-------
1
2
Appendix 4: Fuels input file
jijfj] File Edit View Insert Format Tools Data Window Help
iJ-^.d^^q jj. Jt -a A ' /
Alii"ft
100% ' ซ* & ; Century Gothic
1
2
3
4
5
6
7
Fuel Type >
G
D
EL
B i
9
10
1.1
12
13
14
15
16 [
17
18
19 |
20
21
22
zT|
24 |
25
26
27 |
28 |
29 [
30
31
32 |
33
34
35
36 |
37 t
38 I
39 i
40 |
41
B
|
1 15,000
129,488
3413
C
i
2819
3206
0
Carbon Density ' o
2433
3206
853
i< < > H \Fuel / Validation List /Errors /
: Draw ,-$ iAytoShapes' ~. s [I] : : ..j, *; ^
p
!
1
3.00
3.44
0.115
j : -s* '
p
CM
!
1
3.15
3.63
0.093
^- J.
G
D
!
8
c
3.26
3.75
0.096
^ rr^r
H
"tf
8
I
3.47
3.99
0.099
ฃ 4
I
W)
1
1
3.66
4.09
0.102
J|
J
^0
B
s
ฃ
3.59
4.13
0.105
K
f*.
1
I
3.60
4.14
0.108
L
CO
8
1
3.65
4.20
0.111
M
0-
8
8
ฃ
3.67
4.22
0.114
N
o
B
1
3.67
4.22
0.117
0
8
8
ฃ
3.69
4.24
0.120
_P_
tv
B
1
3.75
4.31
0.123
Q
B
1
3.79
4.36
0.126
R
8
1
3.82
4.39
0.129
S
to
B
1
3.82
4.40
0.132
T
-o
8
1
3.86
4.44
0.135
U
r-v
B
1
3.
4.
0.1
<
-------
1
2
Appendix 5: Tables of hard-coded input data, which will soon be included in an editable input file.
Downstream Criteria Pollutant Emissions
a
b
c
Regression
Coefficients
CO
LDV
4.5689
1.5073
LOT
3.315
1.3852
VOC
LDV
0.0980
-0.0052
0.0030
LOT
0.1429
-0.0054
0.0033
N(
LDV
0.0008
0.0275
0.0262
Upstream Emissions from Fuel/Energy Production, Storage,
and Distribution
Pollutant
CO
VOC
NOx
PM2.5
SOx
CO2
Fuel Type
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Conventional Gasoline
Low Sulfur Diesel
Electricity Generation
Total Upstream Emissions
(grams/mmBtu)
14.45
12.67
58.55
27.42
7.78
19.73
48.11
42.92
239.85
4.30
3.48
76.31
24.13
20.94
527.33
17067
15560
219933
y = b*[x] + a
y = c*[x2] + b*[x] + a
-------
Model Year
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999
1998
1997
1996
1995
1994
1993
1992
1991
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
Mveidye i^wz.
emissions
(gpm)
Cars
364
365
365
365
366
365
365
366
366
366
360
360
357
356
362
358
362
358
364
355
375
375
372
375
381
436
443
456
446
455
538
616
646
661
691
698
Trucks
514
514
517
518
519
519
523
524
519
520
494
495
495
496
458
465
456
457
453
447
483
497
510
538
463
513
497
799
956
593
1088
1197
1245
1027
1124
1124
New Vehicle Sales
Cars
8100000
8000000
7919000
7885000
8130000
7964000
7538000
7951000
8304000
8408000
9128000
8379000
7972000
8335000
7890000
9396000
8415000
8456000
8108000
8524000
8810000
10018000
10736000
10731000
11015000
10791000
10675000
8002000
7819000
8733000
9443000
10794000
11175000
11300000
9722000
8237000
Trucks
6300000
6700000
7020000
7290000
6932000
7886000
8173000
7824000
7815000
7202000
7447000
6839000
6485000
6124000
5254000
5749000
5710000
4754000
4064000
4049000
3805000
4435000
4559000
4134000
4350000
3669000
3345000
2300000
1914000
1821000
1863000
3088000
3273000
2823000
2612000
1987000
-------
1
2
3
4
5
6
1
8
9
10
11
12
13
Vehicle Age Data
Vehicle
Age
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
Proportion of Original Sales Surviving to
Age:
Car
0.9950
0.9900
0.9831
0.9731
0.9593
0.9413
0.9188
0.8918
0.8604
0.8252
0.7866
0.7170
0.6125
0.5094
0.4142
0.3308
0.2604
0.2028
0.1565
0.1200
0.0916
0.0696
0.0527
0.0399
0.0301
0.0227
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Truck
0.9950
0.9741
0.9603
0.9420
0.9190
0.8590
0.8226
0.7827
0.7401
0.6956
0.6956
0.6501
0.6042
0.5517
0.5009
0.4522
0.4062
0.3633
0.3236
0.2873
0.2542
0.2244
0.1975
0.1735
0.1522
0.1332
0.1165
0.1017
0.0887
0.0773
0.0673
0.0586
0.0509
0.0443
0.0385
0.0334
Average Annual Miles Driven
Car
13,389
13,135
12,860
12,567
12,257
1 1 ,933
1 1 ,596
1 1 ,248
10,893
10,531
10,165
9,797
9,429
9,063
8,702
8,346
7,999
7,662
7,337
7,028
6,734
6,459
6,206
5,974
5,768
5,589
5,438
5,319
5,233
5,182
5,182
5,182
5,182
5,182
5,182
5,182
Truck
15,133
14,849
14,529
14,178
13,799
13,396
12,974
12,535
12,084
1 1 ,625
11,161
10,697
10,235
9,781
9,337
8,908
8,498
8,109
7,747
7,415
7,117
6,857
6,638
6,464
6,340
6,269
6,254
6,254
6,254
6,254
6,254
6,254
6,254
6,254
6,254
6,254
Appendix 6: Definitions of variables in Model Equations
RIE =
CO2t-i =
CO2t =
GWPt-i
GWP t =
CDt-i =
CDt =
FCt
refrigerant incremental effectiveness of the technology package on that vehicle type
tailpipe CO 2 emissions before technology addition
tailpipe CO2 emissions after technology addition
= global warming potential of the refrigerant before technology addition
global warming potential of the refrigerant after technology addition
carbon density of fuel before technology addition
carbon density of fuel after technology addition
fuel applicable to prior technology
fuel applicable to new technology
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
IR =
PP =
FEE =
GAP =
VMTn,FS,i
VMTr>,co2,i
RCO2t =
RCO2t-i =
RCO2t =
TCO2 =
REB =
TEB =
reflected in
CEB =
baseline
discount rate
annual increase in value of CO2
payback period
fine for non-compliance (CAFE)
difference between test-cycle fuel economy and real-world fuel economy
annual miles traveled in year i
annual miles traveled in year i, discounted
annual miles traveled in year i, discounted
refrigerant leakage rate in year i (g/mi)
refrigerant leakage before technology addition
refrigerant leakage after technology addition
tailpipe CO 2 (e.g., the test cycle CO 2 emissions)
rebound coefficient (% change in VMTfor every 1% change in fuel consumption)
technology effectiveness basis, which is the effectiveness of the technology package
the baseline
cost effectiveness basis, which is the cost of the technology package reflected in the
-------
1
2
3
4
6
7
8
9
10
Appendix 7: TARF Equations (full)
CostEffj
MFR i+35
FC, xY
:
PP PP r -,
xV \VMTDPSi ]
L D^!J
(l-Gap)
11
12
TechCost- FC x
- FC x
PP r -, 1
V \VMTDPS . ]x - -
/_,L D,F5,!j _r
RC021) + (C02t_1 -C02t)]xVMTDC02,]x l
-------
ATTACHMENT 3
MODEL REFERENCE GUIDE
VGHG Model Documents Page 34 of 43
-------
Vehicle Greenhouse Gas (VGHG) Application
Quick Reference Guide
Model Version: .9
Introduction:
This document is to serve as a quick reference guide for using the Vehicle Greenhouse Gas
application and the associated input spreadsheet files.
Input Spreadsheets:
There are four spreadsheets, in the current version of the application, that are required for a given
scenario. Each spreadsheet consists of multiple worksheets as follows:
1. Scenario Spreadsheet (Scenario.xls)
a. Scenarios - contains scenario run parameters and references to associated input
files, suffixed by the scenario id number, e.g. Market-l.xls
b. Economics- provides economic parameters such as discount rate and payback
period
c. Targets - contains cycle-specific, user-entered target values for cars and trucks
2. Market Spreadsheet (Market-1 .xls)
a. Market Data - provides sales and engineering information for each vehicle for each
given scenario run
b. MFR Sales - provides inputs corresponding to sales percentages by manufacturer
used to generate generic model records
c. Vehicle Type - provides lookup information associated to inputs and linkage
between the market file spreadsheets for each vehicle type
3. Technology Spreadsheet (Technology-1 .xls)
a. Vehicle Type (1.. .X) Worksheet - contains technology cost, efficiency, and market
cap assumptions and other related information specific to a vehicle type
4. Fuels Spreadsheet (Fuels-1 .xls)
a. Fuel - contains the forecasted fuel prices by year as well as fuel's chemical
properties
Each spreadsheet also contains an Error Worksheet that provides the
Validate Data button. If errors exist throughout the separate worksheets,
the error messages will be presented after the data validation. Note
that skipping the data validation can result in unexpected behavior in
the application.
All spreadsheet column headers include special color coding to
indicate if and how the associated column values are used.
Green background indicates, columns that contain lookup values,
e.g. Vehicle Type column in the Market spreadsheet.
Yellow background indicates values that are auto-generated by the
spreadsheet and/or read-only, e.g. ID column in the Scenario
VGHG Model Documents Page 35 of 43
-------
spreadsheet.
Gray background indicates columns with values that are read in but
not currently used, e.g. Horsepower in the Market spreadsheet.
Turquoise background indicates calculated values, e.g. Combine FE in
the Market spreadsheet.
Instructions:
Updating the Spreadsheets:
1. Navigate to the folder containing the spreadsheets. (C:\Program FilesYVGHGMnput)
2. Open input spreadsheet(s), starting with the Scenario spreadsheet and modify input
parameters as needed. (Note not to add any data rows in the Scenario.xls)
3. Click on the Error tab.
4. To verify the accuracy of the new data, click on the Validate Data button.
a. If no errors exist, the Error Worksheet will remain blank.
b. If errors exist, the Error Worksheet will have a row populated per error. The column
headers convey the following information:
i. Sheet - worksheet the error will be found
ii. Row - row number on the proceeding worksheet where error will be located
iii. Col - column where error will be located
iv. Error - explains why the data isn't correct
dj File Edit View Insert Format lools Data Window Help Adobe PDF
J ^ A J _j _3 .i x A --i ^' J
J ' J |J
^ Snagtt l^1 Window - _
D38
J4
$ %
1 Sheet
validation date: ?/30/2008 12:01:29 P
Value |'a] is not a number.
X'alue (oj is not a number.
5. If no errors exist, save the spreadsheet.
6. If errors exist, the individual cells will be highlighted in red. Make the appropriate changes
and then save the spreadsheet.
7. Follow similar process with the other 3 related spreadsheets until all run data has been
entered and validated.
Common Error Examples
VGHG Model Documents Page 36 of 43
-------
Issue
Fix
Blank Field - Value () is not a
number.
String Field - Value (1) is not a
string.
Enter a number into the field
Enter an alphabetic string into
the cell
Number Field - Value (A) is not a Enter a numeric value into the
number. cell
Percentage Field - Value (1200) Enter a numeric value between
must be equal to or less than 1. 0 and 1 into the cell
Running the application:
1. On the desktop, click on the VGHG icon to open the VGHG application.
You will be presented with the VGHG Model user interface. VGHG
VGHG Model - 0.85
File Help
Open
Exit
2. Click on the File drop-down and select the 'Open' option. You will be presented with the
Open Scenario File pop-up box.
VGHG Model Documents Page 37 of 43
-------
File Help
Open Scenario File
Look in:
! Input
3jFuels-l.xls
=4] Market-l.xls
^J Technology-l.xls
File name:
j Scenario.xls
Files of type: j Excel files (*.xls)
JJ21J
3. Select the Scenario.xls file and Click Open. The tables will be populated with data from
the four spreadsheets.
4. Verify that the correct data has been populated into the VGHG Model.
VGHG Model Documents Page 38 of 43
-------
VGHG Model - 0.85
File Help
.Jni.xl
#
Jk
|l01 MFR1 JGornpa... ll 110000 110000 110000 110000 110000J^246,4JH
102
103
201
202
MFR1
MFR1
MFR2
MFR2
Pickup j 8
Large 3
Compa,,, 1 1
Pickup |8
500000
250000
660000
150000
500000
250000
660000
150000
500000
250000
660000
150000
500000
250000
660000
150000
500000 1 435. 7 P
250000 320,9
660000 246,4
150000 | 435,7 T
m
^J^HJHJHJ^,, ,,,,,,,,,,
i^^^H^^^HlOiH
1 2 PUMP
1 3 AMT
1 |4 ACC
ซ"ซ'''ซ
^B
0,2
1
i'ซiiซi'''iii''ซii''"
^^I^B
0,5 1 1
_| _| _
0,068
0.07
0.08
0.095
0,068 0,068 0,068
0,07 0.07 0.07
0,08 0,08 0.08
O.Q95J 0,095| 0.095
Jk.
169
263
589 '
5. Click on the green car button.
6. The system will run the model and present the step wise results for each cycle and
manufacturer in a text file at the end of the execution.
VGHG Model Documents Page 39 of 43
-------
|P, results-2008 1209 143049.log -Notepad ..
File
Edit Format View Help
MFR1
1-
2-
3-
4-
5-
6-
7-
8-
9-
10-
11-
12-
13-
14-
15-
16-
17-
MFR2
1-
2-
3-
Basel ine Co2avg
ix = 103
ix = 102
ix = 102
ix = 103
ix = 103
ix = 101
ix = 101
Basel ine Co2avg
ix = 203
ix = 202
ix = 202
= 378.1
p 1
320.9
435.7
427.0
305.9
296.3
246.4
235.2
225.6
390.7
207.5
371.2
354.1
277.0
268.0
253.3
190.8
157.8
= 285.8
320.9
435.7
427.0
Target
Steps
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
rtp
Target
Steps
rtp
rtp
rtp
Co2avg
= 1
= 1
= 2
= 2
= 3
= 1
_ -i
Co2avg
= 1
= 1
= 2
= 280.0
D
305
427
390
296
277
235
225
207
371
190
354
327
268
253
244
157
102
= 280.0
D
305
427
390
.9
.0
.7
.3
.0
.2
.6
.5
.2
.8
.1
.7
.0
.3
.4
.8
.0
.9
.0
.7
MFR =
MFR =
MFR =
MFR =
MFR =
MFR =
MFR =
> MFR =
> MFR =
--> MFR =
> MFR =
373.8
368.7
347.6
344.8
339.2
337.8
336.5
334.2
322.9
320.7
310.8
295.4
292.8
288.5
286.0
281.7
274.6
284.1
282.7
276.7
fTS7c;r\nO d
-icQccnnn n
-i^nq^ Rnnn n
?d.o?d.7ono n
-ic 7ff7->f\r\r, n
?6O1 ft^nnn n
?6ft Q7R1 fin n
- In
n
At the end of the run you have the option to save the results as an XML file to load into the
Benefits workbook or use it for other types of post processing analysis. To save the result data to
an XML file, select File|Save from the menu.
You may also run this XML file thru a built in transformation package to "Visualize" the results.
VGHG Model - 0.85
Below is a partial display of the html page produced using the "Visualize" option:
VGHG Model Documents Page 40 of 43
-------
VGHG Results
* otal r! Additions: 55
Cumulative Costs: 51,609,640, 000
Name: First
BaseYean 2010
TargetTjpe; Co2
TariOptiore 1
TargetFunType 1
Cycles; 4
Tech Pack Selections
VGHG Model Documents Page 41 of 43
-------
Manufacturer
Ford
Ford
Ford
Ford
Final Avg CO2
Model
Explorer
F150
Focus
Fusion
Forcl
Cycle 1
1
2
3
1
2
1
* 1
2
* 3
253,6
Cycle2
* 1
2
3
1
* 2
1
2
* 3
* 1
2
. 3
235.6
Cycles
ป 1
2
ซ 3
* 1
2
3
1
2
* 3
* 4
1
ป 2
* *"'
-
217.4
Cycle 4
1
2
3
* 4
* 1
* 2
3
* E
* 6
* 1
2
3
* -
5
1
2
* 3
5
199.6
Details
Manufacturer
Ford
Mode!
