint, the same. With each
additional change from the current
environment (e.g., the scale of mass
change, presence and prevalence of
safety features, demographic
characteristics), the model may become
less accurate. It is recognized that the
light-duty vehicle fleet in the MY 2021–
2026 timeframe will be different from
the MY 20042011 fleet analyzed here.
Nevertheless, one consideration
provides some basis for confidence in
applying regression results to estimate
effects of relatively large mass
reductions or mass reductions over
longer periods. This is NHTSA’s sixth
evaluation of effects of mass reduction
and/or downsizing,310 comprising
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307 Items 0035 (Lie), 0036 (Farmer) and 0037
(Green) in Docket No. NHTSA–2010–0152.
308 Wenzel, T. An Analysis of the Relationship
Between Casualty Risk Per Crash and Vehicle Mass
and Footprint for Model Year 2000–2007 Light Duty
Vehicles, Lawrence Berkeley National Laboratory
(Dec. 2011), available at https://etapublications.lbl.gov/sites/default/files/lbnl5695e.pdf; Tom Wenzel, Lawrence Berkeley
National Laboratory -Assessment of NHTSA Report
Relationships Btw Fatality Risk Mass and Footprint
in MY 2000–2007 PC and LTV,’’ Docket NHTSA–
2010–0131–0315; and a peer review of Wenzel’s
reports—Peer Review of LBNL Statistical Analysis
of the Effect of Vehicle Mass & Footprint Reduction
on Safety (LBNL Phase 1 and 2 Reports), prepared
for U.S. EPA (Feb. 2012), available at Docket ID
NHTSA–2010–0131–0328.
309 Comment by International Council on Clean
Transportation, Docket ID NHTSA–2010–0131–
0258.
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310 As outlined throughout this section, NHTSA’s
six related studies include the new analysis
supporting this rulemaking, and: Kahane, C. J.
Vehicle Weight, Fatality Risk and Crash
Compatibility of Model Year 1991–99 Passenger
Cars and Light Trucks, National Highway Traffic
Safety Administration (Oct. 2003), available at
https://crashstats.nhtsa.dot.gov/Api/Public/View
Publication/809662; Kahane, C. J. Relationships
Between Fatality Risk, Mass, and Footprint in
Model Year 1991–1999 and Other Passenger Cars
and LTVs (Mar. 24, 2010), in Final Regulatory
Impact Analysis: Corporate Average Fuel Economy
for MY 2012–MY 2016 Passenger Cars and Light
Trucks, National Highway Traffic Safety
Administration (Mar. 2010) at 464–542; Kahane, C.
J. Relationships Between Fatality Risk, Mass, and
Footprint in Model Year 2000–2007 Passenger Cars
and LTVs—Preliminary Report, National Highway
Traffic Safety Administration (Nov. 2011), available
at Docket ID NHTSA–2010–0152- 0023); Kahane, C.
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
databases ranging from MYs 1985 to
2011.
Results of the six studies are not
identical, but they have been consistent
to a point. During this time period,
many makes and models have increased
substantially in mass, sometimes as
much as 30–40%.311 If the statistical
analysis has, over the past years, been
able to accommodate mass increases of
this magnitude, perhaps it will also
succeed in modeling effects of mass
reductions of approximately 10–20%,
should they occur in the future.
sradovich on DSK3GMQ082PROD with PROPOSALS2
J. Relationships Between Fatality Risk, Mass, and
Footprint in Model Year 2000–2007 Passenger Cars
and LTVs: Final Report, NHTSA Technical Report.
Washington, DC: NHTSA, Report No. DOT–HS–
811–665; and Puckett, S. M., & Kindelberger, J. C.
Relationships between Fatality Risk, Mass, and
Footprint in Model Year 2003–2010 Passenger Cars
and LTVs—Preliminary Report, National Highway
Traffic Safety Administration (June 2016), available
at https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/
2016-prelim-relationship-fatalityrisk-massfootprint-2003-10.pdf.
311 For example, one of the most popular models
of small 4-door sedans increased in curb weight
from 1,939 pounds in MY 1985 to 2,766 pounds in
MY 2007, a 43% increase. A high-sales mid-size
sedan grew from 2,385 to 3,354 pounds (41%); a
best-selling pickup truck from 3,390 to 4,742
pounds (40%) in the basic model with two-door cab
and rear-wheel drive; and a popular minivan from
2,940 to 3,862 pounds (31%).
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(d) Calculation of MY 2021–2026 Safety
Impact
Neither CAFE standards nor this
analysis mandate mass reduction, or
mandate mass reduction occur in any
specific manner. However, mass
reduction is one of the technology
applications available to manufacturers,
and thus a degree of mass reduction is
allowed within the CAFE model to: (1)
Determine capabilities of manufacturers;
and (2) to predict cost and fuel
consumption effects of improved CAFE
standards.
The agency utilized the relationships
between weight and safety from the new
NHTSA analysis, expressed as
percentage increases in fatalities per
100-pound weight reduction, and
examined the weight impacts assumed
in this CAFE analysis. The effects of
mass reduction on safety were estimated
relative to estimated baseline levels of
safety across vehicle classes and model
years. To identify baseline levels of
safety, the agency examined effects of
identifiable safety trends over lifetimes
of vehicles produced in each model
year. The projected effectiveness of
existing and forthcoming safety
technologies and expected on-road fleet
penetration of safety technologies were
incorporated into observed trends in
fatality rates to estimate baseline fatality
rates in future years across vehicle
classes and model years.
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The agency assumed safety trends
will result in a reduction in the target
population of fatalities from which the
vehicle mass impacts are derived. Table
II–47 through Table II–52 show results
of NHTSA’s vehicle mass-size-safety
analysis over the cumulative lifetime of
MY 1977–2029 vehicles, for both the
CAFE and GHG programs, based on the
MY 2016 baseline fleet, accounting for
the projected safety baselines. The
reported fatality impacts are
undiscounted, but the monetized safety
impacts are discounted at three-percent
and seven-percent discount rates. The
reported fatality impacts are estimated
increases or decreases in fatalities over
the lifetime of the model year fleet. A
positive number means that fatalities are
projected to increase; a negative number
(in parentheses) means that fatalities are
projected to decrease.
Results are driven extensively by the
degree to which mass is reduced in
relatively light passenger cars and in
relatively heavy vehicles because their
coefficients in the logistic regression
analysis have the most significant
values. We assume any impact on
fatalities will occur over the lifetime of
the vehicle, and the chance of a fatality
occurring in any particular year is
directly related to the weighted vehicle
miles traveled in that year.
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#8
20212026
O.O%Near
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O.O%Near
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No
Change
20212026
0.5%Near
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0.5%Near
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No
Change
20212026
0.5%Near
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0.5%Near
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Phaseout
20222026
20212026
l.O%Near
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2.0%Near
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No
Change
20222026
l.O%Near
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No
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20212026
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Fatalities
-160
-147
-143
-173
-152
-73
-12
-30
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs ($ Billion, 7%
Discount Rate)
-0.9
-0.9
-0.8
-1.1
-0.9
-0.4
-0.1
-0.2
-0.5
-0.5
-0.5
-0.6
-0.5
-0.2
0.0
-0.1
Non-Fatal Crash Costs($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs($
Billion, 7% Discount Rate)
-1.5
-1.3
-1.3
-1.7
-1.5
-0.7
-0.1
-0.3
-0.8
-0.7
-0.7
-1.0
-0.8
-0.4
-0.1
-0.2
Total Crash Costs ($ Billion,
3% Discount Rate)
Total Crash Costs ($ Billion,
7% Discount Rate)
-2.4
-2.2
-2.1
-2.7
-2.4
-1.1
-0.2
-0.5
-1.3
-1.2
-1.2
-1.6
-1.4
-0.6
-0.1
-0.3
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
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Table 11-47- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Light-Duty Vehicles, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars
Discounted at 3% and 7%
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O.O%Near
PC
O.O%Near
LT
No
Change
#2
20212026
0.5%Near
PC
0.5%Near
LT
No
Change
#3
20212026
0.5%Near
PC
0.5%Near
LT
Phaseout
20222026
#4
20212026
l.O%Near
PC
2.0%Near
LT
No
Change
#5
#6
202220212026
2026
l.O%Near 2.0%Near
PC
PC
2.0%Near 3.0%Near
LT
LT
No
No
Change
Change
#7
20212026
2.0%Near
PC
3.0%Near
LT
Phaseout
20222026
#8
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
-281
-262
-234
-197
-167
-87
-17
-42
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs ($ Billion, 7%
Discount Rate)
-1.7
-1.6
-1.4
-1.2
-1.0
-0.5
-0.1
-0.3
-1.0
-0.9
-0.8
-0.7
-0.6
-0.3
-0.1
-0.1
Non-Fatal Crash Costs($ Billion,
3% Discount Rate)
Non-Fatal Crash Costs($ Billion,
7% Discount Rate)
-2.7
-2.5
-2.3
-1.9
-1.6
-0.8
-0.2
-0.4
-1.6
-1.5
-1.3
-1.1
-0.9
-0.5
-0.1
-0.2
-4.4
-4.2
-3.7
-3.1
-2.6
-1.4
-0.3
-0.7
-2.5
-2.4
-2.1
-1.8
-1.5
-0.8
-0.1
-0.4
Model Years Affected by Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Total Crash Costs($ Billion, 3%
Discount Rate)
Total Crash Costs($ Billion, 7%
Discount Rate)
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-48- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Passenger Cars, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars
Discounted at 3% and 7%
43115
EP24AU18.071
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O.O%Near
LT
No
Change
#2
20212026
0.5%Near
PC
0.5%Near
LT
No
Change
#3
20212026
0.5%Near
PC
0.5%Near
LT
Phaseout
20222026
#4
20212026
l.O%Near
PC
2.0%Near
LT
No
Change
#5
20222026
l.O%Near
PC
2.0%Near
LT
No
Change
#6
20212026
2.0%Near
PC
3.0%Near
LT
No
Change
#7
20212026
2.0%Near
PC
3.0%Near
LT
Phaseout
20222026
#8
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
120
116
92
25
15
14
6
12
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs($ Billion, 7%
Discount Rate)
0.8
0.8
0.6
0.2
0.1
0.1
0.0
0.1
0.5
0.5
0.4
0.1
0.1
0.1
0.0
0.0
1.2
1.2
0.9
0.2
0.2
0.1
0.1
0.1
0.8
0.7
0.6
0.1
0.1
0.1
0.0
0.1
2.0
2.0
1.5
0.4
0.3
0.2
0.1
0.2
1.3
1.2
1.0
0.2
0.2
0.1
0.0
0.1
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Non-Fatal Crash Costs ($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs ($
Billion, 7% Discount Rate)
Total Crash Costs($ Billion,
3% Discount Rate)
Total Crash Costs($ Billion,
7% Discount Rate)
EP24AU18.072
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-49- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Light Trucks, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities U ndiscounted, Dollars Discounted
at3% and 7%
sradovich on DSK3GMQ082PROD with PROPOSALS2
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#3
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#8
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O.O%Near
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No
Change
20212026
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0.5%Near
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No
Change
20212026
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PC
0.5%Near
LT
Phaseout
20222026
20212026
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2.0%Near
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20222026
l.O%Near
PC
2.0%Near
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No
Change
20212026
2.0%Near
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3.0%Near
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No
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20212026
2.0%Near
PC
3.0%Near
LT
Phaseout
20222026
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
-468
-461
-410
-297
-219
-186
-111
-85
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs ($ Billion, 7%
Discount Rate)
-2.9
-2.9
-2.6
-1.9
-1.4
-1.2
-0.7
-0.5
-1.7
-1.7
-1.5
-1.1
-0.8
-0.7
-0.5
-0.3
Non-Fatal Crash Costs($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs($
Billion, 7% Discount Rate)
-4.6
-4.5
-4.0
-2.9
-2.2
-1.9
-1.1
-0.8
-2.7
-2.7
-2.4
-1.7
-1.3
-1.1
-0.7
-0.5
Total Crash Costs ($ Billion,
3% Discount Rate)
Total Crash Costs ($ Billion,
7% Discount Rate)
-7.5
-7.4
-6.6
-4.8
-3.5
-3.1
-1.9
-1.4
-4.4
-4.4
-3.9
-2.8
-2.1
-1.9
-1.2
-0.8
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-50- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Light-Duty Vehicles, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars
Discounted at 3% and 7%
43117
EP24AU18.073
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#2
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Change
#3
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#5
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No
Change
#6
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3.0%Near
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No
Change
#7
20212026
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PC
3.0%Near
LT
Phaseout
20222026
#8
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
-567
-551
-502
-389
-242
-205
-139
-92
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs ($ Billion, 7%
Discount Rate)
-3.6
-3.5
-3.2
-2.5
-1.5
-1.3
-0.9
-0.6
-2.1
-2.1
-1.9
-1.5
-0.9
-0.8
-0.6
-0.3
Non-Fatal Crash Costs($ Billion,
3% Discount Rate)
Non-Fatal Crash Costs($ Billion,
7% Discount Rate)
-5.6
-5.5
-5.0
-3.9
-2.4
-2.1
-1.4
-0.9
-3.3
-3.3
-3.0
-2.3
-1.4
-1.3
-0.9
-0.5
Total Crash Costs($ Billion, 3%
Discount Rate)
Total Crash Costs($ Billion, 7%
Discount Rate)
-9.2
-9.0
-8.2
-6.4
-3.9
-3.4
-2.3
-1.5
-5.5
-5.3
-4.9
-3.8
-2.3
-2.0
-1.5
-0.9
Model Years Affected by Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
EP24AU18.074
Table 11-51- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Passenger Cars, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted
at3% and 7%
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#3
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0.5%/Year
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PC
2.0%/Year
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PC
2.0%/Year
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Change
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Phaseout
20222026
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PC
3.0%/Year
LT
No
Change
Fatalities
98
90
91
92
23
19
28
6
Fatality Costs($ Billion, 3%
Discount Rate)
Fatality Costs($ Billion, 7%
Discount Rate)
0.7
0.6
0.6
0.6
0.2
0.1
0.2
0.0
0.4
0.4
0.4
0.4
0.1
0.1
0.1
0.0
Non-Fatal Crash Costs ($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs ($
Billion, 7% Discount Rate)
1.0
1.0
1.0
1.0
0.2
0.2
0.3
0.1
0.7
0.6
0.6
0.6
0.1
0.1
0.2
0.0
1.7
1.6
1.6
1.6
0.4
0.3
0.5
0.1
1.1
1.0
1.0
1.0
0.2
0.2
0.3
0.0
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Total Crash Costs ($Billion,
3% Discount Rate)
Total Crash Costs ($Billion,
7% Discount Rate)
43119
vehicles in all alternatives evaluated.
The effects of mass changes on fatalities
E:\FR\FM\24AUP2.SGM
decrease in fatalities over the
cumulative lifetime of MY 1977–2029
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
For all light-duty vehicles, mass
changes are estimated to lead to a
VerDate Sep<11>2014
EP24AU18.075
Table 11-52- Comparison of the Calculated Vehicle-Mass-Related Fatality Impacts over the Lifetime of MY 1977 through MY
2029 Light Trucks, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted at
3% and 7%
43120
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
range from a combined decrease
(relative to the augural standards, the
baseline) of 12 fatalities for Alternative
#7 to a combined decrease of 173
fatalities for Alternative #4. The
difference in results by alternative
depends upon how much weight
reduction is used in that alternative and
the types and sizes of vehicles to which
the weight reduction applies. The
decreases in fatalities are driven by
impacts within passenger cars
(decreases of between 17 and 281
fatalities) and are offset by impacts
within light trucks (increases of between
6 and 120 fatalities).
Additionally, social effects of
increasing fatalities can be monetized
using NHTSA’s estimated
comprehensive cost per life of
$9,900,000 in 2016 dollars. This
consists of a value of a statistical life of
$9.6 million in 2015 dollars plus
external economic costs associated with
fatalities such as medical care,
insurance administration costs and legal
costs, updated for inflation to 2016
dollars.
Typically, NHTSA would also
estimate the effect on injuries and add
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
that to social costs of fatalities, but in
this case NHTSA does not have a model
estimating the effect of vehicle mass on
injuries. Blincoe et al. estimates that
fatalities account for 39.5% of total
comprehensive costs due to injury.312 If
vehicle mass impacts non-fatal injuries
proportionally to its impact on fatalities,
then total costs would be approximately
2.53 (1⁄0.395) times the value of fatalities
alone or around $25.07 million per
fatality. NHTSA has selected this value
as representative of the relationship
between fatality costs and injury costs
because this approach is internally
consistent among NHTSA studies.
Changes in vehicle mass are estimated
to decrease social safety costs over the
lifetime of the nine model years by
between $176 million (for Alternative
#7) and $2.7 billion (for Alternative #4)
312 Blincoe, L. et al., The Economic and Social
Impact of Motor Vehicle Crashes, 2010 (Revised),
National Highway Traffic Safety Administration
(May 2015), available at https://
crashstats.nhtsa.dot.gov/Api/Public/View
Publication/812013. The estimate of 39.5% (see
Table 1–8) is equal to the estimated value of MAIS6
(fatal) injuries in vehicle incidents divided by the
estimated value of MAIS0–MAIS6 (non-fatal and
fatal) injuries in vehicle incidents.
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relative to the augural standards at a
three-percent discount rate and by
between $97 million and $1.6 billion at
a seven-percent discount rate. The
estimated decreases in social safety
costs are driven by estimated decreases
in costs associated with passenger cars,
ranging from $264 million (for
Alternative #7) to $4.4 billion (for
Alternative #1) relative to the Augural
standards at a three-percent discount
rate and by between $146 million and
$2.5 billion at a seven-percent discount
rate. The estimated decreases in costs
associated with passenger cars are offset
by estimated increases in costs
associated with light trucks, ranging
from $88 million (for Alternative #7) to
$2.0 billion (for Alternative #1) relative
to the Augural standards at a threepercent discount rate and by between
$49 million and $1.3 billion at a sevenpercent discount rate.
Table II–53 through Table II–55
presents average annual estimated safety
effects of vehicle mass changes, for CYs
2035–2045:
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Change
#2
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Change
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Change
#5
20222026
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PC
2.0%Near
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No
Change
#6
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3.0%Near
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No
Change
#7
20212026
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PC
3.0%Near
LT
Phaseout
20222026
#8
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
-22
-19
-17
-17
-16
-6
0
-2
Fatality Costs($ Billion,
3% Discount Rate)
Fatality Costs($ Billion,
7% Discount Rate)
-0.11
-0.10
-0.08
-0.08
-0.08
-0.03
0.00
-0.01
-0.04
-0.04
-0.03
-0.03
-0.03
-0.01
0.00
0.0
Non-Fatal Crash Costs ($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs ($
Billion, 7% Discount Rate)
-0.17
-0.15
-0.13
-0.13
-0.13
-0.05
0.00
-0.02
-0.07
-0.06
-0.05
-0.05
-0.05
-0.02
0.00
0.0
Total Crash Costs($
Billion, 3% Discount Rate)
Total Crash Costs($
Billion, 7% Discount Rate)
-0.27
-0.24
-0.22
-0.21
-0.21
-0.07
0.00
-0.03
-0.11
-0.10
-0.09
-0.09
-0.09
-0.03
0.00
-0.01
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-53- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in
Light-Duty Vehicles, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted
at3% and 7%
43121
EP24AU18.076
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Change
#3
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No
Change
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Phaseout
20222026
#8
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PC
3.0%Near
LT
No
Change
Fatalities
-33
-31
-27
-20
-18
-8
-1
-3
Fatality Costs($ Billion,
3% Discount Rate)
Fatality Costs($ Billion,
7% Discount Rate)
-0.17
-0.15
-0.13
-0.10
-0.09
-0.04
0.00
-0.02
-0.07
-0.06
-0.05
-0.04
-0.04
-0.02
0.00
-0.01
-0.26
-0.24
-0.21
-0.16
-0.14
-0.06
-0.01
-0.02
-0.11
-0.10
-0.09
-0.06
-0.06
-0.02
0.00
-0.01
-0.42
-0.39
-0.34
-0.26
-0.23
-0.10
-0.01
-0.04
-0.18
-0.16
-0.14
-0.11
-0.09
-0.04
-0.01
-0.02
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Non-Fatal Crash Costs($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs($
Billion, 7% Discount Rate)
Total Crash Costs($
Billion, 3% Discount Rate)
Total Crash Costs($
Billion, 7% Discount Rate)
EP24AU18.077
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-54- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in
Passenger Cars, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities U ndiscounted, Dollars Discounted at
3% and 7%
sradovich on DSK3GMQ082PROD with PROPOSALS2
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Change
#2
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Change
#3
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PC
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#5
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PC
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Change
#6
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PC
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Change
#7
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PC
3.0%/Year
LT
Phaseout
20222026
#8
20222026
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PC
3.0%/Year
LT
No
Change
Fatalities
12
11
10
4
2
2
1
1
Fatality Costs($ Billion,
3% Discount Rate)
Fatality Costs($ Billion,
7% Discount Rate)
0.06
0.06
0.05
0.02
0.01
0.01
0.00
0.01
0.02
0.02
0.02
0.01
0.00
0.00
0.00
0.00
Non-Fatal Crash Costs ($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs ($
Billion, 7% Discount Rate)
0.09
0.09
0.08
0.03
0.01
0.01
0.01
0.01
0.04
0.04
0.03
0.01
0.01
0.01
0.00
0.00
Total Crash Costs($
Billion, 3% Discount Rate)
Total Crash Costs($
Billion, 7% Discount Rate)
0.15
0.15
0.12
0.05
0.02
0.02
0.01
0.01
0.06
0.06
0.05
0.02
0.01
0.01
0.00
0.01
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-55- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in Light
Trucks, by CAFE Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted at 3% and
43123
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43124
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PC
O.O%Near
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No
Change
#2
20212026
0.5%Near
PC
0.5%Near
LT
No
Change
#3
20212026
0.5%Near
PC
0.5%Near
LT
Phaseout
20222026
#4
20212026
l.O%Near
PC
2.0%Near
LT
No
Change
#5
20222026
l.O%Near
PC
2.0%Near
LT
No
Change
#6
20212026
2.0%Near
PC
3.0%Near
LT
No
Change
#7
20212026
2.0%Near
PC
3.0%Near
LT
Phaseout
20222026
#8
20222026
2.0%Near
PC
3.0%Near
LT
No
Change
Fatalities
-56
-52
-42
-34
-15
-13
-8
-5
Fatality Costs($ Billion,
3% Discount Rate)
Fatality Costs($ Billion,
7% Discount Rate)
-0.27
-0.25
-0.21
-0.17
-0.08
-0.07
-0.04
-0.02
-0.11
-0.11
-0.09
-0.07
-0.03
-0.03
-0.02
-0.01
-0.43
-0.40
-0.32
-0.26
-0.12
-0.11
-0.06
-0.04
-0.18
-0.16
-0.13
-0.11
-0.05
-0.04
-0.03
-0.02
-0.70
-0.65
-0.53
-0.43
-0.19
-0.17
-0.10
-0.06
-0.29
-0.27
-0.22
-0.18
-0.08
-0.07
-0.04
-0.02
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Non-Fatal Crash Costs($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs($
Billion, 7% Discount Rate)
Total Crash Costs($
Billion, 3% Discount Rate)
Total Crash Costs($
Billion, 7% Discount Rate)
EP24AU18.079
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-56- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in
Light-Duty Vehicles, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted
at3% and 7%
sradovich on DSK3GMQ082PROD with PROPOSALS2
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#4
#5
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2.0%Ncar 2.0%Ncar
LT
LT
No
No
Change
Change
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#1
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O.O%Ncar
LT
No
Change
#2
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PC
0.5%Ncar
LT
No
Change
#3
20212026
O.So/o!Y ear
PC
0.5o/o/Ycar
Fatalities
-65
-61
-53
-39
-20
-16
-11
-8
Fatality Costs ($Billion, 3% Discount
Rate)
Fatality Costs ($Billion, 7% Discount
Rate)
-0.32
-0.30
-0.26
-0.19
-0.10
-0.08
-0.06
-0.04
-0.13
-0.12
-0.11
-0.08
-0.04
-0.03
-0.02
-0.02
-0.50
-0.47
-0.41
-0.30
-0.15
-0.12
-0.09
-0.06
-0.21
-0.19
-0.17
-0.12
-0.06
-0.05
-0.04
-0.02
Total Crash Costs ($ Billion, 3%
Discount Rate)
-0.82
-0.77
-0.67
-0.49
-0.25
-0.20
-0.14
-0.10
Total Crash Costs ($ Billion, 7%
Discount Rate)
-0.41
-0.37
-0.25
-0.38
-0.23
-0.49
-0.33
-0.44
Model Y cars Affected by Policy
Annual Rate of Stringency Increase
AC/Off-Cycle Procedures
Non-Fatal Crash Costs ($Billion, 3%
Discount Rate)
Non-Fatal Crash Costs ($Billion, 7%
Discount Rate)
LT
Phaseout
20222026
#6
20212026
2.0%Near
PC
3.0%Ncar
LT
No
Change
#7
20212026
2.0%Near
PC
3.0%Ncar
LT
Phaseout
20222026
#8
2022-2026
2.0o/o/Year PC
3.0o/o/Year LT
No Change
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Table 11-57- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in
Passenger Cars, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted at
3% and 7%
43125
EP24AU18.080
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43126
7%
Alternative
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24AUP2
2045. The effects of mass changes on
fatalities range from a combined
E:\FR\FM\24AUP2.SGM
average annual decrease in fatalities in
all alternatives evaluated for CYs 2035–
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O.Oo/o!Y ear
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No
Change
20212026
0.5%/Year
PC
0.5%/Year
LT
No
Change
20212026
0.5%/Year
PC
0.5%/Year
LT
Phaseout
20222026
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1.0%/Year
PC
2.0%/Year
LT
No
Change
20222026
1.0%/Year
PC
2.0%/Year
LT
No
Change
20212026
2.0%/Year
PC
3.0%/Year
LT
No
Change
20212026
2.0%/Year
PC
3.0%/Year
LT
Phaseout
20222026
20222026
2.0%/Year
PC
3.0%/Year
LT
No
Change
Fatalities
10
9
10
5
5
2
3
3
Fatality Costs($ Billion,
3% Discount Rate)
Fatality Costs($ Billion,
7% Discount Rate)
0.05
0.05
0.05
0.02
0.02
0.01
0.02
0.02
0.02
0.02
0.02
0.01
0.01
0.00
0.01
0.01
Non-Fatal Crash Costs ($
Billion, 3% Discount Rate)
Non-Fatal Crash Costs ($
Billion, 7% Discount Rate)
0.08
0.07
0.08
0.04
0.04
0.02
0.03
0.02
0.03
0.03
0.03
0.02
0.01
0.01
0.01
0.01
Total Crash Costs($
Billion, 3% Discount Rate)
Total Crash Costs($
Billion, 7% Discount Rate)
0.12
0.12
0.14
0.06
0.06
0.03
0.04
0.04
0.05
0.05
0.06
0.03
0.02
0.01
0.02
0.02
Model Years Affected by
Policy
Annual Rate of Stringency
Increase
AC/Off-Cycle Procedures
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
For all light-duty vehicles, mass
changes are estimated to lead to an
VerDate Sep<11>2014
EP24AU18.081
Table 11-58- Comparison of the Calculated Annual Average Vehicle-Mass-Related Fatality Impacts for CY 2035-2045 in Light
Trucks, by GHG Policy Alternative, Relative to Augural Standards, Fatalities Undiscounted, Dollars Discounted at 3% and
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
decrease (relative to the Augural
standards) of 1 fatality per year for
Alternative #7 to a combined increase of
22 fatalities per year for Alternative #1.
The difference in the results by
alternative depends upon how much
weight reduction is used in that
alternative and the types and sizes of
vehicles to which the weight reduction
applies. The decreases in fatalities are
generally driven by impacts within
passenger cars (decreases of between 1
and 33 fatalities per year relative to the
Augural standards) and are generally
offset by impacts within light trucks
(increases of between 1 and 12 fatalities
per year).
Changes in vehicle mass are estimated
to decrease average annual social safety
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
costs in CY 2035–2045 by between $2
million (for Alternative #7) and $271
million (for Alternative #1) relative to
the Augural standards at a three-percent
discount rate and by between $1 million
and $111 million at a seven-percent
discount rate. The estimated decreases
in social safety costs are generally
driven by estimated decreases in costs
associated with passenger cars,
decreasing between $13 million (for
Alternative #7) and $424 million (for
Alternative #1) relative to the Augural
standards at a three-percent discount
rate and decreasing between $5 million
and $175 million at a seven-percent
discount rate. The estimated decreases
in costs associated with passenger cars
are generally offset by estimated
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43127
increases in costs associated with light
trucks, decreasing between $11 million
(for Alternative #7) and $153 million
(for Alternative #1) relative to the
Augural standards at a three-percent
discount rate and decreasing between $5
million and $64 million at a sevenpercent discount rate.
To help illuminate effects at the
model year level, Table II–59 presents
the lifetime fatality impacts associated
with vehicle mass changes for passenger
cars, light trucks, and all light-duty
vehicles by model year under
Alternative #1, relative to the Augural
standards for the CAFE Program. Table
II–59 presents an analogous table for the
GHG Program.
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24AUP2
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in MYs 2017 and 2018 to an increase of
14 fatalities in MYs 2026 through 2029.
Altogether, light-duty vehicle fatality
reductions associated with mass
changes under Alternative #1 are
E:\FR\FM\24AUP2.SGM
fatalities), peaking in MY 2025 (37
fatalities). Corresponding estimates of
light truck fatalities associated with
mass changes are generally positive,
ranging from a decrease of one fatality
PO 00000
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
1977
2017
2018
2019
2020
2021
2022
202
3
2024
2025
2026
2027
2028
2029
2016
-2
-3
-2
-3
-5
-11
-16
-29
-30
-37
-35
-35
-36
-36
-280
-2
-1
-1
3
2
11
13
12
13
12
14
14
14
14
118
-3
-3
-3
0
-3
1
-3
-16
-17
-24
-23
-22
-22
-22
-160
Passenger
Cars
Light
Trucks
Total
TOTAL
Table 11-60- Comparison of Lifetime Vehicle-Mass-Related Fatality Impacts by Model Year for GHG Program under
Alternative #1. Relative to Au!!ural Standards. Fatalities Undiscounted
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
MY
1977
2017
2018
2019
2020
2021
2022
202
3
2024
2025
2026
2027
2028
2029
2016
-2
-4
-9
-10
-22
-29
-37
-49
-57
-60
-68
-74
-75
-72
-568
-2
-1
0
1
2
10
13
11
12
13
11
7
9
11
97
-5
-4
-10
-9
-20
-19
-24
-38
-45
-47
-57
-66
-65
-60
-469
Passenger
Cars
Light
Trucks
Total
TOTAL
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Under Alternative #1, passenger car
fatalities associated with mass changes
are estimated to decrease generally from
MY 2017 (decrease of three fatalities)
through MY 2029 (decrease of 36
VerDate Sep<11>2014
EP24AU18.082
Table 11-59- Comparison of Lifetime Vehicle-Mass-Related Fatality Impacts by Model Year for CAFE Program under
Alternative #1. Relative to Ammral Standards. Fatalities Undiscounted
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
estimated to be concentrated among MY
2023 through MY 2029 vehicles (146 out
of 165, or 91% of net fatalities
mitigated).
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
Table II–61 and Table II–62 present
estimates of monetized lifetime social
safety costs associated with mass
changes by model year at three-percent
and seven-percent discount rates,
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43129
respectively for the CAFE Program.
Table II–63 and Table II–64 show
comparable tables from the perspective
of the GHG Program.
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Passenge
r Cars
Light
Trucks
Total
19772016
-0.01
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
-0.02
-0.02
-0.01
-0.03
-0.07
-0.11
-0.19
-0.20
-0.23
-0.22
-0.21
-0.21
-0.20
-1.73
-0.01
0.00
-0.01
0.02
0.02
0.08
0.10
0.08
0.09
0.08
0.08
0.09
0.09
0.08
0.79
-0.02
-0.02
-0.02
0.01
-0.01
0.01
-0.01
-0.10
-0.11
-0.15
-0.14
-0.13
-0.13
-0.12
-0.94
Sfmt 4725
E:\FR\FM\24AUP2.SGM
Table II-62 - Com paris on of Lifetime Social Safety Costs Associated with Mass Changes for CAFE Program by Model Year
Amwral
Dollars
Discounted at 7'X
der ------------.Alternative #1. --------·Relative to
------------------ Standards.
·--------------------------------MY
MY MY MY MY MY MY MY MY MY MY MY MY MY TOTAL
-;;
24AUP2
Passenger
Cars
Light
Trucks
Total
---;;-
19772016
-0.01
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
-0.01
-0.01
-0.01
-0.02
-0.04
-0.07
-0.12
-0.12
-0.14
-0.13
-0.12
-0.11
-0.10
-0.99
0.00
0.00
0.00
0.02
0.02
0.06
0.06
0.06
0.05
0.05
0.05
0.05
0.05
0.04
0.49
-0.01
-0.01
-0.01
0.01
0.00
0.01
0.00
-0.06
-0.07
-0.09
-0.08
-0.07
-0.06
-0.06
-0.50
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
EP24AU18.083
Table 11-61- Comparison of Lifetime Social Safety Costs Associated with Mass Changes for CAFE Program by Model Year
der Alternative #1. Relative to Amwral Standards. Dollars Discounted at 3'X
MY
MY MY MY MY MY MY MY MY MY MY MY MY MY TOTAL
sradovich on DSK3GMQ082PROD with PROPOSALS2
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24AUP2
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
-0.03
-0.06
-0.07
-0.16
-0.20
-0.25
-0.33
-0.37
-0.38
-0.42
-0.44
-0.44
-0.41
-3.59
-0.01
0.00
0.00
0.01
0.02
0.07
0.09
0.08
0.08
0.08
0.07
0.05
0.06
0.07
0.67
-0.02
-0.03
-0.07
-0.06
-0.14
-0.13
-0.16
-0.25
-0.29
-0.30
-0.35
-0.40
-0.38
-0.34
-2.92
Table 11-64 - Comparison of Lifetime Social Safety Costs Associated with Mass Changes for GHG Program by Model Year
Amwral
Dollars
Discounted at 7'X
der ------------.Alternative #1. --------·Relative to
------------------ Standards.
·--------------------------------MY
MY MY MY MY MY MY MY MY MY MY MY MY MY TOTAL
-;;
Passenger
Cars
Light
Trucks
Total
---;;-
19772016
-0.01
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
-0.02
-0.05
-0.05
-0.11
-0.14
-0.17
-0.21
-0.23
-0.23
-0.24
-0.25
-0.23
-0.21
-2.13
0.00
0.00
0.00
0.01
0.02
0.05
0.06
0.05
0.05
0.05
0.04
0.03
0.03
0.03
0.43
-0.01
-0.02
-0.05
-0.04
-0.10
-0.08
-0.10
-0.16
-0.18
-0.18
-0.20
-0.22
-0.20
-0.17
-1.70
43131
partially by increases associated with
light trucks. At a three-percent discount
E:\FR\FM\24AUP2.SGM
model year, with decreases associated
with passenger cars generally offset
PO 00000
Passenge
r Cars
Light
Trucks
Total
19772016
-0.01
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
23:42 Aug 23, 2018
Lifetime social safety costs are
estimated to decrease generally by
VerDate Sep<11>2014
EP24AU18.084
Table 11-63 - Comparison of Lifetime Social Safety Costs Associated with Mass Changes for GHG Program by Model Year
der Alternative #1. Relative to Amwral Standards. Dollars Discounted at 3'X
MY
MY MY MY MY MY MY MY MY MY MY MY MY MY TOTAL
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
rate, decreases in lifetime social safety
costs related to passenger cars are
estimated to range from $13 million for
existing (MY 1977 through MY 2016)
cars, to $230 million for MY 2025 cars.
The corresponding estimates at a sevenpercent discount rate range from $7
million to $136 million. At a threepercent discount rate, impacts on
lifetime social safety costs related to
light trucks are estimated to range from
a decrease of $5 million for MY 2017
light trucks to an increase of $96 million
for MY 2022 light trucks. The
corresponding estimates at a sevenpercent discount rate range from $3
million to $65 million.
Consistent with the analysis of fatality
impacts by model year in Table II–61,
decreases in lifetime social safety costs
associated with mass changes are
generally concentrated in MY 2023
through MY 2029 light-duty vehicles
under Alternative #1. At a three-percent
discount rate, 93% of the reduction in
total lifetime costs ($872 million out of
$937 million) is attributed to MY 2023
through MY 2029 light-duty vehicles; at
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
a seven-percent discount rate, 97% of
the reduction in total lifetime costs
($486 million out of $501 million) is
attributed to MY 2023 through MY 2029
light-duty vehicles.
(e) Sensitivity Analyses
Table II–65 shows the principal
findings and includes sampling-error
confidence bounds for the five
parameters used in the CAFE model.