Focus
Cyde 1
StepS
* TP = 1
ป 2-6. - ->
-> T. c ";
Cuml Cost =
$93,845,600
Cycle!
StepS
~P = 1
246. i -> 235.2
Cuml Cost =
$116,675,600
Step 10
Cycle3
StepS
TP = 1
* 2d6.i -:= 235. 2
Cuml Cost =
5150,025,600
Step 10
Cycle 4
StepS
T = 1
ซ 2-6.4 -= 235.2
Cuml Cost =
5150,025,600
Step 10
VGHG Model Documents Page 42 of 43
-------
ATTACHMENT 4
BENEFITS CALCULATIONS INSTRUCTIONS
VGHG Model Documents Page 43 of 43
-------
Benefit Calculation Spreadsheet
Vehicle Green House Gas Model
The Benefit Calculation spreadsheet is an analysis tool for determining the total cost savings
from CC>2 reductions forecast by the Vehicle GHG model. The January 23, 2009 version of the
spreadsheet includes a number of modifications to facilitate both expandability and error
checking
The original spreadsheet has been reorganized to facilitate a smooth connection to the Vehicle
GHG core model. Major changes include:
The original input worksheet has been divided into four separate sheets:
o Load, which serves as the point of entry for output from the model. The name
of the most recent loaded XML file is displayed on this page as well as some
additional information.
o Model Results, which contains the manufacturer/model/redesign results from
the Vehicle GHG model. This sheet also includes a number of aggregations to
the Car/Truck level by redesign cycle.
o Exclusive Inputs, which include inputs required only by the Benefits
Calculation spreadsheet. These are primarily physical constants and emissions
damage costs.
o Shared Inputs, which are required by both the Benefits Calculation spreadsheet
and the Vehicle GHG model (e.g. the discount rate, payback period and fuel
price forecast.) These values are also read from the Vehicle GHG output to
insure that the Benefits Calculations use the same values used by the model.
VBA code has been added to handle data import from the model.
The Benefits2 (Sales) tab has been reoriented so that the sales forecast goes down
rather than across. This is for easier viewing of the data.
The VMT_Lookup sheet includes a table of VMT by vehicle age with separate columns
that reflect different first year starting points - these are calculated from the rebound
effect.
The VMT_Rebound_Effect table includes all of the Model Year / Calendar year data
that was originally included in the triangular tables.
The AnnualTotals table summarizes information from the VMT_Rebound_Effect sheet
into Calendar year totals.
The remaining pages in the Benefit Calculation spreadsheet have been updated so that
all references are to the new pages.
Note that the cell background color scheme (see the legend on the Load sheet), is used
on all pages.
Several pages were no longer required as their functionality has been moved to the new
sheets. These have been removed from the spreadsheet to eliminate confusion (and to
greatly reduce the size of the spreadsheet)
VGHG Model Documents Page 44 of 43
-------
Loading Model Results:
The system transfers data from the Vehicle GHG model to the Benefits Calculation spreadsheet
via an XML file that is exported by the model after all redesign cycles are complete. The XML
file contains and organizes all of the spreadsheet input data and the model output data. This
approach of using a separate XML output file allows for flexible integration into other future
post-processing spreadsheets since all of the important data is organized into a single file.
Results from a Vehicle GHG scenario run may be loaded automatically into the appropriate cells
in the Benefit Calculation spreadsheet via the Load button that appears on the "Load" tab. Data
read from the Vehicle GHG scenario includes:
CO2 emission and cost forecasts for each make and model in each redesign cycle.
Vehicle sales data for each make and model in each redesign cycle.
Shared Inputs
The spreadsheet contains the following sheets:
Sheet Name
Load
MODEL RESULTS
EXCLUSI VE INPUTS
SHARED INPUTS
BENEFITS2 (SALES)
VMT Lookup
VMT_Rebound_Effect
AnnualTotals
EXTERNAL VMTCOSTS ($)
DOWNSTREAMCOSTS ($)
Purpose
Specify scenario and read in the XML
outputs from Vehicle GHG.
Summarizes model outputs in a flat table.
Also includes Redesign cycle totals and
averages for Cars and Trucks
Data values required by the Benefits
Calculation spreadsheet, but NOT by the
core Vehicle GHG mode
Data values require by both the Vehicle
GHG model AND the Benefits Calculation
spreadsheet.
Interpolates annual Car and Truck sales
based on the input data for sales in the
redesign cycles.
Tables of VMT by vehicle age with
increasing values calculated from the
rebound effect.
All Model Year / Calendar year calculations
for impacts due to the rebound effect. This
includes both costs and benefits.
Calendar year totals for the model year /
calendar year data on the
VMT Rebound Effect pag.
Calculate negative impact of rebound VMT
due to Congestion, Accidents and Noise
Summarizes downstream costs calculated on
the above six worksheets. Applies a
discount rate to determine the net present
value of the future cost stream.
Comments
Loads data for up to four manufacturers
and a maximum of four redesign cycles.
Note that the XML file is usually located
in the Aoutput subdirectory of the VGHG
installation directory.
If data is read in for less than eight
cycles, values from the last cycle read in
will be copied forward to fill in a full
eight cycles.
Sales forecast now extends through all
eight redesign cycles (2050)
Note that the Baseline and earlier CO2
values for Cars and Trucks are included
as the last two columns on this tab.
VGHG Model Documents Page 45 of 43
-------
Sheet Name
FUELCOSTS ($)
EXTERNALCRUDECOSTS ($)
UPSTREAMCOSTS ($)
ALL NON-TECH COSTS
TECH COSTS
ALL COSTS
Purpose
Calculates cost savings due to reduced fuel
consumption.
Calculates cost savings due to reduced need
for crude oil.
Calculates the upstream savings due to
reduced emissions of CO2, CO, VOX, NOX,
PM and SO2 due to reduced need for
gasoline production from crude oil.
Summary of all Non-Technology costs and
benefits for a given Vehicle GHG scenario.
Summary of Technology costs from the
model.
Summary of Technology and Non-
Technology costs.
Comments
VGHG Model Documents Page 46 of 43
-------
APPENDIX C
JOHN GERMAN'S REVIEW DOCUMENT
-------
The charge to reviewers was, "EPA staff are seeking your expert opinion on the concepts and
methodologies upon which the model relies and whether or not the model will execute these
algorithms correctly." The emphasis of my review is on the inputs to the model and the model
concepts and methodologies. I did not devote much attention to the outputs and whether or not
the model executes the algorithms correctly, as the model will certainly evolve and improve over
time. Thus, assessing outputs and proper execution of algorithms will be a living, constantly
changing challenge, as the model itself changes. My time and expertise is better spent focusing
on inputs and model structure. (Not to mention that I just ran out of time.)
Concepts and Methodologies Upon Which the Model Relies:
(A) Model structure
The model is an accounting model. This is neither good nor bad. The advantage is that it avoids
overmodeling and embedding errors in the model itself. The disadvantage is that the factors
affecting the results are all inputs to the model. This requires a great deal more sophistication
and work by anyone using the model to prepare the inputs properly. It will also make it more
difficult for anyone outside EPA to use the model, unless EPA is willing to provide the detailed
inputs to other users.
With this type of model, it is essential that EPA release the data in the Technology and
Economics input files and discuss them in the Notice of Proposed Rulemaking, as the real
analyses and modeling are in these input files. But as long as this is done, the overall model
construction is fine.
(B) Redesign cycles
I completely agree with EPA's logic in creating a model based upon vehicle redesign cycles. As
EPA states, adding technologies incrementally to each vehicle model by model year does not add
value to the model results. Using redesign cycles also allows for simplification of the fleet. It is
impossible to predict the direction of vehicle redesigns for each manufacturer. It is just as
accurate to assume, for example, that future mid-size cars from each manufacturer will be
identical; as it is to assume that current differences in mid-size cars from one manufacturer to the
next will be continued into the future. As a recent example, Honda left their compact crossover,
the CR-V, virtually unchanged in size during the latest redesign. However, Toyota chose to
lengthen their compact crossover, the RAV4, by 14" during its latest redesign. It is pointless to
try to predict differences in vehicles from different manufacturers in the future and it is pointless
to try to predict the exact year when redesigns will occur. This is a welcome simplification.
Another advantage of using redesign cycles is that GHG standards for interim model years can
only be set, reasonably, as a straight line (or a constant % decrease) between the baseline year
and the end of the redesign cycle. This is appropriate. Constant yearly % reductions provide a
consistent signal to manufacturers for investment decisions.
However, there is one potential problem with using redesign cycles. It masks the investment
Appendix C-l John German Review
-------
needed to bring new technology to the market. The auto industry is extremely capital intensive.
Initial investment in a new technology is expensive, both for tooling and the resources necessary
to assess (and fix) system-level effects and effects on reliability, durability, safety, and
manufacturing. Redesign cycles tend to assess only the costs for high-volume production and
skip over the high initial costs. Care must be taken to properly assess costs in the inputs.
(C) Leadtime
The model handles leadtime issues far too simplistically. This was also a problem with the
Volpe model. Leadtime is one of the most important issues in setting standards and one of the
most difficult issues to assess properly. Thus, it is disappointing to see both NHTSA and EPA
provide so little attention to the issue.
The only leadtime constraints in the draft model are industry-wide caps on the maximum
technology penetration by redesign cycle and vehicle type. There are several problems with this
approach:
The largest problem is that it is inappropriate to treat all manufacturers the same. A
manufacturer that has already invested in a particular technology in the baseline year will be
capable of higher penetration rates than a manufacturer that has never used the technology
before - and also of producing the technology at lower cost. An obvious example is hybrid
vehicles. Over 10% of Toyota's vehicles already have hybrid systems on them. After
introduction of the CR-Z next year, Honda should also have more than 10% hybrids. Due to
their experience and head start with hybrids, both manufacturers will be capable of much
higher penetration rates than most other manufacturers. They are also further along the
learning curve, so their costs will be lower. Similar situations exist with most technologies.
Another problem is that costs will vary from manufacturer to manufacturer. As noted in my
comments on redesign cycles, above, there are large upfront costs when a manufacturer
introduces a new technology. For example, Toyota has already amortized large R&D and
system-level costs for hybrid vehicles. They will be able to produce hybrids cheaper than
manufacturers that are just starting to offer hybrids. The point is that the "Initial Incremental
Cost" in the Technology Input File should not be applied to all manufacturers at the same
time, but rather to each manufacturer at the time they first introduce a new technology.
The third problem is that there is no such thing as a hard cap on technology penetration rates.
There is a tradeoff that exists between cost and leadtime. Technology introduction can be
accelerated by increasing investment - and cost and risk.
Long-Term Recommendation - The best way to handle leadtime constraints and technology
penetration is to assess capital investments by manufacturer. This would require adding a new
section on capital expenditures. In addition to assessing the cost of each technology, the capital
expenditure would also be assessed. Ideally, there would be two components to the capital
expenditure assessment for each technology, one for R&D expenditures for the first
implementation of the technology and one for the capital investment needed to add the
technology to additional models. However, the second is more important. Each manufacturer
would be assigned a total capital expenditure budget for the redesign cycle and technologies
could only be added up to the point where the sum of the technology capital expenditures did not
exceed the manufacturer cap. Alternatively, some increase in technology penetration over the
Appendix C-2 John German Review
-------
cap could be allowed, but only if coupled with increasing technology costs. This would
appropriately handle leadtime constraints and technology penetration rates.
Short-Term Recommendation - The long-term recommendation would require a lot of new work
and is clearly not feasible in the timeframe needed for EPA's rulemaking. As a short-term fix,
instead of using industry-wide caps on maximum penetration for each technology, EPA should:
(a) Set caps on the maximum increase permitted per year. This would be applied to each
manufacturers' individual technology penetration; and
(b) Establish the model year for initial introduction. For technology that has not been
introduced to the market yet, this year could be the same for all manufacturers. For a
technology that is already being used by a manufacturer, the baseline year would be used
for that manufacturer. However, if a manufacturer were not using a technology yet, even
if another manufacturer is using it, a year of introduction would need to be set for that
manufacturer.
(c) Some technologies would still need caps on maximum penetration. However, this should
reflect market restrictions, not leadtime constraints. This would incorporate consumer
values for particular technologies that go beyond just efficiency and performance. For
example, even though manual transmissions are more efficient than automatics, most
consumers will not give up the convenience of an automatic. PHEVs do not have much
benefit for people driving a lot of highway miles each day. Diesels are desired for trailer
towing and have advantages on highway fuel economy, while hybrids have advantages in
stop-and-go driving. These types of market considerations can be handled by
establishing maximum penetration caps, but they should be handled separately from how
leadtime is handled by manufacturer.
Note that the yearly cap and introduction date violates the design cycle principal, but it is
important to create the proper cap for each manufacturer and technology combination. Instead of
using a model year for (b), above, the user could specify how many years into the design cycle a
technology could be introduced.
(D) Technology Assessment
Requiring the user to input technology in rank order of cost-effectiveness is an interesting
attempt to handle the synergy issue. Unfortunately, it fails to work in other ways:
It only works if the learning rate is the same for all technologies and if no technology
changes effectiveness over time. If one technology has a steeper learning curve than another,
or if a technology increases benefits in the future, then the cost-effective order will change
over time. For example, high-tech diesels are a relatively mature technology, as over 5
million per year have been sold in Europe for several years. Their future cost reduction
potential is much less than that of hybrid vehicles, whose sales are at least an order of
magnitude lower and which are still at early stages of development. Also, the high power Li-
ion batteries just starting to penetrate the market will allow much smaller battery packs for
conventional hybrids, with large cost reductions. In addition, analyses by MIT (2007)
suggest that hybrid benefits will increase in the future as manufacturers figure out how to use
the hybrid system to minimize operation at less efficient engine speed/load points.
The synergies will differ depending on the specific technologies into which an individual
Appendix C-3 John German Review
-------
manufacturer has already invested. For example, consider one manufacturer that has
invested in MPI turbos and a second that has invested in DI naturally aspirated engines. If
both manufacturers move to DI turbo engines, the first manufacturer will gain the benefits of
DI adjusted for the Dl/turbo synergies, while the 2nd manufacturer will gain the benefits of
turbocharging adjusted for the same Dl/turbo synergies. Thus, the synergy impact of
Dl/turbo must be assessed independently of each technology. Even if the model ignores the
leadtime constraints imposed by baseline technology investment and assumes every
manufacturer will adopt the exact same technology packages for a given vehicle type (not a
good idea, as discussed, above), a problem still exists in backing out "any advanced
technology that might have been present in the baseline" (page 12, line 3-4). In order to back
out the baseline technology for different vehicles and manufacturers, the technology input
file must contain independent assessments of MPI turbo, DI naturally aspirated, and DI turbo.
The DI turbo line includes the synergies, but the other two lines do not. How does the model
add them back in? If the turbo lines and DI lines occur before the DI turbo line, then the
technologies will be added together first without consideration of the synergy effect.
It does not allow for different markets for different technologies. For example, diesel
engines have additional value for (a) customers who tow and (b) customers in rural areas.
Towing is valued only by a small part of the market, but it is an important feature for that
market. Customers in rural areas do a lot of highway driving and value the high efficiency of
the diesel on the highway, while hybrids excel in urban areas. Thus, the markets for diesels
and hybrids will be self-selected to some extent by their relative city and highway mpg, not
the combined mpg used to select all technology.
In order to work properly, the model must be able to handle multiple pathways. For example, the
model cannot allow turbo and DI benefits to be added sequentially, but must force each to go to a
DI turbo input. A similar situation exists with the various variable valve timing systems and
VCM. All offer primarily pumping loss reductions and all options must be present in the input
file in order to back out technologies in the baseline. All these options cannot be added back by
the model one after the other - the model must also be able to handle these multiple pathways.
Another example is transmissions, where the input file must list 5-, 6-, 7-, and 8-speed
automatics, as well as DCTs and CVTs (even ignoring manual transmissions). I could go on.
The point is that I do not see how the model can avoid handling multiple technology pathways
and depend only on the input order to handle synergies.
The model must also be able to handle technologies with different rates of change in benefits and
costs in the future. This also requires that the model process the lines independently and not rely
on the input order.