The confidence bounds represent the
statistical uncertainty that is a
consequence of having less than a
census of data. NHTSA’s 2011, 2012,
and 2016 reports acknowledged another
source of uncertainty: The baseline
statistical model can be varied by
choosing different control variables or
redefining the vehicle classes or crash
types, which for example, could
produce different point estimates.
Beginning with the 2012 Kahane
report, NHTSA has provided results of
11 plausible alternative models that
serve as sensitivity tests of the baseline
model. Each alternative model was
tested or proposed by: Farmer (IIHS) or
PO 00000
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Fmt 4701
Sfmt 4725
Green (UMTRI) in their peer reviews;
Van Auken (DRI) in his public
comments; or Wenzel in his parallel
research for DOE. The 2012 Kahane and
2016 Puckett and Kindelberger reports
provide further discussion of the models
and the rationales behind them.
Alternative models use NHTSA’s
databases and regression-analysis
approach but differ from the baseline
model in one or more explanatory
variables, assumptions, or data
restrictions. NHTSA applied the 11
techniques to the latest databases to
generate alternative CAFE model
coefficients. The range of estimates
produced by the sensitivity tests offers
insight to the uncertainty inherent in
the formulation of the models, subject to
the caveat these 11 tests are, of course,
not an exhaustive list of conceivable
alternatives.
The baseline and alternative results
follow, ordered from the lowest to the
highest estimated increase in societal
risk per 100-pound reduction for cars
weighing less than 3,201 pounds:
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
The sensitivity tests illustrate both the
fragility and the robustness of baseline
estimates. On the one hand, the
variation among NHTSA’s coefficients is
quite large relative to the baseline
estimate: In the preceding example of
cars < 3,201 pounds, the estimated
coefficients range from almost zero to
almost double the baseline estimate.
This result underscores the key
relationship that the societal effect of
mass reduction is small and, as Wenzel
has said, it ‘‘is overwhelmed by other
known vehicle, driver, and crash
factors.’’ 313 In other words, varying how
to model some of these other vehicle,
driver, and crash factors, which is
exactly what sensitivity tests do, can
appreciably change the estimate of the
societal effect of mass reduction.
On the other hand, variations are not
particularly large in absolute terms. The
ranges of alternative estimates are
generally in line with the sampling-error
confidence bounds for the baseline
estimates. Generally, in alternative
models as in the baseline models, mass
reduction tends to be relatively more
harmful in the lighter vehicles and more
beneficial in the heavier vehicles, just as
they are in the central analysis. In all
models, the point estimate of NHTSA’s
coefficient is positive for the lightest
vehicle class, cars < 3,201 pounds. In
nine out of 11 models, the point
estimate is negative for CUVs and
minivans, and in eight out of 11 models
the point estimate is negative for LTVs
≥ 5,014 pounds.
(f) Fleet Simulation Model
NHTSA has traditionally used real
world crash data as the basis for
projecting the future safety implications
for regulatory changes. However,
because lightweight vehicle designs are
introducing fundamental changes to the
structure of the vehicle, there is some
concern that historical safety trends may
not apply. To address this concern,
NHTSA developed an approach to
utilize lightweight vehicle designs to
evaluate safety in a subset of real-world
representative crashes. The
methodology focused on frontal crashes
because of the availability of existing
vehicle and occupant restraint models.
Representative crashes were simulated
between baseline and lightweight
vehicles against a range of vehicles and
roadside objects using two different size
belted driver occupants (adult male and
small female) only. No passenger(s) or
313 Wenzel, T. Assessment of NHTSA’s Report
‘‘Relationships Between Fatality Risk, Mass, and
Footprint in Model Year 2000–2007 Passenger Cars
and LTVs,’’ Lawrence Berkeley National Laboratory
at iv (Nov. 2011), available at Docket ID NHTSA–
2010–0152–0026.
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unbelted driver occupants were
considered in this fleet simulation. The
occupant injury risk from each
simulation was calculated and summed
to obtain combined occupant injury
risk. The combined occupant injury risk
was weighted according to the
frequency of real world occurrences to
develop overall societal risk for baseline
and light-weighted vehicles. Note: The
generic restraint system developed and
used in the baseline occupant
simulations was also used in the lightweighted vehicle occupant simulations
as the purpose of this fleet simulation
was to understand changes in societal
injury risks because of mass reduction
for different classes of vehicles in
frontal crashes. No modifications to the
restraint systems were made for lightweighted vehicle occupant simulations.
Any modifications to restraint systems
to improve occupant injury risks or
societal injury risks in the lightweighted vehicle would have conflated
results without identifying effects of
mass reduction only. The following
sections provide an overview of the fleet
simulation study:
NHTSA contracted with George
Washington University to develop a
fleet simulation model 314 to study the
impact and relationship of lightweighted vehicle design with injuries
and fatalities. In this study, there were
eight vehicles as follows:
• 2001 model year Ford Taurus finite
element model baseline and two simple
design variants included a 25% lighter
vehicle while maintaining the same
vehicle front end stiffness and 25%
overall stiffer vehicle while maintaining
the same overall vehicle mass.315
• 2011 model year Honda Accord
finite element baseline vehicle and its
20% light-weight vehicle designed by
Electricore. (This mass reduction study
was sponsored by NHTSA).316
314 Samaha, R. R. et al., Methodology for
Evaluating Fleet Protection of New Vehicle Designs:
Application to Lightweight Vehicle Designs,
National Highway Traffic Safety Administration
(Aug. 2014), available at https://www.nhtsa.gov/
crashworthiness/vehicle-aggressivity-and-fleetcompatibility-research (accessed by clicking on the
.zip file for DOT HS 812 051).
315 Samaha, R. R. et al., Methodology for
Evaluating Fleet Protection of New Vehicle Designs:
Application to Lightweight Vehicle Designs,
appendices, National Highway Traffic Safety
Administration (Aug. 2014), available at https://
www.nhtsa.gov/crashworthiness/vehicleaggressivity-and-fleet-compatibility-research
(accessed by clicking on the .zip file for DOT HS
812 051 [appendices are Part 2]).
316 Singh, H. et al., Update to future midsize
lightweight vehicle findings in response to
manufacturer review and IIHS small-overlap
testing, National Highway Traffic Safety
Administration (Feb. 2016), available at https://
www.nhtsa.gov/sites/nhtsa.dot.gov/files/812237_
lightweightvehiclereport.pdf.
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• 2009/2010 model year Toyota
Venza finite element baseline vehicle
and two design variants included a 20%
light-weight vehicle model (2010 Venza)
(Low option mass reduction vehicle
funded by EPA and International
Council on Clean Transportation (ICCT))
and a 35% light-weight vehicle (2009
Venza) (High option mass reduction
vehicle funded by California Air
Resources Board).317
Light weight vehicles were designed
to have similar vehicle crash pulses as
baseline vehicles. More than 440 vehicle
crash simulations were conducted for
the range of crash speeds and crash
configurations to generate crash pulse
and intrusion data points. The crash
pulse data and intrusion data points
will be used as inputs in the occupant
simulation models.
For vehicle to vehicle impact
simulations, four finite element models
were chosen to represent the fleet. The
partner vehicle models were selected to
represent a range of vehicle types and
weights. It was assumed vehicle models
would reflect the crash response for all
vehicles of the same type, e.g. mid-size
car. Only the safety or injury risk for the
driver in the target vehicle and in the
partner vehicle were evaluated in this
study.
As noted, vehicle simulations
generated vehicle deformations and
acceleration responses utilized to drive
occupant restraint simulations and
predict the risk of injury to the head,
neck, chest, and lower extremities. In
all, more than 1,520 occupant restraint
simulations were conducted to evaluate
the risk of injury for mid-size male and
small female drivers.
The computed societal injury risk
(SIR) for a target vehicle v in frontal
crashes is an aggregate of individual
serious crash injury risks weighted by
real-world frequency of occurrence (v)
of a frontal crash incident. A crash
incident corresponds to a crash with
different partners (Npartner) at a given
impact speed (Pspeed), for a given
driver occupant size (Loccsize), in the
target or partner vehicle (T/P), in a given
crash configuration (Mconfig), and in a
single- or two-vehicle crash (Kevent).
CIR (v) represents the combined injury
risk (by body region) in a single crash
incident. (v) designates the weighting
factor, i.e., percent of occurrence,
derived from National Automotive
Sampling System Crashworthiness Data
System (NASS CDS) for the crash
incident. A driver age group of 16 to 50
317 Light-Duty Vehicle Mass Reduction and Cost
Analysis — Midsize Crossover Utility Vehicle, U.S.
EPA (Aug. 2012), https://cfpub.epa.gov/si/si_
public_record_report.cfm?dirEntryID=230748.
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years old was chosen to provide a
population with a similar, i.e., more
consistent, injury tolerance.
The fleet simulation was performed
using the best available engineering
models, with base vehicle restraint and
airbag settings, to estimate societal risks
of future lightweight vehicles. The range
of the predicted risks for the baseline
vehicles is from 1.25% to 1.56%, with
an average of 1.39%, for the NASS
frontal crashes that were simulated. The
change in driver injury risk between the
baseline and light-weighted vehicles
will provide insight into the estimate of
modification needed in the restraint and
airbag systems of lightweight vehicles. If
the difference extends beyond the
expected baseline vehicle restraint and
airbag capability, then adjustments to
the structural designs would be needed.
Results from the fleet simulation study
show the trend of increased societal
injury risk for light-weighted vehicle
designs, as compared to their baselines,
occurs for both single vehicle and twovehicle crashes. Results are listed in
Table II–66.
In general, the societal injury risk in
the frontal crash simulation associated
with the small size driver is elevated
when compared to that of the mid-size
driver. However, both occupant sizes
had reasonable injury risk in the
simulated impact configurations
representative of the regulatory and
consumer information testing. NHTSA
examined three methods for combining
injuries with different body regions.
One observation was the baseline midsize CUV model was more sensitive to
leg injuries.
This study only looked at lightweight
designs for a midsize sedan and a midsize CUV and did not examine safety
implications for heavier vehicles. The
study was also limited to only frontal
crash configurations and considered just
mid-size CUVs whereas the statistical
regression model considered all CUVs
and all crash modes.
The change in the safety risk from the
MY 2010 fleet simulation study was
directionally consistent with results for
passenger cars from NHTSA 2012
regression analysis study,318 which
covered data for MY 2000–MY 2007.
The NHTSA 2012 regression analysis
study was updated in 2016 to reflect
newer MY 2003 to MY 2010. Comparing
the fleet simulation societal risk to the
2016 update of the NHTSA 2012
regression analysis and the updated
analysis used in this NPRM, the risk
assessment from the fleet simulation is
similarly directionally consistent with
the passenger car risk assessment from
the regression analysis. As noted, fleet
simulations were performed only in
frontal crash mode and did not consider
other crash modes including rollover
crashes.319
This fleet simulation study does not
provide information that can be used to
modify coefficients derived for the
NPRM regression analysis because of
the restricted types of crashes 320 and
vehicle designs. As explained earlier,
the fleet simulation study assumed
restraint equipment to be as in the
baseline model, in which restraints/
airbags are not redesigned to be optimal
with light-weighting.
318 The 2012 Kahane study considered only
fatalities, whereas, the fleet simulation study
considered severe (AIS 3+) injuries and fatalities
(DOT HS 811 665).
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319 The risk assessment for CUV in the regression
model combined CUVs and minivans in all crash
modes and included belted and unbelted
occupants.
320 The fleet simulation considered only frontal
crashes.
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2. Impact of Vehicle Scrappage and
Sales Response on Fatalities
Previous versions of the CAFE model,
and the accompanying regulatory
analyses relying on it, did not carry a
representation of the full on-road
vehicle population, only those vehicles
from model years regulated under
proposed (or final) standards. The
omission of an on-road fleet implicitly
assumed the population of vehicles
registered at the time a set of CAFE
standards is promulgated is not affected
by those standards. However, there are
several mechanisms by which CAFE
standards can affect the existing vehicle
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population. The most significant of
these is deferred retirement of older
vehicles. CAFE standards force
manufacturers to apply fuel saving
technologies to offered vehicles and
then pass along the cost of those
technologies (to the extent possible) to
buyers of new vehicles. These price
increases affect the length of loan terms
and the desired length of ownership for
new vehicle buyers and can discourage
some buyers on the margin from buying
a new vehicle in a given year. To the
extent new vehicle purchases offset
pending vehicle retirements, delaying
new purchases in favor of continuing to
use an aging vehicle affects the overall
safety of the on-road fleet even if the
vehicle whose retirement was delayed
was not directly subject to a binding
CAFE standard in the model year during
its production.
The sales response in the CAFE model
acts to modify new vehicle sales in two
ways:
1. Changes in new vehicle prices
either increase or decrease total sales
(passenger cars and light trucks
combined) each year in the context of
forecasted macroeconomic conditions.
2. Changes in new vehicle attributes
and fuel prices influence the share of
new vehicles sold that are light trucks,
and therefore also passenger cars.
These two responses change the total
number of new vehicles sold in each
model year across regulatory
alternatives and the relative proportion
of new vehicles that are passenger cars
and light trucks. This response has two
effects on safety. The first response
slows the rate at which new vehicles,
and their associated safety
improvements, enter the on-road
population. The second response
influences the mix of vehicles on the
road—with more stringent CAFE
standards leading to a higher share of
light trucks sold in the new vehicle
market, assuming all else is equal. Light
trucks have higher rates of fatal crashes
when interacting with passenger cars
and, as earlier sections discussed,
different directional responses to mass
reduction technology based on the
existing mass and body style of the
vehicle.
The sales response and scrappage
response influence safety outcomes
through the same basic mechanism, fleet
turnover. In the case of the scrappage
response, delaying fleet turnover keeps
drivers in older vehicles likely to be less
safe than newer model year vehicles
that could replace them. Similarly,
delaying the sale of new vehicles can
force households to keep older vehicles
in use longer, reallocate VMT within
their household fleet, and generally
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meet travel demand through the use of
older, less safe vehicles. As an
illustration, if we simplify by ignoring
that the share of new vehicles that are
passenger cars changes with the
stringency of the alternatives, simply
changing the number of new vehicles
between scenarios affects the mileage
accumulation of the fleet and therefore
all fleet level effects. Reducing the
number of new vehicles sold, relative to
a baseline forecasted value, reduces the
size of the registered vehicle fleet that
is able to service the underlying demand
for travel.
Consider a simple example where we
show sales effects operating on a microscale for a single household whose
choices of whether to purchase a new
vehicle is affected by vehicle price. A
household starts with three vehicles,
aged three, five, and eight years old. In
a scenario with no CAFE standards and
therefore no related changes in vehicle
sales prices, the household buys a new
car and scraps the eight-year old car; the
other two cars in the fleet each get a year
older. In a scenario where CAFE
standards become more stringent
causing vehicle sales prices to increase,
this household chooses to delay buying
a new car and each of their three
existing cars gets a year older. In both
cases, all three vehicles (including the
new car in the first scenario, and the
year-year-old car in the second scenario)
have to serve the family’s travel
demand.
The scrappage effect is visible in the
household’s vehicle fleet as it moves
from the first scenario to the second
scenario with changes in CAFE
standards. In the second scenario, the
nine-year-old car remains in the
household’s fleet to service demand for
travel, when it would otherwise have
been retired. While the scrappage effect
can be symmetrical to the sales effect, it
need not be. The ‘‘new car’’ in the
scenario without CAFE standards could
be a new vehicle from the current model
year or a used car that is of a newer
vintage than the 8-year-old vehicle it
replaces. The latter instance is an effect
of scrappage decisions that do not
directly affect new vehicle sales.
Eventually, new vehicles transition to
the used car market, but that on average
take several years, and the shift is slow.
At the household level, the scrappage
decision occurs in a single year, each
year, for every vehicle in the fleet. To
the extent CAFE standards affect new
vehicle prices and fuel economies,
relative to vehicles already owned,
scrappage could accelerate or decelerate
depending upon the direction (and
magnitude) of the changes.
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3. Safety Model
The analysis supporting the CAFE
rule for MYs 2017 and beyond did not
account for differences in exposure or
inherent safety risk as vehicles aged
throughout their useful lives. However,
the relationship between vehicle age
and fatality risk is an important one. In
a 2013 Research Note,321 NHTSA’s
National Center for Statistics and
Analysis concluded a driver of a vehicle
that is four to seven years old is 10%
more likely to be killed in a crash than
the driver of a vehicle zero to three
years old, accounting for the other
factors related to the crash. This trend
continued for older vehicles more
generally, with a driver of a vehicle 18
years or older being 71% more likely to
be killed in a crash than a driver in a
new vehicle. While there are more
registered vehicles that are zero to three
years old than there are 20 years or
older (nearly three times as many)
because most of the vehicles in earlier
vintages are retired sooner, the average
age of vehicles in the United States is
11.6 years old and has risen
significantly in the past decade.322 This
relationship reflects a general trend
visible in the Fatality Analysis
Reporting System (FARS) when looking
at a series of calendar years: Newer
vintages are safer than older vintages,
over time, at each age. This is likely
because of advancements in safety
technology, like side-impact airbags,
electronic stability control, and (more
recently) sophisticated crash avoidance
systems starting to work their way into
the vehicle population. In fact, the 2013
Research Note indicated that the
percentage of occupants fatally injured
in fatal crashes increased with vehicle
age: From 27% for vehicles three or
fewer years old, to 41% for vehicles 12–
14 years old, to 50% for vehicles 18 or
more years old.
With an integrated fleet model now
part of the analytical framework for
CAFE analysis, any effects on fleet
turnover (either from delayed vehicle
retirement or deferred sales of new
vehicles) will affect the distribution of
both ages and model years present in
the on-road fleet. Because each of these
vintages carries with it inherent rates of
fatal crashes, and newer vintages are
generally safer than older ones,
changing that distribution will change
321 National Center for Statistics and Analysis,
How Vehicle Age and Model Year Relate to Driver
Injury Severity in Fatal Crashes, National Highway
Traffic Safety Administration (Aug. 2013), available
at https://crashstats.nhtsa.dot.gov/Api/Public/View
Publication/811825.
322 Based on data acquired from Ward’s
Automotive.
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the total number of on-road fatalities
under each regulatory alternative.
To estimate the empirical relationship
between vehicle age, model year
vintage, and fatalities, DOT conducted a
statistical analysis linking data from the
FARS database, a time series of Polk
registration data to represent the onroad vehicle population, and assumed
per-vehicle mileage accumulation rates
(the derivation of which is discussed in
detail in PRIA Chapter 11). These data
were used to construct per-mile fatality
rates that varied by vehicle vintage,
accounting for the influence of vehicle
age. However, unlike the NCSA study
referenced above, any attempt to
account for this relationship in the
CAFE analysis faces two challenges. The
first challenge is the CAFE model lacks
the internal structure to account for
other factors related to observed fatal
crashes—for example, vehicle speed,
seat belt use, drug use, or age of
involved drivers or passengers. Vehicle
interactions are simply not modeled at
this level; the safety analysis in the
CAFE model is statistical, using
aggregate values to represent the totality
of fleet interactions over time. The
second challenge is perhaps the more
significant of the two: The CAFE
analysis is inherently forward-looking.
To implement a statistical model
analogous to the one developed by
NCSA, the CAFE model would require
forecasts of all factors considered in the
NCSA model—about vehicle speeds in
crashes, driver behavior, driver and
passenger ages, vehicle vintages, and so
on. In particular, the model would
require distributions (joint distributions,
in most cases) of these factors over a
period of time spanning decades. Any
such forecasts would be highly
uncertain and would be likely to assume
a continuation of current conditions.
Instead of trying to replicate the
NCSA work at a similar level of detail,
DOT conducted a simpler statistical
analysis to separate the safety impact of
the two factors the CAFE model
explicitly accounts for: The distribution
of vehicle ages in the fleet and the
number of miles driven by those
vehicles at each age. To accomplish this,
DOT used data from the FARS database
at a lower level of resolution; rather
than looking at each crash and the
specific factors that contributed to its
occurrence, staff looked at the total
number of fatal crashes involving lightduty vehicles over time with a focus on
the influence of vehicle age and vehicle
vintage. When considering the number
of fatalities relative to the number of
registered vehicles for a given model
year (without regard to the passenger
car/light-truck distinction, which has
evolved over time and can create
inconsistent comparisons), a somewhat
noisy pattern develops. Using data from
calendar year 1996 through 2015, some
consistent stories develop. The points in
Figure II–4 represent the number of
fatalities per registered vehicle with
darker circles associated with
increasingly current calendar years.
As shown in Figure II–4, fatalities per
registered vehicle have generally
declined over time across all vehicle
ages (the darker points representing
newer vintages being closer to the xaxis) and, across most recent calendar
years, fatality rates (per registered
vehicle) start out at a low point, rise
through age 15 or so, then decline
through age 30 (at which point little of
the initial model year cohort is still
registered). While this pattern is evident
in the registration data, it is magnified
by imposing a mileage accumulation
schedule on the registered population
and examining fatalities per billion
miles of VMT.
The mileage accumulation schedule
used in this analysis was developed
using odometer readings of vehicles
aged 0–15 years in calendar year 2015.
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The years spanned by the FARS
database cover all model years from
calendar year 1996 through 2015. Given
that there is a significant number of
years between the older vehicles in the
1996 CY data and the most recent model
years in the odometer data the informed
the mileage accumulation schedules,
staff applied an elasticity of ¥0.20 to
the change in the average cost per mile
of vehicles over their lives. While the
older vehicles had lower fuel
economies, which would be associated
with higher per-mile driving costs, they
also (mostly) faced lower fuel prices.
This adjustment increased the mileage
accumulation for older vehicles, but not
by large amounts. Because the CAFE
model uses the mileage accumulation
schedule and applies it to all vehicles in
the fleet, it is necessary to use the same
schedule to estimate per-mile fatality
rates in the statistical analysis—even if
the schedule is based on vehicles that
look different than the oldest vehicles in
the FARS dataset.
When the per-vehicle fatality rates are
converted into per-mile fatality rates,
the pattern observed in the registration
comparison becomes clearer. As Figure
II–5 shows, the trend present in the
fatality data on a per-registration basis is
even clearer on a per-mile basis: Newer
vintages are safer than older vintages, at
each age, over time.
The shape of the curve in Figure II–
5 suggests a polynomial relationship
between fatality rate and vehicle age, so
DOT’s statistical model is based on that
structure.
The final model is a weighted quartic
polynomial regression (by number of
registered vehicles) on vehicle age with
fixed effects for the model years present
in the dataset: 323
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323 Note: The dataset included MY 1975, but that
fixed effect is excluded from the set. The constant
term acts as the fixed effect for 1975 and all others
are relative to that one.
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The coefficient estimates and model
summary are in Table II–67.
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T abl e II-67 - D escn. pf IOn ofstafISf1caI mo dl
e
Coefficients:
Estimate
Std.
Error
28.59***
(Intercept)
3.067
-3.63***
Vehicle Age
0.2298
0.76***
0.03016
Age 2
Agej
-0.04***
0.001453
4
0.0005*** 2.25E-05
Age
MY 1976
-0.72
3.621
MY 1977
-2.24
3.425
MY 1978
-1.53
3.324
MY 1979
-4.46
3.268
MY 1980
-3.78
3.437
MY 1981
-2.88
3.38
MY 1982
-4.42
3.329
MY 1983
-4.93
3.236
MY 1984
-4.71
3.142
MY 1985
-4.78
3.113
MY 1986
-5.54.
3.092
MY 1987
-5.86.
3.086
MY 1988
-4.37
3.079
MY 1989
-4.78
3.074
MY 1990
-5.17.
3.077
MY 1991
-5.84.
3.072
MY 1992
-7.26*
3.07
-7.92**
MY 1993
3.062
-9.69**
MY 1994
3.058
-10.61 *** 3.053
MY 1995
-12.07*** 3.06
MY 1996
-12.8***
MY 1997
3.056
-13.88*** 3.057
MY 1998
-14.91 *** 3.055
MY 1999
-15.68*** 3.054
MY2000
-16.33*** 3.059
MY 2001
-17.1***
3.06
MY2002
-17.7***
3.065
MY2003
-18.24*** 3.069
MY2004
-18.91 *** 3.074
MY2005
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This function is now embedded in the
CAFE model, so the combination of
VMT per vehicle and the distribution of
ages and model years present in the onroad fleet determine the number of
fatalities in a given calendar year. The
model reproduces the observed fatalities
of a given model year, at each age,
reasonably well with more recent model
years (to which the VMT schedule is a
better match) estimated with smaller
errors.
While the final specification was not
the only one considered, the fact this
model was intended to live inside the
CAFE model to dynamically estimate
fatalities for a dynamically changing onroad vehicle population was a
constraining factor.
(a) Predicting Future Safety Trends
The base model predicts a net
increase in fatalities due primarily to
slower adoption of safer vehicles and
added driving because of less costly
vehicle operating costs. In earlier
calendar years, the improvement in
safety of the on-road fleet produces a net
reduction in fatalities, but from the mid2020s forward, the baseline model
predicts no further increase in safety,
and the added risk from more VMT and
older vehicles produces a net increase
in fatalities. This model thus reflects a
conservative limitation; it implicitly
assumes the trend toward increasingly
safe vehicles that has been apparent for
the past 3 decades will flatten in mid2020s. The agency does not assert this
is the most likely case. In fact, the
development of advanced crash
avoidance technologies in recent years
indicates some level of safety
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improvement is almost certain to occur.
The difficulty is for most of these
technologies, their effectiveness against
fatalities and the pace of their adoption
are highly uncertain. Moreover,
autonomous vehicles offer the
possibility of significantly reducing or
eventually even eliminating the effect of
human error in crash causation, a
contributing factor in roughly 94% of all
crashes. This conservative assumption
may cause the NPRM to understate the
beneficial effect of proposed standards
on improving (reducing) the number of
fatalities.
Advanced technologies that are
currently deployed or in development
include:
Forward Collision Warning (FCW)
systems are intended to passively assist
the driver in avoiding or mitigating the
impact of rear-end collisions (i.e., a
vehicle striking the rear portion of a
vehicle traveling in the same direction
directly in front of it). FCW uses
forward-looking vehicle detection
capability, such as RADAR, LIDAR
(laser), camera, etc., to detect other
vehicles ahead and use the information
from these sensors to warn the driver
and to prevent crashes. FCW systems
provide an audible, visual, or haptic
warning, or any combination thereof, to
alert the driver of an FCW-equipped
vehicle of a potential collision with
another vehicle or vehicles in the
anticipated forward pathway of the
vehicle.
Crash Imminent Braking (CIB)
systems are intended to actively assist
the driver by mitigating the impact of
rear-end collisions. These safety systems
have forward-looking vehicle detection
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capability provided by sensing
technologies such as RADAR, LIDAR,
video camera, etc. CIB systems mitigate
crash severity by automatically applying
the vehicle’s brakes shortly before the
expected impact (i.e., without requiring
the driver to apply force to the brake
pedal).
Dynamic Brake Support (DBS) is a
technology that actively increases the
amount of braking provided to the
driver during a rear-end crash avoidance
maneuver. If the driver has applied
force to the brake pedal, DBS uses
forward-looking sensor data provided by
technologies such as RADAR, LIDAR,
video cameras, etc. to assess the
potential for a rear-end crash. Should
DBS ascertain a crash is likely (i.e., the
sensor data indicate the driver has not
applied enough braking to avoid the
crash), DBS automatically intervenes.
Although the manner in which DBS has
been implemented differs among
vehicle manufacturers, the objective of
the interventions is largely the same: To
supplement the driver’s commanded
brake input by increasing the output of
the foundation brake system. In some
situations, the increased braking
provided by DBS may allow the driver
to avoid a crash. In other cases, DBS
interventions mitigate crash severity.
Pedestrian AEB (PAEB) systems
provide automatic braking for vehicles
when pedestrians are in the forward
path of travel and the driver has taken
insufficient action to avoid an imminent
crash. Like CIB, PAEB safety systems
use information from forward-looking
sensors to automatically apply or
supplement the brakes in certain driving
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situations in which the system
determines a pedestrian is in imminent
danger of being hit by the vehicle. Many
PAEB systems use the same sensors and
technologies used by CIB and DBS.
Rear Automatic Braking feature
means installed vehicle equipment that
has the ability to sense the presence of
objects behind a reversing vehicle, alert
the driver of the presence of the
object(s) via auditory and visual alerts,
and automatically engage the available
braking system(s) to stop the vehicle.
Semi-automatic Headlamp Beam
Switching device provides either
automatic or manual control of
headlamp beam switching at the option
of the driver. When the control is
automatic, headlamps switch from the
upper beam to the lower beam when
illuminated by headlamps on an
approaching vehicle and switch back to
the upper beam when the road ahead is
dark. When the control is manual, the
driver may obtain either beam manually
regardless of the conditions ahead of the
vehicle.
Rear Turn Signal Lamp Color Turn
signal lamps are the signaling element
of a turn signal system, which indicates
the intention to turn or change direction
by giving a flashing light on the side
toward which the turn will be made.
FMVSS No. 108 permits a rear turn
signal lamp color of amber or red.
Lane Departure Warning (LDW)
system is a driver assistance system that
monitors lane markings on the road and
alerts the driver when their vehicle is
about to drift beyond a delineated edge
line of their current travel lane.
Blind Spot Detection (BSD) systems
uses digital camera imaging technology
or radar sensor technology to detect one
or more vehicles in either of the
adjacent lanes that may not be apparent
to the driver. The system warns the
driver of an approaching vehicle’s
presence to help facilitate safe lane
changes.
These technologies are either under
development or are currently being
offered, typically in luxury vehicles, as
either optional or standard equipment.
To estimate baseline fatality rates in
future years, NHTSA examined
predicted results from a previous NCSA
study 324 that measured the effect of
known safety regulations on fatality
rates. This study relied on statistical
evaluations of the effectiveness of motor
vehicle safety technologies based on real
world performance in the on-road
vehicle fleet to determine the
effectiveness of each safety technology.
These effectiveness rates were applied
to existing fatality target populations
and adjusted for current technology
penetration in the on-road fleet, taking
into account the retirement of existing
vehicles and the pace of future
penetration required to meet statutory
compliance requirements, as well as
adjustments for overlapping target
populations. Based on these factors, as
well as assumptions regarding future
VMT, the study predicted future fatality
levels and rates. Because the safety
impact in the CAFE model
independently predicts future VMT, we
removed the VMT growth rate from the
NCSA study and developed a prediction
of vehicle fatality trends based only on
the penetration pace of new safety
technologies into the on-road fleet.
These data were then normalized into
relative safety factors with CY 2015 as
the baseline (to match the baseline
fatality year used in this CAFE analysis).
These factors were then converted into
equivalent fatality rates/100 million
VMT by anchoring them to the 2015
fatality rate/100 million VMT published
by NHTSA. Figure II–6 below illustrates
the modelling output and projected
fatality trend from the analysis of the
NCSA study, prior to adjustment to
fatality rates/100 million VMT.
324 Blincoe, L. & Shankar, U. The Impact of Safety
Standards and Behavioral Trends on Motor Vehicle
Fatality Rates, National Highway Traffic Safety
Administration (Jan. 2007), available at https://
www.nhtsa.gov/sites/nhtsa.dot.gov/files/
documents/810777v3.pdf.
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This model was based on inputs
representing the impact of technology
improvement through CY 2020.
Projecting this trend beyond 2020 can
be justified based on the continued
transformation of the on-road fleet to
100% inclusion of the known safety
technologies. Based on projections in
the NCSA study, significant further
technology penetration can be expected
in the on-road fleet for side impact
improvements (FMVSSS 214),
electronic stability control (FMVSS
126), upper interior head impact
protection (FMVSS 301), tire pressure
monitoring systems (FMVSS 138),
ejection mitigation (FMVSS 226), and
heavy truck stopping distance
improvements (FMVSS 121). These
technologies were estimated to be
installed in only 40–70% of the on-road
fleet as of CY 2020, implying further
safety improvement well beyond the
2020 calendar year.
The NCSA study focused on
projections to reflect known technology
adaptation requirements, but it was
conducted prior to the 2008 recession,
which disrupted the economy and
changed travel patterns throughout the
country. Thus, while the relative trends
it predicts seem reasonable, they cannot
account for the real-world disruption
and recovery that occurred in the 2008–
2015 timeframe. In addition, the NCSA
study did not attempt to adjust for safety
impacts that may have resulted from
changes in the vehicle sales mix
(vehicle types and sizes creating
different interactions in crashes), in
commuting patterns, or in shopping or
socializing habits associated with
internet access and use. To address this,
NHTSA also examined the actual
change in the fatality rate as measured
by fatality counts and VMT estimates.
Figure II–7 below illustrates the actual
fatality rates measured from 2000
through 2016 and the modeled fatality
rate trend based on these historical data.
The effect of the recession and
subsequent recovery can be seen in
chaotic shift in the fatality rate trend
starting in 2008. The generally gradual
decline that had been occurring over the
previous decade was interrupted by a
slowdown in the rate of change
followed by subsequent upward and
downward shifts. More recently, the rate
has begun to increase. These shifts
reflect some combination of factors not
captured in the NCSA analysis
mentioned above. The significance of
this is that although there was a steady
increase in the penetration of safety
technologies into the on-road fleet
between 2008 and 2015, other unknown
factors offset their positive influence
and eventually reversed the trend in
vehicle safety rates. Because of the
upward shift over the 2014–2015
period, this model, which does not
reflect technology trend savings after
2015, will predict an upward shift of
fatality rates after 2020.
Predicting future safety trends has
significant uncertainty. Although
further safety improvements are
expected because of advanced safety
technologies such as automatic braking
and eventually, fully automated
vehicles, the pace of development and
extent of consumer acceptance of these
improvements is uncertain. Thus, two
imperfect models exist for predicting
future safety trends. The NCSA model
reflects the expected trend from
required technologies and indicates
continued improvement well beyond
the 2020 timeframe, which is when the
historical fatality rate based model
breaks down. By contrast, the historical
fatality rate model reflects shifts in
safety not captured by the NCSA model,
but gives arguably implausible results
after 2020. It essentially represents a
scenario in which economic, market, or
behavioral factors minimize or offset
much of the potential impact of future
safety technology.
For the NPRM, the analysis examines
a scenario projecting safety
improvements beyond 2015 using a
simple average of the NCSA and
historical fatality rate models, accepting
each as an illustration of different and
conflicting possible future scenarios. As
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both models eventually curve up
because of their quadratic form, each
models’ results are flattened at the point
where they begin to trend upward. This
occurs in 2045 for the NCSA model and
in 2021 for the historical model. The
results are shown in Figure II–8 below.
The results indicate roughly a 19%
reduction in fatality rates between 2015
and 2050. This is a slower pace than
what has historically occurred over the
past several decades, but the biggest
influence on historical rates was
significant improvement in safety belt
use, which was below 10% in 1960 and
had risen to roughly 70% by 2000, and
is now more than 90%. Because belt use
is now above 90%, further such
improvements are unlikely unless they
come from new technologies.
A difficulty with these trend models
is they are based on calendar year
predictions, which are derived from the
full on-road vehicle fleet rather than the
model year fleet, which is the basis for
calculations in the CAFE model. As
such they are useful primarily as
indicators that vehicle safety has
steadily improved over the past several
decades, and given the advanced safety
technologies under current
development, we would expect some
continuation of improvement in MY
vehicle safety over the near and midterm future. To account for this, NHTSA
approximated a model year safety trend
continuing through about 2035 (Figure
II–9). For this trend the agency used
actual data from FARS to calculate the
change in fatality rates through 2007.
The recession, which struck our
economy in 2008, distorted normal
behavioral patterns and affected both
VMT and the mix of drivers and type of
driving to an extent we do not believe
the recession era gives an accurate
picture of the safety trends inherent in
the vehicles themselves. Therefore,
beginning in 2008, NHTSA
approximated a trend for safety
improvement through about MY 2035 to
reflect the continued effect of improved
safety technologies such as advanced
automatic braking, which manufacturers
have announced will be in all new
vehicles by MY 2022. The agency
recognize this is only an estimate, and
actual MY trends could be above or
below this line. NHTSA examined
alternate trends in a sensitivity analysis
and request comments on the best way
to address future safety trends.
NHTSA also notes although we
project vehicles will continue to become
safer going forward to about 2035, we do
not have corresponding cost information
for technologies enabling this
improvement. In a standard elasticity
model, sales impacts are a function of
the percent change in vehicle price.
Hypothetically, increasing the base
price for added safety technologies
would decrease the impact of higher
prices due to impacts of CAFE standards
on vehicle sales. The percentage change
in baseline price would decrease, which
would mean a lower elasticity effect,
which would mean a lower impact on
sales. NHTSA will consider possible
ways to address this issue before the
final rule, and we request comments on
the need and/or practicability for such
an adjustment, as well as any data and
other relevant information that could
support such an analysis of these costs,
as well as the future pace of
technological adoption within the
vehicle fleet.
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(b) Adjusting for Behavioral Impacts
The influence of delayed purchases of
new vehicles is estimated to have the
most significant effect on safety
imposed by CAFE standards. Because of
a combination of safety regulations and
voluntary safety improvements,
passenger vehicles have become safer
over time. Compared to prior decades,
fatality rates have declined significantly
because of technological improvements,
as well as behavioral shifts, such as
increased seat belt use. As these safer
vehicles replace older less safe vehicles
in the fleet, the on-road fleet is replaced
with vehicles reflecting the improved
fatality rates of newer, safer vehicles.
However, fatality rates associated with
different model year vehicles are
influenced by the vehicle itself and by
driver behavior. Over time, used
vehicles are purchased by drivers in
different demographic circumstances
who also tend to have different
behavioral characteristics. Drivers of
older vehicles, on average, tend to have
lower belt use rates, are more likely to
drive inebriated, and are more likely to
drive over the speed limit. Additionally,
older vehicles are more likely to be
driven on rural roadways, which
typically have higher speeds and
produce more serious crashes. These
relationships are illustrated graphically
in Chapter 11 of the PRIA
accompanying this proposed rule.
The behavior being modelled and
ascribed to CAFE involves decisions by
drivers who are contemplating buying a
new vehicle, and the purchase of a
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newer vehicle will not in itself cause
those drivers to suddenly stop wearing
seat belts, speed, drive under the
influence, or shift driving to different
land use areas. The goal of this analysis
is to measure the effect of different
vehicle designs that change by model
year. The modelling process for
estimating safety essentially involves
substituting fatality rates of older MY
vehicles for improved rates that would
have been experienced with a newer
vehicle. Therefore, it is important to
control for behavioral aspects associated
with vehicle age so only vehicle design
differences are reflected in the estimate
of safety impacts. To address this, the
CAFE safety model was run to control
for vehicle age. That is, it does not
reflect a decision to replace an older
model year vehicle that is, for example,
10 years old with a new vehicle. Rather,
it reflects the difference in the average
fatality rate of each model year across its
entire lifespan. This will account for
most of the difference because of vehicle
age, but it may still reflect a bias caused
by the upward trend in societal seat belt
use over time. Because of this secular
trend, each subsequent model year’s
useful life will occur under increasingly
higher average seat belt use rates. This
could cause some level of behavioral
safety improvement to be ascribed to the
model year instead of the driver cohort.
However, it is difficult to separate this
effect from the belt use impacts of
changing driver cohorts as vehicles age.
Glassbrenner (2012) analyzed the
effect of improved safety in newer
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vehicles for model years 2001 through
2008. She developed several statistical
regression models that specifically
controlled for most behavioral factors to
isolate model year vehicle
characteristics. However, her study did
not specifically report the change in MY
fatality rates—rather, she reported total
fatalities that could have been saved in
a baseline year (2008) had all vehicles
in the on-road fleet had the same safety
features as the MY 2001 through MY
2008 vehicles. This study potentially
provides a basis for comparison with
results of the CAFE safety estimates. To
make this comparison, the CY 2008
passenger car and light truck fatalities
total from FARS were modified by
subtracting the values found in Figure
II–9 of her study. This gives a stream of
comparable hypothetical CY 2008
fatality totals under progressively less
safe model year designs. Results
indicated that had the 2008 on-road
fleet been equipped with MY 2008
safety equipment and vehicle
characteristics, total fatalities would
have been reduced by 25% compared to
vehicles that were actually on the road
in 2008. Similar results were calculated
for each model years’ vehicle
characteristics back to 2001.
For comparison, predicted MY fatality
rates were derived from the CAFE safety
model and applied to the CY 2008 VMT
calculated by that model. This gives an
estimate of CY 2008 fatalities under
each model years’ fatality rate, which,
when compared to the predicted CY
fatality total, gives a trendline
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comparable to the Glassbrenner
trendline illustrating the change in MY
fatality rates. Both models are sensitive
to the initial 2008 baseline fatality total,
and because the predicted CAFE total is
somewhat lower than the actual total,
the agency ran a third trendline to
examine the influence of this difference.
Results are shown in Figure II–10.
Using the corrected fatality count, but
retaining the predicted VMT changes
the initial 2018 CY fatality rate to 12.62
(instead of 12.15) and produces the
result shown in Figure II–10. The CAFE
model trendline shifts up, which
narrows the difference in early years but
expands it in later years. However, VMT
and fatalities are linked in the CAFE
model, so the actual level of the MY
safety predicted by the CAFE curve has
uncertainty. Perhaps the most
meaningful result from this comparison
is the difference in slopes; the CAFE
model predicts more rapid change
through 2006, but in the last few years
change decreases. This might reflect the
trend in societal belt use, which rose
steadily through 2005 and levelled off.
Later model years’ fatality rates would
benefit from this trend while earlier
model years would suffer. This seems
consistent with our using lifetime MY
fatality rates to reflect MY change rather
than first year MY fatality rates
(although even first year rates would
reflect this bias, but not as much).
To provide another perspective on
safety impacts, NHTSA accessed data
from a comprehensive study of the
effects of safety technologies on motor
vehicle fatalities. Kahane (2015) 325
examined all safety effects of vehicle
safety technologies from 1960 through
2012 and found these technologies
saved more than 600,000 lives during
that time span. Kahane is currently
working under contract for NHTSA to
update this study through 2016. At
NHTSA’s request, Kahane accessed his
database to provide a measure of
relative MY vehicle design safety by
controlling for seat belt use. The result
was a MY safety index illustrating the
progress in vehicle safety by model year
which isolates vehicle design from the
primary behavioral impact—seat belt
usage. We normalized Kahane’s index to
MY 1975 and did the same to the ‘‘fixed
effects’’ we are currently using from our
safety model to compare the trends in
MY safety from the two methods.
Results are shown in Figure II–11.
325 Kahane, C.J. Lives Saved by Safety Standards
and Associated Vehicle Safety Technologies, 1960–
2012—Passenger Cars and LTVs—with Reviews of
26 FMVSS and the Effectiveness of their Associated
Safety Technologies in Reducing Fatalities, Injuries,
and Crashes, National Highway Traffic Safety
Administration (Jan. 2015), available at https://
crashstats.nhtsa.dot.gov/Api/Public/View
Publication/812069.
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From Figure II–11 both approaches
show similar long-term downward
trends, but this model shows a steeper
slope than Kahane’s model. The two
models involve completely different
approaches, so some difference is to be
expected. However, it is also possible
this reflects different methods used to
isolate vehicle design safety from
behavioral impacts. As discussed
previously, NHTSA addressed this issue
by removing vehicle age impacts from
its model, whereas Kahane’s model does
it by controlling for belt use. As noted
previously, aside from the age impact on
belt use associated with the different
demographics driving older vehicles,
there is a secular trend toward more belt
use reflecting the increase in societal
awareness of belt use importance over
time. This trend is illustrated in Figure
II–12 below.326 NHTSA’s current
approach removes the age trend in belt
use, but it’s not clear whether it
accounts for the full impacts of the
secular trend as well. If not, some
portion of the gap between the two
trendlines could reflect behavioral
impacts rather than vehicle design.
These models (NHTSA, Glassbrenner,
and Kahane) involve differing
approaches and assumptions
contributing to uncertainty, and given
this, their differences are not surprising.
It is encouraging they show similar
directional trends, reinforcing the basic
concept we are measuring. NHTSA
recognizes predicting future fatality
impacts, as well as sales impacts that
cause them, is a difficult and imprecise
task. NHTSA will continue to
investigate this issue, and we seek
comment on these estimates as well as
alternate methods for predicting the
safety effects associated with delayed
new vehicle purchases.
326 Note: The drop occurring in 1994 reflects a
shift in the basis for determining belt use rates.
Effective in 1994, data were reported from the
National Occupant Protection Survey (NOPUS).
Prior to this, a conglomeration of state studies
provided the basis. It is likely the pre-NOPUS
surveys produced inflated results, especially in the
1991–1993 period.
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4. Impact of Rebound Effect on Fatalities
Based on historical data, it is possible
to calculate a baseline fatality rate for
vehicles of any model year vintage. By
simply taking the total number of
vehicles involved in fatal accidents over
all ages for a model year and dividing
by the cumulative VMT over the useful
life of every vehicle produced in that
model year, one arrives at a baseline
hazard rate denominated in fatalities per
billion miles. The fatalities associated
with vehicles produced in that model
year are then proportional to the
cumulative lifetime VMT, where total
fatalities equal the product of the
baseline hazard rate and VMT. A more
comprehensive discussion of the
rebound effect and the basis for
calculating its impact on mileage and
risk is in Chapter 8 of the PRIA
accompanying this proposed rule.
5. Adjustment for Non-Fatal Crashes
Fatalities estimated to be caused by
various alternative CAFE standards are
valued as a societal cost within the
CAFE models’ cost/benefit accounting.
Their value is based on the
comprehensive value of a fatality
derived from data in Blincoe et al.
(2015), adjusted to 2016 economics and
updated to reflect the official DOT
guidance on the value of a statistical life
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in 2016. This gives a societal value of
$9.9 million for each fatality. The CAFE
safety model estimates effects on traffic
fatalities but does not address
corresponding effects on non-fatal
injuries and property damage that
would result from the same factors
influencing fatalities. To address this,
we developed an adjustment factor that
would account for these crashes.
Development of this factor is based on
the assumption nonfatal crashes will be
affected by CAFE standards in
proportion to their nationwide
incidence and severity. That is, NHTSA
assumes the same injury profile, the
relative number of cases of each injury
severity level, that occur nationwide,
will be increased or decreased because
of CAFE. The agency recognizes this
may not be the case, but the agency does
not have data to support individual
estimates across injury severities. There
are reasons why this may not be true.
For example, because older model year
vehicles are generally less safe than
newer vehicles, fatalities may make up
a larger portion of the total injury
picture than they do for newer vehicles.
This would imply lower ratios across
the non-fatal injury and PDO profile and
would imply our adjustment may
overstate total societal impacts. NHTSA
requests comments on this assumption
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and alternative methods to estimate
injury impacts.
The adjustment factor is derived from
Tables 1–8 and I–3 in Blincoe et al.
(2015). Incidence in Table I–3 reflects
the Abbreviated Injury Scale (AIS),
which ranks nonfatal injury severity
based on an ascending 5 level scale with
the most severe injuries ranked as level
5. More information on the basis for
these classifications is available from
the Association for the Advancement of
Automotive Medicine at https://
www.aaam.org/abbreviated-injury-scaleais/.
Table 1–3 in Blincoe lists injured
persons with their highest (maximum)
injury determining the AIS level
(MAIS). This scale is represented in
terms of MAIS level, or maximum
abbreviated injury scale. MAIS0 refers
to uninjured occupants in injury
vehicles, MAIS1 are generally
considered minor injuries, MAIS2
moderate injuries, MAIS3 serious
injuries, MAIS4 severe injuries, and
MAIS5 critical injuries. PDO refers to
property damage only crashes, and
counts for PDOs refer to vehicles in
which no one was injured. From Table
II–68, ratios of injury incidence/fatality
are derived for each injury severity level
as follows:
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327 Press Release, Kelley Blue Book, New-Car
Transaction Prices Remain High, Up More Than 3
Percent Year-Over-Year in January 2017, According
to Kelley Blue Book (Feb. 1, 2017), https://
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F = change in fatalities estimated for CAFE
due to retaining used vehicles
r = ratio of nonfatal injuries or PDO vehicles
to fatalities (F)
p = value of property damage prevented by
retaining older vehicle
328 Edmunds Used Vehicle Market Report,
Edmunds (Feb. 2017), https://
dealers.edmunds.com/static/assets/articles/2017_
Feb_Used_Market_Report.pdf.
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Where:
S = total property damage savings from
retaining used vehicles longer
2016. There is a minor timing
discrepancy in these data because the
new vehicle data represent January
2017, and the used vehicle price is for
the average over 2016. NHTSA was
unable to locate exact matching data at
this time, but the agency believes the
difference will be minor.
Based on these data, new vehicles are
on average worth 82% more than used
vehicles. To estimate the effect of higher
property damage costs for newer
vehicles on crashes, the per unit
property damage costs from Table I–9 in
Blincoe et al. (2015) were multiplied by
this factor. Results are illustrated in
Table II–69.
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The total property damage cost
reduction was then calculated as a
function of the number of fatalities
reduced or increased by CAFE as
follows:
vehicles are worth less and will cost less
to repair, if they are repaired at all. The
consumer’s property damage loss is thus
reduced by longer retention of these
vehicles. To estimate this loss, average
new and used vehicle prices were
compared. New vehicle transaction
prices were estimated from a study
published by Kelley Blue Book.327
Based on these data, the average new
vehicle transaction price in January
2017 was $34,968. Used vehicle
transaction prices were obtained from
Edmonds Used Vehicle Market Report
published in February of 2017.328
Edmonds data indicate the average used
vehicle transaction price was $19,189 in
EP24AU18.099
sradovich on DSK3GMQ082PROD with PROPOSALS2
For each fatality that occurs
nationwide in traffic crashes, there are
561 vehicles involved in PDOs, 139
uninjured occupants in injury vehicles,
105 minor injuries, 10 moderate
injuries, 3 serious injuries, and
fractional numbers of the most serious
categories which include severe and
critical nonfatal injuries. For each
fatality ascribed to CAFE it is assumed
there will be nonfatal crashes in these
same ratios.
Property damage costs associated with
delayed new vehicle purchases must be
treated differently because crashes that
subsequently occur damage older used
vehicles instead of newer vehicles. Used
43147
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
sradovich on DSK3GMQ082PROD with PROPOSALS2
The number of fatalities ascribed to
CAFE because of older vehicle retention
was multiplied by the unit cost per
fatality from Table I–9 in Blincoe et al.
(2015) to determine the societal impact
accounted for by these fatalities.329
From Table I–8 in Blincoe et al. (2015),
NHTSA subtracted property damage
costs from all injury severity levels and
recalculated the total comprehensive
value of societal losses from crashes.
The agency then divided the portion of
these crashes because of fatalities by the
resulting total to estimate the portion of
crashes excluding property damage that
are accounted for by fatalities. Results
indicate fatalities accounted for
approximately 40% of all societal costs
exclusive of property damage. NHTSA
then divided the total cost of the added
fatalities by 0.4 to estimate the total cost
of all crashes prevented exclusive of the
savings in property damage. After
subtracting the total savings in property
damage from this value, we divided the
fatality cost by it to estimate that
overall, fatalities account for 43% of the
total costs that would result from older
vehicle retention.
For the fatalities that occur because of
mass effects or to the rebound effect, the
calculation was more direct, a simple
application of the ratio of the portion of
costs produced by fatalities. In this case,
there is no need to adjust for property
damage because all impacts were
derived from the mix of vehicles in the
on-road fleet. Again, from Table I–8 in
Blincoe et al (2015), we derive this ratio
based on all cost factors including
property damage to be .36. These
calculations are summarized as follows:
Where:
SV = Value of societal Impacts of all crashes
F = change in fatalities estimated for CAFE
due to retaining used vehicles
v = Comprehensive societal value of
preventing 1 fatality
x = Percent of total societal loss from crashes
excluding property damage accounted
for by fatalities
S = total property damage savings from
retaining used vehicles longer
M = change in fatalities due to changes in
vehicle mass to meet CAFE standards
c = Percent of total societal loss from all cost
factors in all crashes accounted for by
fatalities
For purposes of application in the
CAFE model, these two factors were
combined based on the relative
contribution to total fatalities of
different factors. As noted, although a
safety impact from the rebound effect is
calculated, these impacts are considered
to be freely chosen rather than imposed
by CAFE and imply personal benefits at
least equal to the sum of their added
costs and safety consequences. The
impacts of this nonfatal crash
adjustment affect costs and benefits
equally. When considering safety
impacts actually imposed by CAFE
standards, only those from mass
changes and vehicle purchase delays are
considered. NHTSA has two different
factors depending on which metric is
considered. The agency created these
factors by weighting components by the
relative contribution to changes in
fatalities associated with each
component. This process and results are
shown in Table II–70. Note: For the
NPRM, NHTSA applied the average
weighted factor to all fatalities. This will
tend to slightly overstate costs because
of sales and scrappage and understate
costs associated with mass and rebound.
The agency will consider ways to adjust
this minor discrepancy for the final rule.
Table II–71, Table II–72, Table II–73,
and Table II–74 summarize the safety
effects of CAFE standards across the
various alternatives under the 3% and
7% discount rates. As noted in Section
II.F.5, societal impacts are valued using
a $9.9 million value per statistical life
(VSL). Fatalities in these tables are
undiscounted; only the monetized
societal impact is discounted.
329 Note: These calculations used the original
values in the Blincoe et all (2015) tables without
adjusting for economics. These calculations
produce ratios and are thus not sensitive to
adjustments for inflation.
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n = the 8 injury severity categories
EP24AU18.101
43148
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Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Table 11-71 - Change in Safety Parameters from CAFE Augural Standards Baseline
A verage A nnuaI F at ar1f1es, CY 2036 -2045 3%0 D.ISCOUn t R at e
'
Change in Safety Parameters from Augural Standards Baseline
Alt 1
Alt2
Alt 3
Alt4
Alt 5
Alt 6
Alt 7
Alt 8
-22
-180
-202
-19
-162
-181
-17
-151
-168
-17
-112
-129
-16
-76
-92
-6
-59
-65
0
-24
-24
-2
-33
-35
-692
-894
-650
-831
-605
-773
-511
-640
-392
-484
-317
-382
-174
-198
-219
-254
-0.11
-0.90
-1.01
-0.10
-0.81
-0.91
-0.08
-0.76
-0.84
-0.08
-0.56
-0.64
-0.08
-0.38
-0.46
-0.03
-0.30
-0.33
0.00
-0.12
-0.12
-0.01
-0.16
-0.17
-3.43
-4.44
-3.21
-4.12
-3.00
-3.84
-2.53
-3.18
-1.94
-2.40
-1.57
-1.90
-0.86
-0.98
-1.09
-1.26
-0.17
-1.41
-1.58
-0.15
-1.27
-1.42
-0.13
-1.18
-1.31
-0.13
-0.88
-1.01
-0.13
-0.59
-0.72
-0.05
-0.46
-0.51
0.00
-0.19
-0.19
-0.02
-0.26
-0.27
-5.36
-6.94
-5.03
-6.45
-4.69
-6.00
-3.96
-4.97
-3.04
-3.76
-2.46
-2.97
-1.35
-1.53
-1.70
-1.97
-0.27
-2.31
-2.59
-0.24
-2.08
-2.33
-0.22
-1.94
-2.15
-0.21
-1.44
-1.65
-0.21
-0.97
-1.18
-0.07
-0.76
-0.83
0.00
-0.30
-0.31
-0.03
-0.42
-0.45
-8.79
-11.4
-8.24
-10.6
-7.69
-9.84
-6.49
-8.15
-4.98
-6.16
-4.03
-4.87
-2.21
-2.51
-2.79
-3.23
Fatalities
Mass changes
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
Total
Fatalities
Societal $B
Mass changes
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
Total
Nonfatal
Societal $B
Mass changes
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
Total
sradovich on DSK3GMQ082PROD with PROPOSALS2
Total Societal
$B
Mass changes
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
Total
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Average Annual Fatalities, CY 2036-2045. 3% Discount Rate
43150
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Table 11-72 - Change in Safety Parameters from CAFE Augural Standards Baseline
A veraee A nnuaI F at ar1f1es, CY 2036 -2045 7%0 D.ISCOUn t R at e
'
Change in Safety Parameters from Augural Standards Baseline
Fatalities
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
Fatalities
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
sradovich on DSK3GMQ082PROD with PROPOSALS2
Nonfatal
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
VerDate Sep<11>2014
Alt 1
Alt2
Alt3
Alt4
Alt5
Alt 6
Alt 7
Alt 8
-22
-19
-17
-17
-16
-6
0
-2
-180
-162
-151
-112
-76
-59
-24
-33
-202
-181
-168
-129
-92
-65
-24
-35
-692
-650
-605
-511
-392
-317
-174
-219
-894
-831
-773
-640
-484
-382
-198
-254
-0.04
-0.04
-0.03
-0.03
-0.03
-0.01
0.00
0.00
-0.38
-0.34
-0.32
-0.24
-0.16
-0.12
-0.05
-0.07
-0.42
-0.38
-0.35
-0.27
-0.19
-0.14
-0.05
-0.07
-1.42
-1.33
-1.24
-1.05
-0.80
-0.65
-0.36
-0.45
-1.84
-1.71
-1.59
-1.32
-1.00
-0.79
-0.41
-0.52
-0.07
-0.06
-0.05
-0.05
-0.05
-0.02
0.00
-0.01
-0.59
-0.53
-0.50
-0.37
-0.25
-0.19
-0.08
-0.11
-0.66
-0.60
-0.55
-0.42
-0.30
-0.21
-0.08
-0.11
-2.22
-2.08
-1.94
-1.64
-1.26
-1.02
-0.56
-0.70
23:42 Aug 23, 2018
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EP24AU18.104
Average Annual Fatalities, CY 2036-2045. 7% Discount Rate
Total
sradovich on DSK3GMQ082PROD with PROPOSALS2
Total
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
VerDate Sep<11>2014
-2.88
-2.67
-2.49
-2.06
-1.56
-1.23
-0.64
-0.82
-0.11
-0.10
-0.09
-0.09
-0.09
-0.03
0.00
-0.01
-0.97
-0.88
-0.81
-0.61
-0.41
-0.32
-0.13
-0.18
-1.09
-0.98
-0.90
-0.69
-0.50
-0.35
-0.13
-0.19
-3.64
-3.41
-3.18
-2.69
-2.06
-1.67
-0.92
-1.15
-4.72
-4.38
-4.08
-3.38
-2.56
-2.02
-1.04
-1.34
23:42 Aug 23, 2018
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43151
EP24AU18.105
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
43152
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Table 11-73 - Change in Safety Parameters from CAFE Augural Standards Baseline
Total Fatalities MY 1977-2029, 3% Discount Rate
Change in Safctv Parameters from Augural Standards Baseline
Total Fatalities MY 1977-2029, 3% Discmmt Rate
Alt l
Alt2
Alt3
Alt4
Alt5
Alt 6
Alt 7
Alt 8
Mass changes
-160
-147
-143
-173
-152
-73
-12
-30
Sales Impacts
-6,180
-5,680
-5,260
-4,280
-3,170
-2,550
-1,030
-1,480
Subtotal CAFE
Atrb.
Rebound effect
-6,340
-5,830
-5,400
-4,460
-3,330
-2,630
-1,050
-1,520
-6,340
-5,960
-5,620
-4,850
-3,610
-3,320
-2,200
-2,170
Total
-12,700
-11,800
-11,000
-9,300
-6,940
-5,950
-3,240
-3,690
Fatalities
Fatalities Societal
$B
Mass changes
-0.9
-0.9
-0.8
-1.1
-0.9
-0.4
-0.1
-0.2
Sales Impacts
-34.4
-31.6
-29.3
-23.9
-17.6
-14.4
-6.2
-8.3
Subtotal CAFE
Atrb.
Rebound effect
-35.4
-32.4
-30.1
-24.9
-18.5
-14.8
-6.3
-8.4
-41.7
-39.2
-37.0
-31.9
-23.7
-22.1
-14.8
-14.3
Total
-77.0
-71.6
-67.1
-56.9
-42.2
-36.9
-21.1
-22.8
Nonfatal Societal
$B
Mass changes
-1.5
-1.3
-1.3
-1.7
-1.5
-0.7
-0.1
-0.3
Sales Impacts
-53.8
-49.4
-45.8
-37.3
-27.5
-22.5
-9.7
-12.9
Subtotal CAFE
Atrb.
Rebound effect
-55.3
-50.7
-47.1
-39.0
-29.0
-23.2
-9.8
-13.2
-65.2
-120
-61.3
-112
-57.9
-105
-50.0
-37.0
-34.6
-23.2
-22.4
-89.0
-66.0
-57.8
-33.0
-35.6
Mass changes
-2.4
-2.2
-2.1
-2.7
-2.4
-1.1
-0.2
-0.5
Sales Impacts
-88.2
-81.0
-75.1
-61.2
-45.1
-36.9
-15.9
-21.2
Subtotal CAFE
Atrb.
Rebound effect
-90.7
-83.1
-77.2
-63.9
-47.5
-38.0
-16.0
-21.6
-107
-101
-94.9
-81.9
-60.7
-56.7
-38.0
-36.7
Total
-197
-184
-172
-146
-108
-94.7
-54.1
-58.4
Total
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sradovich on DSK3GMQ082PROD with PROPOSALS2
Total Societal $B
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
VerDate Sep<11>2014
23:42 Aug 23, 2018
Jkt 244001
noted in Section II.F.5, societal impacts
are valued using a $9.9 million value
per statistical life (VSL). Fatalities in
these tables are undiscounted; only the
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monetized societal impact is
discounted.
E:\FR\FM\24AUP2.SGM
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EP24AU18.107
sradovich on DSK3GMQ082PROD with PROPOSALS2
Table II–75 through Table II–78
summarize the safety effects of GHG
standards across the various alternatives
under the 3% and 7% discount rates. As
43153
43154
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
Table 11-75- Change in Safety Parameters from GHG Augural Standards Baseline
A vera~e A nnuaI F at ar1f1es, CY 2036 -2045 3%0 D.ISCOUn t R at e
'
Change in Safety Parameters from Augural Standards Baseline
Average Annual Fatalities, CY 2036-2045. 3% Discount Rate
Alt 1
Alt2
Alt 3
Alt4
Alt 5
Alt 6
Alt 7
Alt 8
Mass changes
Sales Impacts
-56
-221
-52
-213
-42
-177
-34
-131
-15
-93
-13
-66
-8
-34
-5
-36
Subtotal CAFE
Atrb.
Rebound effect
Total
-277
-265
-219
-165
-108
-79
-42
-41
-872
-838
-1,150
-1,100
-726
-945
-594
-759
-415
-523
-336
-415
-165
-207
-215
-256
-0.27
-0.25
-0.21
-0.17
-0.08
-0.07
-0.04
-0.02
sradovich on DSK3GMQ082PROD with PROPOSALS2
Fatalities
Societal $B
Mass changes
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
Total
-1.11
-1.39
-1.07
-1.33
-0.89
-1.10
-0.66
-0.83
-0.47
-0.54
-0.33
-0.40
-0.17
-0.21
-0.18
-0.21
-4.31
-5.70
-4.15
-5.47
-3.60
-4.69
-2.94
-3.76
-2.05
-2.59
-1.66
-2.06
-0.82
-1.03
-1.06
-1.27
Nonfatal
Societal $B
Mass changes
-0.43
-0.40
-0.32
-0.26
-0.12
-0.11
-0.06
-0.04
Sales Impacts
Subtotal CAFE
Atrb.
Rebound effect
-1.74
-2.17
-1.68
-2.07
-1.39
-1.71
-1.03
-1.29
-0.73
-0.85
-0.52
-0.62
-0.27
-0.33
-0.29
-0.32
-6.75
-6.48
-5.62
-4.60
-3.21
-2.60
-1.28
-1.66
Total
-8.92
-8.56
-7.34
-5.89
-4.06
-3.22
-1.60
-1.99
Total Societal
$B
Mass changes
-0.70
-0.65
-0.53
-0.43
-0.19
-0.17
-0.10
-0.06
Sales Impacts
-2.85
-2.75
-2.28
-1.69
-1.20
-0.85
-0.44
-0.47
Subtotal CAFE
Atrb.
Rebound effect
-3.56
-3.40
-2.81
-2.12
-1.39
-1.02
-0.54
-0.53
-11.1
-10.6
-9.22
-7.54
-5.26
-4.26
-2.10
-2.72
Total
-14.6
-14.0
-12.0
-9.65
-6.65
-5.28
-2.63
-3.26
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Fatalities
Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules
43155
Table 11-76- Change in Safety Parameters from GHG Augural Standards Baseline
A veraee A nnuaI F at ar1f1es, CY 2036 -2045 7%0 D.ISCOUn t R at e
'
Change in Safety Parameters from Augural Standards Baseline
Fatalities
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
Fatalities
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
sradovich on DSK3GMQ082PROD with PROPOSALS2
Nonfatal
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
VerDate Sep<11>2014
Alt 1
Alt2
Alt3
Alt4
Alt5
Alt 6
Alt 7
Alt 8
-56
-52
-42
-34
-15
-13
-8
-5
-221
-213
-177
-131
-93
-66
-34
-36
-277
-265
-219
-165
-108
-79
-42
-41
-872
-838
-726
-594
-415
-336
-165
-215
-1,150
-1,100
-945
-759
-523
-415
-207
-256
-0.11
-0.11
-0.09
-0.07
-0.03
-0.03
-0.02
-0.01
-0.47
-0.45
-0.37
-0.28
-0.20
-0.14
-0.07
-0.08
-0.58
-0.56
-0.46
-0.35
-0.23
-0.17
-0.09
-0.09
-1.78
-1.71
-1.49
-1.22
-0.85
-0.69
-0.34
-0.44
-2.36
-2.27
-1.95
-1.56
-1.08
-0.86
-0.43
-0.53
-0.18
-0.16
-0.13
-0.11
-0.05
-0.04
-0.03
-0.02
-0.73
-0.71
-0.59
-0.44
-0.31
-0.22
-0.11
-0.12
-0.91
-0.87
-0.72
-0.54
-0.36
-0.26
-0.14
-0.14
-2.79
-2.68
-2.32
-1.90
-1.33
-1.07
-0.53
-0.69
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Average Annual Fatalities, CY 2036-2045. 7% Discount Rate
43156
Total
sradovich on DSK3GMQ082PROD with PROPOSALS2
Total
Societal
$B
Mass
changes
Sales
Impacts
Subtotal
CAFE
Atrb.
Rebound
effect
Total
VerDate Sep<11>2014
-3.70
-3.55
-3.04
-2.44
-1.68
-1.34
-0.67
-0.83
-0.29
-0.27
-0.22
-0.18
-0.08
-0.07
-0.04
-0.02
-1.20
-1.16
-0.96
-0.72
-0.51
-0.36
-0.19
-0.20
-1.49
-1.43
-1.18
-0.89
-0.59
-0.43
-0.23
-0.22
-4.57
-4.39
-3.81
-3.12
-2.18
-1.76
-0.87
-1.13
-6.06
-5.82
-4.99
-4.00
-2.76
-2.20
-1.09
-1.35
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Table 11-77- Change in Safety Parameters from GHG Augural Standards Baseline
Total Fatalities MY 1977-2029~ 3% Discount Rate
Change in Safety Parameters from Augural Standards Baseline
Fatalities
Mass changes
Sales Impacts
Subtotal
CAFE Atrb.
Rebound
effect
Total
Fatalities
Societal $B
Mass changes
Alt2
Alt3
Alt 4
Alt 5
Alt 6
Alt 7
Alt 8
-468
-461
-410
-297
-219
-186
-111
-85
-7,880
-8,350
-7,600
-8,060
-6,630
-7,040
-5,460
-5,760
-4,150
-4,370
-3,240
-3,430
-1,530
-1,640
-2,090
-2,170
-7,300
-6,930
-6,340
-5,250
-3,480
-3,260
-2,110
-2,010
-15,600
-15,000
-13,400
-11,000
-7,850
-6,690
-3,760
-4,190
-2.9
-2.9
-2.6
-1.9
-1.4
-1.2
-0.7
-0.5
Sales Impacts
-43.3
-41.7
-36.6
-30.1
-22.5
-18.0
-8.9
-11.6
Subtotal
CAFE Atrb.
Rebound
effect
Total
-46.2
-44.6
-39.2
-32.0
-23.9
-19.2
-9.7
-12.1
-47.8
-45.3
-41.6
-34.4
-22.7
-21.5
-14.2
-13.3
-94.0
-89.9
-80.8
-66.4
-46.6
-40.7
-23.8
-25.4
Nonfatal
Societal $B
Mass changes
-4.6
-4.5
-4.0
-2.9
-2.2
-1.9
-1.1
-0.8
Sales Impacts
-67.8
-65.2
-57.3
-47.1
-35.2
-28.2
-13.9
-18.1
Subtotal
CAFE Atrb.
Rebound
effect
Total
-72.3
-69.7
-61.3
-50.0
-37.3
-30.0
-15.1
-18.9
-74.7
-70.8
-65.0
-53.9
-35.6
-33.7
-22.1
-20.8
-147
-141
-126
-104
-72.9
-63.7
-37.2
-39.7
-7.5
-111
-7.4
-107
-6.6
-93.9
-4.8
-77.2
-3.5
-57.7
-3.1
-46.2
-1.9
-22.8
-1.4
-29.7
-119
-114
-101
-82.0
-61.2
-49.2
-24.8
-31.0
-123
-116
-107
-88.3
-58.3
-55.2
-36.3
-34.1
-241
-231
-207
-170
-120
-104
-61.0
-65.1
Total Societal
$B
Mass changes
Sales Impacts
Subtotal
CAFE Atrb.
Rebound
effect
Total
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Total Fatalities MY 1977-2029, 3% Discount Rate
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While NHTSA notes the value of
rebound effect fatalities, as well as total
fatalities from all causes, the agency
does not add rebound effects to the
other CAFE-related impacts because
rebound-related fatalities and injuries
result from risk that is freely chosen and
offset by societal valuations that at a
minimum exceed the aggregate value of
safety consequences plus added vehicle
operating and maintenance costs.330
These costs implicitly involve a cost
and a benefit that are offsetting. The
relevant safety impacts attributable to
CAFE are highlighted in bold in the
above tables.
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1. Specification of No-Action and Other
Regulatory Alternatives
(a) Mathematical Functions Defining
Passenger Car and Light Trucks
Standards for Each Model Year During
2016–2032
In the U.S. market, the stringency of
CAFE and CO2 standards can influence
the design of new vehicles offered for
sale by requiring manufacturers to
produce increasingly fuel efficient
vehicles in order to meet program
330 It would also include some level of consumer
surplus, which we have estimated using the
standard triangular function. This is discussed in
Chapter 8.5.1 of the PRIA.
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G. How the Model Analyzes Different
Potential CAFE and CO2 Standards
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requirements. This is also true in the
CAFE model simulation, where the
standards can be defined with a great
deal of flexibility to examine the impact
of different program specifications on
the auto industry. Standards are defined
for each model year and can represent
different slopes that relate fuel economy
to footprint, different regions of flat
slopes, and different rates of increase for
each of three regulatory classes covered
by the CAFE program (domestic
passenger cars, imported passenger cars,
and light trucks).
The CAFE model takes, as inputs, the
coefficients of the mathematical
functions described in Sections III and
IV. It uses these coefficients and the
function to which they belong to define
the target for each vehicle in the fleet,
then computes the standard using the
harmonic average of the targets for each
manufacturer and fleet. The model also
allows the user to define the extent and
duration of various compliance
flexibilities (e.g., limits on the amount
of credit that a manufacturer may claim
related to air conditioning efficiency
improvements or off-cycle fuel economy
adjustments) as well as limits on the
number of years that CAFE credits may
be carried forward or the amount that
may be transferred between a
manufacturer’s fleets.
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(b) Off-Cycle and A/C Efficiency
Adjustments Anticipated for Each
Model Year
Another aspect of credit accounting is
partially implemented in the CAFE
model at this point—those related to the
application of off-cycle and A/C
efficiency adjustments, which
manufacturers earn by taking actions
such as special window glazing or using
reflective paints that provide fuel
economy improvements in real-world
operation but do not produce
measurable improvements in fuel
consumption on the 2-cycle test.
NHTSA’s inclusion of off-cycle and
A/C efficiency adjustments began in MY
2017, while EPA has collected several
years’ worth of submissions from
manufacturers about off-cycle and A/C
efficiency technology deployment.
Currently, the level of deployment can
vary considerably by manufacturer with
several claiming extensive Fuel
Consumption Improvement Values
(FCIV) for off-cycle and A/C efficiency
technologies and others almost none.
The analysis of alternatives presented
here does not attempt to project how
future off-cycle and A/C efficiency
technology use will evolve or speculate
about the potential proliferation of FCIV
proposals submitted to the agencies.
Rather, this analysis uses the off-cycle
credits submitted by each manufacturer
for MY 2017 compliance and carries
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these forward to future years with a few
exceptions. Several of the technologies
described in Section II.D are associated
with A/C efficiency and off-cycle FCIVs.
In particular, stop-start systems,
integrated starter generators, and full
hybrids are assumed to generate offcycle adjustments when applied to
vehicles to improve their fuel economy.
Similarly, higher levels of aerodynamic
improvements are assumed to include
active grille shutters on the vehicle,
which also qualify for off-cycle FCIVs.
The analysis assumes that any offcycle FCIVs that are associated with
actions outside of the technologies
discussed in Section II.D (either chosen
from the pre-approved ‘‘pick list,’’ or
granted in response to individual
manufacturer petitions) remain at the
levels claimed by manufacturers in MY
2017. Any additional A/C efficiency and
off-cycle adjustments that accrue as the
result of explicit technology application
are calculated dynamically in each
model year for each alternative. The offcycle FCIVs for each manufacturer and
fleet, denominated in grams CO2 per
mile,331 are provided in Table II–79.