The market considerations could perhaps be handled with maximum penetration caps. For
example, it could be considered that diesel engines will not compete well with hybrids in urban
areas, so that the maximum penetration of diesels would be equal to their sale in rural areas plus
trucks designed to tow, with the reverse true for hybrids. Of course, this will differ by
manufacturer, which is a problem if universal caps, instead of manufacturer-specific caps, are
maintained.
Appendix C-4 John German Review
-------
(E) Maximizing Net Social Value
The model only outputs total costs and benefits. It presents these with great amounts of detailed
information. But it is impossible to tell if the scenario has maximized net social value.
To put it another way, the model is only capable of counting up the benefits and costs of
complying with pre-determined GHG standards. It is not able to do the reverse, which is to input
the desired benefit and have the model determine the resulting GHG standard.
This is not a trivial issue. The 2007 EISA specifically mandates "maximum feasible" CAFE
standards after 2020. NHTSA has long interpreted existing statutory authority to also require
maximum feasible standards and established long ago that "maximum feasible" is determined by
the point at which the costs of adding the next technology exceed the benefits. Even without a
mandate, any credible analysis must be able to compare the costs and benefits of the chosen
GHG standard to the maximum net social value.
Given the existing complexity of the model, it is not unreasonable for the model to also
determine the GHG standard that maximizes net social value. The Volpe model calculates this
point even with a much more complex model. EPA's model will lose considerable credibility if
it is not capable of calculating the maximum net social value point.
Appropriateness and Completeness of the Contents of the Sample Input Files:
(F) Market Input File
The market input file appears to be appropriate and complete - perhaps too complete in one way.
The file contains separate inputs for reference case technology benefits and costs. The
percentages in these columns should simply reflect the existing market penetration of each
technology package. They should be identical for both costs and benefits. Is there a reason why
these would be different? If so, the Model Description should explain this. If not, the duplicate
columns can be removed.
Minor Suggestions:
If the model wants to "back out" existing technologies, you will need a lot more than 20
columns to do this. You'll need 10 columns just to handle transmissions and another 10 just
to handle different valve timing systems. Not to mention differing levels of high strength
steel and aluminum use.
The Model Description should state that vehicle types are a user input defined in the
"Vehicle Type" tab of the Market Input File (I looked around for a while before I found this.)
If you maintain separate columns for reference case technology costs and benefits, it would
help the user to add a row above the existing descriptions and define columns AD-AW as
"reference case benefits" and columns AX-BQ as "reference case costs".
Appendix C-5 John German Review
-------
(G) Technology Input File
As discussed above, the technology input files need to be substantially modified in conjunction
with changing the model to handle multiple technology paths.
In addition, also as discussed above, the "Cap Cycle" numbers need to be replaced with generic
caps on the maximum increase permitted per year and manufacturer-specific model years for
initial introduction. The annual technology penetration increase cap would be applied to each
manufacturers' individual baseline technology penetration, from the Market Input File, or
starting with the manufacturer-specific initial model year for technology packages that have not
been used yet by individual manufacturers.
The Average Incremental Effectiveness fields are fine, although, as noted above, if these change
for future redesign cycles, the cost-effective order of the technology packages can also change.
I could not find any explanation of how the Initial Incremental Cost, a, Decay, seedV, kD, and
Cycle Learning Available fields are used in the model. Even the detailed algorithms on pages 9-
16 of the Model Description contain no reference to how technology costs are adjusted for the
TARF calculations. Thus, I was not able to assess the appropriateness of these fields. However,
in general, the cost reduction curve is not likely to be the same for all technologies. Some
flexibility may be needed here.
The Technology Input File does not address weight impacts associated with different
technologies. For example, both diesel engines and hybrids add considerable weight to the
vehicle, which negatively impacts both performance and efficiency. It is possible to handle this
off-board in the efficiency benefit estimation. However, if so the Model Description should
explicitly state that weight impacts are expected to be assessed by the user and included in the
technology inputs.
(H) Scenario Input File
The compliance options - universal standard, linear attribute, or logistic attribute - are fine.
However, there are columns in the Scenario input file that are not described in the Model
Description on page 6:
TARF Option (column E) - Is this the "two TARF equations from which the user can
choose", described on page 13? If so, should state this on page 6.
o Why is the "Effective Cost" TARF equation limited to fuel savings over the payback
period? Why aren't the discounted lifetime fuel savings considered? Is this done to
try to mimic what technologies will be most acceptable to the customer? If so, this
should be explained in the Model Description. I'm also not sure this is appropriate.
Most technologies will be invisible to the customer. In addition, the primary point of
CAFE and GHG standards is to fill in the gap between the consumers' value of fuel
savings and the value to society. So, the standards should be targeted towards
society's values, not the customers.
o The equation for "Cost Effectiveness - Manufacturer" equation does not make sense.
Appendix C-6 John German Review
-------
Unless a technology includes a fuel change, this equation will produce virtually
identical results for all technologies. The CO2 summed in the denominator is directly
proportional to fuel consumed summed in the numerator. The ratio should be
virtually the same for all technologies, unless there is a fuel change. What is this
equation trying to do?
o Why is the fuel savings only summed over the payback period, while the CO2
savings are summed over the useful life? Why are they not the same?
Target Function Type (column F) -1 could not find a description of this field anywhere in
the Model Description.
Fleet type (column G) - The description in Rykowski's email response to Rubin should be
added to the Model Description.
Trading limit (column I) - The description in Rykowski's email response to Rubin should be
added to the Model Description.
Economic parameters - The "CAFE fine" and "CO2 value increase rate" are fine. However, the
other parameters may need modification:
Discount rate - There is some thought that the CO2 discount rate should be different from the
economic discount rate. I am not sure I agree with these arguments, but you may want to
include flexibility to have a different discount rate for CO2 in the model.
Payback period - As discussed, above, I am not sure this is needed. Any use of payback
period should be explained and justified in the Model Description.
CO2 fine - While the CAFE fine is used appropriately in the model, there is no consideration
of a manufacturer paying CO2 fines instead of complying with CO2 standards. Of course,
this is dependent on the compliance strategy adopted by EPA for its CO2 standards. But the
model should have the flexibility to model CO2 fines; similar to how it handles CAFE fines.
Gap - It is appropriate to adjust the test values for differences in real-world fuel
consumption. However, the gap is not linear. As EPA demonstrated in their fuel economy
label rulemaking, the gap increases as fuel consumption decreases. While the fuel economy
label adjustments overstate the actual gap, the curves for city and highway fuel economy
labels from the generic equations are illustrative. The model should add the ability for the
user to input a nonlinear gap function.
I do not understand the value of "threshold cost" or how it is used. Lines 8-10 of page 8
state, "threshold technology cost (the cost at which manufacturers add technology to only
enough vehicles to meet the standard as opposed to adding technology to all of a model
line)". The detailed calculations later in the Model Description do not discuss how this is
done. From a practical point of view, how does the model know whether or not the
technology is needed to meet the standard when the technologies are feed into the model one
at a time? More importantly, manufacturers have limited resources and the standards will
drive technology development well beyond what a manufacturer would have done without
them. Thus, why would a manufacturer add any technology to more vehicles than are
required to meet the standard? Unless these concerns can be addressed in the Model
Description, the "threshold cost" should be eliminated.
Rebound effect - Line 38 on page 17 states that the rebound effect is an input in the
"Economics" worksheet. However, it is not listed in the worksheet. In any case, the rebound
effect is not handled appropriately in the model. The rebound effect is a sensitivity factor.
Appendix C-7 John German Review
-------
But it is determined from a regression. Which means that the change in VMT is NOT a
linear function of the change in fleet fuel consumption. Thus, the equation on lines 41-43 of
page 17 is wrong. The actual relationship is logarithmic or exponential or something like
that (I don't remember exactly what). The correct equation should be built into the model.
o The rebound effect is also impacted by the price of fuel and household income. This
should be added to the model (see medium- to long-term recommendations, below).
Minor suggestions:
It appears that the "Cars A", "Cars B", "Cars C", and "Cars D" columns in the Target tab are
intended to describe the footprint-based logistic curve. Does this mean that "Cars C" and
Cars D" are also the Xmax and Xmin under the linear attribute option? If so, both
descriptions should be in the column headings. Also, while the Model Description (page 6-7)
includes a good explanation of the how the linear target and logistic curve work, it should
also specifically state where the A, B, C, D, and X coefficients can be found in the
spreadsheet.
The economic parameters are discussed as part of the Scenario input file on page 8. Lines
12-13 also state that an example of the Scenario input file is in Appendix 3. However,
Appendix 3 only includes the "Scenarios" tab and the "Target" tab. The "Economics" tab
should also be added to Appendix 3.
(I) Fuels Input File
The fuels file works fine for conventional gasoline and diesel. The Model Description does not
address biofuels, but if needed the Fuel Input and the Upstream Emissions worksheets should be
able to handle them.
Electricity is a special problem. A minor issue is that the Energy Density (column B), Mass
Density (column C), and Carbon density (column D) are different than for liquid fuels. Liquid
fuels are generally expressed in units per gallon. This doesn't work for electricity. The units for
electricity in the Fuels Input sheet need to be defined. Also, I'm not sure what Mass Density
would be for electricity - kg/kWh? And isn't carbon density meaningless, as the carbon is all
upstream?
More importantly, the energy density and mass density for electricity are not fixed, but are
dependent on battery construction. High-power Li-ion batteries for conventional hybrids may
only have about 15 Wh/kg energy density, while high-energy batteries for PHEVs and EVs may
have over 100 Wh/kg. In addition, start/stop systems and belt-alternator/starter systems may use
lead-acid batteries and some conventional hybrids may continue to use NiMH batteries through
the 2013-2015 timeframe. All will have different energy densities.
Minor suggestions:
The Model Description, line 6 page 6, says, "There is a small subset of fuel information not
included in this file". This is not accurate. Appendix 5 contains upstream emissions, which
is an extremely important factor for fuels. This connection should be discussed in the Model
Description.
The appendices should be ordered to match the order they are discussed in the Model
Appendix C-8 John German Review
-------
Description (i.e. the fuels Appendix should be before the Scenario appendix).
(J) Reference Data in Appendix 5
Downstream Criteria Pollutant Emissions:
The fields and the regressions as a function of age are appropriate. However, there is not enough
flexibility to handle differences in fuel, future emission standards, and future fuel sulfur control:
The model should be able to handle future reductions in emission control standards. This
means that the model should allow the user to specify effective years for future emission
standards and enter new regression coefficients.
SO2 emissions are almost entirely a function of the sulfur level in the fuel. Thus, the model
should also handle changes in fuel sulfur level. The model should allow the user to specify
effective years for future sulfur reduction and the fuel sulfur level for both current and future
fuels. If desired, the user would not have to enter regression coefficients for SO2, as there is
a fixed relationship between fuel sulfur, fuel consumption, and SO2 emissions (much like
CO2 to fuel consumption) that could be hard-coded in the model if the user specifies fuel
sulfur levels.
The regression coefficients will be different for gasoline, diesel, and electric vehicles.
Average coefficients can be used for the current fleet, but these will not be appropriate if
there is a substantial change in the future mix of diesels, PHEVs, or EVs. The model needs
to allow input of different coefficients for diesel and gasoline - and possibly biofuels.
Downstream emissions of electric operation should be zero and do not have to be input.
It appears that the model does NOT calculate downstream pollutant emissions as part of the
normal model accounting, only the additional emissions caused by the VMT rebound effect.
This is not appropriate. If there is a switch to diesels or EVs, the downstream pollutant
impact needs to be assessed by the model.
Upstream Emissions:
The upstream emission inputs are fine for gasoline and diesel, although addition rows will
likely be needed to handle biofuels and unconventional oils.
It is not clear if the efficiency of battery recharging is included in electricity upstream
emissions. The model likely calculates only the mmBtu actually used by PHEVs and EVs
during use. However, the mmBtu draw from the utility will be larger due to losses in the
battery charger and in the battery chemical process. To ensure that the user handles this
properly, it would be best to add an input somewhere for charging efficiency. Otherwise, the
Model Description should explicitly state that the upstream grams/mmBtu for electricity
must be incremented to include the losses in the charger and battery.
Upstream emissions, both carbon and pollutant, for electricity will vary by region. While it
is the responsibility of the user to input proper factors, there is a potential issue with
stratification of PHEV and EV sales across the nation. Customers in urban areas are most
likely to buy PHEVs and EVs will likely be limited primarily to a few, dense urban cores. It
might be useful to have the Model Description briefly discuss the need for the user to input
upstream values for electricity that are consistent with utility emissions in the urban areas
most likely to purchase PHEVs and EVs.
Appendix C-9 John German Review
-------
Vehicle Age Data and historical data on average CO2 emissions and new vehicle sales:
These fields and inputs are fine.
(K) Other Reference Data
Externalities related to crude oil use:
The externalities in the Externalities worksheet of the Benefits Calculation are only listed for
imported oil. This is appropriate for military costs for protecting oil supplies, but it is not for the
economic impact of periodic price shocks (and possibly for monopsony effects as well). Oil is a
global commodity. Any reduction in oil use, either domestic or imported, will help reduce the
economic impact of periodic price shocks.
Rebound effects:
The discussion of the rebound effects on lines 10-19 of page 3 and on pages 20-21 both imply
that rebound effects are NOT considered in assessing the societal benefits from reduced crude oil
use and GHG emission reductions. However, I would assume that these benefits are based upon
total fuel consumption, which includes the additional VMT from the rebound effect. If my
assumption is not accurate, then the social benefits associated with reduced crude oil use and the
value of GHG emission reductions must be revised to include the rebound effect. If the benefits
do include the additional VMT from the rebound effect, this should be clarified in the discussion
on both page 3 and page 20.
Recommendations for Improved Model Functionality - beyond "future work":
(L) Recommendations for Short-Term Functionality
The functionality of the model is good. My only recommendations are those already described
above, for improved handling of leadtime (section C), ability to handle multi-path technology
inputs, (section D), and ability to calculate "maximum net social benefits" (section E).
(M) Important Medium-Term and Long-Term Recommendations
1) By far the most important improvement is to use budgets for capital expenditures to assess
leadtime. The need for this and suggestions on how to implement it were discussed in section
(C), above.
2) The rebound effect is impacted by both the price of fuel and household income. These
should be added to the model. The work has already been done by Small and vanDender. Their
equations should be added to the model, along with the necessary user input fields for future
household income. An option to skip the fuel and income effects can be maintained, but it is
important that the model be capable of properly calculating rebound effects.
The time value of congestion and vehicle refueling are also related to household
income. While this is of lesser importance than the rebound effect, it should be
relatively easy to add household income effects to the value of congestion and vehicle
refueling in conjunction with adding household income to the VMT rebound effect.
Appendix C-10 John German Review
-------
(N) Less Important Long-Term Suggestions
3) Inclusion of the city and highway fuel economy/CO2 values may help with assessing
market penetration caps, although this can be done externally. Also, separate city and highway
values could help calculate an appropriate in-use fuel economy/CO2 "gap" for different
technologies with different city/highway fuel economy ratios. Separate city and highway
numbers might also be useful for other purposes. EPA should consider adding these to the
model.
4) Value of time required to refuel vehicles:
The model handles this appropriately for liquid-fuel vehicles. However, PHEVs and EVs will
add refueling time, both because of the need to plug in and, in the case of EVs, the shorter range.
This should be added to the model. Ideally, it should also be added to the TARF assessment.
Appendix C-l 1 John German Review
-------
APPENDIX D
PAUL LEIBY'S REVIEW DOCUMENT
-------
May 29, 2009
Paul N. Leiby
pleiby@gmail.com
Review Comments on
EPA's GHG Model and the documentation, "Description and Methodologies of the EPA
Vehicle Greenhouse Gas Emission Cost and Compliance Model"
(Based on Drafts received May 1, 2009)
Thank you for the opportunity to review this model and its documentation. This is an important
project, and the EPA team has made great progress in developing a coherent, informative, and
very usable system. I understand that this is a work in progress and, regrettably, many comments
can only refer to its current (May 1, 2009) state. Also most of the comments are in the form of
what might be changed or improved, with the hope that these might be most useful. I would like
to say at the outset that everything achieved so far is well worthwhile, and some features are
quite marvelous. Please also interpret statements below of the form "the model does/does not"
as meaning "as far as I could discern so far, it seems like the model does/does not." Statements
like "the model/documentation should" really mean "Perhaps it would be helpful if the
model/documentation were adjusted to...." In sum, this work is to be applauded and I look
forward to its next iteration. Comments are offered in order of the questions posed, and in
structured bullet form.
Questions to address:
1) Comments on: The overall approach to the specified modeling purpose and the
particular methodologies chosen to achieve that purpose;
This model fills an important need for an independent capability to assess how
manufacturers might respond to GHG emission regulations on light-duty vehicles.
There is much to recommend this model, which grapples with some key challenges of
assessing how progress toward tighter fuel use or GHG emissions standards can be
achieved through incremental vehicle technological change, and at what cost.
The essential approach of this model is consistent with others in a similar vein, with the
most notable predecessor being the NHTSA "Volpe Model." It describes the set of
technological possibilities for improving vehicle fuel economy, or reducing GHG
emissions, characterizing for each technology the cost and incremental change in
emissions and fuel use. It determines a sequence of introduction for fuel-economy (or
fuel switching) technologies necessary to meet a fleet-average CO2 emission constraint
for each manufacturer. However it differs from some other approaches in significant
ways:
o 1. The sequence of discrete technologies that can be used for any single "Vehicle
Type" is exogenously specified by the user. Those fixed technology successions t,
t+\ ... for each vehicle type v,essentially define a vehicle-type-specific supply
(marginal cost) curve for emissions reduction. The model determines the
sequence in vehicle types each separately progress in an orderly fashion down
their emissions reduction technology curve.
Appendix D-l Paul Leiby Review
-------
o 2. The model makes vehicle technology redesign decisions not annually, but for
each vehicle "design cycle," which is typically specified as a fixed number of
years.
o 3. The algorithm does not do a simultaneous choice of the set of technologies that
minimize vehicle net costs such that the GHG emission standard is met. Rather it
iteratively "dispatches" discrete new technologies by choosing which vehicle is to
progress next by one more step through its sequence of technologies. It repeats
this dispatching over vehicle types until the fleet average GHG emission standard
is finally met. The choice of which vehicle type is to receive more advanced
technology is based on one of two figures of merit, called "TARFs."
It is wisely stated that effective model design hinges on a careful definition of its purpose
or purposes, and an acknowledgement of its bounds and limitations. The documentation
could be much strengthened in this regard. Here is my impression of its suitability:
o This model is currently most suited to estimating the incremental net
technological cost of any single manufacturer achieving various GHG emission
levels, specified as an average for that manufacturer's new-car fleet. It accounts
for technology costs and lifetime fuel cost savings in its dispatching of
technologies for each manufacturer's fleet. Other attributes and societal impacts
may be monitored ex post (e.g. the extensive and somewhat disparate list on the
top half of p. 3, including criteria pollutant emissions, noise, congestion, refueling
time, etc.) but these are not considerations in the model's solution, i.e. in the core
algorithm that sequences the application of vehicle technologies.
o A compact way to describe the models approach is that, like the Volpe Model, its
solution has two phases: "manufacturer compliance simulation" (with cost-based
technology choice) and "effects estimation" (based on a diverse set of ex post
calculations).
o The model does not project vehicle sales, or sales mix, or aspects of vehicle
design and vehicle appeal to consumers, apart from altered lifetime vehicle capital
and fuel use costs. This is not mentioned as a flaw, but as an important design
choice that should be stated. Large changes in fuel economy and GHG emissions
could have important indirect impacts on the design and appeal of the vehicle,
particularly if tradeoffs are made in the areas of vehicle size, weight,
performance, range, and, for alternative fuels, fuel availability and convenience.
o The model treats each manufacturer's regulatory attainment problem
independently, and is not currently designed to model "flexible" emission
standards that allow permit trading among manufacturers, permit banking or
borrowing, or economy-wide GHG trading systems.
Suitability of method
o To some extent the discussion of the manifold ancillary benefits and costs can be
a distraction, since a coherent and complete framework for their endogenous
analysis is currently outside the scope of this model. I suggest that the model
developers may wish to stay focused first on clearly and rigorously modeling the
fuel-economy technology choice and cost-effectiveness considerations, for
various GHG emission levels. Where possible, one reasonable design approach
Appendix D-2 Paul Leiby Review
-------
might be to assume that other vehicle attributes are essentially held relatively
constant, for each vehicle size and type.
o Overall, the model documentation suggests that model developers may be hopeful
of doing too much soon, with many (over 10) stated intentions for future
extensions. Better and sounder results may follow from strategically limiting the
model scope, carefully testing the model (in full, with real datasets), and then
selectively adding features over time.
o One feature of this model approach is its comparative analytical simplicity but
heavy reliance on specialized data inputs (discussed further in Item 2 below).
This should be viewed as a model strength: its contribution need not rely on
analytical sophistication, but also on the coherent application of good quality,
widely reviewed data.
Two major methodological points:
o In any model, particularly any model of markets with social externalities and
government intervention, it is essential to be very explicit about whose behavior
and objectives are being modeled. Otherwise there is danger that nobody is really
being described, or that we might impute particular knowledge and incentives to
market actors who actually have neither. Naturally a model can be both
normative, saying what should be done optimally, or descriptive, saying what we
think will be done by some actors in certain circumstances even if it is not clearly
optimal. And it can apply to what would or should best be done for different
agents: vehicle consumers, manufacturers, or the government/society as a whole.
I am a little unclear about whose behavior is being modeled in the succession of
technology decisions made. It appears the intent is to model market behavior of
competitive vehicle manufacturers facing cost-minimizing consumers and a firm-
wide emission constraint. But the objective of such a firm is not explicitly stated,
and the solution rules are not clearly mapped to that objective.
In this matter it seems that the Volpe Model has set a good example by
succinctly and specifically stating up-front whose behavior is being
modeled: "The system first estimates how manufacturers might respond to
a given CAFE scenario, and from that the system estimates what impact
that response will have on fuel consumption, emissions, and economic
externalities." [P. 1,
http://www.nhtsa.gov/staticfiles/DOT/NHTSA/Traffic%20Injury%20Cont
rol/Articles/Associated%20Files/811112.pdf1
Would a similar description not also apply to the EPA GHG model?
o Given this idea of modeling the behavior of particular actors, e.g. manufacturers,
in mind, the objectives of the actors should be reflected in the solution method or
optimization condition. Bearing this in mind, there are some concerns with each
of the two TARFs proposed as technology-dispatching figures of merit.
The "EffectiveCost" TARF is essentially the cost of each technology net
of its discounted lifetime fuel savings (omitting the problematic "FEE"
component, which seems mis-specified). Arguably, minimizing this
would be a correct objective of new-vehicle consumers who discount fuel
Appendix D-3 Paul Leiby Review
-------
savings in the same way and given no change in non-cost vehicle
attributes. This could also be the objective of competitive firms acting on
behalf of prospective consumers. In a mixed integer program these costs
would be minimized subject to meeting the emission standard, and the
algorithm would choose the least cost combination of technologies. The
possible problem is that the EPA GHG Model algorithm sequentially
dispatches new technologies in order of EffectiveCost, but without regard
to their effectiveness in reducing GHGs. Some technologies with low net-
cost could do little for GHG reduction. In the limit a low EffectiveCost
technology, say using a high-GHG alternative fuel could even increase
GHGs (FFVs with coal-fired corn-ethanol?). Regardless, there is no
assurance that the suite of technologies finally assembled to reach the
GHG standard in this way would be the low-cost suite. The authors may
wish to consider when they recommend that the first, EffectiveCost
TARF, is appropriate.
The "CostEff' TARF on the other hand leads to an algorithm sensitive to
both cost and cost-effectiveness for GHG reductions. Such a cost-benefit
ratio can lead to optimal selection rules for packing (knapsack or budget)
problems. But some confusing terms are included in the TARF, most
notably the non-standard way in which VMT is discounted for the
purposes of this TARF (See equation top of page 11, line 1). The
inclusion of "IR" ("the annual increase in the value of CO2") in the
discount factor is done without explanation or justification. While the
term IR is never really defined (is it meant to be the growth rate in GHG
damages, abatement cost, or a CO2 tax?). It inclusion seems to conflate
considerations of social benefit (value of GHG avoidance over time with
cost (of technologies). The vehicle manufacturer's cost of GHG
avoidance is already embodied in the TARF numerator. The denominator
should perhaps only reflect the quantity of GHGs avoided. As currently
written, this CostEff TARF would not seem to be a consideration for
vehicle manufacturers whose objective is to produce a new-car fleet
meeting consumer needs and a GHG emission standard at least cost. What
objective was intended with this hybrid aspect of the TARF?
o There are other important methodological points to raise, that are discussed below
in Section 3 on conceptual algorithms.
o At this point, please allow an extended comment on the model documentation.
Clearly it is in draft form only, and there would be much benefit from improving
and clarifying it. This is not simply a matter of fastidiousness, but is an essential
aspect of making the intellectual case for this model. As it stands, understanding
the model was much more work than need be. Some specific suggestions are:
Restructure the presentation, perhaps following the pattern of a j ournal
article. (E.g., begin with stated purpose and background. Place this
model in the constellation of related models and indicate what is different
and why. Describe approach, data sources. Sample results.)
Appendix D-4 Paul Leiby Review
-------
Bringing description of the "Core Program" and what the model does
toward the front.
Clarify and condense the model description. Classically, this would
involve:
State model objective (typically stating what is maximized,
minimized, or what final solution condition is sought)
State model constraints
State and discriminate between principle decision variables,
exogenous inputs, parameters, and internally calculated results.
(This is not done in the variable list of Appendix 6, which also is
incomplete. It omits AIE, PF, CAP, TCO2, IncrementalCost,
TechCost, TARF, VMT, SurvivalFraction, AnnualMilesDriven,
Leakrate, RefLeakage).
State the solution algorithm and termination condition
Rigorous use of notation. Currently, for example, the subscript / usually
refers to "year" (eqns on page 10 and 11) but sometimes indexes
technology (eqns at line 10 on p. 12).
Use consistent variable names. For example, on pp. 16 and 17, it appears
that the same variable is called "ModelSales", "Sales,", and "Annual
Sales."
Clarify subscripts and carefully apply them. The principle subscripts that
seem to apply are:
t: technology number in sequence for each vehicle type
i: actually vehicle age, which is to be distinguished from year
y: year (which indexes, eg. fuel prices)
v: vehicle type
m: ma nufacturer
For example, equation at bottom of p. 12 is missing subscripts on
AIE and RIE (presumably t), while GWP in that equation is
indexed by technology t yet elsewhere (e.g. middle of page 11) it is
not.
Carefully state units. Physical equations cannot be fully understood
without a statement of the dimensions. For example, the equation in the
middle of page 11 can be more readily understood if "Leakrate" is known
to be in [g-GHG/yr], not [g-GHG/mi].
o Overall, the authors might wish to look at the documentation of the NHTSA
Volpe model as a helpful template.
That documentation is actually reasonably compact (35 pp plus an
extended guide to operation).
Appendix D-5 Paul Leiby Review
-------
It gives an excellent, succinct prose summary of what the model does in
the first 3 pages (1-3), and much of the wording might be applicable to the
EPA model.
It clearly states what is being modeled:
There is a flow chart and a technology sequencing flow chart
Equations are then presented in orderly manner with consistent notation
and subscripting.
2) Comments on: The appropriateness and completeness of the contents of the sample
input files. (EPA staff are not seeking comment on the particular values of the contents
of the input files, which are samples only.)
First, an overall point on data. While the instructions urge reviewers to not consider the
particular values of sample data, it must be born in mind that models are essentially
datasets, the equations which link the data, and the algorithms for achieving the solution
of those equations. In this case the model equations (in the documentation) are
reasonably straightforward, although the algorithm for their solution is somewhat opaque
(not explicitly stated and embedded within a compiled module). Assuming a reliable
solution algorithm (something hard to test in this review and with limited data), model
quality will then depend strongly on the quality of model data. This is particularly worth
mentioning because many of the data needed for this model are not readily available from
established sources. The model calls for detailed, specialized, knowledge about vehicle
technologies, their costs, incremental contributions and interactions, their availability
over time and across vehicle types, and the data-providers must determine the sequence
of technology application within each vehicle type. Ultimately, this dataset is likely to be
the most valuable and significant component of this model. Particularly if it becomes
publicly available, and serves as a standard. Thus the data issues should not be
minimized.
In all data input files, it would help minimize errors if units were specified. Kilograms or
grams, etc. The "Fuel" datasheet does not indicate the unit for price ($/gge, in nominal
$?. What are the units for electricity?)
The "Data Validation" capability and error report is a very useful feature. Ultimately the
modelers may wish to error check almost all inputs for acceptable range, if that is not
already done.
2a) The elements of the Market input file, Appendix 1, which characterize the vehicle
fleet;
This file describes vehicle sales by manufacturer and vehicle type, and provides the
attributes of those vehicle types.
No specific comments at this time.
2b) The elements of the Technology input file, in Appendix 2, that constrain the
application of technology;
Appendix D-6 Paul Leiby Review
-------
As discussed above, this could be said to be the heart of the model. It requires both
detailed technological knowledge and considerable judgment about the sequence, timing
and impact of each technology.
o It may be worth a special task just considering what range of technology attributes
can reasonably be specified, even by a technology or industry expert.
o The possible strong-sensitivity to data specification may also call for formal
method of risk or sensitivity analysis, given limits on the ability to refine the data.
How are technology interdependences across vehicle types represented? Given
outsourcing and the cost reductions from component sharing, would the application of a
technology for one vehicle type make it more likely to be applied to another vehicle type?
I could not discern how such considerations are represented in the data, and reflected in
the solution algorithm, if they are.
The data challenge is even greater if the stated goal of representing technological learning
is pursued. While ultimately technological progress (through autonomous gains from
R&D, scale economies and learning-by-doing) should probably be acknowledged in a
later model version, benchmarking that progress is never easy. Moreover, technological
learning and progress will be a function not of choices for each Vehicle Type (as the
spreadsheet organizations suggests), but of industry-wide developments across vehicle
types and manufacturers.
o In our models on new vehicle technology introduction, we have found it useful to
distinguish between 3 types of technological progress: autonomous progress over
time due to R&D; progress or cost reduction due to production scale (units
produced per plant); and progress from Learning By Doing (LED). All three of
these play a role, but the proper benchmarking of each is quite challenging. I
agree learning should be approached, but cautiously because its specification and
parameterization can have such a pronounced effect on model results.
Spot-checking these entries, I did not see any items associated with changing vehicle size
and weight. This may be a design choice rather than happenstance for the sample data:
technologies that substantially change the vehicle design and hedonic attributes for the
consumer would call for a more rigorous assessment of net-value to the consumer, and a
potential re-statement of objective (TARF sequencing rule).
2c) Scenario input file, definition of the standard and economic conditions (Appendix
3)
2d) The elements of the Fuels input file, Appendix 4
This list does not yet reflect biofuels or renewable fuels, which are a growing
consideration, in no small part due to recent law and EPA RFSs.
Some provision may be needed for the variable energy and GHG content of gasoline,
as the ethanol content varies over time.
Provision may also be needed for E85, and the uncertain fraction of E85 use by FFVs.
The net fuel economy and emissions by PHEVs remains an area of continued study.
EPA is well aware that fuel use by fuel type and resulting emissions depend on PHEV
design (AER), consumer use patterns, time of recharging, and the fuel used for
regional grid generation. Nonetheless, some simplified representation of the
Appendix D-7 Paul Leiby Review
-------
alternative PHEV designs will be needed soon. I was unable to ascertain what
progress EPA has made in this area.
2e) The reference data contained in Appendix 5. (Implied flexibilities and constraints
of the model)
No specific comments
3) The accuracy and appropriateness of the model's conceptual algorithms and equations
for technology application and calculation of compliance;
Equations for technology application:
o The sequence of technology application, and timing and extent of application, for
each vehicle type, is exogenous.
o Modelers acknowledge that "This approach puts some onus on the user to develop
a reasonable sequence of technologies." As noted, the onus may in fact be quite
substantial. Therefore, it is helpful that the model "produces information which
helps the user determine when a particular technology or bundle of technologies
might be 'out of order.'" [p. 7] Any such capability to assist the user with stage-1
exogenous technology sequencing for individual vehicle types is worthy of further
development and greater prominence in the documentation and model.
o The Volpe model seems to currently offer more facility for specifying the
structured sequences introduction of technologies or groups of technologies. The
EPA GHG Modelers may also wish to develop some tools that make it easier for
users to group and sequence technologies, perhaps even with logical diagrams that
map to or from the Technology.xls dataset. This would help experts represent
their best judgement about technologies can or would be applied.
o While this model allows for substantial technological detail, there will always
arise further, potentially important, complexities. In this review I could not
determined the degree to which the model can account for cross-vehicle-type, or
cross-manufacturer, interactions in the selection and sequencing of technologies.