331 For the purpose of estimating their
contribution to CAFE compliance, the grams CO2/
mile values in Table II–79 are converted to gallons/
mile and applied to a manufacturer’s 2-cycle CAFE
performance. When calculating compliance with
EPA’s GHG program, there is no conversion
necessary (as standards are also denominated in
grams/mile).
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The model currently accounts for any
off-cycle adjustments associated with
technologies that are included in the set
of fuel-saving technologies explicitly
simulated as part of this proposal (for
example, start-stop systems that reduce
fuel consumption during idle or active
grille shutters that improve
aerodynamic drag at highway speeds)
and accumulates these adjustments up
to the 10 g/mi cap. As a practical matter,
most of the adjustments for which
manufacturers are claiming off-cycle
FCIV exist outside of the technology
tree, so the cap is rarely reached during
compliance simulation. If those FCIVs
become a more important compliance
mechanism, it may be necessary to
model their application explicitly.
However, doing so will require data on
which vehicle models already possess
these improvements as well as the cost
and expected value of applying them to
other models in the future. Comment is
sought on both the data requirements
and strategic decisions associated with
manufacturers’ use of A/C efficiency
and off-cycle technologies to improve
CAFE and CO2 compliance.
(c) Civil Penalty Rate and OEMs’
Anticipated Willingness To Treat Civil
Penalties as a Program Flexibility
Throughout the history of the CAFE
program, some manufacturers have
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consistently achieved fuel economy
levels below their standard. As in
previous versions of the CAFE model,
the current version allows the user to
specify inputs identifying such
manufacturers and to consider their
compliance decisions as if they are
willing to pay civil penalties for noncompliance with the CAFE program.
The assumed civil penalty rate in the
current analysis is $5.50 per 1/10 of a
mile per gallon, per vehicle sold.
It is worth noting that treating a
manufacturer as if they are willing to
pay civil penalties does not necessarily
mean that it is expected to pay penalties
in reality. It merely implies that the
manufacturer will only apply fuel
economy technology up to a point, and
then stop, regardless of whether or not
its corporate average fuel economy is
above its standard. In practice, we
expect that many of these manufacturers
will continue to be active in the credit
market, using trades with other
manufacturers to transfer credits into
specific fleets that are challenged in any
given year, rather than paying penalties
to resolve CAFE deficits. The CAFE
model calculates the amount of
penalties paid by each manufacturer,
but it does not simulate trades between
manufacturers. In practice, some
(possibly most) of the total estimated
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penalties may be a transfer from one
OEM to another.
While the Energy Policy and
Conservation Act (EPCA), as amended
in 2007 by the Energy Independence
and Security Act, prescribes these
specific civil penalty provisions for
CAFE standards, the Clean Air Act
(CAA) does not contain similar
provisions. Rather, the CAA’s
provisions regarding noncompliance
constitute a de facto prohibition against
selling vehicles failing to comply with
emissions standards. Therefore, inputs
regarding civil penalties—including
inputs regarding manufacturers’
potential willingness to treat civil
penalty payment as an economic
choice—apply only to simulation of
CAFE standards.
(d) Treatment of Credit Provisions for
‘‘Standard Setting’’ and
‘‘Unconstrained’’ Analyses
NHTSA may not consider the
application of CAFE credits toward
compliance with new standards when
establishing the standards
themselves.332 As such, this analysis
considers 2020 to be the last model year
in which carried-forward or transferred
credits can be applied for the CAFE
program. Beginning in model year 2021,
332 49
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today’s ‘‘standard setting’’ analysis is
conducted assuming each fleet must
comply with the CAFE standard
separately in every model year.
The ‘‘unconstrained’’ perspective
acknowledges that these flexibilities
exist as part of the program and, while
not considered in NHTSA’s decision of
the preferred alternative, are important
to consider when attempting to estimate
the real impact of any alternative. Under
the ‘‘unconstrained’’ perspective, credits
may be earned, transferred, and applied
to deficits in the CAFE program
throughout the full range of model years
in the analysis. The Draft Environmental
Impact Analysis (DEIS) accompanying
today’s NPRM presents results of
‘‘unconstrained’’ modeling. Also,
because the CAA provides no direction
regarding consideration of any CO2
credit provisions, today’s analysis
includes simulation of carried-forward
and transferred CO2 credits in all model
years.
(e) Treatment of AFVs for ‘‘Standard
Setting’’ and ‘‘Unconstrained’’ Analyses
NHTSA is also prohibited from
considering the possibility that a
manufacturer might produce
alternatively fueled vehicles as a
compliance mechanism,333 taking
advantage of credit provisions related to
AFVs that significantly increase their
fuel economy for CAFE compliance
purposes. Under the ‘‘standard setting’’
perspective, these technologies (pure
battery electric vehicles and fuel cell
vehicles 334) are not available in the
compliance simulation to improve fuel
economy. Under the ‘‘unconstrained’’
perspective, such as is documented in
the DEIS, the CAFE model considers
these technologies in the context of all
other available technologies and may
apply them if they represent costeffective compliance pathways.
However, under both perspectives, the
analysis continues to include dedicated
AFVs that already exist in the MY 2016
fleet (and their projected future
volumes) in CAFE calculations. Also,
because the CAA provides no direction
regarding consideration of alternative
fuels, today’s analysis includes
simulation of the potential that some
manufacturers might introduce new
AFVs in response to CO2 standards. To
fully represent the compliance benefit
from such a response, NHTSA modified
the CAFE model to include the specific
provisions related to AFVs under the
CO2 standards. In particular, the CAFE
333 Id.
334 Dedicated compressed natural gas (CNG)
vehicles should also be excluded in this perspective
but are not considered as a compliance strategy
under any perspective in this analysis.
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model now carries a full representation
of the production multipliers related to
electric vehicles, fuel cell vehicles,
plug-in hybrids, and CNG vehicles, all
of which vary by year through MY 2021.
(3) For manufacturers assumed to be
willing to pay civil penalties (in the CAFE
program), the manufacturer reaches the point
at which doing so would be more costeffective (from the manufacturer’s
perspective) than adding further technology.
2. Simulation of Manufacturers’ [and
Buyers’] Potential Responses to Each
Alternative
The CAFE model provides a way of
estimating how manufacturers could
attempt to comply with a given CAFE
standard by adding technology to fleets
that the agencies anticipate they will
produce in future model years. This
exercise constitutes a simulation of
manufacturers’ decisions regarding
compliance with CAFE or CO2
standards.
This compliance simulation begins
with the following inputs: (a) The
analysis fleet of vehicles from model
year 2016 discussed above in Section
II.B, (b) fuel economy improving
technology estimates discussed above in
Section II.D, (c) economic inputs
discussed above in Section II.E, and (d)
inputs defining baseline and potential
new CAFE standards. For each
manufacturer, the model applies
technologies in both a logical sequence
and a cost-minimizing strategy in order
to identify a set of technologies the
manufacturer could apply in response to
new CAFE or CO2 standards. The model
applies technologies to each of the
projected individual vehicles in a
manufacturer’s fleet, considering the
combined effect of regulatory and
market incentives while attempting to
account for manufacturers’ production
constraints. Depending on how the
model is exercised, it will apply
technology until one of the following
occurs:
The model accounts explicitly for
each model year, applying technologies
when vehicles are scheduled to be
redesigned or freshened and carrying
forward technologies between model
years once they are applied (until, if
applicable, they are superseded by other
technologies). The model then uses
these simulated manufacturer fleets to
generate both a representation of the
U.S. auto industry and to modify a
representation of the entire light-duty
registered vehicle population. From
these fleets, the model estimates
changes in physical quantities (gallons
of fuel, pollutant emissions, traffic
fatalities, etc.) and calculates the
relative costs and benefits of regulatory
alternatives under consideration.
The CAFE model accounts explicitly
for each model year, in turn, because
manufacturers actually ‘‘carry forward’’
most technologies between model years,
tending to concentrate the application of
new technology to vehicle redesigns or
mid-cycle ‘‘freshenings,’’ and design
cycles vary widely among
manufacturers and specific products.
Comments by manufacturers and model
peer reviewers strongly support explicit
year-by-year simulation. Year-by-year
accounting also enables accounting for
credit banking (i.e., carry-forward), as
discussed above, and at least four
environmental organizations recently
submitted comments urging the
agencies to consider such credits, citing
NHTSA’s 2016 results showing impacts
of carried-forward credits.337 Moreover,
EPCA/EISA requires that NHTSA make
a year-by-year determination of the
appropriate level of stringency and then
set the standard at that level, while
ensuring ratable increases in average
fuel economy through MY 2020. The
multi-year planning capability,
(optional) simulation of ‘‘market-driven
overcompliance,’’ and EPCA credit
mechanisms (again, for purposes of
modeling the CAFE program) increase
the model’s ability to simulate
manufacturers’ real-world behavior,
accounting for the fact that
(1) The manufacturer’s fleet achieves
compliance 335 with the applicable standard
and continuing to add technology in the
current model year would be attractive
neither in terms of stand-alone (i.e., absent
regulatory need) cost-effectiveness nor in
terms of facilitating compliance in future
model years;
(2) The manufacturer ‘‘exhausts’’ available
technologies; 336 or
335 When determining whether compliance has
been achieved in the CAFE program, existing CAFE
credits that may be carried over from prior model
years or transferred between fleets are also used to
determine compliance status. For purposes of
determining the effect of maximum feasible CAFE
standards, NHTSA cannot consider these
mechanisms for years being considered (though
does so for model years that are already final) and
exercises the CAFE model without enabling these
options.
336 In a given model year, it is possible that
production constraints cause a manufacturer to
‘‘run out’’ of available technology before achieving
compliance with standards. This can occur when:
(a) An insufficient volume of vehicles are expected
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to be redesigned, (b) vehicles have moved to the
ends of each (relevant) technology pathway, after
which no additional options exist, or (c)
engineering aspects of available vehicles make
available technology inapplicable (e.g., secondary
axle disconnect cannot be applied to two-wheel
drive vehicles).
337 Comment by Environmental Law & Policy
Center, Natural Resources Defense Council (NRDC),
Public Citizen, and Sierra Club, Docket ID EPA–
HQ–OAR–2015–0827–9826, at 28–29.
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manufacturers will seek out compliance
paths for several model years at a time,
while accommodating the year-by-year
requirement. This same multi-year
planning structure is used to simulate
responses to standards defined in grams
CO2/mile, and utilizing the set of
specific credit provisions defined under
EPA’s program.
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(a) Representation of Manufacturers’
Production Constraints
After the light-duty rulemaking
analysis accompanying the 2012 final
rule that finalized NHTSA’s standards
through MY 2021, NHTSA began work
on changes to the CAFE model with the
intention of better reflecting constraints
of product planning and cadence for
which previous analyses did not
account.
(b) Product Cadence
Past comments on the CAFE model
have stressed the importance of product
cadence—i.e., the development and
periodic redesign and freshening of
vehicles—in terms of involving
technical, financial, and other practical
constraints on applying new
technologies, and DOT has steadily
made changes to both the CAFE model
and its inputs with a view toward
accounting for these considerations. For
example, early versions of the model
added explicit ‘‘carrying forward’’ of
applied technologies between model
years, subsequent versions applied
assumptions that most technologies will
be applied when vehicles are freshened
or redesigned, and more recent versions
applied assumptions that manufacturers
would sometimes apply technology
earlier than ‘‘necessary’’ in order to
facilitate compliance with standards in
ensuing model years. Thus, for example,
if a manufacturer is expected to redesign
many of its products in model years
2018 and 2023, and the standard’s
stringency increases significantly in
model year 2021, the CAFE model will
estimate the potential that the
manufacturer will add more technology
than necessary for compliance in MY
2018, in order to carry those product
changes forward through the next
redesign and contribute to compliance
with the MY 2021 standard. This
explicit simulation of multiyear
planning plays an important role in
determining year-by-year analytical
results.
As in previous iterations of CAFE
rulemaking analysis, the simulation of
compliance actions that manufacturers
might take is constrained by the pace at
which new technologies can be applied
in the new vehicle market. Operating at
the Make/Model level (e.g., Toyota
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Camry) allows the CAFE model to
explicitly account for the fact that
individual vehicle models undergo
significant redesigns relatively
infrequently. Many popular vehicle
models are only redesigned every six
years or so, with some larger/legacy
platforms (the old Ford Econoline Vans,
for example) stretching more than a
decade between significant redesigns.
Engines, which are often shared among
many different models and platforms for
a single manufacturer, can last even
longer—eight to ten years in most cases.
While these characterizations of
product cadence are important to any
evaluation of the impacts of CAFE or
CO2 standards, they are not known with
certainty—even by the manufacturers
themselves over time horizons as long
as those covered by this analysis.
However, lack of certainty about
redesign schedules is not license to
ignore them. Indeed, when
manufacturers meet with the agencies to
discuss manufacturers’ plans vis-a`-vis
CAFE and CO2 requirements,
manufacturers typically present specific
and detailed year-by-year information
that explicitly accounts for anticipated
redesigns. Such year-by-year analysis is
also essential to manufacturers’ plans to
make use of provisions (for CAFE,
statutory and specific) allowing credits
to be carried forward to future model
years, carried back from future model
years, transferred between regulated
fleets, and traded with other
manufacturers. Manufacturers are never
certain about future plans, but they
spend considerable effort developing,
continually adjusting, and
implementing them.
For every model that appears in the
MY 2016 analysis fleet, the model years
have been estimated in which future
redesigns (and less significant
‘‘freshenings,’’ which offer
manufacturers the opportunity to make
less significant changes to models) will
occur. These appear in the market data
file for each model variant. Mid-cycle
freshenings provide additional
opportunities to add some technologies
in years where smaller shares of a
manufacturer’s portfolio is scheduled to
be redesigned. In addition, the analysis
accounts for multiyear planning—that
is, the potential that manufacturers may
apply ‘‘extra’’ technology in an early
model year with many planned
redesigns in order to carry technology
forward to facilitate compliance in a
later model year with fewer planned
redesigns. Further, the analysis accounts
for the potential that manufacturers
could earn CAFE and/or CO2 credits in
some model years and use those credits
in later model years, thereby providing
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another compliance option in years with
few planned redesigns. Finally, it
should be noted that today’s analysis
does not account for future new
products (or discontinued products)—
past trends suggest that some years in
which an OEM had few redesigns may
have been years when that OEM
introduced significant new products.
Such changes in product offerings can
obviously be important to
manufacturers’ compliance positions
but cannot be systematically and
transparently accounted for with a fleet
forecast extrapolated forward 10 or more
years from a largely-known fleet. While
manufacturers’ actual plans reflect
intentions to discontinue some products
and introduce others, those plans are
considered CBI. Further research would
be required in order to determine
whether and, if so, how it would be
practicable to simulate such decisions,
especially without relying on CBI.
Additionally, each technology
considered for application by the CAFE
model is assigned to either a ‘‘refresh’’
or ‘‘redesign’’ cadence that dictates
when it can be applied to a vehicle.
Technologies that are assigned to
‘‘refresh/redesign’’ can be applied at
either a refresh or redesign, while
technologies that are assigned to
‘‘redesign’’ can only be applied during
a significant vehicle redesign. Table II–
80 and Table II–81 show the
technologies available to manufacturers
in the compliance simulation, the level
at which they are applied (described in
greater detail in the CAFE model
documentation), whether they are
available outside of a vehicle redesign,
and a short description of each. A brief
examination of the tables shows that
most technologies are only assumed to
be available during a vehicle redesign—
and nearly all engine improvements are
assumed to be available only during
redesign. In a departure from past CAFE
analyses, all transmission improvements
are assumed to be available during
refresh as well as redesign. While there
are past and recent examples of midcycle product changes, it seems
reasonable to expect that manufacturers
will tend to attempt to keep engineering
and other costs down by applying most
major changes mainly during vehicle
redesigns and some mostly modest
changes during product freshenings. As
mentioned below, comment is sought on
the approach to account for product
cadence.
(c) Component Sharing and Inheritance
(Engines, Transmissions, and Platforms)
In practice, manufacturers are limited
in the number of engines and
transmissions that they produce.
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Typically, a manufacturer produces a
number of engines—perhaps six or eight
engines for a large manufacturer—and
tunes 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 service
costs that scale with the number of parts
produced.
In previous analyses that used the
CAFE model (with the exception of the
2016 Draft TAR), engines and
transmissions in individual vehicle
models were allowed relative freedom
in technology application, potentially
leading to solutions that would, if
followed, create many more unique
engines and transmissions than exist in
the analysis fleet (or in the market) for
a given model year. This multiplicity
likely failed to sufficiently account for
costs associated with such increased
complexity in the product portfolio and
may have represented an unrealistic
diffusion of products for manufacturers
that are consolidating global production
to increasingly smaller numbers of
shared engines and platforms.338 The
lack of a constraint in this area allowed
the model to apply different levels of
technology to the engine in each vehicle
in which it was present at the time that
vehicle was redesigned or refreshed,
independent of what was done to other
vehicles using a previously identical
engine.
One peer reviewer of the CAFE model
recently commented, ‘‘The integration
of inheritance and sharing of engines,
transmissions, and platforms across a
manufacturer’s light duty fleet and
separately across its light duty truck
fleet is standard practice within the
industry.’’ In the current version of the
CAFE model, engines and transmissions
that are shared between vehicles must
apply the same levels of technology, in
all technologies, dictated by engine or
transmission inheritance. This forced
adoption is referred to as ‘‘engine
inheritance’’ in the model
documentation. In practice, the model
first chooses an ‘‘engine leader’’ among
vehicles sharing the same engine—the
vehicle with the highest sales in MY
2016. If there is a tie, the vehicle with
the highest average MSRP is chosen,
representing the idea that manufacturers
will choose to pilot the newest
technology on premium vehicles if
possible. The model applies the same
logic with respect to the application of
transmission changes. After the model
338 2015
NAS Report, at pg. 258–259.
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modifies the engine on the ‘‘engine
leader’’ (or ‘‘transmission leader’’), the
changes to that engine propagate
through to the other vehicles that share
that engine (or transmission) in
subsequent years as those vehicles are
redesigned. The CAFE model has been
modified to provide additional
flexibility vis-a`-vis product cadence. In
a recent public comment, NRDC noted:
EPA and NHTSA currently constrain their
model to apply significant fuel-efficient
technologies mainly during a productredesign as opposed to product-refresh (or
mid-cycle). This was identified as one of the
most sensitive assumptions affecting overall
program costs by NHTSA in the TAR. By
constraining the model, the agencies have
likely under-estimated the ability of auto
manufacturers to incorporate some
technologies during their product refreshes.
This is particularly true regarding the critical
powertrain technologies which are
undergoing continuous improvement. The
agency should account for these trends and
incorporate greater flexibility for
automakers—within their models—to
incorporate more mid-cycle
enhancements.339
While engine redesigns are only
applied to the engine leader when it is
redesigned in the model, followers may
now inherit upgraded engines (that they
share with the leader) at either refresh
or redesign. All transmission changes,
whether upgrades to the ‘‘leader’’ or
inheritance to ‘‘followers’’ can occur at
refresh as well as redesign. This
provides additional opportunities for
technology diffusion within
manufacturers’ product portfolios.
While ‘‘follower’’ vehicles are
awaiting redesign (or, for transmissions,
refreshing as applicable), they carry a
legacy version of the shared engine or
transmission. As one peer reviewer
recently stated, ‘‘Most of the time a
manufacturer will convert only a single
plant within a model year. Thus both
the ‘old’ and ‘new’ variant of the engine
(or transmission) will produced for a
finite number of years.’’ 340 The CAFE
model currently carries no additional
cost associated with producing both
earlier revisions of an engine and the
updated version simultaneously.
Further research would be needed to
determine whether sufficient data is
likely to be available to explicitly
specify and apply additional costs
involved with continuing to produce an
existing engine or transmission for some
vehicles that have not yet progressed to
a newer version of that engine or
transmission. Comment is sought on
339 Comment by Environmental Law & Policy
Center, Natural Resources Defense Council (NRDC),
Public Citizen, and Sierra Club, Docket ID EPA–
HQ–OAR–2015–0827–9826, at 32.
340 CAFE Model Peer Review, p. 19.
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possible data sources and approaches
that could be used to represent any
additional costs associated with phased
introduction of new engines or
transmissions.
There are some logical consequences
of this approach, the first of which is
that forcing engine and transmission
changes to propagate through to other
vehicles in this way effectively dictates
the pace at which new technology can
be applied and limits the total number
of unique engines that the model
simulates. In the past, NHTSA used
‘‘phase-in caps’’ (see discussion below)
to limit the amount of technology that
can be applied to any vehicle in a given
year. However, by explicitly tying the
engine changes to a specific vehicle’s
product cadence, rather than letting the
timing of changes vary across all the
vehicles that share an engine, the model
ensures that an engine is only changed
when its leader is redesigned (at most).
Given that most vehicle redesign cycles
are five to eight years, this approach still
represents shorter average lives than
most engines in the market, which tend
to be in production for eight to ten years
or more. It is also the case that vehicles
which share an engine in the analysis
fleet (MY 2016, for this analysis) are
assumed to share that same engine
throughout the analysis—unless one or
both of them are converted to powersplit hybrids (or farther) on the
electrification path. In the market, this
is not true—since a manufacturer will
choose an engine from among the
engines it produces to fulfill the
efficiency and power demands of a
vehicle model upon redesign. That
engine need not be from the same family
of engines as the prior version of that
vehicle. This is a simplifying
assumption in the model. While the
model already accommodates detailed
inputs regarding redesign schedules for
specific vehicles and commercial
information sources are available to
inform these inputs, further research
would be needed to determine whether
design schedules for specific engines
and transmissions can practicably be
simulated.
The CAFE model has implemented a
similar structure to address shared
vehicle platforms. The term ‘‘platform’’
is used loosely in industry but generally
refers to a common structure shared by
a group of vehicle variants. The degree
of commonality varies with some
platform variants exhibiting traditional
‘‘badge engineering’’ where two
products are differentiated by little more
than insignias, while other platforms
may be used to produce a broad suite of
vehicles that bear little outer
resemblance to one another.
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Given the degree of commonality
between variants of a single platform,
manufacturers do not have complete
freedom to apply technology to a
vehicle: While some technologies (e.g.
low rolling resistance tires) are very
nearly ‘‘bolt-on’’ technologies, others
involve substantial changes to the
structure and design of the vehicle, and
therefore necessarily are constant among
vehicles that share a common platform.
NHTSA has, therefore, modified the
CAFE model such that all mass
reduction technologies are forced to be
constant among variants of a platform.
Within the analysis fleet, each vehicle
is associated with a specific platform.
Similar to the application of engine and
transmission technologies, the CAFE
model defines a platform ‘‘leader’’ as the
vehicle variant of a given platform that
has the highest level of observed mass
reduction present in the analysis fleet.
If there is a tie, the CAFE model begins
mass reduction technology on the
vehicle with the highest sales in model
year 2016. If there remains a tie, the
model begins by choosing the vehicle
with the highest MSRP in MY 2016. As
the model applies technologies, it
effectively levels up all variants on a
platform to the highest level of mass
reduction technology on the platform.
So, if the platform leader is already at
MR3 in MY 2016, and a ‘‘follower’’
starts at MR0 in MY 2016, the follower
will get MR3 at its next redesign (unless
the leader is redesigned again before
that time, and further increases the MR
level associated with that platform, then
the follower would receive the new MR
level).
In the 2015 NPRM proposing new fuel
consumption and GHG standards for
heavy-duty pickups and vans, NHTSA
specifically requested comment on the
general use of shared engines,
transmissions, and platforms within
CAFE rulemakings. While no
commenter responded to this specific
request, comments from some
environmental organizations cited
examples of technology sharing between
light- and heavy-duty products. NHTSA
has continued to refine its
implementation of an approach
accounting for shared engines,
transmissions, and platforms, and again
seeks comment on the approach,
recommendations regarding any other
approaches, and any information that
would facilitate implementation of the
agency’s current approach or any
alternative approaches.
(d) Phase-In Caps
The CAFE model retains the ability to
use phase-in caps (specified in model
inputs) as proxies for a variety of
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practical restrictions on technology
application, including the
improvements described above. Unlike
vehicle-specific restrictions related to
redesign, refreshes or platforms/engines,
phase-in caps constrain technology
application at the vehicle manufacturer
level for a given model year. Introduced
in the 2006 version of the CAFE model,
they were intended to reflect a
manufacturer’s overall resource capacity
available for implementing new
technologies (such as engineering
research and development personnel
and financial resources), thereby
ensuring that resource capacity is
accounted for in the modeling process.
Compared to prior analyses of lightduty standards, these model changes
result in some changes in the broad
characteristics of the model’s
application of technology to
manufacturers’ fleets. Since the use of
phase-in caps has been de-emphasized
and manufacturer technology
deployment remains tied strongly to
estimated product redesign and
freshening schedules, technology
penetration rates may jump more
quickly as manufacturers apply
technology to high-volume products in
their portfolio. As a result, the model
will ignore a phase-in cap to apply
inherited technology to vehicles on
shared engines, transmissions, and
platforms.
In previous CAFE rulemakings,
redesign/refresh schedules and phase-in
caps were the primary mechanisms to
reflect an OEM’s limited pool of
available resources during the
rulemaking time frame and the years
preceding it, especially in years where
many models may be scheduled for
refresh or redesign. The newlyintroduced representation of platform-,
engine-, and transmission-related
considerations discussed above augment
the model’s preexisting representation
of redesign cycles and eliminate the
need to rely on phase-in caps. By
design, restrictions that enforce
commonality of mass reduction on
variants of a platform, and those that
enforce engine and transmission
inheritance, will result in fewer vehicletechnology combinations in a
manufacturer’s future modeled fleet.
The integration of shared components
and product cadence as a mechanism to
control the pace of technology
application also more accurately
represents each manufacturer’s unique
position in the market and its existing
technology footprint, rather than a
technology-specific phase-in cap that is
uniformly applied to all manufacturers
in a given year. Comment is sought
regarding this shift away from relying
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on phase-in caps and, if greater reliance
on phase-in caps is recommended, what
approach and information can be used
to define and apply these caps.
(e) Interactions Between Regulatory
Classes
Like earlier versions, the current
CAFE model provides the capability for
integrated analysis spanning different
regulatory classes, accounting both for
standards that apply separately to
different classes and for interactions
between regulatory classes. Light
vehicle CAFE and CO2 standards are
specified separately for passenger cars
and light trucks. However, there is
considerable sharing between these two
regulatory classes—where a single
engine, transmission, or platform can
appear in both the passenger car and
light truck regulatory class. For
example, some sport-utility vehicles are
offered in 2WD versions classified as
passenger cars and 4WD versions
classified as light trucks. Integrated
analysis of manufacturers’ passenger car
and light truck fleets provides the
ability to account for such sharing and
reduces the likelihood of finding
solutions that could involve introducing
impractical levels of complexity in
manufacturers’ product lines.
Additionally, integrated fleet analysis
provides the ability to simulate the
potential that manufacturers could earn
CAFE and CO2 credits by over
complying with the standard in one
fleet and use those credits toward
compliance with the standard in
another fleet (i.e., to simulate credit
transfers between regulatory classes).
While previous versions of the CAFE
model have represented manufacturers’
fleets by drawing a distinction between
passenger cars and light trucks, the
current version of the CAFE model adds
a further distinction, capturing the
difference between passenger cars
classified as domestic passenger cars
and those classified as imports. The
CAFE program regulates those passenger
cars separately, and the current version
of the CAFE model simulates all three
CAFE regulatory classes separately:
Domestic Passenger Cars (DC), Imported
Passenger Cars (IC), and Light Trucks
(LT). CAFE regulations state that
standards, fuel economy levels, and
compliance are all calculated separately
for each class. These requirements are
specified explicitly by the Energy Policy
and Conservation Act (EPCA), with the
2007 Energy Independence and Security
Act (EISA) having added the
requirement to enforce minimum
standards for domestic passenger cars.
This update to the accounting imposes
two additional constraints on
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manufacturers that sell vehicles in the
U.S.: (1) The domestic minimum floor,
and (2) Limited transfers between cars
classified as ‘‘domestic’’ versus those
classified as ‘‘imported.’’ The domestic
minimum floor creates a threshold that
every manufacturer’s domestic car fleet
must exceed without the application of
CAFE credits. If a manufacturer’s
calculated standard is below the
domestic minimum floor, then the
domestic floor is the binding constraint
(even for manufacturers that are
assumed to be willing to pay fines for
non-compliance). The second constraint
poses challenges for manufacturers that
sell cars from both the domestic and
imported passenger car categories.
While previous versions of the CAFE
model considered those fleets as a single
fleet (i.e., passenger cars), the model
now forces them to comply separately
and limits the volume of credits that can
be shifted between them for compliance.
However, the CAA provides no
direction regarding compliance by
domestic and imported vehicles; EPA
has not adopted provisions similar to
the aforementioned EPCA/EISA
requirements and is not doing so today.
Therefore, consistent with current and
proposed CO2 regulations, the CAFE
model determines compliance for
manufacturers’ overall passenger car
fleets for EPA’s program.
During 2015–2016, a single version of
the CAFE model was applied to produce
analyses supporting both a rulemaking
regarding heavy-duty pickups and vans
(HD PUV) and the 2016 draft TAR
regarding CAFE standards for passenger
cars and light trucks. Both analyses
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reflected integrated analysis of the lightduty and HD PUV fleets, thereby
accounting for sharing between the
fleets. However, for most OEMs, that
analysis showed considerably less
sharing between light-duty and HD PUV
fleets than initially expected. Today’s
analysis includes only vehicles subject
to CAFE and light-duty CO2 standards,
and the agencies invite comment on
whether integrated analysis of the two
fleets should be pursued further.
3. Technology Application Algorithm
(a) Technology Representation and
Pathways
While some properties of the
technologies included in the analysis
are specified by the user (e.g., cost of the
technology), the set of included
technologies is part of the model itself,
which contains the information about
the relationships between
technologies.341 In particular, the CAFE
model contains the information about
the sequence of technologies, the paths
on which they reside, any prerequisites
associated with a technology’s
application, and any exclusions that
naturally follow once it is applied.
341 Unlike the 2012 Final Rule, where each
technology had a single effectiveness value for the
CAFE analysis, technology effectiveness in the
current version of the CAFE model is based on the
ANL simulation project and defined for each
combination of technologies, resulting in more than
100,000 technology effectiveness values for each of
ten technology classes. This large database is
extracted locally the first time the model is run and
can be modified by the user in that location to
reflect alternative assumptions about technology
effectiveness.
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The ‘‘application level’’ describes the
system of the vehicle to which the
technology is applied, which in turn
determines the extent to which that
decision affects other vehicles in a
manufacturer’s fleet. For example, if a
technology is applied at the ‘‘engine’’
level, it naturally affects all other
vehicles that share that same engine
(though not until they themselves are
redesigned, if it happens to be in a
future model year). Technologies
applied at the ‘‘vehicle’’ level can be
applied to a vehicle model without
impacting the other models with which
it shares components. Platform-level
technologies affect all of the vehicles on
a given platform, which can easily span
technology classes, regulatory classes,
and redesign cycles.
The ‘‘application schedule’’ identifies
when manufacturers are assumed to be
able to apply a given technology—with
many available only during vehicle
redesigns. The application schedule also
accounts for which technologies the
CAFE model tracks but does not apply.
These enter as part of the analysis fleet
(‘‘Baseline Only’’), and while they are
necessary for accounting related to cost
and incremental fuel economy
improvement, they do not represent a
choice that manufacturers make in the
model. As discussed in Section II.B, the
analysis fleet contains the information
about each vehicle model, engine, and
transmission selected for simulation and
defines the initial technology state of
the fleet relative to the sets of
technologies in Table II–80 and Table
II–81.
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Table 11-80- CAFE Model Technologies (1)
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SOHC
DOHC
OHV
VVT
VVL
SGDI
DEAC
HCR
HCR2
TURBOl
TURB02
CEGRl
ADEAC
CNG
ADSL
DSLI
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Level
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
Engine
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Application
Schedule
Baseline Only
Baseline Only
Baseline Only
Baseline Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Redesign Only
Baseline Only
Redesign Only
Redesign Only
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Description
Single Overhead Camshaft Engine
Double Overhead Camshaft Engine
Overhead Valve Engine (maps to SOHC)
Variable Valve Timing
Variable Valve Lift
Stoichiometric Gasoline Direct Injection
Cylinder Deactivation
High Compression Ratio Engine
High Compression Ratio Engine with DEAC and CEGR
Turbocharging and Downsizing, Level 1 (18 bar)
Turbocharging and Downsizing, Level 2 (24 bar)
Cooled Exhaust Gas Recirculation, Level 1 (24 bar)
Advanced Cylinder Deactivation
Compressed Natural Gas Engine
Advanced Diesel Engine
Diesel engine improvements
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~ c;~,.;uuology
As Table II–80 and Table II–81 show,
all of the engine technologies may only
be applied (for the first time) during
redesign. New transmissions can be
applied during either refresh or
redesign, except for manual
transmissions, which can only be
upgraded during redesign. Unlike
previous versions of the model, which
only allowed significant changes to
vehicle powertrains at redesign, this
version allows vehicles to inherit
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updates to shared components during
refresh. For example, assume Vehicle A
and Vehicle B share Engine 1, and
engine 1 is redesigned as part of Vehicle
A’s redesign in MY 2020. Vehicle B is
not redesigned until 2025 but is
refreshed in MY 2022. In the current
version of the CAFE model, Vehicle B
would inherit the updated version of
Engine 1 when it is freshened in MY
2022. This change allows more rapid
diffusion of powertrain updates (for
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example) throughout a manufacturer’s
portfolio and reduces the number of
years during which a manufacturer
would build both new and legacy
versions of the same engine. Despite
increasing the rate of technology
diffusion, this change still restricts the
pace at which new engines (for
example) can be designed and built (i.e.,
no faster than the redesign schedule of
the ‘‘leader’’ vehicle to which they are
tied). The only technology for which
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this does not hold is mass reduction
improvements; these occur at the
platform level, and each model on that
platform must be redesigned (not merely
refreshed) in order to receive the newest
version of the platform that contains the
most current mass reduction
technology.
The CAFE model defines several
‘‘technology classes’’ and ‘‘technology
pathways’’ for logically grouping all
available technologies for application on
a vehicle. Technology classes provide
costs and improvement factors shared
by all vehicles with similar body styles,
curb weights, footprints, and engine
types, while technology pathways
establish a logical progression of
technologies on a vehicle within a
system or sub-system (e.g., engine
technologies).
Technology classes, shown in Table–
II–82, are a means for specifying
common technology input assumptions
for vehicles that share similar
characteristics. Predominantly, these
classes signify the degree of
applicability of each of the available
technologies to a specific class of
vehicles and represent a specific set of
Autonomie simulations (conducted as
part of the Argonne National Lab largescale simulation study) that determine
the effectiveness of each technology to
improve fuel economy. The vehicle
technology classes also define, for each
technology, the additional cost
associated with application.342 Like the
TAR analysis, the model uses separate
technology classes for compact cars,
midsize cars, small SUVs, large SUVs,
and pickup trucks. However, in this
analysis, each of those distinctions also
has a ‘‘performance’’ version, that
represents another class with similar
body style but higher levels of
performance attributes (for a total of 10
technology classes). As the model
simulates compliance, identifying
technologies that can be applied to a
given manufacturer’s product portfolio
to improve fleet fuel economy, it relies
on the vehicle class to provide relevant
cost and effectiveness information for
each vehicle model.
The model defines technology
pathways for grouping and establishing
a logical progression of technologies on
a vehicle. Each pathway (or path) is
evaluated independently and in
parallel, with technologies on these
paths being considered in sequential
order. As the model traverses each path,
the costs and fuel economy
improvements are accumulated on an
incremental basis with relation to the
preceding technology. The system stops
examining a given path once a
combination of one or more
technologies results in a ‘‘best’’
technology solution for that path. After
evaluating all paths, the model selects
the most cost-effective solution among
all pathways. This parallel path
approach allows the modeling system to
progress through technologies in any
given pathway without being
unnecessarily prevented from
considering technologies in other paths.
Rather than rely on a specific set of
technology combinations or packages,
the model considers the universe of
applicable technologies, dynamically
identifying the most cost-effective
combination of technologies for each
manufacturer’s vehicle fleet based on
each vehicle’s initial technology content
and the assumptions about each
technology’s effectiveness, cost, and
interaction with all other technologies
both present and available.
(b) Technology Paths
The modeling system incorporates 16
technology pathways for evaluation as
shown in Table–II—83. Similar to
individual technologies, each path
carries an intrinsic application level that
denotes the scope of applicability of all
technologies present within that path
and whether the pathway is evaluated
on one vehicle at a time, or on a
collection of vehicles that share the
same platform, engine, or transmission.
342 Inputs are specified to assign each vehicle in
the analysis fleet to one of these technology classes,
as discussed in Section II.B.
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The technologies that comprise the
five Engine-Level paths available within
the model are presented in Figure-II-13.