For example, various forms of hybridization are mentioned as technology options.
We already see that one manufacturer, Toyota, develops a hybridization
technology for one vehicle it quickly spread to other vehicles from that
manufacturer, and that same technology is also sourced to other manufacturers
(Nissan). Can this be represented in some way?
o P. 17 says: "Finally, the model determines the order in which technology
packages are added to vehicles. The model first compares the TARFs
corresponding to technology package 1 on all of the different vehicle types in the
fleet and chooses the combination with the lowest TARF."
What does "combination" mean here? I understand it to mean the model
chooses a combination (pair) of particular vehicle v and technology step t
(advancing from t-l to t).
o Technical points on the TARF-based rules for technology application (Equations
p. 14):
As mentioned, net cost ("EffCost") alone would not seem to be adequate
for sequencing GHG-reduction technologies
Appendix D-8 Paul Leiby Review
-------
The inclusion of a FEE for non-compliance has some issues (admittedly,
the Volpe Model does something like this as well, but the justification is
not compelling):
It embeds the cost of non-compliance in an algorithm that ends
only with compliance. Hence the fee should ultimately be zero. Is
the intent here to employ some sort of penalty-function based
algorithm for constrained optimization?
"Non-compliance" is a manufacturer-wide condition, and cannot
be associated with a specific individual vehicle or technology
(Note: I believe the TARF measures should be subscripted with
m,v, and t, to highlight that they are specific at that level).
As written, the FEE is applied to the change in fuel economy
(mi/gge, MPG) for that particular technology step. This is not a
measure of non-compliance, and its essential effect is to exaggerate
the relative importance of fuel savings. Note that the fuel-savings
term is proportional to (FCt-i - FCt) while the Fee term is
proportional to (l/FCt - l/FCt-i), essentially a monotonic non-
linear transformation of fuel-savings. So even though there will be
compliance an no fee, the effect will be to boost the weighting of
fuel savings in a non-linear way.
A maintained assumption is that fuel economy technology will not alter
sales volume or share. But does or could vehicle sales volume influence
the choice of technology introduction? I only noted "Sales" being
referenced in the post-processing calculations, and it is used in the tests for
compliance. But sales is not a consideration in the TARF for a vehicle-
technology pair, nor in the terms leading up to it, so the technology
sequencing is based entirely on per-vehicle cost analysis. This approach is
taken in other models and is not unreasonable. But if technology learning
or scale economies matter, for example, the choice of which vehicle to
apply the next technology to could be related to the sales volume of
particular vehicle-types.
As mentioned, the non-standard adjustment of VMT discounting in the
denominator of the CostEff TARF should either be eliminated or more
explicitly and rigorously motivated. As it stands it seems to either mix
social benefits of GHG reduction with the manufacturer's objective of
meeting the emission standard.
o On p. 13, the equation for Fuel Savings (FS) seems to be in error. Fuel price (FP)
is divided by /', which denotes the age of the vehicle (year after its production). Is
this simply a typographical error and a discount factor was intended (e.g.
(1+DR)1?)
In all cases where the lifetime value of fuel savings in considered, the
challenge is to be clear about whose valuation of fuel savings is being
calculated. It is widely observed that consumers, when making new
vehicle purchase, may "undervalue" fuel savings either with a higher
discount rate or a short planning period than actual vehicle operating life.
I understand that these issues are probably behind the formulation used
Appendix D-9 Paul Leiby Review
-------
here, but it would help to be more explicit. If manufacturer decisions are
being modeled, the relevant question seems to be "How many years of
discounted fuel savings would the manufacturer assume it will be able to
recover from the consumer through the vehicle sale price?"
Calculation of compliance to Attribute-based standards:
o An overarching feature of the methodology is that progress in reducing
GHGs/fuel-use occurs by advancing drivetrain technology and other attributes
largely transparent to the consumer. Technologies are sequenced based per-
vehicle figures of merit, assuming no impact on vehicle designs (apart from fuel
use technology) and constant vehicle sales shares. One issue to consider is
whether these assumptions of unchanged vehicle and unchanged sales mix
become less defensible for attribute standards like the footprint standard.
o On page 7, equation for the logistic-based footprint, there appears to be a sign
error in the denominator (should be l+exp((x-C)/D) not l-exp((x-C)/D)). This is
likely a typo in the documentation alone.
Calculation of compliance to possible market-based standards
o No discussion or provision for market-based (permit trading) standards is yet
made. This should at least be acknowledged.
o One strategy for doing more flexible standards would be to simply merge the
datasets and technology-sequence stage for all manufacturers and vehicle types in
a trading group. However, this would not provide information about potential
permit prices and burdens across manufacturers.
4) The congruence between the conceptual methodologies and the program execution
(examining the results with good engineering judgment)
This is difficult to assess and a careful validation of this model's execution would require
further examination. The results appear generally reasonable, but that is a weak test.
I was only able to experiment with cases for one design cycle. The longer-term cases
involving multiple design cycles are more challenging. It has been noted the model
solves for design cycles independently of one another. So it would be worthwhile to test
what this implies for the sequence of technologies used from one cycle to the next.
One observation is that the inclusion of the non-compliance FEE does affect the model
solution and choice of technologies. As mentioned above, the theoretical justification for
this is not well formed, given that all manufacturers are typically assumed to end in
compliance. However, I did not that the impact of including the FEE is modest, only
changing per-vehicle costs by a few dollars. However, for at least one manufacturer (#9)
the cost and technology sequence changes significantly. I am not sure this is a desirable
outcome.
Also, simple tests with the sample dataset show a relative insensitivity to the choice of
TARF. This was surprising, and needs more investigation.
5) Clarity, completeness and accuracy of the calculations in the Benefits Calculations output
file, in which costs and benefits are calculated;
This system produces a large number of useful side calculations.
Again, further investigation is necessary to investigate their accuracy.
Appendix D-10 Paul Leiby Review
-------
Overall, a careful independent validation of the two phases of this model's execution
(manufacturer compliance simulation and effects calculation) would be well worthwhile.
The code for compliance simulation is compiled and not visible. Working through the
logic in the post-processing calculations of the BenefitsCalculation spreadsheet would
take a bit of time. But it would be worthwhile. Overall a useful validation effort could
probably be complete in about a week of focused attention.
6) Clarity, completeness, and accuracy of the model's visualization output, in which the
technology application is displayed; and
The XML format for data transfer and display is a very good design choice, allowing
flexibility, modern data-exchange capability, ready output to internet, and easy extension
of the report.
This display in the visualization output is useful overall, but it seems more oriented
toward "expert users" who are willing to wade through details to find understanding and
the information they need.
o TechPack are reference by number only, but perhaps could easily be labeled with
the full name or 4-character abbreviation, or cross-reference by hyperlink to a
description of the technology.
o Additionally, hyperlinks could be added that would allow the user to easily jump
to the table for a particular manufacturer or vehicle type.
It would be very helpful to have some graphical summaries of the input and output
results.
All output files should embed clear documentation on the inputs used. E.g.
o The .log file does list names of the 4 input files, which is essential.
o The "Visualization Output" file does not (yet) report the input files (but the
information could be retrieve from the XML file).
7) Recommendations for any functionalities beyond what we have described as "future
work."
Clearly defined improvements that can be readily made based on data or literature reasonably
available to EPA
o First I note that there were multiple references to "future work." It may be helpful for
EPA to construct a list of these prospective improvements, and establish priorities and
a staged, progressive approach for revision. Specific releases of the model with
carefully specified functionality will allow prospective users at EPA and elsewhere be
clear about what the model is and can do at any point in time.
o While the model has a number of valuable aids to execution and reporting (input
validation, automated generation of run logs, XML data, and "Visualization" tables
for web/browser display), more could be done here to improve usability and provide
greater insight about each case run. Comparatively simple revisions and extensions
to the operational procedures and output could be well worthwhile.
Provision for side-by-side case comparisons, reporting or graphing difference.
Case management and logging facilities.
Appendix D-11 Paul Leiby Review
-------
Currently the system labels every file with generic name concatenated
to a time-date stamp. Very quickly a directory can be cluttered with
cryptically named log, xml, htm files.
A case archiving facility, that compresses all input and output files to
document the case, might be useful
The ability to specify a CaseName in the Scenario file, that then
becomes part of each output file, would also be helpful.
When the VGHG.exe file reads a scenario file, it does not record, or at
least display, the name of the file read. It is easy to forget which case
was read if you step away, or are doing many cases.
Relatedly, the purpose of the VGHG.exe's separate menu options is
not yet clear to me.
o It seems that once a scenario and the associated datafiles are
read, execution would be the logical next step. The scrollable
tables from data input are really too constrained a view to
allow useful review or verification of the data.
o Once the case is run, it seems "Save" to XML might be
automatic, otherwise one is limited to the text-based log files,
that omit summary information. "Saving" seems needed for
Visualization and Benefits Calculation in the spreadsheet.
o So perhaps VGHG.exe might load-run-save in one step,
although I may be missing something important.
Graphical capabilities [more thought required here about exactly what graphs
would be most useful. But there are many data in the tables, and they are not
simple to process mentally.]
Improvements that are more exploratory.
o Extension to accommodate flexible/market-based emission or fuel-economy
regulations.
Permit trading extensions, constructed by pooling selected vehicle
types/classes, and/or manufacturers, during the compliance phase of the
analysis.
Ex post calculation of implied permit prices based on marginal costs of
compliance (measured by the cost/GHG reduction of the final technology
pack applied).
Ex post calculation of economic implications for individual manufacturers, by
comparing results with and without trading/pooling, and accounting for the
implied costs and revenues from permit exchanges between manufacturers.
o Extensions to consider endogenous (standards-induced) changes in vehicle attributes.
These are a higher challenge, but would be very valuable for an improved
understanding of the market responses to regulations.
Endogenous changes in sales volume/mix
Endogenous changes in vehicle size/footprint
Appendix D-12 Paul Leiby Review
-------
Appendix D-13 Paul Leiby Review
-------
APPENDIX E
JONATHAN RUBIN'S REVIEW DOCUMENT
-------
Review:
Vehicle Greenhouse Gas Emission (VGHG) Emissions Cost and Compliance Model
Jonathan Rubin
23 September 2009
Dear Sir/Madam:
I would like to congratulate the EPA for undertaking to build this tool which will be very useful
for possible regulatory compliance and anticipated and unanticipated policy analyses. The
construction of such a tool requires extensive expertise, professional judgment, necessary
compromises and assumptions. The validity of the output will of course depend on these factors
as well as the data available to populate the model.
My comments are based on my review of the materials provided to me by Southwest Research
Institute: the EPA vehicle GHG Emission Cost and Compliance Model Description and
associated attachments and appendices and the VGHG model and the associated spreadsheets.
These comments reflect my understanding of EPA's possible use for this model for regulatory
compliance as well as use by external researchers and policy analysts who may use the model for
analyses of state and regional policies.
My comments below respond to the particular questions posed in the transmittal letter from
Southwest Research Institute.
Overall Approach to the specified modeling purpose and the particular methodologies
chosen to achieve that purpose
The authors have clearly put in a great deal of work on this challenging project and should be
commended for an excellent start. That said, more effort and thought needs to go into what I call
the accounting stance. On page 2, line 42-43 (p. 2,1. 42-3) the documentation states that "The
primary cost of the GHG emission control is the cost of the added technology compared to the
baseline." My question is: "cost to whom?" Costs to consumers will differ from costs to society
or costs to manufacturers. At times, the documentation reads as though these are costs to
manufacturers - since CAFE fines are considered; other times the costs seem to be towards
consumers or society. These accounting stances will differ for several reasons: 1) private and
social discount rates differ, 2) social and private risk differs (on average technology performs as
well as expected, but not for each vehicle), 3) subsidies to purchase plug-in vehicles or other
advanced technology vehicles drive a wedge between private and social costs, 4) subsidies to
biofuels and electricity at the state level (exemption for some or all road-use tax) mean that
consumer costs are not equal to full resource costs. Clarifying the accounting stance is a high
priority, because many further calculations rely on its clear definition.
Since the potentially regulated agents are vehicle manufacturers, my recommendation is to
define costs as the costs to manufacturers of incremental technology and vehicle re-design costs.
The net costs to manufacturers are equivalent to the incremental costs of fuel economy
-------
technology less any increase in retail prices that manufacturers can charge for more fuel efficient
vehicles. This should be equal to some portion of the expected fuel savings plus any changes in
the hedonic value of vehicles due to changes in vehicle performance, noise, size, and refueling
time (more on this later). By separating out manufacturing costs more clearly from consumer
valuation of vehicles, the presentation will be more transparent. This also will make clearer the
distinctions between consumers' rates of discount from manufacturers' costs of capital from
society's rate of time preference.
Additionally, I recommend that the net costs clearly incorporate and identify all subsidies (for
electric or plug-in hybrid vehicles and alternative fuels) but display costs and benefits separately
to private agents (manufacturers, consumers) and society. These will generally not be the same.
For example, the benefit calculation spreadsheet "Externalities" adds together consumer money
saved on fuel with savings from lower oil imports. I would be very surprised to learn that the
assumptions of the discount rate or risk premium or both in the calculation of benefits of reduced
crude oil imports are the same as consumers' discount rates for expected future gasoline savings.
2) The appropriateness and completeness of the contents of the sample input files.
a) The elements of the Market input file, as shown in Appendix 1 of the model description,
which characterize the vehicle fleet
If the data are available, it would be useful to have the cross-price elasticities for makes and
models or model segments such that mix-shift impacts could be taken into account as vehicle
prices rise in response to additional technology packages.
Some of the market data are interesting, but do not seem necessary. For example, what is the use
of knowing a vehicle's structure (e.g., unibody) or the maximum seating capacity?
Does the market spreadsheet contain data for mid-size trucks, gross vehicle weight 8,500 -
10,000? If not, I would think it should, given that they are now covered under the revised light
truck CAFE rules.
b) The elements of the Technology input file, in Appendix 2, that constrain the application
of technology
Are the incremental costs shown in column X retail or wholesale? What do they assume about
the volume of production? If I read the file correctly the incremental price for plug-in hybrid
technology often has a low first cycle cap of 5%. Is the incremental cost of this technology
consistent with its use on 5% of a market segment of a given manufacturer? It is important to
clearly define the relationship between scale of use and incremental technology cost. The
columns "a", "Decay", "seedV", "kD", and "cycle learning available" need further clarification.
P. 2,1. 14 notes that the GHG target can be set as a function of vehicle footprint. The technology
input file does not show an indication of how down-weighting and changes in footprints may be
-------
used to meet a set of given standards. This may not be able to be accomplished immediately
given available data, but it should be considered as more experience with the footprint standards
is gained from CAFE compliance.
c) The definition of the standard and economic conditions in the Scenario input file, as
shown in Appendix 3
As per my earlier comments, I think there ought to be a place for 3 different discount rates:
consumers, manufacturers and society. Similarly, their ought to be a places for payback periods
for consumers and society.
d) The elements of the Fuels input file, as shown in Appendix 4, which characterize the fuel
types, properties, and prices
It would be useful to reference the data sources for many/most of the data items. For example,
energy density - please see EIA report XYZ. The value shown for gasoline, for example, at
115,000 is different than that published by the USDOE, Transportation Energy Data Book v 27
(Davis, Diegel, Boundy, 2008, Table B4), which shows a (lower heating) value of 115,400
Btu/gallon.
The units should also be displayed for all inputs. Again, using the gasoline example, being
familiar with the data, it is clear that the unit of analysis is Btu/gallon (lower heating value). For
other data, the units are less obvious. For electricity, the input file or the documentation, or both,
should give the assumed conversions from kilowatts to energy density or motive energy such that
users can adjust for different end-use efficiencies. Also for electricity, the assumed grid mix
should be given with conversion rates such that users can make appropriate adjustments for
different policy analyses.
I do not see a statement indicating whether the fuel price data is in nominal or real dollars.
I do not see a row for ethanol giving its energy density, mass, and density. I am assuming that
fuel type "EL" is electricity. Also, should you not have at least two types of ethanol - corn and
cellulosic - with different price paths?