Note: The baseline-level technologies
(SOHC, DOHC, OHV, and CNG) appear
in gray boxes. These technologies are
used to inform the modeling system of
the initial engine’s configuration and are
not otherwise applicable during the
analysis. Additionally, the VCR path
(intended to house fuel economy
improvements from variable
compression ratio engines) was not used
in this analysis but is present within the
model. Unlike earlier versions of the
CAFE model, that enforced strictly
sequential application of technologies
like VVL and SGDI, this version of the
CAFE model allows basic engine
technologies to be applied in any order
once an engine has VVT (the base state
of all ANL simulations). Once the model
progresses past the basic engine path, it
considers all of the more advanced
engine paths (Turbo, HCR, Diesel, and
ADEAC) simultaneously. They are
assumed to be mutually exclusive. Once
one path is taken, it locks out the others
to avoid situations where the model
could be perceived to force
manufacturers to radically change
engine architecture with each redesign,
incurring stranded capital costs and lost
opportunities for learning.
For all pathways, the technologies are
evaluated and applied to a vehicle in
sequential order, as shown from top to
bottom. In some cases, however, if a
technology is deemed ineffective, the
system will bypass it and skip ahead to
the next technology. If the modeling
system applies a technology that resides
later in the pathway, it will ‘‘backfill’’
anything that was previously skipped in
order to fully account for costs and fuel
economy improvements of the full
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technology combination.343 For any
technology that is already present on a
vehicle (either from the MY 2016 fleet
or previously applied by the model), the
system skips over those technologies as
well and proceeds to the next. These
skipped technologies, however, will not
be applied again during backfill.
While costs are still purely
incremental, technology effectiveness is
no longer constructed that way. The
non-sequential nature of the basic
engine technologies have no obvious
preceding technology except for VVT,
the root of our engine path. It was a
natural extension to carry this approach
to the other branches as well. The
technology effectiveness estimates are
now an integrated part of the CAFE
model and represent a translation of the
Argonne simulation database that
compares the fuel consumption of any
combination of technologies (across all
paths) to the base vehicle (that has only
VVT, 5-speed automatic transmission,
no electrification, and no body-level
improvements).344
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343 More detail about how the Argonne simulation
database was integrated into the CAFE model can
be found in PRIA Chapter 6.
344 This is true for all combinations other than
those containing manual transmissions. Because the
model does not convert automatic transmissions to
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The Basic Engine path begins with
SOHC, DOHC, and OHV technologies
defining the initial configuration of the
vehicle’s engine. Since these
technologies are not available during
modeling, the system evaluates this
pathway starting with VVT. Whenever a
technology pathway forks into two or
more branch points, as the engine path
does at the end of the basic engine path,
all of the branches are treated as
mutually exclusive. The model
evaluates all technologies forming the
branch simultaneously and selects the
most cost-effective for the application,
while disabling the unchosen remaining
paths.
The technologies that make up the
four Transmission-Level paths defined
by the modeling system are shown in
Figure-II-14. The baseline-level
technologies (AT5, MT5 and CVT)
appear in gray boxes and are only used
to represent the initial configuration of
a vehicle’s transmission. For simplicity,
all manual transmissions with five
forward gears or fewer have been
assigned the MT5 technology in the
manual transmissions, nor the inverse, technology
combinations containing manual transmissions use
a reference point identical to the base vehicle
description, but containing a 5-speed manual rather
than automatic transmission.
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analysis fleet. Similarly, all automatic
transmissions with five forward gears or
fewer have been assigned the AT5
technology. The model preserves the
initial configuration for as long as
possible, and prohibits manual
transmissions from becoming automatic
transmissions at any point. Automatic
transmissions may become CVT level 2
after progressing though the 6-speed
automatic. While the structure of the
model still allows automatic
transmissions to consider the move to
DCT, in practice they are restricted from
doing so in the market data file. This
allows vehicles that enter with a DCT to
improve it (if opportunities to do so
exist) but does not allow automatic
transmissions to become DCTs, in
recognition of low consumer
enthusiasm for the earlier versions the
transmission that have been introduced
over the last decade. The model does
not attempt to simulate ‘‘reversion’’ to
less advanced transmission
technologies, such as replacing a 6speed AT with a DCT and then
replacing that DCT with a 10-speed AT.
The agencies invite comment on
whether or not the model should be
modified to simulate such ‘‘reversion’’
and, if so, how this possible behavior
might be practicably simulated.
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larger architectural change of the two. In
general, the electrification technologies
are applied as vehicle-level
technologies, meaning that the model
applies them without affecting
components that might be shared with
other vehicles. In the case of the more
advanced electrification technologies,
where engines and transmissions are
removed or replaced, the model will
choose a new vehicle to be the leader on
that component (if necessary) and will
not force other vehicles sharing that
engine or transmission to become
hybrids (or EVs). In addition to the
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electrification technologies, there are
two electrical system improvements,
electric power steering (EPS) and
accessory improvements (IACC), which
were not part of the ANL simulation
project and are applied by the model as
fixed percentage improvements to all
technology combinations in a particular
technology class. Their improvements
are superseded by technologies in the
other electrification paths, BISG or
CISG, in the case of EPS, and strong
hybrids (and above) in the case of IACC,
which are assumed to include those
improvements already.
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The root of the Electrification path,
shown in Figure-II-15, is a conventional
powertrain (CONV) with no
electrification. The two strong hybrid
technologies (SHEVP2 and SHEVPS) on
the Hybrid/Electric path, are defined as
stand-alone and mutually exclusive.
These technologies are not incremental
over each other for cost or effectiveness
and do not follow a traditional
progression logic present on other paths.
While the SHEVP2 represents a hybrid
system paired with the existing engine
on a given vehicle, the SHEVPS removes
and replaces that engine, making it the
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The technology paths related to load
reduction of the vehicle are shown in
Figure-II-16. Of these, only the Mass
Reduction (MR) path is applied at the
platform level, thus affecting all
vehicles (across classes and body styles)
on a given platform. The remaining
technology paths are all applied at the
vehicle level, and technologies within
each path are considered purely
sequential. For mass reduction,
aerodynamic improvements, and
reductions in rolling resistance, the base
level of each path is the ‘‘zero state,’’ in
which a vehicle has exhibited none of
the improvements associated with the
technology path. In addition to choosing
among possible engine, transmission,
and electrification improvements to
improve a vehicle’s fuel economy, the
CAFE model will consider technologies
each of the possible load improvement
paths simultaneously.
Even though the model evaluates each
technology path independently, some of
the pathways are interconnected to
allow for additional logical progression
and incremental accounting of
technologies. For example, the cost of
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SHEVPS (power-split strong hybrid/
electric) on the Hybrid/Electric path is
defined as incremental over the
complete basic engine path (an engine
that contains VVT, VVL, SGDI, and
DEAC), the AT5 (5-speed automatic)
technology on the Automatic
Transmission path, and the CISG (crank
mounted integrated starter/generator)
technology on the Electrification path.
For that reason, whenever the model
evaluates the SHEVPS technology for
application on a vehicle, it ensures that,
at a minimum, all the aforementioned
technologies (as well as their
predecessors) have already been applied
on that vehicle. However, if it becomes
necessary for a vehicle to progress to the
power-split hybrid, the model will
virtually apply the technologies
associated with the reference point in
order to evaluate the attractiveness of
transitioning to the strong hybrid.
Of the 17 technology pathways
present in the model, all Engine paths,
the Automatic Transmission path, the
Electrification path, and both Hybrid/
Electric paths are logically linked for
incremental technology progression.
Some of the technology pathways, as
defined in the model and shown in
Figure-II-17, may not be compatible
with a vehicle given its state at the time
of evaluation. For example, a vehicle
with a 6-speed automatic transmission
will not be able to get improvements
from a Manual Transmission path. For
this reason, the model implements logic
to explicitly disable certain paths
whenever a constraining technology
from another path is applied on a
vehicle. On occasion, not all of the
technologies present within a pathway
may produce compatibility constraints
with another path. In such a case, the
model will selectively disable a
conflicting pathway (or part of the
pathway) as required by the
incompatible technology.
For any interlinked technology
pathways shown in Figure-II-17, the
model also disables all preceding
technology paths whenever a vehicle
transitions to a succeeding pathway. For
example, if the model applies SHEVPS
technology on a vehicle, the model
disables the Turbo, HCR, ADEAC, and
Diesel Engine paths, as well as the Basic
Engine, the Automatic Transmission,
and the Electrification paths (all of
which precede the Hybrid/Electric
path).345 This implicitly forces vehicles
to always move in the direction of
increasing technological sophistication
each time they are reevaluated by the
model.
MY 2016 analysis fleet contains
information about each manufacturer’s:
345 The only notable exception to this rule occurs
whenever SHEVP2 technology is applied on a
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4. Simulating Manufacturer Compliance
With Standards
As a starting point, the model needs
enough information to represent each
manufacturer covered by the program.
As discussed above in Section II.B, the
vehicle. This technology may be present in
conjunction with any engine-level technology, and
as such, the Basic Engine path is not disabled upon
application of SHEVP2 technology, even though
this pathway precedes the Hybrid/Electric path.
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• Vehicle models offered for sale—their
current (i.e., MY 2016) production volumes,
manufacturer suggested retail prices
(MSRPs), fuel saving technology content
(relative to the set of technologies described
in Table II–80 and Table II–81), and other
attributes (curb weight, drive type,
assignment to technology class and
regulatory class),
• Production constraints—product
cadence of vehicle models (i.e., schedule of
model redesigns and ‘‘freshenings’’), vehicle
platform membership, degree of engine and/
or transmission sharing (for each model
variant) with other vehicles in the fleet,
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• Compliance constraints and
flexibilities—historical preference for full
compliance or penalty payment/credit
application, willingness to apply additional
cost-effective fuel saving technology in
excess of regulatory requirements, projected
applicable flexible fuel credits, and current
credit balance (by model year and regulatory
class) in first model year of simulation.
Each manufacturer’s regulatory
requirement represents the productionweighted harmonic mean of their
vehicle’s targets in each regulated fleet.
This means that no individual vehicle
has a ‘‘standard,’’ merely a target, and
each manufacturer is free to identify a
compliance strategy that makes the most
sense given its unique combination of
vehicle models, consumers, and
competitive position in the various
market segments. As the CAFE model
provides flexibility when defining a set
of regulatory standards, each
manufacturer’s requirement is
dynamically defined based on the
specification of the standards for any
simulation and the distribution of
footprints within each fleet.
Given this information, the model
attempts to apply technology to each
manufacturer’s fleet in a manner than
minimizes ‘‘effective costs.’’ The
effective cost captures more than the
incremental cost of a given technology;
it represents the difference between
their incremental cost and the value of
fuel savings to a potential buyer over the
first 30 months of ownership.346 In
addition to the technology cost and fuel
savings, the effective cost also includes
the change in fines from applying a
given technology and any estimated
welfare losses associated with the
technology (e.g., earlier versions of the
CAFE model simulated low-range
electric vehicles that produced a welfare
loss to buyers who valued standard
operating ranges between re-fueling
events). The effective cost metric
applied by the model does not attempt
to reflect all costs of vehicle ownership.
Further research would be required in
order to support simulation that
assumes buyers behave as if they
actually consider all ownership costs,
and that assumes manufacturers
respond accordingly. The agencies will
continue to consider the metric applied
to represent manufactuers’ approach to
making decisions regarding the
application of fuel-saving technologies
and invite comment regarding any
practicable changes that might make
346 The length of time over which to value fuel
savings in the effective cost calculation is a model
input that can be modified by the user. This
analysis uses 30 months’ worth of fuel savings in
the effective cost calculation, using the price of fuel
at the time of vehicle purchase.
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this aspect of the model even more
realistic.
This construction allows the model to
choose technologies that both improve a
manufacturer’s regulatory compliance
position and are most likely to be
attractive to its consumers. This also
means that different assumptions about
future fuel prices will produce different
rankings of technologies when the
model evaluates available technologies
for application. For example, in a high
fuel price regime, an expensive but very
efficient technology may look attractive
to manufacturers because the value of
the fuel savings is sufficiently high to
both counteract the higher cost of the
technology and, implicitly, satisfy
consumer demand to balance price
increases with reductions in operating
cost. Similarly, technologies for which
there exist consumer welfare losses
(discussed in Section II.E) will be seen
as less attractive to manufacturers who
may be concerned about their ability to
recover the full amount of the
technology cost during the sale of the
vehicle. The model continues to add
technology until a manufacturer either:
(a) Reaches compliance with regulatory
standards (possibly through the
accumulation and application of
overcompliance credits), (b) reaches a
point at which it is more cost effective
to pay penalties than to add more
technology (for CAFE), or (c) reaches a
point beyond compliance where the
manufacturer assumes its consumers
will be unwilling to pay for additional
fuel saving/emissions reducing
technologies.
In general, the model adds technology
for several reasons but checks these
sequentially. The model then applies
any ‘‘forced’’ technologies. Currently,
only VVT is forced to be applied to
vehicles at redesign since it is the root
of the engine path and the reference
point for all future engine technology
applications.347 The model next applies
any inherited technologies that were
applied to a leader vehicle and carried
forward into future model years where
follower vehicles (on the shared system)
are freshened or redesigned (and thus
eligible to receive the updated version
of the shared component). In practice,
very few vehicle models enter without
VVT, so inheritance is typically the first
step in the compliance loop. Then the
model evaluates the manufacturer’s
compliance status, applying all costeffective technologies regardless of
compliance status (essentially any
347 As a practical matter, this affects very few
vehicles. More than 95% of vehicles in the market
file either already have VVT present or have
surpassed the basic engine path through the
application of hybrids or electric vehicles.
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technology for which the effective cost
is negative). Then the model applies
expiring overcompliance credits (if
allowed to under the perspective of
either the ‘‘unconstrained’’ or ‘‘standard
setting’’ analysis, for CAFE purposes).
At this point, the model checks the
manufacturer’s compliance status again.
If the manufacturer is still not compliant
(and is unwilling to pay civil penalties,
again for CAFE), the model will add
technologies that are not cost-effective
until the manufacturer reaches
compliance. If the manufacturer
exhausts opportunities to comply with
the standard by improving fuel
economy/reducing emissions (typically
due to a limited percentage of its fleet
being redesigned in that year), the
model will apply banked CAFE or CO2
credits to offset the remaining deficit. If
no credits exist to offset the remaining
deficit, the model will reach back in
time to alter technology solutions in
earlier model years.
The CAFE model implements multiyear planning by looking back, rather
than forward. When a manufacturer is
unable to comply through cost-effective
(i.e., producing effective cost values less
than zero) technology improvements or
credit application in a given year, the
model will ‘‘reach back’’ to earlier years
and apply the most cost-effective
technologies that were not applied at
that time and then carry those
technologies forward into the future and
re-evaluate the manufacturer’s
compliance position. The model repeats
this process until compliance in the
current year is achieved, dynamically
rebuilding previous model year fleets
and carrying them forward into the
future, accumulating CAFE or CO2
credits from over-compliance with the
standard wherever appropriate.
In a given model year, the model
determines applicability of each
technology to each vehicle model,
platform, engine, and transmission. The
compliance simulation algorithm begins
the process of applying technologies
based on the CAFE or CO2 standards
specified during the current model year.
This involves repeatedly evaluating the
degree of noncompliance, identifying
the next ‘‘best’’ technology (ranked by
the effective cost discussed earlier)
available on each of the parallel
technology paths described above and
applying the best of these. The
algorithm combines some of the
pathways, evaluating them sequentially
instead of in parallel, in order to ensure
appropriate incremental progression of
technologies.
The algorithm first finds the best next
applicable technology in each of the
technology pathways then selects the
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best among these. For CAFE purposes,
the model applies the technology to the
affected vehicles if a manufacturer is
either unwilling to pay penalties or if
applying the technology is more costeffective than paying penalties.
Afterwards, the algorithm reevaluates
the manufacturer’s degree of
noncompliance and continues
application of technology. Once a
manufacturer reaches compliance (i.e.,
the manufacturer would no longer need
to pay penalties), the algorithm
proceeds to apply any additional
technology determined to be costeffective (as discussed above).
Conversely, if a manufacturer is
assumed to prefer to pay penalties, the
algorithm only applies technology up to
the point where doing so is less costly
than paying penalties. The algorithm
stops applying additional technology to
this manufacturer’s products once no
more cost-effective solutions are
encountered. This process is repeated
for each manufacturer present in the
input fleet. It is then repeated again for
each model year. Once all model years
have been processed, the compliance
simulation algorithm concludes. The
process for CO2 standard compliance
simulation is similar, but without the
option of penalty payment.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(a) Compliance Example
The following example will illustrate
the features discussed above for the
CAFE program. While the example
describes the actions that General
Motors takes to modify the Chevrolet
Equinox in order to comply with the
augural standards (the baseline in this
analysis), and the logical consequences
of these actions, a similar example
would develop if instead simulating
compliance with the EPA standards for
those years. The structure of GM’s fleet
and the mechanisms at work in the
CAFE model are identical in both cases,
but different features of each program
(unlimited credit transfers between
fleets, for example) would likely cause
the model to choose different
technology solutions.
At the start of the simulation in MY
2016, GM has 30 unique engines shared
across over 33 unique nameplates, 260
model variants, and three regulatory
classes. As discussed earlier, the CAFE
model will attempt to preserve that level
of sharing across GM’s fleets to avoid
introducing additional production
complexity for which the agencies do
not estimate additional costs. An even
smaller number of transmissions (16)
and platforms (12) are shared across the
same set of nameplates, model variants,
and regulatory classes.
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The Chevrolet Equinox is represented
in the model inputs as a single
nameplate, with five model variants
distinguished by the presence of allwheel drive and four distinct
powertrain configurations (two engines
paired with two different
transmissions). Across all five model
variants, GM produced above 220,000
units of the Equinox nameplate. About
150,000 units of that production volume
is regulated as Domestic Passenger Car,
with the remainder regulated as Light
Trucks. The easiest way to describe the
actions taken by the CAFE model is to
focus on a single model variant of the
Equinox (one row in the market data
file). The model variant of the Equinox
with the highest production volume,
about 130,000 units in MY 2016, is
vehicle code 110111.348 This unique
model variant is the basis for the
example. However, because it is only
one of five variants on the Equinox
nameplate, the modifications made to
that model in the simulation will affect
the rest of the Equinox variants and
other vehicles across all fleets.
The example Equinox variant is
designated as an engine and platform
leader. As discussed earlier, this implies
that modifications to its engine (11031,
a 2.4L I–4) are tied to the redesign
cadence of this Equinox, as are
modifications to its platform (Theta/TE).
The engine is shared by the Buick
LaCrosse, Regal, and Verano, and by the
GMC Terrain (as well as appearing in
two other variants of the Equinox). So
those vehicles, if redesigned after this
Equinox, will inherit changes to engine
11031 when they are redesigned,
carrying the legacy version of the engine
until then. Similarly, this Equinox
shares its platform with the Cadillac
SRX and GMC Terrain, which will
inherit changes made to this platform
when they are redesigned (if later than
the Equinox, as is the case with the
SRX).
This specific Equinox is a
transmission ‘‘follower,’’ getting updates
made to its transmission leader (the
Chevrolet Malibu) when it is freshened
or redesigned. Additionally, two other
variants of the Equinox nameplate (the
more powerful versions, containing a
3.6L V–6 engine) are not ‘‘leaders’’ on
any of the primary components. Those
variants are built on the same platform
as the example Equinox variant but
share their engine with the Buick
Enclave and LaCrosse, the Cadillac SRX
348 This numeric designation is not important to
understand the example but will allow an
interested reader to identify the vehicle in model
outputs to either recreate the example or use it as
a template to create similar examples for other
manufacturers and vehicles.
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and XTS,349 the Chevrolet Colorado,
Impala and Traverse (which is the
designated ‘‘leader’’), and the GMC
Acadia, Canyon, and Terrain. This is an
example of how shared and inherited
components interact with product
cadence: when the Equinox nameplate
is redesigned, the CAFE model has more
leverage over some variants than others
and cannot make changes to the engines
of the variants of the Equinox with V–
6 unless that change is consistent with
all of the other nameplates just listed.
The transmissions on the other variants
of the Equinox are similarly widely
shared and represent the same kind of
production constraint just described
with respect to the engine. When
accounting for the full set of engines,
transmissions, and platforms
represented across the Equinox
nameplate’s five variants, components
are shared across all three regulatory
classes.
This example uses a ‘‘standard
setting’’ perspective to minimize the
amount of credit generation and
application, in order to focus on the
mechanics of technology application
and component sharing. The actions
taken by the CAFE model when
operating on the example Equinox
during GM’s compliance simulation are
shown in Table–II–84. In general, the
example Equinox begins the compliance
simulation with the technology
observed in its MY 2016 incarnation—
a 2.6L I–4 with VVT and SGDI, a 6speed automatic transmission, low
rolling resistance tires (ROLL20) and a
10% realized improvement in
aerodynamic drag (AERO10). In MY
2018, the Equinox is redesigned, at
which time the engine adds VVL and
level-1 turbocharging. The transmission
on the Malibu is upgraded to an 8-speed
automatic in 2018, which the Equinox
also gets. The platform, for which this
Equinox is the designated leader, gets
level-4 mass reduction. The CAFE
model also applies a few vehicle-level
technologies: low-drag brakes,
electronic accessory improvements, and
additional aerodynamic improvements
(AERO20). Upon refresh in MY 2021, it
acquires an upgraded 10-speed
transmission (AT10) from the Malibu.
349 The agencies recognized that GM last
produced the Cadillac SRX for MY 2016, and note
this as one example of the limitations of using an
analysis fleet defined in terms of even a recent
actual model year. Section II.B discusses these
tradeoffs, and the tentative judgment that, as a
foundation for analysis presented here, it was better
to develop the analysis fleet using the best
information available for MY 2016 than to have
used manufacturers’ CBI to construct an analysis
fleet that, though more current, would have limited
the agencies’ ability to make public all analytical
inputs and outputs.
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Then in MY 2025 it is redesigned again
and upgrades the engine to level-2
turbocharging, replaces the 10-speed
automatic transmission with a 8-speed
automatic transmission, adds a P2
strong hybrid, and further reduces the
mass of the platform (MR5). Using an
‘‘unconstrained’’ perspective would
possibly lead to additional actions taken
after MY 2025, where GM may have
been simulated to use credits earned in
earlier model years to offset small,
persistent CAFE deficits in one or more
fleets. In the ‘‘standard setting’’
perspective, that forces compliance
without the use of CAFE credits, this is
not an issue.
The technology applications
described in Table–II–84 have
consequences beyond the single variant
of the Equinox shown in the table. In
particular, two other variants of the
Equinox (both of which are regulated as
Light Trucks) get the upgraded engine,
which they share with the example, in
MY 2018. Thus, this application of
engine technology to a single variant of
the Equinox in the Domestic Car fleet,
‘‘spills over’’ into the Light Truck fleet,
generating improvements in fuel
economy and additional costs.
Furthermore, the Buick LaCrosse and
Regal, and the GMC Terrain also get the
same engine, which they share with the
example, in MY 2018. Those vehicles
also span the Domestic Car and Light
Truck fleets. However, the Buick
Verano, which is not redesigned until
MY 2019, continues with the legacy
(i.e., MY 2016) version of the shared
engine until it is redesigned. When it
inherits the new engine in MY 2019, it
does so without modification; the
engine it inherits is the same one that
was redesigned in MY 2018. This means
that the Verano will improve its fuel
economy in MY 2019 when the new
engine is inherited but only to the
extent that the new version of the
engine is an improvement over the
legacy version in the context of the
Verano’s other technology (which it is—
the Verano moves from 32 MPG to 44
MPG when accounting for the other
technologies added during the MY 2019
redesign).
This same story continues with the
diffusion of platform improvements
simulated by the CAFE model in MY
2018. The GMC Terrain is simulated to
be redesigned in MY 2018, in
conjunction with the Equinox. The
performance variants of the Equinox,
with a 3.5L V–6, also upgrade their
engines in MY 2018 (in conjunction
with the estimated Chevrolet Traverse
redesign). However, when the Equinox
is next redesigned in MY 2025, the
engine shared with the Traverse is not
upgraded again until MY 2026, so the
performance versions of the Equinox
continue with the 2018 version of the
engine throughout the remainder of the
simulation. While these inheritances
and sharing dynamics are not a perfect
representation of each manufacturer’s
specific constraints, nor the flexibilities
available to shift strategies in real-time
as a response to changing market or
regulatory conditions, they are a
reasonable way to consider the resource
constraints that prohibit fleet-wide
technology diffusion over shorter
windows than have been observed
historically and for which the agencies
have no way to impose additional costs.
Aside from the technology application
and its consequences throughout the
GM product portfolio, discussed above,
there are other important conclusions to
draw from the technology application
example. The first of these is that
product cadence matters, and only by
taking a year-by-year perspective can
this be seen. When the example Equinox
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is redesigned in MY 2018, the CAFE
model takes actions that cause the
redesigned Equinox to significantly
exceed its fuel economy target. While no
single vehicle has a ‘‘standard,’’ having
high volume vehicles significantly
below their individual targets can
present compliance challenges for
manufacturers who must compensate by
exceeding targets on other vehicles.
While the example Equinox exceeds its
MY 2018 target by almost 9 mpg, this
version of the Equinox is not eligible to
see significant technology changes again
before MY 2025 (except for the
transmission upgrade that occurs in MY
2021). Thus, the CAFE model is
redesigning the Equinox in MY 2018
with respect to future targets and
standards—this Equinox is nearly 2 mpg
below its target in MY 2024 before being
redesigned in MY 2025. This reflects a
real challenge that manufacturers face in
the context of continually increasing
CAFE standards, and represents a clear
example of why considering two model
year snapshots where all vehicles are
assumed to be redesigned is
unrealistically simplistic. The MY 2018
version of the example Equinox persists
(with little change) through six model
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years and the standards present in those
years. This is one reason why the CAFE
model, rather than OMEGA, was chosen
to examine the impacts of the proposed
standards in this analysis.
Another feature of note in Table–II–84
is the cost of applying these
technologies. The costs are all
denominated in dollars and represent
incremental cost increases relative to
the MY 2016 version of the Equinox.
Aside from the cost increase of over
$5,000 in MY 2025 when the vehicle is
converted to a strong hybrid, the
incremental technology costs display a
consistent trend between application
events—decreasing steadily over time as
the cost associated with each given
combination of technologies ‘‘learns
down.’’ By MY 2032, even the most
expensive version of the example
Equinox costs nearly $800 less to
produce than it did in MY 2025.
The technology application in the
example occurs in the context of GM’s
attempt to comply with the augural
standards. As some of the components
on the Equinox nameplate are shared
across all three regulated fleets, Table–
II–85 shows the compliance status of
each fleet in MYs 2016–2025. In MY
2017, the CAFE model applies expiring
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credits to offset deficits in the DC and
LT fleets. In MY 2028, when GM is
simulated to aggressively apply
technology to the example Equinox, the
DC fleet exceeds its standard while the
LT fleet still generates deficits. The
CAFE model offset that deficit with
expiring (and possibly transferred)
credits. However, by MY 2020 the
‘‘standard setting’’ perspective removes
the option of using CAFE credits to
offset deficits and GM exceeds the
standard in all three fleets, though by
almost 2 mpg in DC and LT. As the
Equinox example showed, many of the
vehicles redesigned in MY 2020 will
still be produced at the MY 2020
technology level in MY 2025 where GM
is simulated to comply exactly across all
three fleets. Under an ‘‘unconstrained’’
perspective, the CAFE model would use
the CAFE credits earned through overcompliance with the standards in MYs
2020–2023 to offset deficits created by
under-compliance as the standards
continued to increase, pushing some
technology application until later years
when the standards stabilized and those
credits expired. The CAFE model
simulates compliance through MY 2032
to account for this behavior.
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(b) Representation of OEMs’ Potential
Responsiveness to Buyers’ Willingness
To Pay for Fuel Economy Improvements
The CAFE model simulates
manufacturer responses to both
regulatory standards and technology
availability. In order to do so, it requires
assumptions about how the industry
views consumer demand for additional
fuel economy because manufacturer
responses to potential standards depend
not just on what they think they are best
off producing to satisfy regulatory
requirements (considering the
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consequences of not satisfying those
requirements), but also on what they
think they can sell, technology-wise, to
consumers. In the 2012 final rule, the
agencies analyzed alternatives under the
assumption that manufacturers would
not improve the fuel economy of new
vehicles at all unless compelled to do so
by the existence of increasingly
stringent CAFE and GHG standards.350
This ‘‘flat baseline’’ assumption led the
agencies to attribute all of the fuel
350 See,
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savings that occurred in the simulation
after MY 2016 to the proposed standards
because none of the fuel economy
improvements were considered likely to
occur in the absence of increasing
standards. However, this assumption
contradicted much of the literature on
this topic and the industry’s recent
experience with CAFE compliance, and
for CAFE standards, the analysis
published in 2016 applied a reference
case estimate that manufacturers will
treat all technologies that pay for
themselves within the first three years
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of ownership (through reduced
expenditures on fuel) as if the cost of
that technology were negative.351
The industry has exceeded the
required CAFE level for both passenger
cars and light trucks in the past;
notably, by almost 5 mpg during the fuel
price spikes of the 2000s when CAFE
standards for passenger cars were still
frozen at levels established for the 1990
model year.352 In fact, a number of
manufacturers that traditionally paid
CAFE civil penalties even reached
compliance during years with
sufficiently high fuel prices.353 The
model attempts to account for this
observed consumer preference for fuel
economy, above and beyond that
required by the regulatory standards, by
allowing fuel price to influence the
ranking of technologies that the model
considers when modifying a
manufacturer’s fleet in order to achieve
compliance. In particular, the model
ranks available technology not by cost,
but by ‘‘effective cost.’’
When the model chooses which
technology to apply next, it calculates
the effective cost of available
technologies and chooses the
technology with the lowest effective
cost. The ‘‘effective cost’’ itself is a
combination of the technology cost, the
fuel savings that would occur if that
technology were applied to a given
vehicle, the resulting change in CAFE
penalties (as appropriate), and the
affected volumes. User inputs determine
how much fuel savings manufacturers
believe new car buyers will pay for
(denominated in the number of years
before a technology ‘‘pays back’’ its
cost).
Because the civil penalty provisions
specified for CAFE in EPCA do not
apply to CO2 standards, the effective
cost calculation applied when
simulating compliance with CO2
standards uses an estimate of the
potential value of CO2 credits. Including
a valuation of CO2 credits in the
effective cost metric provides a potential
basis for future explicit modeling of
credit trading.354 Manufacturers,
351 Draft TAR, p. 13–10, available at https://
www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/
Draft-TAR-Final.pdf (last accessed June 15, 2018).
352 NHTSA, Summary of Fuel Economy
Performance, 2014, available at https://
www.nhtsa.gov/sites/nhtsa.dot.gov/files/
performance-summary-report-12152014-v2.pdf (last
accessed June 27, 2018).
353 Ibid. Additional data available at https://
one.nhtsa.gov/cafe_pic/CAFE_PIC_Mfr_LIVE.html
(last accessed June 27, 2018).
354 By treating all passenger cars and light trucks
as being manufactured by a single ‘‘OEM,’’ inputs
to the CAFE model can be structured to simulate
perfect trading. However, competitive and other
factors make perfect trading exceedingly unlikely,
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though, have thus far declined to
disclose the actual terms of CAFE or
CO2 credit trades, so this calculation
currently uses the CAFE civil penalty
rate as the basis to estimate this value.
It seems reasonable to assume that the
CAFE civil penalty rate likely sets an
effective ceiling on the price of any
traded CAFE credits, and considering
that each manufacturer can only
produce one fleet of vehicles for sale in
the U.S., prices of CO2 credits might
reasonably be expected to be equivalent
to prices of CAFE credits. However, the
current CAFE model does not explicitly
simulate credit trading; therefore, the
change in the value of CO2 credits
should only capture the change in
manufacturer’s own cost of compliance,
so the compliance simulation algorithm
applies a ceiling at 0 (zero) to each
calculated value of the CO2 credits.355
Just as manufacturers’ actual
approaches to vehicle pricing are
closely held, manufacturers’ actual
future approaches to making decisions
about technology are not perfectly
knowable. The CAFE model is intended
to illustrate ways manufacturers could
respond to standards, given a set of
production constraints, not to predict
how they will respond. Alternatives to
these ‘‘effective cost’’ metrics have been
considered and will continue to be
considered. For example, instead of
using a dollar value, the model could
use a ratio, such as the net cost
(technology cost minus fuel savings) of
an application of technology divided by
corresponding quantity of avoided fuel
consumption or CO2 emissions. Any
alternative metric has the potential to
shift simulated choices among
technology application options, and
some metrics would be less suited to the
CAFE model’s consideration of
multiyear product planning, or less
adaptable than others to any future
simulation of credit trading. Comment is
sought regarding the definition and
application of criteria to select among
technology options and determine when
to stop applying technology (consider
not only standards, but also factors such
as fuel prices, civil penalties for CAFE,
and the potential value of credits for
both programs), and this aspect of the
model may be further revised. Any
future revision to the effective cost
would be considered in light of
and future efforts will focus consideration on more
plausible imperfect trading.
355 Having the model continue to add technology
in order to build a surplus of credits as warranted
by the estimated (whether specified as a model
input or calculated dynamically as a clearing price)
market value of credits would provide part of the
basis for having the model build the supply side of
an explicitly-simulated credit trading market.
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manufacturers different compliance
positions relative to the standards, and
in light of the likelihood that some
OEMs will continue to use civil
penalties as a means to resolve CAFE
deficits (at least for some fleets).
While described in greater detail in
the CAFE model documentation, the
effective cost reflects an assumption not
about consumers’ actual willingness to
pay for additional fuel economy but
about what manufacturers believe
consumers are willing to pay. The
reference case estimate for today’s
analysis is that manufacturers will treat
all technologies that pay for themselves
within the first 21⁄2 years of ownership
(through reduced expenditures on fuel)
as if the cost of that technology were
negative. Manufacturers have repeatedly
indicated to the agencies that new
vehicle buyers are only willing to pay
for fuel economy-improving technology
if it pays back within the first two to
three years of vehicle ownership.356
NHTSA has therefore incorporated this
assumption (of willingness to pay for
technology that pays back within 30
months) into today’s analysis.
Alternatives to this 30-month estimate
are considered in the sensitivity
analysis included in today’s notice. In
the current version of the model, this
assumption holds whether or not a
manufacturer has already achieved
compliance. This means that the most
cost-effective technologies (those that
pay back within the first 21⁄2 years) are
applied to new vehicles even in the
absence of regulatory pressure.
However, because the value of fuel
savings depends upon the price of fuel,
the model will add more technology
even without regulatory pressure when
fuel prices are high compared to
simulations where fuel prices are
assumed to be low. This assumption is
consistent with observed historical
compliance behavior (and consumer
demand for fuel economy in the new
vehicle market), as discussed above.
One implication of this assumption is
that futures with higher, or lower, fuel
prices produce different sets of
attractive technologies (and at different
times). For example, if fuel prices were
above $7/gallon, many of the
technologies in this analysis could pay
for themselves within the first year or
two and would be applied at high rates
in all of the alternatives. Similarly, at
the other extreme (significantly reduced
fuel prices), almost no additional fuel
economy would be observed.
356 This is supported by the 2015 NAS study,
which found that consumers seek to recoup added
upfront purchasing costs within two or three years.
See 2015 NAS Report, at pg. 317.
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While these assumptions about
desired payback period and consumer
preferences for fuel economy may not
affect the eventual level of achieved
CAFE and CO2 emissions in the later
years of the program, they will affect the
amount of additional technology cost
and fuel savings that are attributable to
the standard. The approach currently
only addresses the inherent trade-off
between additional technology cost and
the value of fuel savings, but other costs
could be relevant as well. Further
research would be required to support
simulations that assume buyers behave
as if they consider all ownership costs
(e.g., additional excise taxes and
insurance costs) at the time of purchase
and that manufacturers respond
accordingly. Comment is sought on the
approach described above, the current
values ascribed to manufacturers’ belief
about consumer willingness-to-pay for
fuel economy, and practicable
suggestions for future improvements
and refinements, considering the
model’s purpose and structure.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(c) Representation of Some OEMs’
Willingness To Treat Civil Penalties as
a Program Flexibility
When considering technology
applications to improve fleet fuel
economy, the model will add
technology up to the point at which the
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effective cost of the technology (which
includes technology cost, consumer fuel
savings, consumer welfare changes, and
the cost of penalties for non-compliance
with the standard) is less costly than
paying civil penalties or purchasing
credits. Unlike previous versions of the
model, the current implementation
further acknowledges that some
manufacturers experience transitions
between product lines where they rely
heavily on credits (either carried
forward from earlier model years or
acquired from other manufacturers) or
simply pay penalties in one or more
fleets for some number of years. The
model now allows the user to specify,
when appropriate for the regulatory
program being simulated, on a year-byyear basis, whether each manufacturer
should be considered as willing to pay
penalties for non-compliance. This
provides additional flexibility,
particularly in the early years of the
simulation. As discussed above, this
assumption is best considered as a
method to allow a manufacturer to
under-comply with its standard in some
model years—treating the civil penalty
rate and payment option as a proxy for
other actions it may take that are not
represented in the CAFE model (e.g.,
purchasing credits from another
manufacturer, carry-back from future
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model years, or negotiated settlements
with NHTSA to resolve deficits).
In the current analysis, NHTSA has
relied on past compliance behavior and
certified transactions in the credit
market to designate some manufacturers
as being willing to pay CAFE penalties
in some model years. The full set of
assumptions regarding manufacturer
behavior with respect to civil penalties
is presented in Table–II–86, which
shows all manufacturers are assumed to
be willing to pay civil penalties prior to
MY 2020. This is largely a reflection of
either existing credit balances (which
manufacturers will use to offset CAFE
deficits until the credits reach their
expiration dates) or assumed trades
between manufacturers that are likely to
happen in the near-future based on
previous behavior. The manufacturers
in the table whose names appear in bold
all had at least one regulated fleet (of
three) whose CAFE was below its
standard in MY 2016. Because the
analysis began with the MY 2016 fleet,
and no technology can be added to
vehicles that are already designed and
built, all manufacturers can generate
civil penalties in MY 2016. However,
once a manufacturer is designated as
unwilling to pay penalties, the CAFE
model will attempt to add technology to
the respective fleets to avoid shortfalls.
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(d) Representation of CAFE and CO2
Credit Provisions
The model’s approach to simulating
compliance decisions accounts for the
potential to earn and use CAFE credits
as provided by EPCA/EISA. The model
similarly accumulates and applies CO2
credits when simulating compliance
with EPA’s standards. Like past
versions, the current CAFE model can
be used to simulate credit carry-forward
(a.k.a. banking) between model years
and transfers between the passenger car
and light truck fleets but not credit
carry-back (a.k.a. borrowing) from future
model years or trading between
manufacturers. Some manufacturers
have made occasional use of credit
carry-back provisions, although the
analysis does not assume use of carryback as a compliance strategy because of
the risk in relying on future
improvements to offset earlier
compliance deficits. Thus far, NHTSA
has not attempted to include simulation
of credit carry-back or trading in the
CAFE model. Unlike past versions, the
current CAFE model provides a basis to
specify (in model inputs) CAFE credits
available from model years earlier than
those being simulated explicitly. For
example, with this analysis representing
model years 2016–2032 explicitly,
credits earned in model year 2012 are
made available for use through model
year 2017 (given the current five-year
limit on carry-forward of credits). The
banked credits are specific to both
model year and fleet in which they were
earned. Comment and supporting
information are invited regarding
whether and, if so, how the CAFE model
and inputs might practicably be
modified to account for trading of
credits between manufacturers and/or
carry-back of credits from later to earlier
model years.
As discussed in the CAFE model
documentation, the model’s default
logic attempts to maximize credit carryforward—that is, to ‘‘hold on’’ to credits
for as long as possible. If a manufacturer
needs to cover a shortfall that occurs
when insufficient opportunities exist to
add technology in order to achieve
compliance with a standard, the model
will apply credits. Otherwise it carries
forward credits until they are about to
expire, at which point it will use them
before adding technology that is not
considered cost-effective. The model
attempts to use credits that will expire
within the next three years as a means
to smooth out technology application
over time to avoid both compliance
shortfalls and high levels of overcompliance that can result in a surplus
of credits. As further discussed in the
CAFE model documentation, model
inputs can be used to adjust this logic
to shift the use of credits ahead by one
or more model years. In general, the
logic used to generate credits and apply
them to compensate for compliance
shortfalls, both in a given fleet and
across regulatory fleets, is an area that
requires more attention in the next
phase of model development. While the
current model correctly accounts for
credits earned when a manufacturer
exceeds its standard in a given year, the
strategic decision of whether to earn
additional credits to bank for future
years (in the current fleet or to transfer
into another regulatory fleet) and when
to optimally apply them to deficits is
challenging to simulate. This will be an
area of focus moving forward.
NHTSA introduced the CAFE Public
Information Center 357 to provide public
access to a range of information
regarding the CAFE program, including
manufacturers’ credit balances.
However, there is a data lag in the
information presented on the CAFE PIC
that may not capture credit actions
across the industry for as much as
several months. Additionally, CAFE
credits that are traded between
manufacturers are adjusted to preserve
the gallons saved that each credit
represents.358 The adjustment occurs at
the time of application rather than at the
time the credits are traded. This means
that a manufacturer who has acquired
credits through trade, but has not yet
applied them, may show a credit
balance that is either considerably
higher or lower than the real value of
the credits when they are applied. For
example, a manufacturer that buys 40
million credits from Tesla, may show a
credit balance in excess of 40 million.
However, when those credits are
applied, they may be worth only 1/10 as
much—making that manufacturer’s true
credit balance closer to 4 million than
40 million.
Having reviewed credit balances (as of
October 23, 2017) and estimated the
potential that some manufacturers could
trade credits, NHTSA developed inputs
that make carried-forward credits
available as summarized in Table–II–87,
Table–II–88, and Table–II–89, after
subtracting credits assumed to be traded
to other manufacturers, adding credits
assumed to be acquired from other
manufacturers through such trades, and
adjusting any traded credits (up or
down) to reflect their true value for the
fleet and model year into which they
were traded.359 While the CAFE model
will transfer expiring credits into
another fleet (e.g., moving expiring
credits from the domestic car credit
bank into the light truck fleet), some of
these credits were moved in the initial
banks to improve the efficiency of
application and to better reflect both the
projected shortfalls of each
manufacturer’s regulated fleets, and to
represent observed behavior. For
context, a manufacturer that produces
one million vehicles in a given fleet,
and experiences a shortfall of 2 mpg,
would need 20 million credits to
completely offset the shortfall.
357 CAFE Public Information Center, https://
www.nhtsa.gov/CAFE_PIC/CAFE_PIC_Home.htm
(last visited June 22, 2018).
358 GHG credits for EPA’s program are
denominated in metric tons of CO2 rather than
gram/mile compliance credits and require no
adjustment when traded between manufacturers or
fleets.
359 The adjustments, which are based upon the
standard, CAFE and year of both the party
originally earning the credits and the party applying
them, were implemented assuming the credits
would be applied to the model year in which they
were set to expire. For example, credits traded into
a domestic passenger car fleet for MY 2014 were
adjusted assuming they would be applied in the
domestic passenger car fleet for MY 2019.
Several of the manufacturers in
Table–II–86 that are assumed to be
willing to pay civil penalties in the early
years of the program have no history of
paying civil penalties. However, several
of those manufacturers have either
bought or sold credits—or transferred
credits from one fleet to another to offset
a shortfall in the underperforming fleet.
As the CAFE model does not simulate
credit trades between manufacturers,
providing this additional flexibility in
the modeling avoids the outcome where
the CAFE model applies more
technology than would be needed in the
context of the full set of compliance
flexibilities at the industry level. By
statute, NHTSA cannot consider credit
flexibilities when setting standards, so
most manufacturers (those without a
history of civil penalty payment) are
assumed to comply with their standard
through fuel economy improvements for
the model years being considered in this
analysis. The notable exception to this
is FCA, who we expect will still satisfy
the requirements of the program through
a combination of credit application and
civil penalties through MY 2025 before
eventually complying exclusively
through fuel economy improvements in
MY 2026.
As mentioned above, the CAA does
not provide civil penalty provisions
similar to those specified in EPCA/
EISA, and the above-mentioned
corresponding inputs apply only to
simulation of compliance with CAFE
standards.
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Table-11-87- Estimated Domestic Car CAFE Credit Banks, MY 2011 -2015
Manufacturer
BMW
Daimler
FCA
Ford
General
Motors
Honda
Hyundai Kia-H
Hyundai Kia-K
Model Year
2011
2012
2013
2014
2015
-
-
-
-
3,533,996
24,094,037
7,682,752
18,886,353
26,139,750
7,246,220
42,604,131
40,611,410
24,976,993
1,682,307
30,152,856
7,338,835
7,089,840
-
99
1,379,203
813,612
39,580,944
52,537,420
JLR
-
Mazda
15,526
-
-
-
-
Nissan
Mitsubishi
Subaru
Tesla
Toyota
-
1,564,100
26,451,158
52,774,443
62,285,009
-
-
-
164,504
29,691,134
491,723
17,474,425
589,594
363,905
12,181,000
2,880,250
25,369,142
4,828,440
Volvo
VWA
-
-
-
-
-
1,529,328
2,836,482
4,390,945
4,479,510
31,937,216
T a bl e-II- 88 - E st.1mat ed Impor ted C ar CAFE C re d·t
1 B an ks, MY 2011 -2015
2012
2013
BMW
Daimler
FCA
Ford
General
Motors
Honda
Hyundai Kia-H
Hyundai Kia-K
-
-
-
-
1,576,672
251,275
1,385,379
2,780,629
101
28,338,076
15,078,920
99
16,403,710
12,759,767
5,431,859
44,063,236
11,603,509
JLR
-
-
Mazda
Nissan
Mitsubishi
Subaru
Tesla
Toyota
5,617,262
1,953,364
322,320
1,606,363
-
-
23:42 Aug 23, 2018
2015
6,329,325
-
-
3,646,294
1,304,196
2,142,966
10,185,700
1,356,300
9,658,416
-
-
1,270,772
293,436
894,783
15,430,643
2,161,883
13,254,400
9,086,088
6,804,584
1,894,165
22,616,350
1,867,661
-
-
-
-
6,326,946
39,697,080
62,935,487
66,791,277
47,709,001
50,293,119
-
-
-
-
-
8,593,792
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4,163,432
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2011
Volvo
VWA
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Manufacturer
43183
In addition to the inclusion of these
existing credit banks, the CAFE model
also updated its treatment of credits in
the rulemaking analysis. Congress has
declared that NHTSA set CAFE
standards at maximum feasible levels
for each model year under consideration
without consideration of the program’s
credit mechanisms. However, as CAFE
rulemakings have evaluated longer time
periods in recent years, the early actions
taken by manufacturers required more
nuanced representation. Therefore, the
CAFE model now allows a ‘‘last year to
consider credits,’’ set at the last year for
which new standards are not being
considered (MY 2019 in this analysis).
This allows the model to replicate the
practical application of existing credits
toward CAFE compliance in early years
but to examine the impact of proposed
standards based solely on fuel economy
improvements in all years for which
new standards are being considered.
Comment is sought regarding the
model’s representation of the CAFE and
CO2 credit provisions, recommendations
regarding any other options, and any
information that could help to refine the
current approach or develop and
implement an alternative approach.
The CAFE model has also been
modified to include a similar
representation of existing credit banks
in EPA’s CO2 program. While the life of
a CO2 credit, denominated in metric
tons CO2, has a five-year life, matching
the lifespan of CAFE credits, credits
earned in the early years of the EPA
program, MY 2009–2011, may be used
through MY 2021.360 The CAFE model
was not modified to allow exceptions to
the life-span of compliance credits
treating them all as if they may be
carried forward for no more than five
years, so the initial credit banks were
modified to anticipate the years in
which those credits might be needed.
The fact that MY 2016 is simulated
explicitly prohibited the inclusion of
these banked credits in MY 2016 (which
could be carried forward from MY 2016
to MY 2021), and thus underestimates
the extent to which individual
manufacturers, and the industry as a
whole, may rely on these early credits
to comply with EPA standards between
MY 2016 and MY 2021. The credit
banks with which the simulations in
this analysis were conducted are
presented in the following tables:
360 In response to comments, EPA placed limits
on credits earned in MY 2009, causing them to
expire prior to this rule. However, credits generated
in MYs 2010–2011 may be carried forward, or
traded, and applied to deficits generated through
MY 2021.
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T a bl e- II- 90 - E sf 1mat ed P assenger C ar CO2 C re d·t
1 B an k s, MY 2011 -2015
Manufacturer
Model Year
2011
790,137
688,000
4,089,000
1,911,000
2,040,000
BMW
Daimler
FCA
Ford
General
Motors
Honda
Hyundai Kia-H
Hyundai Kia-K
JLR
Mazda
Nissan
Mitsubishi
Subaru
Tesla
Toyota
Volvo
VWA
114,000
278,000
2012
1,213,000
777,000
4,554,000
2,546,000
3,804,000
1,236,000
343,000
2013
1,558,000
899,000
5,142,000
3,485,000
3,487,000
548,000
355,000
2014
1,833,000
1,199,000
6,574,000
4,743,000
4,882,000
2015
2,089,000
1,443,000
7,318,000
4,216,000
4,588,000
600,000
2,000,000
973,000
392,000
765,000
1,161,000
379,000
600,000
1,863,000
511,000
611,000
1,000,000
1,200,000
1,400,000
32,000
1,215,000
102,000
1,343,000
169,000
1,700,000
89,000
2,065,000
450,000
143,000
2,444,000
T a bl e- II-91 - E stimate
.
d L.Iglh t T rue k CO2 C re d.It B an k s, MY 2011 -2015
Manufacturer
Volvo
VWA
140,000
556,000
1,715,000
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729,000
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2013
2014
2015
-
-
-
914,000
6,106,000
2,875,000
11,216,000
1,149,000
2,742,000
4,656,000
9,164,000
274,000
1,920,000
6,089,000
6,049,000
446,000
3,614,000
2,122,000
4,829,000
218,000
981,000
1,973,000
945,000
300,000
973,000
1,940,000
1,400,000
300,000
1,219,000
2,168,000
200,000
450,000
500,000
153,000
591,000
1,635,000
193,000
While the CAFE model does not
simulate the ability to trade credits
between manufacturers, it does simulate
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2012
-
8,710,000
8,545,000
9,045,000
8,000,000
384,000
37,000
134,000
50,000
370,000
50,000
547,000
the strategic accumulation and
application of compliance credits, as
well as the ability to transfer credits
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between fleets to improve the
compliance position of a less efficient
fleet by leveraging credits earned by a
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Mazda
Nissan
Mitsubishi
Subaru
Tesla
Toyota
2011
112,314
870,000
7,756,000
6,366,000
11,318,000
EP24AU18.129
sradovich on DSK3GMQ082PROD with PROPOSALS2
BMW
Daimler
FCA
Ford
General
Motors
Honda
Hyundai Kia-H
Hyundai Kia-K
JLR
Model Year
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more efficient fleet. The model prefers
to hold on to earned compliance credits
within a given fleet, carrying them
forward into the future to offset
potential future deficits. This
assumption is consistent with observed
strategic behavior dating back to 2009.
From 2009 to present, no
manufacturer has transferred CAFE
credits into a fleet to offset a deficit in
the same year in which they were
earned. This has occurred with credits
acquired from other manufacturers via
trade but not with a manufacturer’s own
credits. Therefore, the current
representation of credit transfers
between fleets—where the model
prefers to transfer expiring, or soon-tobe-expiring credits rather than newly
earned credits—is both appropriate and
consistent with observed industry
behavior.
This may not be the case for GHG
standards, though it is difficult to be
certain at this point. The GHG program
seeded the industry with a large
quantity of early compliance credits
(earned in MYs 2009–2011 361) prior to
the existence formal standards of the
EPA program. These early credits do not
expire until 2021. So, for manufacturers
looking to offset deficits, it is more
sensible to use current-year credits that
expire in the next five years, rather than
draw down the bank of credits that can
be used until MY 2021. The first model
year for which earned credits outlive the
initial bank is MY 2017, for which final
compliance actions and deficit
resolutions are still pending. Regardless,
in order to accurately represent some of
the observed behavior in the GHG credit
system, the CAFE model allows (and
encourages) within-year transfers
between regulated fleets for the purpose
of simulating compliance with the GHG
standards.
In addition to more rigorous
accounting of CAFE and CO2 credits, the
model now also accounts for air
conditioning efficiency and off-cycle
adjustments. NHTSA’s program
considers those adjustments in a
manufacturer’s compliance calculation
starting in MY 2017, and the current
model uses the adjustments claimed by
each manufacturer in MY 2016 as the
starting point for all future years.
Because the air conditioning and offcycle adjustments are not credits in
NHTSA’s program, but rather
adjustments to compliance fuel
economy (much like the Flexible Fuel
Vehicle adjustments that are due to
361 In response to public comment, EPA
eliminated the use of credits earned in MY 2009 for
future model years. However, credits earned in MY
2010 and MY 2011 remain.
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phase out in MY 2019), they may be
included under either a ‘‘standard
setting’’ or ‘‘unconstrained’’ analysis
perspective.
When the CAFE model simulates
EPA’s program, the treatment of A/C
efficiency and off-cycle credits is
similar, but the model also accounts for
A/C leakage (which is not part of
NHTSA’s program). When determining
the compliance status of a
manufacturer’s fleet (in the case of
EPA’s program, PC and LT are the only
fleet distinctions), the CAFE model
weighs future compliance actions
against the presence of existing (and
expiring) CO2 credits resulting from
over-compliance with earlier years’
standards, A/C efficiency credits, A/C
leakage credits, and off-cycle credits.
5. Impacts on Each OEM and Overall
Industry
(a) Technology Application and
Penetration Rates
The CAFE model tracks and reports
technology application and penetration
rates for each manufacturer, regulatory
class, and model year, calculated as the
volume of vehicles with a given
technology divided by the total volume.
The ‘‘application rate’’ accounts only for
those technologies applied by the model
during the compliance simulation,
while the ‘‘penetration rate’’ accounts
for the total percentage of a technology
present in a given fleet, whether applied
by the CAFE model or already present
at the start of the simulation.
In addition to the aggregate
representation of technology
penetration, the model also tracks each
individual vehicle model on which it
has operated. Each row in the market
data file (the representation of vehicles
offered for sale in MY 2016 in the U.S.,
discussed in detail in Section II.B.a and
PRIA Chapter 6) contains a record for
every model year and every alternative,
that identifies with which technologies
the vehicle started the simulation,
which technologies were applied, and
whether those technologies were
applied directly or through inheritance
(discussed above). Interested parties
may use these outputs to assess how the
compliance simulation modified any
vehicle that was offered for sale in MY
2016 in response to a given regulatory
alternative.
(b) Required and Achieved CAFE and
Average CO2 Levels
The model fully represents the
required CAFE (and now, CO2) levels for
every manufacturer and every fleet. The
standard for each manufacturer is based
on the harmonic average of footprint
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targets (by volume) within a fleet, just
as the standards prescribe. Unlike
earlier versions of the CAFE model, the
current version further disaggregates
passenger cars into domestic and
imported classes (which manufacturers
report to NHTSA and EPA as part of
their CAFE compliance submissions).
This allows the CAFE model to more
accurately estimate the requirement on
the two passenger car fleets, represent
the domestic passenger car floor (which
must be exceeded by every
manufacturer’s domestic fleet, without
the use of credits, but with the
possibility of civil penalty payment),
and allows it to enforce the transfer cap
limit that exists between domestic and
imported passenger cars, all for
purposes of the CAFE program.
In calculating the achieved CAFE
level, the model uses the prescribed
harmonic average of fuel economy
ratings within a vehicle fleet. Under an
‘‘unconstrained’’ analysis, or in a model
year for which standards are already
final, it is possible for a manufacturer’s
CAFE to fall below its required level
without generating penalties because
the model will apply expiring or
transferred credits to deficits if it is
strategically appropriate to do so.
Consistent with current EPA
regulations, the model applies simple
(not harmonic) production-weighted
averaging to calculate average CO2
levels.
(c) Costs
For each technology that the model
adds to a given vehicle, it accumulates
cost. The technology costs are defined
incrementally and vary both over time
and by technology class, where the same
technology may cost more to apply to
larger vehicles as it involves more raw
materials or requires different
specifications to preserve some
performance attributes. While learningby-doing can bring down cost, and
should reasonably be implemented in
the CAFE model as a rate of cost
reduction that is applied to the
cumulative volume of a given
technology produced by either a single
manufacturer or the industry as a whole,
in practice this notion is implemented
as a function of time, rather than
production volume. Thus, depending
upon where a given technology starts
along its learning curve, it may appear
to be cost-effective in later years where
it was not in earlier years. As the model
carries forward technologies that it has
already applied to future model years, it
similarly adjusts the costs of those
technologies based on their individual
learning rates.
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sradovich on DSK3GMQ082PROD with PROPOSALS2
The other costs that manufacturers
incur as a result of CAFE standards are
civil penalties resulting from noncompliance with CAFE standards. The
CAFE model accumulates costs of $5.50
per 1/10–MPG under the standard,
multiplied by the number of vehicles
produced in that fleet, in that model
year. The model reports as the full
‘‘regulatory cost,’’ the sum of total
technology cost and total fines by the
manufacturer, fleet, and model year. As
mentioned above, the relevant EPCA/
EISA provisions do not also appear in
the CAA, so this option and these costs
apply only to simulated compliance
with CAFE standards.
(d) Sales
In all previous versions of the CAFE
model, the total number of vehicles sold
in any model year, in fact the number
of each individual vehicle model sold in
each year, has been a static input that
did not vary in response to price
increases induced by CAFE standards,
nor changes in fuel prices, or any other
input to the model. The only way to
alter sales, was to update the entire
forecast in the market input file.
However, in the 2012 final rule, NHTSA
included a dynamic fleet share model
that was based on a module in the
Energy Information Administration’s
NEMS model. This fleet share model
did not change the size of the new
vehicle fleet in any year, but it did
change the share of new vehicles that
were classified as passenger cars (or
light trucks). That capability was not
included in the central analysis but was
included in the uncertainty analysis,
which looked at the baseline and
preferred alternative in the context of
thousands of possible future states of
the world. As some of those futures
contained extreme cases of fuel prices,
it was important to ensure consistent
modeling responses within that context.
For example, at a gasoline price of $7/
gallon, it would be unrealistic to expect
the new vehicle market’s light truck
share to be the same as the future where
gasoline cost $2/gallon. The current
model has slightly modified, and fully
integrated, the dynamic fleet share
model. Every regulatory alternative and
sensitivity case considered in this
analysis reflects a dynamically
responsive fleet mix in the new vehicle
market.
While the dynamic fleet share model
adjusts unit sales across body styles
(cars, SUVs, and trucks), it does not
modify the total number of new vehicles
sold in a given year. The CAFE model
now includes a separate function to
account for changes in the total number
of new vehicles sold in a given year
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(regardless of regulatory class or body
style), in response to certain
macroeconomic inputs and changes in
the average new vehicle price. The price
impact is modest relative to the
influence of the macroeconomic factors
in the model. The combination of these
two models modify the total number of
new vehicles, the share of passenger
cars and light trucks, and, as a
consequence, the number of each given
model sold by a given manufacturer.
However, these two factors are
insufficient to cause large changes to the
composition of any of a manufacturer’s
fleets. In order to significantly change
the mix of models produced within a
given fleet, the CAFE model would
require a way to trade off the production
of one vehicle versus another both
within a manufacturer’s fleet and across
the industry. While NHTSA has
experimented with fully-integrated
consumer choice models, their
performance has yet to satisfy the
requirements of a rulemaking analysis.
There are multiple levels of sales
impacts that could result from
increasing the prices of new vehicles
across the industry. Any estimate of
impacts at the manufacturer, or model,
level would be subject to an assumed
pricing strategy that spreads technology
cost increases across available models in
a way that may cross-subsidize specific
models or segments at the expense of
others. However, at the industry level, it
is reasonable to assume that all
incremental technology costs can be
captured by the average price of a new
vehicle. To the extent that this factor
influences the total number of new
vehicles sold in a given model year, it
can be included in an empirical model
of annual sales. However, there is
limited historical evidence that the
average price of a new vehicle is a
strong determining factor in the total
number of annual new vehicle sales.
6. National Impacts
(a) Vehicle Stock and Fleet Turnover
The CAFE model carries a complete
representation of the registered vehicle
population in each calendar year,
starting with an aggregated version of
the most recent available data about the
registered population for the first year of
the simulation. In this analysis, the first
model year considered is MY 2016, and
the registered vehicle population enters
the model as it appeared at the end of
calendar year 2015. The initial vehicle
population is stratified by age (or model
year cohort) and regulatory class—to
which the CAFE model assigns average
fuel economies based on the reported
regulatory class industry average
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compliance value in each model year
(and class). Once the simulation begins,
new vehicles are added to the
population from the market data file and
age throughout their useful lives during
the simulation, with some fraction of
them being retired (or scrapped) along
the way. For example, in calendar year
2017, the new vehicles (age zero) are
MY 2017 vehicles (added by the CAFE
model simulation and represented at the
same level of detail used to simulate
compliance), the age one vehicles are
MY 2016 vehicles (added by the CAFE
model simulation), and the age two
vehicles are MY 2015 vehicles
(inherited from the registered vehicle
population and carried through the
analysis with less granularity). This
national registered fleet is used to
calculate annual fuel consumption,
vehicle miles traveled (VMT), pollutant
emissions, and safety impacts under
each regulatory alternative.
In addition to dynamically modifying
the total number of new vehicles sold,
a dynamic model of vehicle retirement,
or scrappage, has also been
implemented. The model implements
the scrappage response by defining the
instantaneous scrappage rate at any age
using two functions. For ages less than
20, instantaneous scrappage is defined
as a function of vehicle age, new vehicle
price, cost per mile of driving (the ratio
of fuel price and fuel economy), and a
small number of macroeconomic factors.
For ages greater than 20, the
instantaneous scrappage rate is a simple
exponential function of age. While the
scrappage response does not affect
manufacturer compliance calculations,
it impacts the lifetime mileage
accumulation (and thus fuel savings) of
all vehicles. Previous CAFE analyses
have focused exclusively on new
vehicles, tracing the fuel consumption
and social costs of these vehicles
throughout their useful lives; the
scrappage effect also impacts the
registered vehicle fleet that exists when
a set of standards is implemented.
As new vehicles enter the registered
population their retirement rates are
governed by the scrappage model, so are
the vehicles already registered at the
start of model year 2016. To the extent
that a given set of CAFE or CO2
standards accelerates or decelerates the
retirement of those vehicles, additional
fuel consumption and social costs may
accrue to those vehicles under that
standard. The CAFE model accounts for
those costs and benefits, as well as
tracking all of the standard benefits and
costs associated with the lifetimes of
new vehicles produced under the rule.
For more detail about the derivation of
the scrappage functions, see Section
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II.E, and PRIA Chapter 8. Comment is
sought on the specification and
inclusion of these factors in the current
model.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(b) Highway Travel
In support of prior CAFE rulemakings,
the CAFE model accounted for new
travel that results from fuel economy
improvements that reduce the cost of
driving. The magnitude of the increase
in travel demand is determined by the
rebound effect. In both previous
versions and the current version of the
CAFE model, the amount of travel
demanded by the existing fleet of
vehicles is also responsive to the
rebound effect (representing the price
elasticity of demand for travel)—
increasing when fuel prices decrease
relative to the fuel price when the VMT
on which our mileage accumulation
schedules were built was observed.
Since the fuel economy of those
vehicles is already fixed, only the fuel
price influences their travel demand
relative to the mileage accumulation
schedule and so is identical for all
regulatory alternatives.
While the average mileage
accumulation per vehicle by age is not
influenced by the rebound effect in a
way that differs by regulatory
alternative, three other factors influence
total VMT in the model in a way that
produces different total mileage
accumulation by regulatory alternative.
The first factor is the total industry sales
response: New vehicles are both driven
more than older vehicles and are more
fuel efficient (thus producing more
rebound miles). To the extent that more
(or fewer) of these new models enter the
vehicle fleet in each model year, total
VMT will increase (or decrease) as a
result. The second factor is the dynamic
fleet share model. The fleet share
influences not only the fuel economy
distribution of the fleet, as light trucks
are less efficient than passenger cars on
average, but the total miles are
influenced by fact that light trucks are
driven more than passenger cars as well.
Both of the first two factors can magnify
the influence of the rebound effect on
vehicles that go through the compliance
simulation (MY 2016–2032) in the
manner discussed above and in Section
II.E. The third factor influencing total
annual VMT is the scrappage model. By
modifying the retirement rates of onroad vehicles under each regulatory
alternative, the scrappage model either
increases or decreases the lifetime miles
that accrue to vehicles in a given model
year cohort.
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(c) Fuel Consumption and GHG
Emissions
For every vehicle model in the market
file, the model estimates the VMT per
vehicle (using the assumed VMT
schedule, the vehicle fuel economy, fuel
price, and the rebound assumption).
Those miles are multiplied by the
volume for each vehicle. Fuel
consumption is the product of miles
driven and fuel economy, which can be
tracked by model year cohort in the
model. Carbon dioxide emissions from
vehicle tailpipes are the simple product
of gallons consumed and the carbon
content of each gallon.
In order to calculate calendar year
fuel consumption, the model needs to
account for the inherited on-road fleet
in addition to the model year cohorts
affected by this proposed rule. Using the
VMT of the average passenger car and
light truck from each cohort, the model
computes the fuel consumption of each
model year class of vehicles for its age
in a given CY. The sum across all ages
(and thus, model year cohorts) in a
given CY provides estimated CY fuel
consumption.
Rather than rely on the compliance
values of fuel economy for either
historical vehicles or vehicles that go
through the full compliance simulation,
the model applies an ‘‘on-road gap’’ to
represent the expected difference
between fuel economy on the laboratory
test cycle and fuel economy under realworld operation. This was a topic of
interest in the recent peer review of the
CAFE model. While the model currently
allows the user to specify an on-road
gap that varies by fuel type (gasoline,
E85, diesel, electricity, hydrogen, and
CNG), it does not vary over time, by
vehicle age, or by technology
combination. It is possible that the
‘‘gap’’ between laboratory fuel economy
and real-world fuel economy has
changed over time, that fuel economy
degrades over time as a vehicle ages, or
that specific combinations of fuel-saving
technologies have a larger discrepancy
between laboratory and real-world fuel
economy than others. Further research
would be required to determine whether
the model should include a functional
representation of the on-road gap to
address these various factors, and
comment is sought on the data sources
and implementation strategies available
to do so.
Because the model produces an
estimate of the aggregate number of
gallons sold in each CY, it is possible to
calculate both the total expenditures on
motor fuel and the total contribution to
the Highway Trust Fund (HTF) that
result from that fuel consumption. The
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Federal fuel excise tax is levied on every
gallon of gasoline and diesel sold in the
U.S., with diesel facing a higher pergallon tax rate. The model uses a
national perspective, where the state
taxes present in the input files represent
an estimated average fuel tax across all
U.S. states. Accordingly, while the
CAFE model cannot reasonably estimate
potential losses to state fuel tax revenue
from increasingly the fuel economy of
new vehicles, it can do so for the HTF,
and the agencies invite comment on the
proposed standards’ implications for the
HTF.
In addition to the tailpipe emissions
of carbon dioxide, each gallon of
gasoline produced for consumption by
the on-road fleet has associated
‘‘upstream’’ emissions that occur in the
extraction, transportation, refining, and
distribution of the fuel. The model
accounts for these emissions as well (on
a per-gallon basis) and reports them
accordingly.
(d) Criteria Pollutant Emissions
The CAFE model uses the entire onroad fleet, calculated VMT (discussed
above), and emissions factors (which are
an input to the CAFE model, specified
by model year and age) to calculate
tailpipe emissions associated with a
given alternative. Just as it does for
additional GHG emissions associated
with upstream emissions from fuel
production, the model captures criteria
pollutants that occur during other parts
of the fuel life cycle. While this is
typically a function of the number of
gallons of gasoline consumed (and miles
driven, for tailpipe criteria pollutant
emissions), the CAFE model also
estimates electricity consumption and
the associated upstream emissions
(resource extraction and generation,
based on U.S. grid mix).
(e) Highway Fatalities
Earlier versions of the CAFE model
accounted for the safety impacts
associated with reducing vehicle mass
in order to improve fuel economy. In
particular, NHTSA’s safety analysis
estimated the additional fatalities that
would occur as a result of new vehicles
getting lighter, then interacting with the
on-road vehicle population. In general,
taking mass out of the heaviest new
vehicles improved safety outcomes,
while taking mass from the lightest new
vehicles resulted in a greater number of
expected highway fatalities. However,
the change in fatalities did not
adequately account for changes in
exposure that occur as a result of
increased demand for travel as vehicles
become cheaper to operate. The current
version of the model resolves that
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limitation and addresses additional
sources of fatalities that can result from
the implementation of CAFE or CO2
standards. These are discussed in
greater detail in Section 0 and PRIA
Chapter 11.
NHTSA has observed that older
vehicles in the population are
responsible for a disproportionate
number of fatalities, both by number of
registrations and by number of miles
driven. Accordingly, any factor that
causes the population of vehicles to turn
over more slowly will induce additional
fatalities—as those older vehicles
continue to be driven, rather than being
retired and replaced with newer (even if
not brand new) vehicle models. The
scrappage effect, which delays (or
accelerates) the retirement of registered
vehicles, impacts the number of
fatalities through this mechanism—
importantly affecting not just new
vehicles sold from model years 2016–
2032 but existing vehicles that are
already part of the on-road fleet.
Similarly, to the extent that a CAFE or
CO2 alternative reduces new vehicle
sales, it can slow the transition from
older vehicles to newer vehicles,
reducing the share of total vehicle miles
that are driven by newer, more
technologically advanced vehicles.
Accounting for the change in vehicle
miles traveled that occurs when
vehicles become cheaper to operate has
led to a number of fatalities that can be
attributed to the rebound effect,
independent of any changes to new
vehicle mass, price, or longevity.
The CAFE model now estimates
fatalities by combining the effects
discussed above. In particular, the
model estimates the fatality rate per
billion miles VMT for each model year
vehicle in the population (the newest of
which are the new vehicles produced
that model year). This estimate is
independent of regulatory class and
varies only by year (and not vehicle
age). The estimated fatality rate is then
multiplied by the estimated VMT for
each vehicle in the population and the
product of the change in curb weight
and the relevant safety coefficient, as in
the equation below.
For the vehicles in the historical fleet,
meaning all those vehicles that are
already part of the registered vehicle
population in CY 2016, only the model
year effect that determines the
‘‘FatalityEstimate’’ is relevant. However,
each vehicle that is simulated explicitly
by the CAFE model, and is eligible to
receive mass reduction technologies,
must also consider the change between
its curb weight and the threshold
weights that are used to define safety
classes. For vehicles above the
threshold, reducing vehicle mass can
have a smaller negative impact on
fatalities (or even reduce fatalities, in
the case of the heaviest light trucks).
The ‘‘ChangePer100Lbs’’ depends upon
this difference. The sum of all estimated
fatalities for each model year vehicle in
the on-road fleet determines the
reported fatalities, which can be
summarized by either model year or
calendar year.
generate social costs. The most obvious
cost associated with the program is the
cost of additional fuel economy
improving/CO2 emissions reducing
technology that is added to new
vehicles as a result of the rule. However,
the model does not inherently draw a
distinction between costs and benefits.
For example, the model tracks fuel
consumption and the dollar value of
fuel consumed. This is the cost of travel
under a given alternative (including the
baseline). The ‘‘cost’’ or ‘‘benefit’’
associated with the value of fuel
consumed is determined by the
reference point against which each
alternative is considered. The CAFE
model reports absolute values for the
amount of money spent on fuel in the
baseline, then reports the amount spent
on fuel in the alternatives relative to the
baseline. If the baseline standard were
fixed at the current level, and an
alternative achieves 100 mpg by 2025,
the total expenditures on fuel in the
alternative would be lower, creating a
fuel savings ‘‘benefit.’’ This analysis
uses a baseline that is more stringent
than each alternative considered, so the
incremental fuel expenditures are
greater for the alternatives than for the
baseline.
Other social costs and benefits emerge
as the result of physical phenomena,
like tailpipe emissions or highway
fatalities, which are the result of
changes in the composition and use of
the on-road fleet. The social costs
associated with those quantities
represent an economic estimate of the
social damages associated with the
changes in each quantity. The model
tracks and reports each of these
quantities by: Model year and vehicle
age (the combination of which can be
used to produce calendar year totals),
regulatory class, fuel type, and social
discount rate.
The full list of potential costs and
benefits is presented in Table–II–92 as
well as the population of vehicles that
determines the size of the factor (either
new vehicles or all registered vehicles)
and the mechanism that determines the
size of the effect (whether driven by the
number of miles driven, the number of
gallons consumed, or the number of
vehicles produced).
sradovich on DSK3GMQ082PROD with PROPOSALS2
(f) Costs and Benefits
As the CAFE model simulates
manufacturer compliance with
regulatory alternatives, it estimates and
tracks a number of consequences that
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NHTSA and EPA are proposing that
the form of the CAFE and CO2 standards
for MYs 2021–2026 would follow the
form of those standards in prior model
years. NHTSA has specific statutory
requirements for the form of CAFE
standards: Specifically, EPCA, as
amended by EISA, requires that CAFE
standards be issued separately for
passenger cars and light trucks, and that
each standard be specified as a
mathematical function expressed in
terms of one or more vehicle attributes
related to fuel economy. Although the
CAA does not have comparable specific
requirements for the form of CO2
standards for light-duty vehicles, EPA
has concluded that it is appropriate to
set CO2 standards according to vehicle
footprint, consistent with the EPCA/
EISA requirements, which simplifies
compliance for the industry.362
For MYs since 2011 for CAFE and
since 2012 for CO2, standards have
taken the form of fuel economy and CO2
targets expressed as functions of vehicle
footprint (the product of vehicle
wheelbase and average track width).