As I indicated in my earlier comments, I think it is important to explicitly note the role of
subsidies when determining costs. Given this assertion, the fuels data file ought to explicitly note
federal and state average subsidies (i.e., the federal blender's tax credit and foregone state excise
taxes) for ethanol and other alternative fuels. As I note below in 7) Extended Functionality,
accounting for foregone taxes is a logical addition to the model, especially when considering
plug-in electric hybrid vehicles.
e) The reference data contained in Appendix 5 which are currently hard-coded into the
model but, in the very near future, will be contained in a user controlled input file
The Exclusive Inputs spreadsheet anticipates E10 and E85. It would seem fairly straightforward
to allow for other blends such as El 5. The proportion of the ethanol that comes from cellulosic
-------
sources in each year should be accounted for such that upstream CC>2 emissions can be properly
credited, similarly for petrodiesel and biodiesel.
3) The accuracy and appropriateness of the model's conceptual algorithms and equations
for technology application and calculation of compliance;
On p. 9,1. 40, the documentation states: "The core model then adds the effectivenesses and the
costs of the technology addition until each manufacturer has met the standard or until all
technology packages have been exhausted." Given that existing law allows credit averaging
across all vehicles sold by a manufacturer, this requires that compliance would be checked
through an iterative routine. Please describe this routine including mechanisms to prevent
cycling so that convergence is assured.
p. 10. VMT is given by: ^r = SurvivalFraction * AnnualMilesDriven j believe this is this
done by vehicle class (from the data file). The documentation should index the function with
separate subscripts.
p. 10. Discounted VMT. I have two issues with this calculation. The first is mechanical. Why
1 +
VMTDFS,=VMT,x
\ + L>K) c[oes the numerator have the term l+DR/2? Is the discount rate not
understood to be the simple annual rate? (Also what do the indices D and FS represent?).
Conceptually, however, I do not think this VMT should be discounted. Costs and benefits are
appropriately discounted, but I think it is a mistake to discount a physical calculation. It blurs the
distinction between consumer and society valuation of VMT and can lead to misleading outputs.
This point is further emphasized by calculation of VMT for GHG calculations (p.l 1)
DR-IR
1 +
VMTDC02j=VMT^
(i + L>K IK) ^ where VMT is enhanced by the rate in change in the value of
CC>2, IR. I strongly suggest that this equation be re-done to separate out measurement of
physical units (VMT) from cost and value calculations.
p. 11.RCO2
Lifetime
( years)
2]RefLeakage,xGWP
i -\ '=1
g I mi) =
Lifetime
(years))
Lifetime
(years)
z
LeaL
Lifetime
(years)
z
1=1
DR-IR 1
9
Rifr -'
(I + DR- IR)'
\ HDR-IR
VA-fT ^ ^
xGWP
* mi -A
(i + DR - IR)'
LifetimeLeakage x GWP
LifetimeVMT
I have two comments. First, it seems to me that, as with VMT, the numerator ought to be
multiplied by the survival function. Second, as with VMT, the leakage rate ought not to be
-------
adjusted by DR and IR. Also, again, I do not understand the form of the adjustment - why
multiply the numerator by 1+ (DR-IR)/2? Should not the GWP be indexed by i?
p. 12. Determine the order of Technology Application. On the previous page the subscript /
represented "year" here it represents technology package. The use of subscripts should be unique
throughout the documents.
P. 12. Intermediate calculations for each vehicle type. It appears that the subscripts have changed
again. CO2 is indexed by t and AIE, RIE are missing subscripts altogether.
p. 13. Calculate the fuel consumption before and after technology additions.
C02,_,
CD,_, x
& -I . Given that CD is in units of carbon, this equation looks unit-less
(CO2/CO2). Where do gallons per mile units come in?
P. 13, 1. 18. In step iii, calculating fuel savings we see the following equation.
PP PP A PP
pp PP pp
x i x - FC xV +FC xV
x / -i- r(^7 x 7 -re., x 7 -i-.ru, x /
^ _ _ _
,=1 t ,=l l )t-l V i=l t i=1 7
t
First, why is FP divided by /'? Second, where is the adjustment for vehicle age? How does this
equation account for consumers' choosing to drive more miles using one fuel v. another?
(Consumer's may want to maximize the time they spend in electric power mode.) Even if the
data do not exist to parameterize the model yet, I suggest that the functionality be built in to
allow for consumers' choosing to use one fuel type or another.
P. 20, 1. 38-46. In calculating the impact of the reduced time required to refuel vehicles, I do not
see a mention of the estimated driving that will occur using electricity in PHEVs.
4) The congruence between the conceptual methodologies and the program execution;
As suggested, I made changes to input values in the spreadsheets and re-ran the model. The
changes as displayed in the benefits calculation spreadsheet were what I had qualitatively
expected.
5) Clarity, completeness and accuracy of the calculations in the Benefits Calculations
output file, in which costs and benefits are calculated;
Please see my comments in the beginning of the document. I believe that the benefits
calculations should more clearly reflect benefits and costs to three different agents:
manufacturers, consumers and the nation.
Recognizing that the benefits data (Benefits Calculation workbook) is subject to change, it would
be really useful to list the data sources for all inputs. For example, if the VMT data is coming
-------
from MOBILE6, the VMT_Lookup spreadsheet should clearly state MOBILE6 as its source and
similarly for the other inputs and spreadsheets.
Similar to the formula used to discount VMT, the spreadsheet "ExternalVMTCosts($)" discounts
r\
externalities using the formula: -; - ^-- . My question is why? Most commonly used discount
factors are simple -, - r- annual rates. In some senses it does not really matter because the
(l + DRj
user can set the discount rate, but by using a non-standard discount rate this is likely to lead to
unnecessary confusion.
In the "Benefits Calculation" workbook, the worksheet, "Emissions_Fuel Conservation" shows
upstream savings from NOx, VOC, CO, PM, and SOx. These emissions savings are all
calculated based on upstream conventional gasoline emission savings. I would think that either:
1) these should be based on a weighted average of gasoline, diesel, ethanol, and electricity
upstream emissions, or 2) the gallons saved should have been weighted gallons. I cannot readily
determine if the saved gasoline gallons are weighed by the proportion of gasoline, electricity,
ethanol and diesel (and the weights would be emission-gallon weights.) This needs to be clarified
or corrected.
In the "Benefits Calculation" workbook, the worksheet, "ExternalVMTcosts($)" displays the
discount factor applied to future costs as the common discount factor used throughout the model.
As I earlier suggest, society's rate of discount for accidents costs (human life) are not likely to be
the same as consumers' rate of discounting future gasoline savings. These should be separate
inputs.
In the "Benefits Calculation" workbook, the worksheet, "DownstreamCosts($)", the units on
CO2 are shown as "$/ton". I believe that the label is missing the modifier, "metric".
In the "Benefits Calculation" workbook, the worksheet, "UpstreamCosts($)" shows benefits
determined for CO, VOC, NOx, SO2, PM2.5 all based on emission factors for conventional
gasoline. As per my earlier comment, I think these ought to use separate emission factors for
each fuel.
In the "Benefits Calculation" workbook, the worksheet, "All Costs" shows costs in aggregate for
the nation. It would be useful to also display the average, per vehicle costs.
6) Clarity, completeness, and accuracy of the model's visualization output, in which the
technology application is displayed; and
In displaying the results Average Incremental Costs, please round to the nearest dollar; showing
two digits to the right of the decimal point gives a false sense of precision and makes the output
harder to read.
-------
7) Recommendations for any functionalities beyond what we have described as "future
work."
The model (VGHG) window box should be made larger - perhaps fill the screen. It is really too
small to perform step 4 in running the model (i.e., Verify that the correct data has been populated
into the VGHG model). There is also no side-to-side scroll to see the whole data field.
Given the renewable and advanced biofuel requirement in the Energy Independence and Security
Act of 2007, it would seem that the model ought to have data input fields to allow users to
specify the quantities (or proportions of total fuel) of ethanol and biodiesel used in each year.
Moreover, the proportion of biofuels which come from cellulosic sources should also be able to
be specified. Accordingly, the GHG emission accounting framework will need to capture that
proportion of the reductions due to changes in vehicles and that proportion due to changes in
fuels. In anticipation of future developments in the biofuels market, it may be worthwhile to
build in placeholder functionality to account for domestic versus imported biofuels or biofuel
feedstocks.
The model would be significantly enhanced if it were made probabilistic. Given that input data
contains underlying uncertainty (What is the actual cost of a given technology? What will be the
price of gasoline in 5 years?), the model should be made to run hundreds or thousands of times
using Monte Carlo analysis on some of the key input data to generate a distribution of outcomes.
Even if this is not done in the near term, having the output columns show results for "high and
low" cost/interest rate scenarios would be convenient. It would save having to run the model
multiple times and pulling the results in to some other summary worksheet.
The documentation notes (p. 2) that the primary cost of the GHG emission control is the cost of
the added technology as compared to the baseline. I do not think this is a valid presumption for
large changes in GHG emission control. The NRC's study on CAFE assumed that vehicles were
hedonically equivalent. Given the likely wide-spread adoption of diesel technology and, quite
possibly, plug-in hybrid vehicles (PHEVs), vehicle driving experiences are not likely to be the
same. Quite possibly, PHEVs will provide a superior level of driving satisfaction. If vehicle
manufacturers downsize or reduce performance (acceleration) to meet compliance, vehicle
satisfaction could diminish. I do not have a good suggestion on how to adjust for these possible
hedonic costs or benefits. Perhaps the model could incorporate placeholder equations that would
allow users to specify hedonic gains and losses. Nonetheless, the model documentation should be
forthright in acknowledging this limitation.
The model should provide for an estimate of the likely gasoline excise tax implications for
different levels of GHG emission reduction. Particularly useful would be to present this
information in the context of different compliance strategies. For example, with tax credits for
PHEVs, and no change in federal gasoline excise tax policy, the revenue losses could be
significant. This functionality could be very useful for policymakers.
As described in the documentation, the model development foresees an increased ability for
users to change input assumptions. Changes to these assumptions may have significant impacts
on costs and GHG emission reductions. It would be useful for the Model Reference Guide
-------
accompanying this model to describe in qualitative terms the impact of or assumptions behind
choosing to adjust certain parameters. For example, the user manual could indicate that lowering
the years of payback for technology would be consistent with a view that consumers only value
the first years of fuel economy gains or place little or no value on GHG emission reduction that
occur near the end of a vehicle's lifetime. If practicable, it would also be useful to point out
inconsistent choices.
It would be very useful to have the model output be available in units that are used
internationally - grams CC>2 /kilometer or grams CC>2 equivalent/KM.
Clearly falling into the work for the future, would be to have a time profile of upstream CC>2
emissions for conventional gasoline and diesel reflecting regional or national low carbon fuel
standards.
-------
EPA Responses to Peer Review Comments
A. Comments by John German
Concepts and Methodologies Upon Which the Model Relies:
(A) Model structure
The model is an accounting model. This is neither good nor bad. The advantage is that it avoids
overmodeling and embedding errors in the model itself. The disadvantage is that the factors
affecting the results are all inputs to the model. This requires a great deal more sophistication
and work by anyone using the model to prepare the inputs properly. It will also make it more
difficult for anyone outside EPA to use the model, unless EPA is willing to provide the detailed
inputs to other users.
With this type of model, it is essential that EPA release the data in the Technology and
Economics input files and discuss them in the Notice of Proposed Rulemaking, as the real
analyses and modeling are in these input files. But as long as this is done, the overall model
construction is fine.
Response: EPA will publish all the input files in their entirety as part of its proposed GHG
emission rule for model year 2012-2016 cars and light trucks (hereafter referred to as the "EPA
vehicle GHG proposal" or "proposed vehicle GHG standards").
(C) Redesign cycles
I completely agree with EPA's logic in creating a model based upon vehicle redesign cycles. As
EPA states, adding technologies incrementally to each vehicle model by model year does not add
value to the model results. Using redesign cycles also allows for simplification of the fleet. It is
impossible to predict the direction of vehicle redesigns for each manufacturer. It is just as
accurate to assume, for example, that future mid-size cars from each manufacturer will be
identical; as it is to assume that current differences in mid-size cars from one manufacturer to the
next will be continued into the future. As a recent example, Honda left their compact crossover,
the CR-V, virtually unchanged in size during the latest redesign. However, Toyota chose to
lengthen their compact crossover, the RAV4, by 14" during its latest redesign. It is pointless to
try to predict differences in vehicles from different manufacturers in the future and it is pointless
to try to predict the exact year when redesigns will occur. This is a welcome simplification.
Another advantage of using redesign cycles is that GHG standards for interim model years can
only be set, reasonably, as a straight line (or a constant % decrease) between the baseline year
and the end of the redesign cycle. This is appropriate. Constant yearly % reductions provide a
consistent signal to manufacturers for investment decisions.
However, there is one potential problem with using redesign cycles. It masks the investment
needed to bring new technology to the market. The auto industry is extremely capitol intensive.
Initial investment in a new technology is expensive, both for tooling and the resources necessary
-------
to assess (and fix) system-level effects and effects on reliability, durability, safety, and
manufacturing. Redesign cycles tend to assess only the costs for high-volume production and
skip over the high initial costs. Care must be taken to properly assess costs in the inputs.
Response: EPA agrees that capital investment is an important consideration when assessing the
feasibility of GHG standards. EPA intended to include explicit accounting for and limitations in
capital investment when developing OMEGA. However, this proved to be a difficult task and
we decided to leave this until later versions of the model. The user can track capital investment
outside of the model based on the types and levels of technology used. The user can also adjust
costs upward during the interim years of a redesign cycle to represent the higher costs which are
typical during technology introduction. EPA did this as part of its cost analysis for its recently
proposed rule for the control of GHG emissions from cars and light trucks.
(C) Leadtime
The model handles leadtime issues far too simplistically. This was also a problem with the
Volpe model. Leadtime is one of the most important issues in setting standards and one of the
most difficult issues to assess properly. Thus, it is disappointing to see both NHTSA and EPA
provide so little attention to the issue.
The only leadtime constraints in the draft model are industry-wide caps on the maximum
technology penetration by redesign cycle and vehicle type. There are several problems with this
approach:
The largest problem is that it is inappropriate to treat all manufacturers the same. A
manufacturer that has already invested in a particular technology in the baseline year will be
capable of higher penetration rates than a manufacture that has never used the technology
before - and also of producing the technology at lower cost. An obvious example is hybrid
vehicles. Over 10% of Toyota's vehicles already have hybrid systems on them. After
introduction of the CR-Z next year, Honda should also have more than 10% hybrids. Due to
their experience and head start with hybrids, both manufacturers will be capable of much
higher penetration rates than most other manufacturers. They are also further along the
learning curve, so their costs will be lower. Similar situations exist with most technologies.
Another problem is that costs will vary from manufacturer to manufacturer. As noted in my
comments on redesign cycles, above, there are large upfront costs when a manufacturer
introduces a new technology. For example, Toyota has already amortized large R&D and
system-level costs for hybrid vehicles. They will be able to produce hybrids cheaper than
manufacturers that are just starting to offer hybrids. The point is that the "Initial Incremental
Cost" in the Technology Input File should not be applied to all manufacturers at the same
time, but rather to each manufacturer at the time they first introduce a new technology.
The third problem is that there is no such thing as a hard cap on technology penetration rates.
There is a tradeoff that exists between cost and leadtime. Technology introduction can be
accelerated by increasing investment - and cost and risk.
Long-Term Recommendation - The best way to handle leadtime constraints and technology
penetration is to assess capitol investments by manufacturer. This would require adding a new
section on capitol expenditures. In addition to assessing the cost of each technology, the capitol
-------
expenditure would also be assessed. Ideally, there would be two components to the capitol
expenditure assessment for each technology, one for R&D expenditures for the first
implementation of the technology and one for the capitol investment needed to add the
technology to additional models. However, the second is more important. Each manufacturer
would be assigned a total capitol expenditure budget for the redesign cycle and technologies
could only be added up to the point where the sum of the technology capitol expenditures did not
exceed the manufacturer cap. Alternatively, some increase in technology penetration over the
cap could be allowed, but only if coupled with increasing technology costs. This would
appropriately handle leadtime constraints and technology penetration rates.
Short-Term Recommendation - The long-term recommendation would require a lot of new work
and is clearly not feasible in the timeframe needed for EPA's rulemaking. As a short-term fix,
instead of using industry-wide caps on maximum penetration for each technology, EPA should:
(d) Set caps on the maximum increase permitted per year. This would be applied to each
manufacturers' individual technology penetration; and
(e) Establish the model year for initial introduction. For technology that has not been
introduced to the market yet, this year could be the same for all manufacturers. For a
technology that is already being used by a manufacturer, the baseline year would be used
for that manufacturer. However, if a manufacturer were not using a technology yet, even
if another manufacturer is using it, a year of introduction would need to be set for that
manufacturer.
(f) Some technologies would still need caps on maximum penetration. However, this should
reflect market restrictions, not leadtime constraints. This would incorporate consumer
values for particular technologies that go beyond just efficiency and performance. For
example, even though manual transmissions are more efficient than automatics, most
consumers will not give up the convenience of an automatic. PHEVs do not have much
benefit for people driving a lot of highway miles each day. Diesels are desired for trailer
towing and have advantages on highway fuel economy, while hybrids have advantages in
stop-and-go driving. These types of market considerations can be handled by
establishing maximum penetration caps, but they should be handled separately from how
leadtime is handled by manufacturer.
Note that the yearly cap and introduction date violates the design cycle principal, but it is
important to create the proper cap for each manufacturer and technology combination. Instead of
using a model year for (b), above, the user could specify how many years into the design cycle a
technology could be introduced.
Response: EPA agrees that the consideration of leadtime constraint is important. The current
model was designed with the implicit assumption that the first year of the first redesign cycle
being modeled was sufficiently in the future so that a manufacturer could completely alter the
design of vehicles being redesigned in that year. For example, in EPA's vehicle GHG proposal,
the first year of the redesign cycle was the 2012 model year. The start of this model year is
approximately two years from the publication of the proposal and the final rule is not expected to
be promulgated until sometime in 2010. Therefore, leadtime for the 2012 model year is quite
short. Therefore, EPA adjusted the technologies caps for all technologies which might be
restricted to years when a vehicle was being refreshed or redesigned to 85% or less, rather than
-------
the more typical 100%. This figure is based on an estimate of the percentage of vehicles which
can be equipped with these technology packages from 2012-2016, though not in a linear fashion.
Due to leadtime constraints, a lower percentage of vehicles was projected to be convertible in the
early years than the later years of the program (i.e., redesign cycle). This is indicative of how the
model inputs can be set in order to approximate leadtime constraints.
We also agree with Mr. German that leadtime is not a hard and fast concept and can be a
function of cost (i.e., a manufacturer can shorten the required leadtime involved in making a
technological change if it is willing to increase costs, though in the very near term there are real-
world lead time constraints such as the time needed for construction of new manufacturering
facilities or capital tooling upgrades). At this same time, coupling cost and technology
penetration would be challenging to simulate in a model such as OMEGA in a way which
addresses all the possible factors involved. Mr. German does not point out studies which
estimate the degree to which costs might increase in return for shortening leadtime. However, if
such relationships can be found, it may be possible to include such flexibility in the model when
EPA adds the effect of learning into the cost estimations. At the present time, the model can be
run with a series of scenarios, each of which contains varying levels of technology penetration
and varying costs. The user can evaluate the results of these runs and determine which level of
cost and leadtime is most appropriate.
We agree with Mr. German that manufacturers which have already implemented technologies
such as hybridization have an advantage over those which haven't. It is probable that such
manufacturers could hybridize a greater percentage of their fleet than other manufacturers.
However, on a practical level, this advantage may not be that important to include in OMEGA at
this time. Manufacturers which have already implemented technologies, especially major ones
like hybridization, are generally in a better position to meet GHG standards than those which
have not implemented such technologies. Thus, there would not be any practical change in the
model's results if we allowed Toyota and Honda to have a greater hybrid penetration than
applicable to other manufacturers, since these manufacturers do not require a greater hybrid
penetration in order to meet the GHG standard. While true for hybrids, this relationship may not
always hold true. We will consider moving the technology caps to the level of the manufacturer,
or even the individual vehicle as we continue to develop OMEGA in the future.
If the user believed this factor was important and should be reflected in the model results, the
user could simply group manufacturers by their estimated technology caps and perform one
model run for each set of technology caps and then combine the results. To use Mr. German's
example, vehicles produced by Toyota and Honda could be modeled in one run with high hybrid
penetration caps and those of other manufacturers modeled separately with a lower technology
cap.
This issue applies primarily to technologies which require sophisticating application at the
vehicle or manufacturer level. Hybridization is probably the best example of this due to the
complex integration of electric motor, battery and engine operation. However, there are many
other technologies which may actually be purchased pre-assembled from a supplier, such as
dual-clutch transmissions. Certainly having some experience with such technologies could
increase the speed at which a manufacturer might be able to convert most or all of its vehicles to
-------
the technology. However, much of the experience is also being gained by the supplier and
available to all manufacturers. The cost paid by each manufacturer may still be a function of
sales volume, but this can be reflecting through learning factors when appropriate. Thus, we
believe that this issue does not apply to most of the technologies which, for example, EPA
included in its modeling runs in support of the EPA vehicle GHG proposal.
Regarding the variation of costs across manufacturers, this again will be addressed in large part
when we incorporate learning into the cost estimation processes of the model. Currently, this
can and has been done outside of the model.
EPA initially intended to incorporate capital costs into the core model of technology application
as it began development of OMEGA. However, this proved difficult for several reasons. One,
the number of units over which the capital investment should be amortized is not easy to
determine. The model currently applies technology to either individual vehicles which could
represent anywhere from individual vehicle models to vehicle platforms or all of a
manufacturer's cars, for instance. Should the OMEGA model assume that only the sales of the
vehicle being evaluated bear the burden of the investment or all the manufacturer's sales?
Should sales over one or more than one redesign cycle be considered? Some technologies, as
mentioned above, will be manufactured by suppliers. In this case, the capital cost will be borne
by more than one vehicle manufacturer and so should be amortized over the sales of more than
one vehicle manufacturer.
Our initial plan to incorporate capital cost and learning was to base technology ranking (and thus
technology application) on the assumption that all the sales in a particular redesign cycle
received the technology. Then, once the run was completed, the model would recalculate costs
based on the actual application of the technology. This approach recognizes that no technology
would be introduced if it was only going to be applied to a single vehicle. Costs for new
technologies are always high early on, but manufacturers often do not fully recover their costs
until the technology spreads to more vehicles. We will consider this approach, as well as others
as we continue to develop OMEGA in the future. At the present time, the required capital cost
associated with technology application can be assessed outside of the model. Should the results
indicate that the required capital investment is inappropriate in some way, the inputs to the model
can be modified to eliminate the issue.
(D) Technology Assessment
Requiring the user to input technology in rank order of cost-effectiveness is an interesting
attempt to handle the synergy issue. Unfortunately, it fails to work in other ways:
It only works if the learning rate is the same for all technologies and if no technology
changes effectiveness over time. If one technology has a steeper learning curve than another,
or if a technology increases benefits in the future, then the cost-effective order will change
over time. For example, high-tech diesels are a relatively mature technology, as over 5
million per year have been sold in Europe for several years. Their future cost reduction
potential is much less than that of hybrid vehicles, whose sales are at least an order of
magnitude lower and which are still at early stages of development. Also, the high power Li-
ion batteries just starting to penetrate the market will allow much smaller battery packs for
-------
conventional hybrids, with large cost reductions. In addition, analyses by MIT (2007)
suggest that hybrid benefits will increase in the future as manufacturers figure out how to use
the hybrid system to minimize operation at less efficient engine speed/load points.
The synergies will differ depending on the specific technologies into which an individual
manufacturer has already invested. For example, consider one manufacturer that has
invested in MPI turbos and a second that has invested in DI naturally aspirated engines. If
both manufacturers move to DI turbo engines, the first manufacturer will gain the benefits of
DI adjusted for the Dl/turbo synergies, while the 2nd manufacturer will gain the benefits of
turbocharging adjusted for the same Dl/turbo synergies. Thus, the synergy impact of
Dl/turbo must be assessed independently of each technology. Even if the model ignores the
leadtime constraints imposed by baseline technology investment and assumes every
manufacturer will adopt the exact same technology packages for a given vehicle type (not a
good idea, as discussed, above), a problem still exists in backing out "any advanced
technology that might have been present in the baseline" (page 12, line 3-4). In order to back
out the baseline technology for different vehicles and manufacturers, the technology input
file must contain independent assessments of MPI turbo, DI naturally aspirated, and DI turbo.
The DI turbo line includes the synergies, but the other two lines do not. How does the model
add them back in? If the turbo lines and DI lines occur before the DI turbo line, then the
technologies will be added together first without consideration of the synergy effect.
It does not allow for different markets for different technologies. For example, diesel
engines have additional value for (a) customers who tow and (b) customers in rural areas.
Towing is valued only by a small part of the market, but it is an important feature for that
market. Customers in rural areas do a lot of highway driving and value the high efficiency of
the diesel on the highway, while hybrids excel in urban areas. Thus, the markets for diesels
and hybrids will be self-selected to some extent by their relative city and highway mpg, not
the combined mpg used to select all technology.
In order to work properly, the model must be able to handle multiple pathways. For example, the
model cannot allow turbo and DI benefits to be added sequentially, but must force each to go to a
DI turbo input. A similar situation exists with the various variable valve timing systems and
VCM. All offer primarily pumping loss reductions and all options must be present in the input
file in order to back out technologies in the baseline. All these options cannot be added back by
the model one after the other - the model must also be able to handle these multiple pathways.
Another example is transmissions, where the input file must list 5-, 6-, 7-, and 8-speed
automatics, as well as DCTs and CVTs (even ignoring manual transmissions). I could go on.
The point is that I do not see how the model can avoid handling multiple technology pathways
and depend only on the input order to handle synergies.
The model must also be able to handle technologies with different rates of change in benefits and
costs in the future. This also requires that the model process the lines independently and not rely
on the input order.
The market considerations could perhaps be handled with maximum penetration caps. For
example, it could be considered that diesel engines will not compete well with hybrids in urban
areas, so that the maximum penetration of diesels would be equal to their sale in rural areas plus
trucks designed to tow, with the reverse true for hybrids. Of course, this will differ by
-------
manufacturer, which is a problem if universal caps, instead of manufacturer-specific caps, are
maintained.
Response: Regarding Mr. German's concern that the technology ranking will change over time
due to differing learning rates and changing effectiveness over time, it is not clear whether his
concern applies to changes within a redesign cycle or across numerous redesign cycles. We do
not believe that this issue exists within a redesign cycle. Certainly, technologies can differ in
their learning rates and strictly speaking, this means that their costs change each year and this
could affect the order of technologies. However, manufacturers focus on the mid to long term
when redesigning their vehicles. Focusing on costs at the end of the redesign cycle is consistent
with this. Technology rankings are more likely to change across redesign cycles. This can be
accomplished in the current model by listing a specific technology twice, once in the correct
position for one redesign cycle and second, in the correct position for the second or later redesign
cycle. The technology cap for the first listing would be zero in the second or later cycle. The
technology cap for the second listing would be zero in the first redesign cycle. Of course, this
can only be done for a few technologies before the user runs into the limit on the number of
technologies which can be handled in the model. If the desired order of technologies cannot be
accommodated in this way, the model could simply be run with two separate scenarios, one for
each redesign cycle with its own technology file. The results could then be combined in the
same benefits calculation worksheet if calendar year impacts were desired. Since the core model
of technology application starts over for each redesign cycle, the results of the scenarios
evaluating the second or later redesign cycles would be exactly the same as a single, multiple
redesign cycle run with that technology file. In future versions of the OMEGA model, it may be
possible to provide separate effectiveness estimates for each redesign cycle, as well as separate
technology order for each redesign cycle.
We believe that Mr. German's second comment above about dis-synergies is incorrect. In fact,
the set order of technology application is what allows OMEGA to accurately estimate dis-
synergies. This estimation is not in the effectiveness estimate included in the Technology file,
but in the Technology Effectiveness Basis (TEB) for the DI Turbo technology which is input for
each vehicle. To use Mr. German's example, let us assume that the effectiveness of
turbocharging alone is 5% and that of direct injection 7%. However, combining the two only
reduces CO2 emissions by 10%. The effectiveness for DI Turbo technology in the Technology
file will be the full 10%. Vehicles which already are turbocharged will have a TEB for the DI
Turbo technology of 50% (5%/10%). Vehicles which already equipped with direct injection will
have a TEB for the DI Turbo technology of 70% (7%/10%). The result is that the incremental
benefit of moving the first vehicle to DI Turbo technology is 5%, while that for the second
vehicle is 3%.
The advantage of the approach taken in the OMEGA model is that the technology path for each
vehicle is fully known. The user can use any level of vehicle simulation modeling or vehicle
testing to assess the overall effectiveness of the technology already on a vehicle and that which
would exist after the application of each technology made available to it. At each point, the dis-
synergies can be fully assessed because the full regimen of technologies on the vehicle is
completely known. The TEB values in the Market File contain exactly the type of information
which Mr. German says must be included. The only difference is that this information is in the
-------
Market file and not the Technology file, to which Mr. German alludes. It is likely that this
confusion arose due to a lack of clarity in our description of the critical role played by the TEB
values in the draft model documentation provided to the peer reviewers.
Mr. German is correct in that OMEGA does not contain representations of distinct segments of
the vehicle market (e.g., towing, rural drivers, etc.). However, OMEGA can still be designed to
reflect such market segments if distinctions in the preferences or needs of these segments can be
related to the acceptability of various technologies. For example, the need to tow can affect the
acceptability of turbocharged downsized engines. The user can place vehicles which are used to
tow trailers or haul heavy loads in different vehicle types from those vehicles which are not used
in these ways. The technologies made available to vehicles with towing or hauling requirements
then differ to the appropriate degree. A review of the lists of technologies made available to
different vehicle types in the modeling which it performed in the EPA vehicle GHG proposal
reflect such differences.
Another approach would be to limit the application of certain technologies to less than 100% of
sales. For example, the user may believe that all electric vehicles would be acceptable to only
50% of the users of subcompact cars. Range limitations could severely limit their desirability to
the remaining 50%. The user can simply set the technology penetration cap to 50% for the
electrification technology for the vehicle type applicable to subcompact cars. The same can be
done for factors which would affect the applicability or desirability of technology associated
with rural driving, etc. Such limits would apply to all vehicles within a given technology type
and thus, in general, to all manufacturers. If the user desires to limit the application of
technology at the vehicle level, this can be approximated by setting the TEB and CEB values for
that vehicle above the level actually present, so that the model will apply the technology to less
than 100% of the sales of that vehicle.
(E) Maximizing Net Social Value
The model only outputs total costs and benefits. It presents these with great amounts of detailed
information. But it is impossible to tell if the scenario has maximized net social value.
To put it another way, the model is only capable of counting up the benefits and costs of
complying with pre-determined GHG standards. It is not able to do the reverse, which is to input
the desired benefit and have the model determine the resulting GHG standard.
This is not a trivial issue. The 2007 EISA specifically mandates "maximum feasible" CAFE
standards after 2020. NHTSA has long interpreted existing statutory authority to also require
maximum feasible standards and established long ago that "maximum feasible" is determined by
the point at which the costs of adding the next technology exceed the benefits. Even without a
mandate, any credible analysis must be able to compare the costs and benefits of the chosen
GHG standard to the maximum net social value.
Given the existing complexity of the model, it is not unreasonable for the model to also
determine the GHG standard that maximizes net social value. The Volpe model calculates this
point even with a much more complex model. EPA's model will lose considerable credibility if
-------
it is not capable of calculating the maximum net social value point.
Response: We do not address Mr. German's comments about the need for either EPA or
NHTSA to set GHG or fuel economy standards using a model which automatically identifies a
standard which maximizes the difference between societal benefits and costs which can be
estimated and monetized. These issues are beyond the scope of this peer review.
EPA agrees with Mr. German that it would be useful for OMEGA to be able to perform such a
task. We have developed a spreadsheet which combines two of OMEGA's output files and
identifies the level of GHG control which maximizes net societal benefits. The two files are: 1)
the results file in text format which shows each manufacturer's emissions and cost after each step
of technology application and 2) an abbreviated version of the benefit calculation file. The
OMEGA model only needs to be run once with a GHG standard which is sufficiently stringent to
require the addition of all available technologies to all vehicles. The spreadsheet adjusts each
manufacturer's standard in a consistent manner off a predetermined universal or footprint-based
standard until net benefits reach their maximum. EPA will consider publishing this spreadsheet
once a set of instructions for its set up and use are drafted.