NHTSA and EPA continue to believe
that footprint is the most appropriate
attribute on which to base the proposed
standards, as discussed in Section II.C.
Under the footprint-based standards, the
function defines a CO2 or fuel economy
performance target for each unique
footprint combination within a car or
truck model type. Using the functions,
each manufacturer thus will have a
CAFE and CO2 average standard for
each year that is unique to each of its
fleets,363 depending on the footprints
and production volumes of the vehicle
models produced by that manufacturer.
A manufacturer will have separate
footprint-based standards for cars and
for trucks. The functions are mostly
sloped, so that generally, larger vehicles
(i.e., vehicles with larger footprints) will
be subject to lower CAFE mpg targets
and higher CO2 grams/mile targets than
smaller vehicles. This is because,
generally speaking, smaller vehicles are
more capable of achieving higher levels
of fuel economy/lower levels of CO2
emissions, mostly because they tend not
to have to work as hard to perform their
driving task. Although a manufacturer’s
fleet average standards could be
estimated throughout the model year
based on the projected production
volume of its vehicle fleet (and are
estimated as part of EPA’s certification
process), the standards to which the
manufacturer must comply will be
determined by its final model year
production figures. A manufacturer’s
calculation of its fleet average standards
as well as its fleets’ average performance
at the end of the model year will thus
be based on the production-weighted
average target and performance of each
model in its fleet.364
For passenger cars, consistent with
prior rulemakings, NHTSA is proposing
to define fuel economy targets as
follows:
362 Such an approach is permissible under section
202(a) of the CAA and EPA has used the attributebased approach in issuing standards under
analogous provisions of the CAA.
363 EPCA/EISA requires NHTSA to separate
passenger cars into domestic and import passenger
car fleets whereas EPA combines all passenger cars
into one fleet.
364 As in prior rulemakings, a manufacturer may
have some vehicle models that exceed their target
and some that are below their target. Compliance
with a fleet average standard is determined by
comparing the fleet average standard (based on the
production-weighted average of the target levels for
each model) with fleet average performance (based
on the production-weighted average of the
performance of each model).
III. Proposed CAFE and CO2 Standards
for MYs 2021–2026
A. Form of the Standards
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Where:
TARGETFE is the fuel economy target (in
mpg) applicable to a specific vehicle
model type with a unique footprint
combination,
a, b, c, and d are as for passenger cars, but
taking values specific to light trucks,
e is a second minimum fuel economy target
(in mpg),
f is a second maximum fuel economy target
(in mpg),
g is the slope (in gpm per square foot) of a
second line relating fuel consumption
(the inverse of fuel economy) to
footprint, and
h is an intercept (in gpm) of the same second
line.
functions that are similar, with
coefficients a–h corresponding to those
listed above.365 For passenger cars, EPA
is proposing to define CO2 targets as
follows:
TARGETCO2 = MIN[b,MAX[a,c ×
FOOTPRINT + d]]
sradovich on DSK3GMQ082PROD with PROPOSALS2
Although the general model of the
target function equation is the same for
each vehicle category (passenger cars
and light trucks) and each model year,
the parameters of the function equation
differ for cars and trucks. For MYs
2020–2026, the parameters are
unchanged, resulting in the same
stringency in each of those model years.
Mathematical functions defining the
proposed CO2 targets are expressed as
Here, MIN and MAX are functions
that take the minimum and maximum
values, respectively, of the set of
Where:
TARGETCO2 is the CO2 target (in grams per
mile, or g/mi) applicable to a specific
vehicle model configuration,
a is a minimum CO2 target (in g/mi),
b is a maximum CO2 target (in g/mi),
c is the slope (in g/mi, per square foot) of a
line relating CO2 emissions to footprint,
and
d is an intercept (in g/mi) of the same line.
For light trucks, CO2 targets are
defined as follows:
TARGETCO2 = MIN[MIN[b, MAX[a,c ×
FOOTPRINT + d]], MIN[f,MAX[e, g
× FOOTPRINT + H]]
Where:
TARGETCO2 is the CO2 target (in g/mi)
applicable to a specific vehicle model
configuration,
included values. For example,
MIN[40,35] = 35 and MAX(40, 25) = 40,
such that MIN[MAX(40, 25), 35] = 35.
For light trucks, also consistent with
prior rulemakings, NHTSA is proposing
to define fuel economy targets as
follows:
a, b, c, and d are as for passenger cars, but
taking values specific to light trucks,
e is a second minimum CO2 target (in g/mi),
f is a second maximum CO2 target (in g/mi),
g is the slope (in g/mi per square foot) of a
second line relating CO2 emissions to
footprint, and
h is an intercept (in g/mi) of the same second
line.
To be clear, as has been the case since
the agencies began establishing
attribute-based standards, no vehicle
need meet the specific applicable fuel
economy or CO2 targets, because
compliance with either CAFE or CO2
standards is determined based on
corporate average fuel economy or fleet
average CO2 emission rates. The
required CAFE level applicable to a
given fleet in a given model year is
determined by calculating the
production-weighted harmonic average
of fuel economy targets applicable to
specific vehicle model configurations in
the fleet, as follows:
Where:
CAFErequired is the CAFE level the fleet is
required to achieve,
i refers to specific vehicle model/
configurations in the fleet,
PRODUCTIONi is the number of model
configuration i produced for sale in the
U.S., and
TARGETFE,i the fuel economy target (as
defined above) for model configuration i.
Similarly, the required average CO2
level applicable to a given fleet in a
given model year is determined by
calculating the production-weighted
365 EPA regulations use a different but
mathematically equivalent approach to specify
targets. Rather than using a function with nested
minima and maxima functions, EPA regulations
specify requirements separately for different ranges
of vehicle footprint. Because these ranges reflect the
combined application of the listed minima,
maxima, and linear functions, it is mathematically
equivalent and more efficient to present the targets
as in this Section.
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c is the slope (in gallons per mile per square
foot, or gpm, per square foot) of a line
relating fuel consumption (the inverse of
fuel economy) to footprint, and
d is an intercept (in gpm) of the same line.
EP24AU18.134
Where:
TARGETFE is the fuel economy target (in
mpg) applicable to a specific vehicle
model type with a unique footprint
combination,
a is a minimum fuel economy target (in mpg),
b is a maximum fuel economy target (in
mpg),
EP24AU18.133
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applicable to specific vehicle model
configurations in the fleet, as follows:
Where:
CO2required is the average CO2 level the fleet
is required to achieve,
i refers to specific vehicle model/
configurations in the fleet,
PRODUCTIONi is the number of model
configuration i produced for sale in the
U.S., and
TARGETCO2,i is the CO2 target (as defined
above) for model configuration i.
Today’s action would set standards
that only apply to fuel economy and
CO2. EPA seeks comment on this
approach.
Comment is sought on the proposed
standards and on the analysis presented
here; we seek any relevant data and
information and will review responses.
That review could lead to selection of
Section II.C above discusses in detail
how the coefficients in Table III–1 were
developed for this proposal. The
coefficients result in the footprintdependent targets shown graphically
below for MYs 2021–2026. The MYs
one of the other regulatory alternatives
for the final rule.
B. Passenger Car Standards
For passenger cars, NHTSA and EPA
are proposing CAFE and CO2 standards,
respectively, for MYs 2021–2026 that
are defined by the following
coefficients:
2017–2020 standards are also shown for
comparison.
EP24AU18.137
average (not harmonic) of CO2 targets
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Figure 111-1 -Passenger Car Fuel Economy Targets
While we do not know yet with
certainty what CAFE and CO2 levels
will ultimately be required of individual
manufacturers, because those levels will
depend on the mix of vehicles that they
produce for sale in future model years,
based on the market forecast of future
sales that was used to examine today’s
proposed standards, we currently
estimate that the target functions shown
above would result in the following
average required fuel economy and CO2
emissions levels for individual
manufacturers during MYs 2021–2026.
Prior to MY 2021, average required CO2
levels reflect underlying target functions
(specified above) that reflect the use of
automotive refrigerants with reduced
global warming potential (GWP) and/or
the use of technologies that reduce the
refrigerant leaks. EPA is proposing to
exclude air conditioning refrigerants
and leakage, and nitrous oxide and
methane GHGs from average
performance calculations after model
year 2020; CO2 targets and resultant
fleet average requirements for model
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43193
years 2021 and beyond do not reflect
these adjustments.
EPA seeks comments on whether to
proceed with this proposal to
discontinue accounting for A/C leakage,
methane emissions, and nitrous oxide
emissions as part of the CO2 emissions
standards to provide for better harmony
with the CAFE program, or whether to
continue to consider these factors
toward compliance and retain that as a
feature that differs between the
programs. A/C leakage credits, which
are accounted for in the baseline model,
have been extensively generated by
manufacturers, and make up a portion
of their compliance with EPA’s CO2
standards. In the 2016 MY,
manufacturers averaged six grams per
mile equivalent in A/C leakage credits,
ranging from three grams per mile
equivalent for Hyundai and Kia, to 17
grams per mile equivalent for Jaguar
Land Rover.367 As related to methane
(CH4) and nitrous oxide (N2O)
emissions, manufacturers averaged 0.1
grams per mile equivalent in deficits for
the 2016 MY, with deficits ranging from
0.1 grams per mile equivalent for GM,
Mazda, and Toyota, to 0.6 grams per
mile equivalent for Nissan.368
EPA notes that since the 2010
rulemaking on this subject, the agencies
have accounted for the ability to apply
A/C leakage credits by increasing EPA’s
CO2 standard stringency by the average
anticipated amount of credits when
compared to the CAFE stringency
requirements.369 For model years 2021–
2025, the A/C leakage offset, or
366 Prior to MY 2021, CO targets include
2
adjustments reflecting the use of automotive
refrigerants with reduced global warming potential
(GWP) and/or the use of technologies that reduce
the refrigerant leaks and optionally nitrous oxide
and methane emissions. EPA is proposing to
exclude air conditioning refrigerants and leakage,
and nitrous oxide and methane GHGs from average
performance calculations after model year 2020;
CO2 targets (and resultant fleet average
requirements) for model years 2021 and beyond do
not reflect these adjustments.
367 Other manufacturers’ A/C leakage credit grams
per mile equivalent include: BMW, Honda,
Mistubishi, Nissan, Toyota, and Volkswagen at 5 g/
mi; Mercedes at 6 g/mi; Ford, GM, and Volvo at 7
g/mi; and FCA at 14 g/mi.
368 Other manufacturers’ methane and nitrous
oxide deficit grams per mile equivalent include
BMW at 0.2 g/mi, and Ford at 0.3 g/mi. FCA and
Volkswagen numbers are not reported due to an
ongoing investigation and/or corrective actions.
369 75 FR 25330, May 7, 2010.
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equivalent stringency increase
compared to the CAFE standard, is 13.8
g/mi equivalent for passenger cars and
17.2 g/mi equivalent for light trucks.370
For those model years, manufacturers
are currently allowed to apply A/C
leakage credits capped at 18.8 g/mi
equivalent for passenger cars and 24.4 g/
mi equivalent for light trucks.371
For methane and nitrous oxide
emissions, as part of the MY 2012–2016
rulemaking, EPA finalized standards to
cap emissions of N2O at 0.010 g/mile
and CH4 at 0.030 g/mile for MY 2012
and later vehicles.372 However, EPA
also provided an optional CO2equivalent approach to address industry
concerns about technological feasibility
and leadtime for the CH4 and N2O
standards for MY 2012–2016 vehicles.
The CO2 equivalent standard option
allowed manufacturers to fold all 2cycle weighted N2O and CH4 emissions,
on a CO2-equivalent basis, along with
CO2, into their CO2 emissions fleet
average compliance level.373 EPA
estimated that on a CO2 equivalent
basis, folding in all N2O and CH4
emissions could add up to 3–4 g/mile to
a manufacturer’s overall CO2 emissions
level because the equivalent standard
must be used for the entire fleet, not just
for ‘‘problem vehicles.’’ 374 To address
this added difficulty, EPA amended the
MY 2012–2016 standards to allow
manufacturers to use CO2 credits, on a
CO2-equivalent basis, to meet the lightduty N2O and CH4 standards in those
model years. EPA subsequently
extended that same credit provision to
MY 2017 and later vehicles. EPA seeks
comment on whether to change existing
methane and nitrous oxide standards
that were finalized in the 2012 rule.
Specifically, EPA seeks information
from the public on whether the existing
standards are appropriate, or whether
they should be revised to be less
stringent or more stringent based on any
updated data.
If the agency moves forward with its
proposal to eliminate these factors, EPA
would consider whether it is
appropriate to initiate a new rulemaking
to regulate these programs
independently, which could include an
effective date that would result in no
lapse in regulation of A/C leakage or
emissions of nitrous oxide and methane.
If the agency decides to retain the A/C
leakage and nitrous oxide and methane
emissions provisions for CO2
compliance, it would likely re-insert the
current A/C leakage offset and increase
the stringency levels for CO2
compliance by the offset amounts
described above (i.e., 13.8 g/mi
equivalent for passenger cars and 17.2 g/
mi equivalent for light trucks), and
retain the current caps (i.e., 18.8 g/mi
equivalent for passenger cars and 24.4 g/
mi equivalent for light trucks). The
agency will publish an analysis of this
alternative approach in a memo to the
docket for this rulemaking. The agency
seeks comment on whether the current
offsets and caps would continue to be
appropriate in such circumstances or
whether changes are warranted.
We emphasize again that the values in
these tables are estimates, and not
necessarily the ultimate levels with
which each of these manufacturers will
have to comply, for the reasons
described above.
CAFE standard with both their
domestically-manufactured and
imported passenger car fleets—that is,
domestic and imported passenger car
fleets must comply separately with the
passenger car CAFE standard in each
model year.375 In doing so, they may use
whatever flexibilities are available to
them under the CAFE program, such as
using credits ‘‘carried forward’’ from
prior model years, transferred from
another fleet, or acquired from another
manufacturer. On top of this
requirement, EISA expressly requires
each manufacturer to meet a minimum
flat fuel economy standard for
domestically manufactured passenger
cars.376 According to the statute, the
minimum standard shall be the greater
of (A) 27.5 miles per gallon; or (B) 92%
of the average fuel economy projected
by DOT for the combined domestic and
374 In the final rule for MYs 2012–2016, EPA
acknowledged that advanced diesel or lean-burn
gasoline vehicles of the future may face greater
challenges meeting the CH4 and N2O standards than
the rest of the fleet. [See 75 FR 25422, May 7, 2010].
375 49 U.S.C. 32904(b) (2007).
376 Transferred or traded credits may not be used,
pursuant to 49 U.S.C. 32903(g)(4) and (f)(2), to meet
the domestically manufactured passenger
automobile minimum standard specified in 49
U.S.C. 32902(b)(4) and in 49 CFR 531.5(d).
C. Minimum Domestic Passenger Car
Standards
EPCA has long required
manufacturers to meet the passenger car
370 77
FR 62805, Oct. 15, 2012.
FR 62649, Oct. 15, 2012.
372 75 FR 25421–24, May 7, 2010.
373 77 FR 62798, Oct. 15, 2012.
371 77
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nondomestic passenger automobile
fleets manufactured for sale in the
United States by all manufacturers in
the model year, which projection shall
be published in the Federal Register
when the standard for that model year
is promulgated.377 NHTSA discusses
this requirement in more detail in
Section V.A.1 below.
The following table lists the proposed
minimum domestic passenger car
standards (which very likely will be
updated for the final rule as the agency
updates its overall analysis and
resultant projection), highlighted as
D. Light Truck Standards
respectively, for MYs 2021–2026 that
are defined by the following
coefficients:
EP24AU18.142
377 49
‘‘Preferred (Alternative 3)’’ and
calculates what those standards would
be under the no action alternative (as
issued in 2012, and as updated by
today’s analysis) and under the other
alternatives described and discussed
further in Section IV, below.
U.S.C. 32902(b)(4).
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For light trucks, NHTSA and EPA are
proposing CAFE and CO2 standards,
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Section II.C above discusses in detail
how the coefficients in Table III–4 were
developed for this proposal. The
coefficients result in the footprintdependent targets shown graphically
below for MYs 2021–2026. The MYs
2017–2020 standards are also shown for
comparison.
378 Prior to MY 2021, average achieved CO levels
2
include adjustments reflecting the use of
automotive refrigerants with reduced global
warming potential (GWP) and/or the use of
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technologies that reduce the refrigerant leaks.
Because EPA is today proposing to exclude air
conditioning refrigerants and leakage, and nitrous
oxide and methane GHGs from average performance
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calculations after MY 2020, CO2 targets and
resultant fleet average requirements for MYs 2021
and beyond do not reflect these adjustments.
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Figure 111-4 - Light Truck C02 Targets378
EP24AU18.143
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Figure 111-3 - Light Truck Fuel Economy Targets
While we do not know yet with
certainty what CAFE and CO2 levels
will ultimately be required of individual
manufacturers, because those levels will
depend on the mix of vehicles that they
produce for sale in future model years,
based on the market forecast of future
sales that were used to examine today’s
proposed standards, we currently
estimate that the target functions shown
above would result in the following
average required fuel economy and CO2
emissions levels for individual
manufacturers during MYs 2021–2026.
Prior to MY 2021, average required CO2
levels reflect underlying target functions
(specified above) that reflect the use of
automotive refrigerants with reduced
global warming potential (GWP) and/or
the use of technologies that reduce the
refrigerant leaks. Because EPA is today
proposing to exclude air conditioning
refrigerants and leakage, and nitrous
oxide and methane GHGs from average
performance calculations after model
year 2020, CO2 targets and resultant
fleet average requirements for model
years 2021 and beyond do not reflect
these adjustments.
We emphasize again the values in
these tables are estimates and not
necessarily the ultimate levels with
which each of these manufacturers will
have to comply for reasons described
above.
As discussed above in Chapter II,
today’s notice also presents the results
of analysis estimating impacts under a
range of other regulatory alternatives the
agencies are considering. Aside from the
no-action alternative, NHTSA and EPA
defined the different regulatory
alternatives in terms of percentincreases in CAFE and GHG stringency
from year to year. Under some
alternatives, the rate of increase is the
same for both passenger cars and light
trucks; under others, the rate of increase
differs. Two alternatives also involve a
gradual discontinuation of CAFE and
average GHG adjustments reflecting the
application of technologies that improve
air conditioner efficiency or, in other
ways, improve fuel economy under
conditions not represented by longstanding fuel economy test procedures.
For increased harmonization with
NHTSA CAFE standards, which cannot
account for such issues, under
Alternatives 1–8, EPA would regulate
tailpipe CO2 independently of A/C
refrigerant leakage, nitrous oxide and
methane emissions. Under the no action
alternative, EPA would continue to
regulate A/C refrigerant leakage, nitrous
oxide and methane emissions under the
overall CO2 standard.380 Like the
baseline no-action alternative, all of the
alternatives are more stringent than the
preferred alternative.
EPA also seeks comment on retaining
the existing credit program for
regulation of A/C refrigerant leakage,
nitrous oxide, and methane emissions as
part of the CO2 standard.
The agencies have examined these
alternatives because the agencies intend
to continue considering them as options
for the final rule. The agencies seek
comment on these alternatives and on
the analysis presented here, seek any
relevant data and information, and will
review responses. That review could
lead the agencies to select one of the
IV. Alternative CAFE and GHG
Standards Considered for MYs 2021/
22–2026
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Agencies typically consider regulatory
alternatives in proposals as a way of
evaluating the comparative effects of
different potential ways of
accomplishing their desired goal.379
Alternatives analysis begins with a ‘‘noaction’’ alternative, typically described
as what would occur in the absence of
any regulatory action. Today’s proposal
includes a no-action alternative,
described below, as well as seven
‘‘action alternatives’’ besides the
proposal. The proposal may, in places,
be referred to as the ‘‘preferred
alternative,’’ which is NEPA parlance,
but NHTSA and EPA intend ‘‘proposal,’’
‘‘proposed action,’’ and ‘‘preferred
alternative’’ to be used interchangeably
for purposes of this rulemaking.
379 As Section V.A.3 explains, NEPA requires
agencies to compare the potential environmental
impacts of their proposed actions to those of a
reasonable range of alternatives. Executive Orders
12866 and 13563 and OMB Circular A–4 also
encourage agencies to evaluate regulatory
alternatives in their rulemaking analyses.
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380 For the CAFE program, carbon-based tailpipe
emissions (including CO2, CH4 and CO) are
measured, and fuel economy is calculated using a
carbon balance equation. EPA uses carbon-based
emissions (CO2, CH4 and CO, the same as for CAFE)
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to calculate tailpipe CO2 for its standards. In
addition, under the no action alternative EPA adds
CO2 equivalent (using Global Warming Potential
(GWP) adjustment) for AC refrigerant leakage and
nitrous oxide and methane emissions. The CAFE
program does not include A/C refrigerant leakage,
nitrous oxide and methane emissions because they
do not impact fuel economy. Under Alternatives 1–
8, the standards are completely aligned for gasoline
because compliance is based on tailpipe CO2, CH4
and CO for both programs and not emissions
unrelated to fuel economy. Diesel and alternative
fuel vehicles would continue to be treated
differently between the CAFE and CO2 programs.
While harmonization would be significantly
improved, standards would not be fully aligned
because of the small fraction of the fleet that uses
diesel and alternative fuels (e.g., about four percent
of the MY 2016 fleet), as well as differences
involving EPCA/EISA provisions EPA, lacking any
specific direction under the CAA, has declined to
adopt, such as minimum standards for domestic
passenger cars and limits on credit transfers
between regulated fleets.
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other regulatory alternatives for the final
rule.
A. What alternatives did NHTSA and
EPA consider?
The table below shows the different
alternatives evaluated in this proposal.
Also, as mentioned previously in
Section III.B., EPA seeks comments on
whether to proceed with this proposal
to discontinue accounting for A/C
leakage, methane emissions, and nitrous
oxide emissions as part of the CO2
emissions standards to provide for
381 Carbon dioxide equivalent of air conditioning
refrigerant leakage, nitrous oxide and methane
emissions are included for compliance with the
EPA standards for all MYs under the baseline/no
action alternative. Carbon dioxide equivalent is
calculated using the Global Warming Potential
(GWP) of each of the emissions.
382 Beginning in MY 2021, air conditioning
refrigerant leakage, nitrous oxide, and methane
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emissions may be regulated independently by EPA.
The GWP equivalent of each of the emissions would
no longer be included with the tailpipe CO2 for
compliance with tailpipe CO2 standards. A
lengthier discussion of this issue can be found in
Section III.B.
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better harmony with the CAFE program
or whether to continue to consider these
factors toward compliance and retain
that as a feature that differs between the
programs. EPA seeks comment on
whether to change existing methane and
nitrous oxide standards that were
finalized in the 2012 rule. Specifically,
EPA seeks information from the public
on whether the existing standards are
appropriate, or whether they should be
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draws attention the discussion of
‘‘enhanced flexibilities’’ in Section X.C.
2. Alternative 1 (Proposed)
tailpipe CO2 standards. Section III,
above, defines this alternative in greater
detail.
Alternative 1 holds the stringency of
targets constant and MY 2020 levels
through MY 2026. Beginning in MY
2021, air conditioning refrigerant
leakage, nitrous oxide, and methane
emissions are no longer included with
the tailpipe CO2 for compliance with
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B. Definition of Alternatives
1. No-Action Alternative
The No-Action Alternative applies the
augural CAFE and final GHG targets
announced in 2012 for MYs 2021–2025.
3. Alternative 2
Alternative 2 increases the stringency
of targets annually during MYs 2021–
2026 (on a gallon per mile basis, starting
from MY 2020) by 0.5% for passenger
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For MY 2026, this alternative applies
the same targets as for MY 2025. Carbon
dioxide equivalent of air conditioning
refrigerant leakage, nitrous oxide, and
methane emissions are included for
compliance with the EPA standards for
all model years under the baseline/no
action alternative.
cars and 0.5% for light trucks. Section
III describes the proposed standards
included in the preferred alternative.
Beginning in MY 2021, air conditioning
refrigerant leakage, nitrous oxide, and
methane emissions are no longer
included with the tailpipe CO2 for
compliance with tailpipe CO2 standards.
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EP24AU18.149
revised to be less stringent or more
stringent based on any updated data.
Additionally, the agencies note that
this proposal also seeks comment on a
number of additional compliance
flexibilities for the programs. See
Section X below, and EPA specifically
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Alternative 3 phases out A/C and offcycle adjustments and increases the
stringency of targets annually during
MYs 2021–2026 (on a gallon per mile
basis, starting from MY 2020) by 0.5%
for passenger cars and 0.5% for light
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trucks. The cap on adjustments for AC
efficiency improvements declines from
6 grams per mile in MY 2021 to 5, 4, 3,
2, and 0 grams per mile in MYs 2022,
2023, 2024, 2025, and 2026,
respectively. The cap on adjustments for
off-cycle improvements declines from
10 grams per mile in MY 2021 to 8, 6,
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4, 2, and 0 grams per mile in MYs 2022,
2023, 2024, 2025, and 2026,
respectively. Beginning in MY 2021, air
conditioning refrigerant leakage, nitrous
oxide, and methane emissions are no
longer included with the tailpipe CO2
for compliance with tailpipe CO2
standards.
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4. Alternative 3
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Alternative 4 increases the stringency
of targets annually during MYs 2021–
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2026 (on a gallon per mile basis, starting
from MY 2020) by 1.0% for passenger
cars and 2.0% for light trucks.
Beginning in MY 2021, air conditioning
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refrigerant leakage, nitrous oxide, and
methane emissions are no longer
included with the tailpipe CO2 for
compliance with tailpipe CO2 standards.
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5. Alternative 4
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Alternative 5 increases the stringency
of targets annually during MYs 2022–
2026 (on a gallon per mile basis, starting
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from MY 2021) by 1.0% for passenger
cars and 2.0% for light trucks.
Beginning in MY 2021, air conditioning
refrigerant leakage, nitrous oxide, and
methane emissions are no longer
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included with the tailpipe CO2 for
compliance with tailpipe CO2 standards,
and MY 2021 CO2 targets are adjusted
accordingly.
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6. Alternative 5
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Alternative 6 increases the stringency
of targets annually during MYs 2021–
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2026 (on a gallon per mile basis, starting
from MY 2020) by 2.0% for passenger
cars and 3.0% for light trucks.
Beginning in MY 2021, air conditioning
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refrigerant leakage, nitrous oxide, and
methane emissions are no longer
included with the tailpipe CO2 for
compliance with tailpipe CO2 standards.
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EP24AU18.153
7. Alternative 6
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Alternative 7 phases out A/C and offcycle adjustments and increases the
stringency of targets annually during
MYs 2021–2026 (on a gallon per mile
basis, starting from MY 2020) by 1.0%
for passenger cars and 2.0% for light
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trucks. The cap on adjustments for AC
efficiency improvements declines from
6 grams per mile in MY 2021 to 5, 4, 3,
2, and 0 grams per mile in MYs 2022,
2023, 2024, 2025, and 2026,
respectively. The cap on adjustments for
off-cycle improvements declines from
10 grams per mile in MY 2021 to 8, 6,
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4, 2, and 0 grams per mile in MYs 2022,
2023, 2024, 2025, and 2026,
respectively. Beginning in MY 2021, air
conditioning refrigerant leakage, nitrous
oxide, and methane emissions are no
longer included with the tailpipe CO2
for compliance with tailpipe CO2
standards.
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8. Alternative 7
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Alternative 8 increases the stringency
of targets annually during MYs 2022–
2026 (on a gallon per mile basis, starting
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from MY 2021) by 2.0% for passenger
cars and 3.0% for light trucks.
Beginning in MY 2021, air conditioning
refrigerant leakage, nitrous oxide, and
methane emissions are no longer
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included with the tailpipe CO2 for
compliance with tailpipe CO2 standards,
and MY 2021 CO2 targets are adjusted
accordingly.
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9. Alternative 8
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V. Proposed Standards, the Agencies’
Statutory Obligations, and Why the
Agencies Propose To Choose Them
Over the Alternatives
A. NHTSA’s Statutory Obligations and
Why the Proposed Standards Appear to
be Maximum Feasible
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1. EPCA, as Amended by EISA
EPCA, as amended by EISA, contains
a number of provisions regarding how
NHTSA must set CAFE standards.
NHTSA must establish separate CAFE
standards for passenger cars and light
trucks 383 for each model year,384 and
each standard must be the maximum
feasible that NHTSA believes the
manufacturers can achieve in that
383 49
384 49
U.S.C. 32902(b)(1) (2007).
U.S.C. 32902(a) (2007).
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model year.385 In determining the
maximum feasible level achievable by
the manufacturers, EPCA requires that
NHTSA consider the four statutory
factors of technological feasibility,
economic practicability, the effect of
other motor vehicle standards of the
Government on fuel economy, and the
need of the United States to conserve
energy.386 In addition, NHTSA has the
authority to (and traditionally does)
consider other relevant factors, such as
the effect of the CAFE standards on
motor vehicle safety and consumer
preferences.387 The ultimate
determination of what standards can be
considered maximum feasible involves
a weighing and balancing of these
factors, and the balance may shift
depending on the information before
NHTSA about the expected
circumstances in the model years
covered by the rulemaking. The
agency’s decision must also support the
overarching purpose of EPCA, energy
conservation, while balancing these
factors.388
Besides the requirement that the
standards be maximum feasible for the
fleet in question and the model year in
question, EPCA/EISA also contain
385 Id.
386 49
U.S.C. 32902(f) (2007).
of these additional considerations also
relate, to some extent, to economic practicability,
but NHTSA also has the authority to consider them
independently of that statutory factor.
387 Both
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388 Center for Biological Diversity v. NHTSA, 538
F. 3d 1172, 1197 (9th Cir. 2008) (‘‘Whatever method
it uses, NHTSA cannot set fuel economy standards
that are contrary to Congress’ purpose in enacting
the EPCA—energy conservation.’’)
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several other requirements as explained
below.
sradovich on DSK3GMQ082PROD with PROPOSALS2
(a) Lead Time
EPCA requires that NHTSA prescribe
new CAFE standards at least 18 months
before the beginning of each model
year.389 For light-duty vehicles, NHTSA
has consistently interpreted the
‘‘beginning of each model year’’ as
September 1 of the CY prior, such that
the beginning of MY 2019 would be
September 1, 2018. Thus, if the first year
for which NHTSA is proposing to set
new standards in this NPRM is MY
2022, NHTSA interprets this provision
as requiring us to issue a final rule
covering MY 2022 standards no later
than April 1, 2020.
For amendments to existing
standards, EPCA requires that if the
amendments make an average fuel
economy standard more stringent, at
least 18 months of lead time must be
provided.390 EPCA contains no lead
time requirement unless amendments
make an average fuel economy standard
less stringent. NHTSA therefore
interprets EPCA as allowing
amendments to reduce a standard’s
stringency up until the beginning of the
model year in question. In this
rulemaking, NHTSA is proposing to
amend the standards for model year
2021. Since the agency proposes to
reduce these standards, this action is
not subject to a lead time requirement.
(b) Separate Standards for Cars and
Trucks, and Minimum Standards for
Domestic Passenger Cars
As discussed above, EPCA requires
NHTSA to set separate CAFE standards
for passenger cars and light trucks for
each model year.391 NHTSA interprets
this requirement as preventing the
agency from setting a single combined
CAFE standard for cars and trucks
together, based on the plain language of
the statute. Congress originally intended
separate CAFE standards for cars and
trucks to reflect the different fuel
economy capabilities of those different
types of vehicles, and over the history
of the CAFE program, has never revised
this requirement. Even as many cars and
trucks have come to resemble each other
more closely over time—many crossover
and sport-utility models, for example,
come in versions today that may be
subject to either the car standards or the
truck standards depending on their
characteristics—it is still accurate to say
that vehicles with truck-like
characteristics such as 4 wheel drive,
389 49
U.S.C. 32902(a) (2007).
U.S.C. 32902(g)(2) (2007).
391 49 U.S.C. 32902(b)(1) (2007).
390 49
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cargo-carrying capability, etc., need to
use more fuel per mile to perform those
jobs than vehicles without these
characteristics. Thus, regardless of the
plain language of the statute, NHTSA
believes that the different fuel economy
capabilities of cars and trucks would
generally make separate standards
appropriate for these different types of
vehicles.
EPCA, as amended by EISA, also
requires another separate standard to be
set for domestically-manufactured 392
passenger cars. Unlike under the
standards for passenger cars and light
trucks described above, the compliance
burden of the minimum domestic
passenger car standard is the same for
all manufacturers; the statute clearly
states that any manufacturer’s
domestically-manufactured passenger
car fleet must meet the greater of either
27.5 mpg on average, or
. . . 92 percent of the average fuel economy
projected by the Secretary for the combined
domestic and non-domestic passenger
automobile fleets manufactured for sale in
the United States by all manufacturers in the
model year, which projection shall be
published in the Federal Register when the
standard for that model year is promulgated
in accordance with [49 U.S.C. 32902(b)].393
Since that requirement was
promulgated, the ‘‘92 percent’’ has
always been greater than 27.5 mpg.
NHTSA published the 92-percent
minimum domestic passenger car
standards for model years 2017–2025 at
49 CFR 531.5(d) as part of the 2012 final
rule. For MYs 2022–2025, 531.5(e) states
that these were to be applied if, when
actually proposing MY 2022 and
subsequent standards, the previously
identified standards for those years are
deemed maximum feasible, but if
NHTSA determines that the previously
identified standards are not maximum
feasible, the 92-percent minimum
domestic passenger car standards would
also change. This is consistent with the
statutory language that the 92-percent
standards must be determined at the
time an overall passenger car standard
is promulgated and published in the
Federal Register. Thus, any time
NHTSA establishes or changes a
passenger car standard for a model year,
the minimum domestic passenger car
392 In the CAFE program, ‘‘domesticallymanufactured’’ is defined by Congress in 49 U.S.C.
§ 32904(b). The specifics of the definition are too
many for a footnote, but roughly, a passenger car
is ‘‘domestically manufactured’’ as long as at least
75% of the cost to the manufacturer is attributable
to value added in the United States, Canada, or
Mexico, unless the assembly of the vehicle is
completed in Canada or Mexico and the vehicle is
imported into the United States more than 30 days
after the end of the model year.
393 49 U.S.C. § 32902(b)(4) (2007).
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43207
standard for that model year will also be
evaluated or reevaluated and
established accordingly. NHTSA
explained this in the rulemaking to
establish standards for MYs 2017 and
beyond and received no comments.394
The 2016 Alliance/Global petition for
rulemaking asked NHTSA to
retroactively revise the 92-percent
minimum domestic passenger car
standards for MYs 2012–2016 ‘‘to reflect
92 percent of the required average
passenger car standard taking into
account the fleet mix as it actually
occurred, rather than what was
forecast.’’ The petitioners stated that
doing so would be ‘‘fully consistent
with the statute.’’ 395
NHTSA understands that determining
the 92 percent value ahead of the model
year to which it applies, based on the
information then available to the
agency, results in a different mpg
number than if NHTSA determined the
92 percent value based on the
information available at the end of the
model year in question. NHTSA further
understands that determining the 92
percent value ahead of time can make
the domestic minimum passenger car
standard more stringent than it could be
if it were determined at the end of the
model year, if manufacturers end up
producing more larger-footprint
passenger cars than NHTSA originally
anticipated.
Accordingly, NHTSA seeks comment
on this request by Alliance/Global.
Additionally, recognizing the
uncertainty inherent in projecting
specific mpg values far into the future,
it is possible that NHTSA could define
the mpg values associated with a CAFE
standard (i.e., the footprint curve) as a
range rather than as a single number.
For example, the sensitivity analysis
included in this proposal and in the
accompanying PRIA could provide a
basis for such an mpg range ‘‘defining’’
the passenger car standard in any given
model year. If NHTSA took that
approach, 92 percent of that ‘‘standard’’
would also, necessarily, be a range. We
also seek comment on this or other
similar approaches.
(c) Attribute-Based and Defined by
Mathematical Function
EISA requires NHTSA to set CAFE
standards that are ‘‘based on 1 or more
394 77
FR 62624, 63028 (Oct. 15, 2012).
Alliance and Global Automakers
Petition for Direct Final Rule with Regard to
Various Aspects of the Corporate Average Fuel
Economy Program and the Greenhouse Gas Program
(June 20, 2016) at 5, 17–18, available at https://
www.epa.gov/sites/production/files/2016-09/
documents/petition_to_epa_from_auto_alliance_
and_global_automakers.pdf [hereinafter Alliance/
Global Petition].
395 Automobile
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attributes related to fuel economy and
express[ed] . . . in the form of a
mathematical function.’’ 396 NHTSA has
thus far based standards on vehicle
footprint and proposes to continue to do
so for all the reasons described in
previous rulemakings. As in previous
rulemakings, NHTSA proposes to define
the standards in the form of a
constrained linear function that
generally sets higher (more stringent)
targets for smaller-footprint vehicles and
lower (less stringent) targets for largerfootprint vehicles. These footprint
curves are discussed in much greater
detail in Section II.C above. We seek
comment both on the choice of footprint
as the relevant attribute and on the
rationale for the constrained linear
functions chosen to represent the
standards.
32902(c) and 32902(g). We therefore
believe that it is reasonable to interpret
section 32902(b)(3)(B) as applying only
to the establishing of new standards
rather than to the combined action of
establishing new standards and
amending existing standards.
Moreover, we believe it would be an
absurd result not intended by Congress
if the five year maximum limitation
were interpreted to prevent NHTSA
from revising a previously-established
standard that we have determined to be
beyond maximum feasible, while
concurrently setting five years of
standards not so distant from today. The
concerns Congress sought to address are
much starker when NHTSA is trying to
determine what standards would be
maximum feasible 10 years from now as
compared to three years from now.
(d) Number of Model Years for Which
Standards May Be Set at a Time
EISA also states that NHTSA shall
‘‘issue regulations under this title
prescribing average fuel economy
standards for at least 1, but not more
than 5, model years.’’ 397 In the 2012
final rule, NHTSA interpreted this
provision as preventing the agency from
setting final standards for all of MYs
2017–2025 in a single rulemaking
action, so the MYs 2022–2025 standards
were termed ‘‘augural,’’ meaning ‘‘that
they represent[ed] the agency’s current
judgment, based on the information
available to the agency [then], of what
levels of stringency would be maximum
feasible in those model years.’’ 398 That
said, NHTSA also repeatedly clarified
that the augural standards were in no
way final standards and that a future de
novo rulemaking would be necessary in
order to both propose and promulgate
final standards for MYs 2022–2025.
Today, NHTSA proposes to establish
new standards for MYs 2022–2026 and
to revise the previously-established final
standards for MY 2021. Legislative
history suggests that Congress included
the five year maximum limitation so
NHTSA would issue standards for a
period of time where it would have
reasonably realistic estimates of market
conditions, technologies, and economic
practicability (i.e., not set standards too
far into the future).399 However, the
concerns Congress sought to address by
imposing those limitations are not
present for nearer model years where
NHTSA already has existing standards.
Revisiting existing standards is
contemplated by both 49 U.S.C.
(e) Maximum Feasible
As discussed above, EPCA requires
NHTSA to consider four factors in
determining what levels of CAFE
standards would be maximum feasible,
and NHTSA presents in the sections
below its understanding of what those
four factors mean. All factors should be
considered, in the manner appropriate,
and then the maximum feasible
standards should be determined.
396 49
U.S.C. 32902(b)(3)(A).
U.S.C. 32902(b)(3)(B).
398 77 FR 62623, 62630 (Oct. 15, 2012).
399 See 153 Cong. Rec. 2665 (Dec. 28, 2007).
397 49
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(1) Technological Feasibility
‘‘Technological feasibility’’ refers to
whether a particular method of
improving fuel economy is available for
deployment in commercial application
in the model year for which a standard
is being established. Thus, NHTSA is
not limited in determining the level of
new standards to technology that is
already being commercially applied at
the time of the rulemaking. For this
proposal, NHTSA is considering a wide
range of technologies that improve fuel
economy, subject to the constraints of
EPCA regarding how to treat alternative
fueled vehicles, and considering the
need to account for which technologies
have already been applied to which
vehicle model/configuration, and the
need to realistically estimate the cost
and fuel economy impacts of each
technology. NHTSA has not attempted
to account for every technology that
might conceivably be applied to
improve fuel economy and considers it
unnecessary to do so given that many
technologies address fuel economy in
similar ways.400 Technological
400 For example, NHTSA has not considered highspeed flywheels as potential energy storage devices
for hybrid vehicles; while such flywheels have been
demonstrated in the laboratory and even tested in
concept vehicles, commercially available hybrid
vehicles currently known to NHTSA use chemical
batteries as energy storage devices, and the agency
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feasibility and economic practicability
are often conflated, as will be covered
further in the following section. To be
clear, whether a fuel-economyimproving technology does or will exist
(technological feasibility) is a different
question from what economic
consequences could ensue if NHTSA
effectively requires that technology to
become widespread in the fleet and the
economic consequences of the absence
of consumer demand for technology that
are projected to be required (economic
practicability). It is therefore possible
for standards to be technologically
feasible but still beyond the level that
NHTSA determines to be maximum
feasible due to consideration of the
other relevant factors.
(2) Economic Practicability
‘‘Economic practicability’’ has
traditionally referred to whether a
standard is one ‘‘within the financial
capability of the industry, but not so
stringent as to’’ lead to ‘‘adverse
economic consequences, such as a
significant loss of jobs or unreasonable
elimination of consumer choice.’’ 401 In
evaluating economic practicability,
NHTSA considers the uncertainty
surrounding future market conditions
and consumer demand for fuel economy
alongside consumer demand for other
vehicle attributes. NHTSA has
explained in the past that this factor can
be especially important during
rulemakings in which the auto industry
is facing significantly adverse economic
conditions (with corresponding risks to
jobs). Consumer acceptability is also a
major component to economic
practicability,402 which can involve
consideration of anticipated consumer
responses not just to increased vehicle
cost, but also to the way manufacturers
may change vehicle models and vehicle
sales mix in response to CAFE
standards. In attempting to determine
the economic practicability of attributebased standards, NHTSA considers a
wide variety of elements, including the
annual rate at which manufacturers can
increase the percentage of their fleet that
employs a particular type of fuel-saving
technology,403 the specific fleet mixes of
has considered a range of hybrid vehicle
technologies that do so.
401 67 FR 77015, 77021 (Dec. 16, 2002).
402 See, e.g., Center for Auto Safety v. NHTSA
(CAS), 793 F.2d 1322 (D.C. Cir. 1986)
(Administrator’s consideration of market demand as
component of economic practicability found to be
reasonable); Public Citizen v. NHTSA, 848 F.2d 256
(Congress established broad guidelines in the fuel
economy statute; agency’s decision to set lower
standards was a reasonable accommodation of
conflicting policies).
403 For example, if standards effectively require
manufacturers to widely apply technologies that
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different manufacturers, and
assumptions about the cost of standards
to consumers and consumers’ valuation
of fuel economy, among other things.
Prior to the MYs 2005–2007
rulemaking under the non-attributebased (fixed value) CAFE standards,
NHTSA generally sought to ensure the
economic practicability of standards in
part by setting them at or near the
capability of the ‘‘least capable
manufacturer’’ with a significant share
of the market, i.e., typically the
manufacturer whose fleet mix was, on
average, the largest and heaviest,
generally having the highest capacity
and capability so as to not limit the
availability of those types of vehicles to
consumers. In the first several
rulemakings establishing attribute-based
standards, NHTSA applied marginal
cost-benefit analysis, considering both
overall societal impacts and overall
consumer impacts. Whether the
standards maximize net benefits has
thus been a touchstone in the past for
NHTSA’s consideration of economic
practicability. Executive Order 12866, as
amended by Executive Order 13563,
states that agencies should ‘‘select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits . . .’’ In practice,
however, agencies, including NHTSA,
must consider situations in which the
modeling of net benefits does not
capture all of the relevant
considerations of feasibility. Therefore,
as in past rulemakings, NHTSA is
considering net societal impacts, net
consumer impacts, and other related
elements in the consideration of
economic practicability.
NHTSA’s consideration of economic
practicability depends on a number of
elements. Expected availability of
capital to make investments in new
technologies matters; manufacturers’
expected ability to sell vehicles with
certain technologies matters; likely
consumer choices matter and so forth.
NHTSA’s analysis of the impacts of this
proposal incorporates assumptions to
capture aspects of consumer
preferences, vehicle attributes, safety,
and other elements relevant to an
impacts estimate; however, it is difficult
to capture every such constraint.
Therefore, it is well within the agency’s
discretion to deviate from the level at
which modeled net benefits are
maximized if the agency concludes that
that level would not represent the
maximum feasible level for future CAFE
consumers do not want, or to widely apply
technologies before they are ready to be
widespread, NHTSA believes that these standards
could potentially be beyond economically
practicable.
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standards. Economic practicability is
complex, and like the other factors must
also be considered in the context of the
overall balancing and EPCA’s
overarching purpose of energy
conservation. Depending on the
conditions of the industry and the
assumptions used in the agency’s
analysis of alternative standards,
NHTSA could well find that standards
that maximize net benefits, or that are
higher or lower, could be at the limits
of economic practicability, and thus
potentially the maximum feasible level,
depending on how the other factors are
balanced.
While we discuss safety as a separate
consideration, NHTSA also considers
safety as closely related to, and in some
circumstances a subcomponent of
economic practicability. On a broad
level, manufacturers have finite
resources to invest in research and
development. Investment into the
development and implementation of
fuel saving technology necessarily
comes at the expense of investing in
other areas such as safety technology.
On a more direct level, when making
decisions on how to equip vehicles,
manufacturers must balance cost
considerations to avoid pricing further
consumers out of the market. As
manufacturers add technology to
increase fuel efficiency, they may
decide against installing new safety
equipment to reduce cost increases. And
as the price of vehicles increase beyond
the reach of more consumers, such
consumers continue to drive or
purchase older, less safe vehicles. In
assessing practicability, NHTSA also
considers the harm to the nation’s
economy caused by highway fatalities
and injuries.
(3) The Effect of Other Motor Vehicle
Standards of the Government on Fuel
Economy
‘‘The effect of other motor vehicle
standards of the Government on fuel
economy’’ involves analysis of the
effects of compliance with emission,
safety, noise, or damageability standards
on fuel economy capability and thus on
average fuel economy. In many past
CAFE rulemakings, NHTSA has said
that it considers the adverse effects of
other motor vehicle standards on fuel
economy. It said so because, from the
CAFE program’s earliest years 404 until
recently, the effects of such compliance
on fuel economy capability over the
history of the CAFE program have been
negative ones. For example, safety
standards that have the effect of
404 42 FR 63184, 63188 (Dec. 15, 1977). See also
42 FR 33534, 33537 (June 30, 1977).
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43209
increasing vehicle weight thereby lower
fuel economy capability, thus
decreasing the level of average fuel
economy that NHTSA can determine to
be feasible. NHTSA has considered the
additional weight that it estimates
would be added in response to new
safety standards during the rulemaking
timeframe.405 NHTSA has also
accounted for EPA’s ‘‘Tier 3’’ standards
for criteria pollutants in its estimates of
technology effectiveness.406
In the 2012 final rule establishing
CAFE standards for MYs 2017–2021,
NHTSA also discussed whether EPA
GHG standards and California GHG
standards should be considered and
accounted for as ‘‘other motor vehicle
standards of the Government.’’ NHTSA
recognized that ‘‘To the extent the GHG
standards result in increases in fuel
economy, they would do so almost
exclusively as a result of inducing
manufacturers to install the same types
of technologies used by manufacturers
in complying with the CAFE
standards.’’ 407 NHTSA concluded that
‘‘the agency had already considered
EPA’s [action] and the harmonization
benefits of the National Program in
developing its own [action],’’ and that
‘‘no further action was needed.’’ 408
Considering the issue afresh in this
proposal, and looking only at the words
in the statute, obviously EPA’s GHG
standards applicable to light-duty
vehicles are literally ‘‘other motor
vehicle standards of the Government,’’
in that they are standards set by a
Federal agency that apply to motor
vehicles. Basic chemistry makes fuel
economy and tailpipe CO2 emissions
two sides of the same coin, as discussed
at length above, and when two agencies
functionally regulate both (because by
regulating fuel economy, you regulate
CO2 emissions, and vice versa), it would
be absurd not to link their standards.409
The global warming potential of N2O,
CH4, and HFC emissions are not closely
linked with fuel economy, but neither
do they affect fuel economy capabilities.
How, then, should NHTSA consider
EPA’s various GHG standards?
NHTSA is aware that some
stakeholders believe that NHTSA’s
obligation to set maximum feasible
CAFE standards can best be executed by
letting EPA decide what GHG standards
405 PRIA,
Chapter 5.
Chapter 6.
407 77 FR 62624, 62669 (Oct. 15, 2012).
408 Id.
409 In fact, EPA includes tailpipe CH , CO, and
4
CO2 in the measurement of tailpipe CO2 for GHG
compliance using a carbon balance equation so that
the measurement of tailpipe CO2 exactly aligns with
the measurement of fuel economy for the CAFE
compliance.
406 PRIA,
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are appropriate and reasonable under
the CAA. NHTSA disagrees. While EPA
and NHTSA consider some similar
factors under the CAA and EPCA/EISA,
respectively, they are not identical.
Standards that are appropriate under the
CAA may not be ‘‘maximum feasible’’
under EPCA/EISA, and vice versa.
Moreover, considering EPCA’s language
in the context in which it was written,
it seems unreasonable to conclude that
Congress intended EPA to dictate CAFE
stringency. In fact, Congress clearly
separated NHTSA’s and EPA’s
responsibilities for CAFE under EPCA
by giving NHTSA authority to set
standards and EPA authority to measure
and calculate fuel economy. If Congress
had wanted EPA to set CAFE standards,
it could have given that authority to
EPA in EPCA or at any point since
Congress amended EPCA.410
NHTSA and EPA are obligated by
Congress to exercise their own
independent judgment in fulfilling their
statutory missions, even though both
agencies’ regulations affect both fuel
economy and CO2 emissions. Because of
this relationship, it is incumbent on
both agencies to coordinate and look to
one another’s actions to avoid
unreasonably burdening industry
through inconsistent regulations, but
both agencies must be able to defend
their programs on their own merits. As
with other recent CAFE and GHG
rulemakings, the agencies are
continuing do all of these things in this
proposal.
With regard to standards issued by the
State of California, State tailpipe
standards (whether for greenhouse gases
or for other pollutants) do not qualify as
‘‘other motor vehicle standards of the
Government’’ under 49 U.S.C. 32902(f);
therefore, NHTSA will not consider
them as such in proposing maximum
feasible average fuel economy
standards. States may not adopt or
enforce tailpipe greenhouse gas
emissions standards when such
standards relate to fuel economy
standards and are therefore preempted
under EPCA, regardless of whether EPA
granted any waivers under the Clean Air
Act (CAA).411
Preempted standards of a State or a
political subdivision of a State include,
for example:
(1) A fuel economy standard; and
(2) A law or regulation that has the
direct effect of a fuel economy standard,
410 We note, for instance, that EISA was passed
after the Massachusetts v. EPA decision by the
Supreme Court. If Congress had wanted to amend
EPCA in light of that decision, they would have
done so at the time. They did not.
411 This topic is discussed further in Section VI
below.
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but is not labeled as one (i.e., a State
tailpipe CO2 standard or prohibition on
CO2 emissions).
NHTSA and EPA agree that state
tailpipe greenhouse gas emissions
standards do not become Federal
standards and qualify as ‘‘other motor
vehicle standards of the Government,’’
when subject to a CAA preemption
waiver. EPCA’s legislative history
supports this position.
EPCA, as initially passed in 1975,
mandated average fuel economy
standards for passenger cars beginning
with model year 1978. The law required
the Secretary of Transportation to
establish, through regulation, maximum
feasible fuel economy standards 412 for
model years 1981 through 1984 with the
intent to provide steady increases to
achieve the standard established for
1985 and thereafter authorized the
Secretary to adjust that standard.
For the statutorily-established
standards for model years 1978–1980,
EPCA provided each manufacturer with
the right to petition for changes in the
standards applicable to that
manufacturer. A petitioning
manufacturer had the burden of
demonstrating a ‘‘Federal fuel economy
standards reduction’’ was likely to exist
for that manufacturer in one or more of
those model years and that it had made
reasonable technology choices. ‘‘Federal
standards,’’ for that limited purpose,
included not only safety standards,
noise emission standards, property loss
reduction standards, and emission
standards issued under various Federal
statutes, but also ‘‘emissions standards
applicable by reason of section 209(b) of
[the CAA].’’ 413 (Emphasis added).
Critically, all definitions, processes, and
required findings regarding a Federal
fuel economy standards reduction were
located within a single self-contained
subsection of 15 U.S.C. 2002 that
applied only to model years 1978–
1980.414
In 1994, Congress recodified EPCA.
As part of this recodification, the CAFE
provisions were moved to Title 49 of the
United States Code. In doing so,
412 As is the case today, EPCA required the
Secretary to determine ‘‘maximum feasible average
fuel economy’’ after considering technological
feasibility, economic practicability, the effect of
other Federal motor vehicle standards on fuel
economy, and the need of the Nation to conserve
energy. 15 U.S.C. 2002(e) (recodified July 5, 1994).
413 Section 202 of the CAA (42 U.S.C. 7521)
requires EPA to prescribe air pollutant emission
standards for new vehicles; Section 209 of the CAA
(42 U.S.C. 7543) preempts state emissions standards
but allows California to apply for a waiver of such
preemption.
414 As originally enacted as part of Public Law
94–163, that subsection was designated as section
502(d) of the Motor Vehicle Information and Cost
Savings Act.
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unnecessary provisions were deleted.
Specifically, the recodification
eliminated subsection (d). The House
report on the recodification declared
that the subdivision was ‘‘executed,’’
and described its purpose as
‘‘[p]rovid[ing] for modification of
average fuel economy standards for
model years 1978, 1979, and 1980.’’ 415
It is generally presumed, when Congress
includes text in one section and not in
another, that Congress knew what it was
doing and made the decision
deliberately.
NHTSA has previously considered the
impact of California’s Low Emission
Vehicle standards in establishing fuel
economy standards and occasionally
has done so under the ‘‘other standards’’
sections.416 During the 2012
rulemaking, NHTSA sought comment
on the appropriateness of considering
California’s tailpipe GHG emission
standards in this section and concluded
that doing so was unnecessary.417 In
light of the legislative history discussed
above, however, NHTSA now
determines that this was not
appropriate. Notwithstanding the
improper categorization of such
discussions, NHTSA may consider
elements not specifically designated as
factors to be considered under EPCA,
given the breadth of such factors as
technological feasibility and economic
practicability, and such consideration
was appropriate.418
(4) The Need of the United States To
Conserve Energy
‘‘The need of the United States to
conserve energy’’ means ‘‘the consumer
cost, national balance of payments,
environmental, and foreign policy
implications of our need for large
quantities of petroleum, especially
imported petroleum.’’ 419
(i) Consumer Costs and Fuel Prices
Fuel for vehicles costs money for
vehicle owners and operators. All else
equal, consumers benefit from vehicles
that need less fuel to perform the same
amount of work. Future fuel prices are
a critical input into the economic
415 H.R.
Rep. No. 103–180, at 583–584, tbl. 2A.
e.g., 68 FR 16896, 71 FR 17643.
417 See 77 FR 62669.
418 See, e.g., discussion in Center for Automotive
Safety v. National Highway Traffic Safety
Administration, et al., 793 F.2d. 1322 (D.C. Cir.
1986) at 1338, et seq., providing that NHTSA may
consider consumer demand in establishing
standards, but not ‘‘to such an extent that it ignored
the overarching goal of fuel conservation. At the
other extreme, a standard with harsh economic
consequences for the auto industry also would
represent an unreasonable balancing of EPCA’s
policies.’’
419 42 FR 63184, 63188 (Dec. 15, 1977).
416 See,
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analysis of potential CAFE standards
because they determine the value of fuel
savings both to new vehicle buyers and
to society, the amount of fuel economy
that the new vehicle market is likely to
demand in the absence of new
standards, and they inform NHTSA
about the ‘‘consumer cost . . . of our
need for large quantities of petroleum.’’
In this proposal, NHTSA’s analysis
relies on fuel price projections from the
U.S. Energy Information
Administration’s (EIA) Annual Energy
Outlook (AEO) for 2017. Federal
government agencies generally use EIA’s
price projections in their assessment of
future energy-related policies.
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(ii) National Balance of Payments
Historically, the need of the United
States to conserve energy has included
consideration of the ‘‘national balance
of payments’’ because of concerns that
importing large amounts of oil created a
significant wealth transfer to oilexporting countries and left the U.S.
economically vulnerable.420 As recently
as 2009, nearly half the U.S. trade
deficit was driven by petroleum,421 yet
this concern has largely laid fallow in
more recent CAFE actions, arguably in
part because other factors besides
petroleum consumption have since
played a bigger role in the U.S. trade
deficit. Given significant recent
increases in U.S. oil production and
corresponding decreases in oil imports,
this concern seems likely to remain
fallow for the foreseeable future.422
Increasingly, changes in the price of fuel
have come to represent transfers
between domestic consumers of fuel
and domestic producers of petroleum
rather than gains or losses to foreign
entities. Some commenters have lately
420 See 42 FR 63184, 63192 (Dec. 15, 1977) ‘‘A
major reason for this need [to reduce petroleum
consumption] is that the importation of large
quantities of petroleum creates serious balance of
payments and foreign policy problems. The United
States currently spends approximately $45 billion
annually for imported petroleum. But for this large
expenditure, the current large U.S. trade deficit
would be a surplus.’’
421 See Today in Energy: Recent improvements in
petroleum trade balance mitigate U.S. trade deficit,
U.S. Energy Information Administration (July 21,
2014), https://www.eia.gov/todayinenergy/
detail.php?id=17191.
422 For an illustration of recent increases in U.S.
production, see, e.g., U.S. crude oil and liquid fuels
production, Short-Term Energy Outlook, U.S.
Energy Information Administration (June 2018),
https://www.eia.gov/outlooks/steo/images/
fig13.png. While it could be argued that reducing
oil consumption frees up more domesticallyproduced oil for exports, and thereby raises U.S.
GDP, that is neither the focus of the CAFE program
nor consistent with Congress’ original intent in
EPCA. EIA’s Annual Energy Outlook (AEO) series
provides midterm forecasts of production, exports,
and imports of petroleum products, and is available
at https://www.eia.gov/outlooks/aeo/.
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raised concerns about potential
economic consequences for automaker
and supplier operations in the U.S. due
to disparities between CAFE standards
at home and their counterpart fuel
economy/efficiency and GHG standards
abroad. NHTSA finds these concerns
more relevant to technological
feasibility and economic practicability
than to the national balance of
payments. Moreover, to the extent that
an automaker decides to globalize a
vehicle platform to meet more stringent
standards in other countries, that
automaker would comply with United
States’s standards and additionally
generate overcompensation credits that
it can save for future years if facing
compliance concerns,or sell to other
automakers. While CAFE standards are
set at maximum feasible rates, efforts of
manufacturers to exceed those standards
are rewarded not only with additional
credits but a market advantage in that
consumers who place a large weight on
fuel savings will find such vehicles that
much more attractive.
(iii) Environmental Implications
Higher fleet fuel economy can reduce
U.S. emissions of various pollutants by
reducing the amount of oil that is
produced and refined for the U.S.
vehicle fleet but can also increase
emissions by reducing the cost of
driving, which can result in increased
vehicle miles traveled (i.e., the rebound
effect). Thus, the net effect of more
stringent CAFE standards on emissions
of each pollutant depends on the
relative magnitudes of its reduced
emissions in fuel refining and
distribution and increases in its
emissions from vehicle use. Fuel
savings from CAFE standards also
necessarily results in lower emissions of
CO2, the main GHG emitted as a result
of refining, distribution, and use of
transportation fuels. Reducing fuel
consumption directly reduces CO2
emissions because the primary source of
transportation-related CO2 emissions is
fuel combustion in internal combustion
engines.
NHTSA has considered
environmental issues, both within the
context of EPCA and the context of the
National Environmental Policy Act
(NEPA), in making decisions about the
setting of standards since the earliest
days of the CAFE program. As courts of
appeal have noted in three decisions
stretching over the last 20 years,423
423 CAS, 793 F.2d 1322, 1325 n. 12 (D.C. Cir.
1986); Public Citizen, 848 F.2d 256, 262–63 n. 27
(D.C. Cir. 1988) (noting that ‘‘NHTSA itself has
interpreted the factors it must consider in setting
CAFE standards as including environmental
effects’’); CBD, 538 F.3d 1172 (9th Cir. 2007).
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NHTSA defined ‘‘the need of the United
States to conserve energy’’ in the late
1970s as including, among other things,
environmental implications. In 1988,
NHTSA included climate change
concepts in its CAFE notices and
prepared its first environmental
assessment addressing that subject.424 It
cited concerns about climate change as
one of its reasons for limiting the extent
of its reduction of the CAFE standard for
MY 1989 passenger cars.425 Since then,
NHTSA has considered the effects of
reducing tailpipe emissions of CO2 in its
fuel economy rulemakings pursuant to
the need of the United States to
conserve energy by reducing petroleum
consumption.
(iv) Foreign Policy Implications
U.S. consumption and imports of
petroleum products impose costs on the
domestic economy that are not reflected
in the market price for crude petroleum
or in the prices paid by consumers for
petroleum products such as gasoline.
These costs include (1) higher prices for
petroleum products resulting from the
effect of U.S. oil demand on world oil
prices, (2) the risk of disruptions to the
U.S. economy caused by sudden
increases in the global price of oil and
its resulting impact of fuel prices faced
by U.S. consumers, and (3) expenses for
maintaining the strategic petroleum
reserve (SPR) to provide a response
option should a disruption in
commercial oil supplies threaten the
U.S. economy, to allow the U.S. to meet
part of its International Energy Agency
obligation to maintain emergency oil
stocks, and to provide a national
defense fuel reserve.426 Higher U.S.
consumption of crude oil or refined
petroleum products increases the
magnitude of these external economic
costs, thus increasing the true economic
cost of supplying transportation fuels
above the resource costs of producing
them. Conversely, reducing U.S.
consumption of crude oil or refined
petroleum products (by reducing motor
fuel use) can reduce these external
costs.
While these costs are considerations,
the United States has significantly
increased oil production capabilities in
424 53
FR 33080, 33096 (Aug. 29, 1988).
FR 39275, 39302 (Oct. 6, 1988).
426 While the U.S. maintains a military presence
in certain parts of the world to help secure global
access to petroleum supplies, that is neither the
primary nor the sole mission of U.S. forces
overseas. Additionally, the scale of oil consumption
reductions associated with CAFE standards would
be insufficient to alter any existing military
missions focused on ensuring the safe and
expedient production and transportation of oil
around the globe. See Chapter 7 of the PRIA for
more information on this topic.
425 53
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recent years to the extent that the U.S.
is currently producing enough oil to
satisfy nearly all of its energy needs and
is projected to continue to do so or
become a net energy exporter. This has
added new stable supply to the global
oil market and reduced the urgency of
the U.S. to conserve energy. We discuss
this issue in more detail below.
(5) Factors That NHTSA Is Prohibited
From Considering
EPCA also provides that in
determining the level at which it should
set CAFE standards for a particular
model year, NHTSA may not consider
the ability of manufacturers to take
advantage of several EPCA provisions
that facilitate compliance with CAFE
standards and thereby reduce the costs
of compliance.427 As discussed further
in Section X.B.1.c) below, NHTSA
cannot consider compliance credits that
manufacturers earn by exceeding the
CAFE standards and then use to achieve
compliance in years in which their
measured average fuel economy falls
below the standards. NHTSA also
cannot consider the use of alternative
fuels by dual fuel vehicles nor the
availability of dedicated alternative fuel
vehicles in any model year. EPCA
encourages the production of alternative
fuel vehicles by specifying that their
fuel economy is to be determined using
a special calculation procedure that
results in those vehicles being assigned
a higher fuel economy level than they
actually achieve.
The effect of the prohibitions against
considering these statutory flexibilities
in setting the CAFE standards is that the
flexibilities remain voluntarilyemployed measures. If NHTSA were
instead to assume manufacturer use of
those flexibilities in setting new
standards, higher standards would
appear less costly and therefore more
feasible, which would thus tend to
require manufacturers to use those
flexibilities in order to meet higher
standards. By keeping NHTSA from
including them in our stringency
determination, the provision ensures
that these statutory credits remain true
compliance flexibilities.
Additionally, for non-statutory
incentives that NHTSA developed by
regulation, NHTSA does not consider
these subject to the EPCA prohibition on
considering flexibilities, either. EPCA is
very clear as to which flexibilities are
not to be considered. When the agency
has introduced additional flexibilities
such as A/C efficiency and ‘‘off-cycle’’
technology fuel economy improvement
values, NHTSA has considered those
technologies as available in the analysis.
Thus, today’s analysis includes
assumptions about manufacturers’ use
of those technologies, as detailed in
Section X.B.1.c)(4)
(f) EPCA/EISA Requirements That No
Longer Apply Post-2020
Congress amended EPCA through
EISA to add two requirements not yet
discussed in this section relevant to
determination of CAFE standards during
the years between MY 2011 and MY
2020 but not beyond. First, Congress
stated that, regardless of NHTSA’s
determination of what levels of
standards would be maximum feasible,
standards must be set at levels high
enough to ensure that the combined
U.S. passenger car and light truck fleet
achieves an average fuel economy level
of not less than 35 mpg no later than
MY 2020.428 And second, between MYs
2011 and 2020, the standards must
‘‘increase ratably’’ in each model
year.429 Neither of these requirements
apply after MY 2020, so given that this
rulemaking concerns the standards for
MY 2021 and after, they are not relevant
to this rulemaking.
(g) Other Considerations in Determining
Maximum Feasible Standards
NHTSA has historically considered
the potential for adverse safety
consequences in setting CAFE
standards. This practice has been
consistently approved in case law. As
courts have recognized, ‘‘NHTSA has
always examined the safety
consequences of the CAFE standards in
its overall consideration of relevant
factors since its earliest rulemaking
under the CAFE program.’’ Competitive
Enterprise Institute v. NHTSA, 901 F.2d
107, 120 n. 11 (D.C. Cir. 1990) (‘‘CEI–I’’)
(citing 42 FR 33534, 33551 (June 30,
1977)). The courts have consistently
upheld NHTSA’s implementation of
EPCA in this manner. See, e.g.,
Competitive Enterprise Institute v.
NHTSA, 956 F.2d 321, 322 (D.C. Cir.
1992) (‘‘CEI–II’’) (in determining the
maximum feasible fuel economy
standard, ‘‘NHTSA has always taken
passenger safety into account’’) (citing
CEI–I, 901 F.2d at 120 n. 11);
Competitive Enterprise Institute v.
NHTSA, 45 F.3d 481, 482–83 (D.C. Cir.
1995) (‘‘CEI–III’’) (same); Center for
Biological Diversity v. NHTSA, 538 F.3d
1172, 1203–04 (9th Cir. 2008)
(upholding NHTSA’s analysis of vehicle
safety issues associated with weight in
connection with the MYs 2008–2011
light truck CAFE rulemaking). Thus, in
428 49
427 49
U.S.C. 32902(h).
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U.S.C. 32902(b)(2)(C).
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evaluating what levels of stringency
would result in maximum feasible
standards, NHTSA assesses the
potential safety impacts and considers
them in balancing the statutory
considerations and to determine the
maximum feasible level of the
standards.
The attribute-based standards that
Congress requires NHTSA to set help to
mitigate the negative safety effects of the
historical ‘‘flat’’ standards originally
required in EPCA, in recent
rulemakings, NHTSA limited the
consideration of mass reduction in
lower weight vehicles in its analysis,
which impacted the resulting
assessment of potential adverse safety
effects. That analytical approach did not
reflect, however, the likelihood that
automakers may pursue the most cost
effective means of improving fuel
efficiency to comply with CAFE
requirements. For this rulemaking, the
modeling does not limit the amount of
mass reduction that is applied to any
segment but rather considers that
automakers may apply mass reduction
based upon cost-effectiveness, similar to
most other technologies. NHTSA does
not, of course, mandate the use of any
particular technology by manufacturers
in meeting the standards. The current
proposal, like the Draft TAR, also
considers the safety effect associated
with the additional vehicle miles
traveled due to the rebound effect.
In this rulemaking, NHTSA is
considering the effect of additional
expenses in fuel savings technology on
the affordability of vehicles—the
likelihood that increased standards will
result in consumers being priced out of
the new vehicle market and choosing to
keep their existing vehicle or purchase
a used vehicle. Since new vehicles are
significantly safer than used vehicles,
slowing fleet turnover to newer vehicles
results in older and less safe vehicles
remaining on the roads longer. This
significantly affects the safety of the
United States light duty fleet, as
described more fully in Section 0 above
and in Chapter 11 of the PRIA
accompanying this proposal.
Furthermore, as fuel economy standards
become more stringent, and more fuel
efficient vehicles are introduced into the
fleet, fueling costs are reduced. This
results in consumers driving more
miles, which results in more crashes
and increased highway fatalities.
2. Administrative Procedure Act
To be upheld under the ‘‘arbitrary and
capricious’’ standard of judicial review
in the APA, an agency rule must be
rational, based on consideration of the
relevant factors, and within the scope of
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the authority delegated to the agency by
the statute. The agency must examine
the relevant data and articulate a
satisfactory explanation for its action
including a ‘‘rational connection
between the facts found and the choice
made.’’ Burlington Truck Lines, Inc., v.
United States, 371 U.S. 156, 168 (1962).
Statutory interpretations included in
an agency’s rule are subject to the twostep analysis of Chevron, U.S.A. v.
Natural Resources Defense Council, 467
U.S. 837 (1984). Under step one, where
a statute ‘‘has directly spoken to the
precise question at issue,’’ id. at 842, the
court and the agency ‘‘must give effect
to the unambiguously expressed intent
of Congress,’’ id. at 843. If the statute is
silent or ambiguous regarding the
specific question, the court proceeds to
step two and asks ‘‘whether the agency’s
answer is based on a permissible
construction of the statute.’’ Id.
If an agency’s interpretation differs
from the one that it has previously
adopted, the agency need not
demonstrate that the prior position was
wrong or even less desirable. Rather, the
agency would need only to demonstrate
that its new position is consistent with
the statute and supported by the record
and acknowledge that this is a departure
from past positions. The Supreme Court
emphasized this in FCC v. Fox
Television, 556 U.S. 502 (2009). When
an agency changes course from earlier
regulations, ‘‘the requirement that an
agency provide a reasoned explanation
for its action would ordinarily demand
that it display awareness that it is
changing position,’’ but ‘‘need not
demonstrate to a court’s satisfaction that
the reasons for the new policy are better
than the reasons for the old one; it
suffices that the new policy is
permissible under the statute, that there
are good reasons for it, and that the
agency believes it to be better, which the
conscious change of course adequately
indicates.’’ 430 The APA also requires
that agencies provide notice and
comment to the public when proposing
regulations,431 as we are doing today.
3. National Environmental Policy Act
As discussed above, EPCA requires
NHTSA to determine the level at which
to set CAFE standards for each model
year by considering the four factors of
technological feasibility, economic
practicability, the effect of other motor
vehicle standards of the Government on
fuel economy, and the need of the
United States to conserve energy. The
National Environmental Policy Act
(NEPA) directs that environmental
1181.
U.S.C. 553.
considerations be integrated into that
process.432 To accomplish that purpose,
NEPA requires an agency to compare
the potential environmental impacts of
its proposed action to those of a
reasonable range of alternatives.
To explore the environmental
consequences of this proposed rule in
depth, NHTSA has prepared a Draft
Environmental Impact Statement
(‘‘DEIS’’). The purpose of an EIS is to
‘‘provide full and fair discussion of
significant environmental impacts and
[to] inform decisionmakers and the
public of the reasonable alternatives
which would avoid or minimize adverse
impacts or enhance the quality of the
human environment.’’ 433
NEPA is ‘‘a procedural statute that
mandates a process rather than a
particular result.’’ Stewart Park &
Reserve Coal., Inc. v. Slater, 352 F.3d
545, 557 (2d Cir. 2003). The agency’s
overall EIS-related obligation is to ‘‘take
a ‘hard look’ at the environmental
consequences before taking a major
action.’’ Baltimore Gas & Elec. Co. v.
Natural Resources Defense Council,
Inc., 462 U.S. 87, 97 (1983).
Significantly, ‘‘[i]f the adverse
environmental effects of the proposed
action are adequately identified and
evaluated, the agency is not constrained
by NEPA from deciding that other
values outweigh the environmental
costs.’’ Robertson v. Methow Valley
Citizens Council, 490 U.S. 332, 350
(1989).
The agency must identify the
‘‘environmentally preferable’’
alternative but need not adopt it.
‘‘Congress in enacting NEPA . . . did
not require agencies to elevate
environmental concerns over other
appropriate considerations.’’ Baltimore
Gas & Elec. Co. v. Natural Resources
Defense Council, Inc., 462 U.S. 87, 97
(1983). Instead, NEPA requires an
agency to develop alternatives to the
proposed action in preparing an EIS. 42
U.S.C. 4322(2)(C)(iii). The statute does
not command the agency to favor an
environmentally preferable course of
action, only that it make its decision to
proceed with the action after taking a
hard look at the environmental
consequences.
We seek comment on the DEIS
associated with this NPRM.
4. Evaluating the EPCA Factors and
Other Considerations To Arrive at the
Proposed Standards
NHTSA well recognizes that the
decision it proposes to make in today’s
NPRM is different from the one made in
430 Ibid.,
432 NEPA
431 5
433 40
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