EPA will also add the automatic capability to determine the standard at which societal benefits
are maximized to OMEGA at some time in the future. While such an approach can provide
useful insight during rulemaking development., as Mr. German points out elsewhere, there are
many factors, such as feasibility and leadtime, which are difficult to quantify and other factors
which differ across manufacturers which are difficult to simulate in a model. One practical issue
with model runs which maximize benefits is that they usually show that the standard is infeasible
for a number of manufacturers with the technology that is projected to be available. Thus, EPA
did not rely on the principle of maximizing net societal benefit in setting the standards contained
in the EPA vehicle GHG proposal.
Appropriateness and Completeness of the Contents of the Sample Input Files:
(F) Market Input File
The market input file appears to be appropriate and complete - perhaps too complete in one way.
The file contains separate inputs for reference case technology benefits and costs. The
percentages in these columns should simply reflect the existing market penetration of each
technology package. They should be identical for both costs and benefits. Is there a reason why
these would be different? If so, the Model Description should explain this. If not, the duplicate
columns can be removed.
Minor Suggestions:
If the model wants to "back out" existing technologies, you will need a lot more than 20
columns to do this. You'll need 10 columns just to handle transmissions and another 10 just
to handle different valve timing systems. Not to mention differing levels of high strength
steel and aluminum use.
The Model Description should state that vehicle types are a user input defined in the
"Vehicle Type" tab of the Market Input File (I looked around for a while before I found this.)
-------
If you maintain separate columns for reference case technology costs and benefits, it would
help the user to add a row above the existing descriptions and define columns AD-AW as
"reference case benefits" and columns AX-BQ as "reference case costs".
Response: Mr. German's comments in this section (and our response) intersect with his
comments in Section D. above concerning the ability of OMEGA to recognize and represent
potential dis-synergies between technologies. First, the TEBs and CEBs in the Market file will
usually differ. One reason for this occurs with technology packages which include several
distinct technologies. Using Mr. German's example from Section D. a technology package
might include both converting an engine to direct injection and adding turbocharging. If a
baseline vehicle has a direct injection engine, but is not turbocharged, then the TEB would be the
emission effect of only converting the engine to direct injection compared to adding both
technologies. The CEB would be the cost of only converting the engine to direct injection
compared to adding both technologies. Due to dis-synergies, as discussed in Section D. above,
the emission effect of direct injection might be 60% of the total benefit of both technologies,
while the cost might only be 50% of the total. In general, no two technologies will have exactly
the same ratio of incremental cost and incremental effectiveness, which would be necessary for
the TEB and CEB values for vehicles to be the same. Adding dis-synergies can markedly affect
effectiveness, but generally has minor effect on cost. Thus, with dis-synergies, the chances of
two technologies will have exactly the same ratio of incremental cost and incremental
effectiveness in terms of the percentage of package cost and effectiveness is very small.
When Mr. German refers to the need for more than 20 columns in order to back out technologies,
he again misunderstands the nature of the TEB and CEB values. (Again, this is likely due to a
lack of clarity in the draft model documentation on this subject which EPA provided to the peer
reviewers.) The units of the TEB and CEB values are the percentage of technology package
effectiveness and cost which are already present on the vehicle. These percentages are best
determined using a vehicle efficiency simulation model which can estimate fuel consumption
over the certification driving cycles for various combinations of technologies. EPA's lumped
parameter model is one example of this type of model, as is the Ricardo EasyS full vehicle
simulation model. The presence of individual technologies is not an input to the OMEGA
model. As this is different from NHTSA's Volpe Model, this may be one of the causes of
confusion.
We agree that the headings of the inputs files could be made more clear and descriptive.
However, we have found that adding header lines to the input file has been more complicated
than anticipated. Thus, we are taking the approach of adding more detailed descriptions of each
column of each input file to the model documentation and directing the user to review these
descriptions in order to obtain a fuller understanding of the nature of each of the inputs to the
model.
(G) Technology Input File
As discussed above, the technology input files need to be substantially modified in conjunction
with changing the model to handle multiple technology paths.
-------
In addition, also as discussed above, the "Cap Cycle" numbers need to be replaced with generic
caps on the maximum increase permitted per year and manufacturer-specific model years for
initial introduction. The annual technology penetration increase cap would be applied to each
manufacturers' individual baseline technology penetration, from the Market Input File, or
starting with the manufacturer-specific initial model year for technology packages that have not
been used yet by individual manufacturers.
The Average Incremental Effectiveness fields are fine, although, as noted above, if these change
for future redesign cycles, the cost-effective order of the technology packages can also change.
I could not find any explanation of how the Initial Incremental Cost, a, Decay, seedV, kD, and
Cycle Learning Available fields are used in the model. Even the detailed algorithms on pages 9-
16 of the Model Description contain no reference to how technology costs are adjusted for the
TARF calculations. Thus, I was not able to assess the appropriateness of these fields. However,
in general, the cost reduction curve is not likely to be the same for all technologies. Some
flexibility may be needed here.
The Technology Input File does not address weight impacts associated with different
technologies. For example, both diesel engines and hybrids add considerable weight to the
vehicle, which negatively impacts both performance and efficiency. It is possible to handle this
off-board in the efficiency benefit estimation. However, if so the Model Description should
explicitly state that weight impacts are expected to be assessed by the user and included in the
technology inputs.
Response: As Mr. German alludes, several of the comments in this section have already been
mentioned in earlier sections and are addressed there. Several of Mr. German's other
suggestions would involve the model applying technology on an annual basis. OMEGA is
explicitly designed to apply technology over an entire vehicle redesign cycle. This has received
favorable comment from all three peer reviewers, including Mr. German. As discussed in
Section C above, limits on the annual rate of technology application which the user believes
apply can be input to the current model by simply summing up these limits over the redesign
cycle.
Mr. German is correct that the draft model documentation provided to the peer reviewers did not
describe how the Initial Incremental Cost, a, Decay, seedV, kD, and Cycle Learning Available
fields are used in the model. These inputs are related to the prediction of cost reductions due to
learning, which has not yet been implemented in the OMEGA model. These columns appear in
the Technology file as place holders for future version of the model. The same is true for several
vehicle parameters, such as weight, seating capacity, etc., which are included in the Market file.
We will consider Mr. German's comment that the cost reduction curve is not likely to be the
same for all technologies when we add learning to the model.
We agree with Mr. German that the impact of each technology on vehicle weight and
performance should be included in estimating the effectiveness and cost of each technology.
This is the approach followed in the EPA vehicle GHG proposal. We have modified the model
documentation to clarify this.
-------
(H) Scenario Input File
The compliance options - universal standard, linear attribute, or logistic attribute - are fine.
However, there are columns in the Scenario input file that are not described in the Model
Description on page 6:
TARF Option (column E) - Is this the "two TARF equations from which the user can
choose", described on page 13? If so, should state this on page 6.
o Why is the "Effective Cost" TARF equation limited to fuel savings over the payback
period? Why aren't the discounted lifetime fuel savings considered? Is this done to
try to mimic what technologies will be most acceptable to the customer? If so, this
should be explained in the Model Description. I'm also not sure this is appropriate.
Most technologies will be invisible to the customer. In addition, the primary point of
CAFE and GHG standards is to fill in the gap between the consumers' value of fuel
savings and the value to society. So, the standards should be targeted towards
society's values, not the customers.
o The equation for "Cost Effectiveness - Manufacturer" equation does not make sense.
Unless a technology includes a fuel change, this equation will produce virtually
identical results for all technologies. The CO2 summed in the denominator is directly
proportional to fuel consumed summed in the numerator. The ratio should be
virtually the same for all technologies, unless there is a fuel change. What is this
equation trying to do?
o Why is the fuel savings only summed over the payback period, while the CO2
savings are summed over the useful life? Why are they not the same?
Target Function Type (column F) - I could not find a description of this field anywhere in
the Model Description.
Fleet type (column G) - The description in Rykowski's email response to Rubin should be
added to the Model Description.
Trading limit (column I) - The description in Rykowski's email response to Rubin should be
added to the Model Description.
Economic parameters - The "CAFE fine" and "CO2 value increase rate" are fine. However, the
other parameters may need modification:
Discount rate - There is some thought that the CO2 discount rate should be different from the
economic discount rate. I am not sure I agree with these arguments, but you may want to
include flexibility to have a different discount rate for CO2 in the model.
Payback period - As discussed, above, I am not sure this is needed. Any use of payback
period should be explained and justified in the Model Description.
CO2 fine - While the CAFE fine is used appropriately in the model, there is no consideration
of a manufacturer paying CO2 fines instead of complying with CO2 standards. Of course,
this is dependent on the compliance strategy adopted by EPA for its CO2 standards. But the
model should have the flexibility to model CO2 fines; similar to how it handles CAFE fines.
Gap - It is appropriate to adjust the test values for differences in real-world fuel
consumption. However, the gap is not linear. As EPA demonstrated in their fuel economy
label rulemaking, the gap increases as fuel consumption decreases. While the fuel economy
-------
I do not understand the value of "threshold cost" or how it is used. Lines 8-10 of page 8
state, "threshold technology cost (the cost at which manufacturers add technology to only
enough vehicles to meet the standard as opposed to adding technology to all of a model
line)". The detailed calculations later in the Model Description do not discuss how this is
done. From a practical point of view, how does the model know whether or not the
technology is needed to meet the standard when the technologies are feed into the model one
at a time? More importantly, manufacturers have limited resources and the standards will
drive technology development well beyond what a manufacturer would have done without
them. Thus, why would a manufacturer add any technology to more vehicles than are
required to meet the standard? Unless these concerns can be addressed in the Model
Description, the "threshold cost" should be eliminated.
Rebound effect - Line 38 on page 17 states that the rebound effect is an input in the
"Economics" worksheet. However, it is not listed in the worksheet. In any case, the rebound
effect is not handled appropriately in the model. The rebound effect is a sensitivity factor.
But it is determined from a regression. Which means that the change in VMT is NOT a
linear function of the change in fleet fuel consumption. Thus, the equation on lines 41-43 of
page 17 is wrong. The actual relationship is logarithmic or exponential or something like
that (I don't remember exactly what). The correct equation should be built into the model.
o The rebound effect is also impacted by the price of fuel and household income. This
should be added to the model (see medium- to long-term recommendations, below).
Minor suggestions:
It appears that the "Cars A", "Cars B", "Cars C", and "Cars D" columns in the Target tab are
intended to describe the footprint-based logistic curve. Does this mean that "Cars C" and
Cars D" are also the Xmax and Xmin under the linear attribute option? If so, both
descriptions should be in the column headings. Also, while the Model Description (page 6-7)
includes a good explanation of the how the linear target and logistic curve work, it should
also specifically state where the A, B, C, D, and X coefficients can be found in the
spreadsheet.
The economic parameters are discussed as part of the Scenario input file on page 8. Lines
12-13 also state that an example of the Scenario input file is in Appendix 3. However,
Appendix 3 only includes the "Scenarios" tab and the "Target" tab. The "Economics" tab
should also be added to Appendix 3.
Response: Mr. German is correct in that the TARF column in the Scenario file refers to the
choice of one of the two available TARF equations. The model documentation has been clarified
in this regard. The payback period is the period of time over which manufacturers believe that
vehicle purchasers value fuel saving when purchasing a vehicle. If the user prefers to use
lifetime fuel savings in the TARF calculation, the user can specify a payback period sufficiently
long to cover the life of the vehicle
The point of including the fuel savings over a period of time in the TARF is to recognize that
there is some increase in vehicle fuel economy which would neutralize the consumer's negative
-------
perception of an increase in vehicle price, thus nullifying any negative sales impact. This level
of fuel economy increase is often estimated to be the fuel savings accruing over a specified
number of years of vehicle operation which is usually less than the life of the vehicle. Thus,
when either TARF is negative (i.e., the fuel savings exceed the cost of technology), this implies
that the manufacturer could add the technology at its full cost and potentially increase vehicle
sales (all other factors being held constant). Similarly, when either TARF is positive, this
implies that if the manufacturer added the technology at its full cost, sales would decrease. We
have modified the model documentation to better explain the rationale behind the TARF
equations.
The fuel savings are typically summed only over a portion of the vehicle life because the
timeframe considered by the vehicle purchaser is typically less than the life of the vehicle. (We
have not included an estimate of the residual value of the added technology at the end of this
time period, but will consider adding this in future model versions.) The lifetime CO2 emission
reduction are included in the denominator since that represents the form of the GHG standard,
particularly when car and truck trading is considered. For a single vehicle class, there is no need
to include lifetime GHG reductions; the reduction in terms of g/mi would be sufficient.
However, the lifetime GHG emission reduction provides the same ranking as the reduction in
g/mi and also applies when car-truck trading is allowed. So including lifetime CO2 emissions in
both cases allowed the same equation to be used in all cases.
Mr. German suggests that the point of GHG standards is to fill in the gap between the
consumers' value of fuel savings and the value to society. That can be true, but this is
accomplished primarily through the level of the GHG standard. The current TARFs are focused
on the order in which manufacturers are likely to add technology to meet the standard. The
TARF does not set the level of the standard. Manufacturers' primary goal is to maximize profits.
OMEGA does not address all of the numerous factors which affect profit maximization. For a
specified level of sales across a fixed model mix, profits are maximized by maximizing the profit
per vehicle, or the difference between cost and price. The numerator of both TARFs attempt to
represent this difference. Thus, the more negative the TARF, the greater the potential profit per
vehicle and a manufacturer's desirability to add the technology.
The level of a GHG standard can be based on many factors, societal benefits being one of them.
The benefit calculation worksheet is designed to facilitate the calculation of total societal costs
and benefits and to assist in this evaluation.
The Cost Effectiveness - Manufacturer TARF is not constant for every technology. The Cost
Effectiveness - Manufacturer TARF (ignoring the CAFE fee) is basically :
[ Technology Cost less Fuel Savings over Payback Period ] / Lifetime GHG Emission Reduction
Or
Technology Cost less Fuel Savings over Payback Period
Lifetime GHG Emission Reduction Lifetime GHG Emission Reduction
Mr. German is correct that the ratio of fuel savings to GHG emission reduction will tend to be
-------
constant across technologies (at least those not aimed at reducing refrigerant leakage). However,
the ratio of technology cost to lifetime GHG emission reduction will not be constant across
technologies. The Cost Effectiveness - Manufacturer TARF can be presented as the difference
between these two ratios, so it will differ markedly between technologies. Except for the
inclusion of discounting in the calculation of the GHG emission reduction, Paul Lieby's
comment in section xx of his comments presents an excellent description of the rationale behind
the Cost Effectiveness - Manufacturer TARF.
We have clarified the description of all the model inputs in the model documentation.
We have also added a separate discount rate for the valuation of CO2 emissions.
As discussed above, including the payback period as an input allows the user to evaluate fuel
savings over less than the life of the vehicle or over the entire life of the vehicle.
EPA has not typically allowed the payment of a fee in lieu of non-compliance for car and light
truck emission standards. The typical fine for non-compliance is far in excess of the cost of
technology and is retroactive in that it applies to past sales of vehicles which were found to
violate the applicable emission standards. There is no provision for actively producing vehicles
which do not meet applicable emission standards. Thus, we do not plan to add a separate CO2
fine to the Scenario file. The inclusion of the CAFE fee in the TARFs is to allow the user to use
the OMEGA model under conditions which are similar to those possible with the Volpe Model.
In model runs evaluating GHG emission standards, EPA would set this fee to zero.
Mr. German is correct that EPA's current MPG-based formulae for fuel economy labeling imply
that the "gap" increases as fuel economy increases. The model currently assumes a constant gap
with changing fuel economy. EPA will consider incorporating a more flexible definition of the
gap into future versions of the model.
We have clarified the role of the threshold value in the model documentation. Basically, if the
per vehicle cost of the last technology added by the model in order to enable compliance exceeds
the threshold value, the model reduces the percentage of vehicle sales receiving that technology
to just the degree needed to enable compliance. If modified the per vehicle cost of the last
technology added by the model in order to enable compliance is below the threshold value, the
model leaves the percentage of vehicle sales receiving that technology at the technology
penetration cap for that technology. This flexibility was included in the model to reflect the
different ways in which manufacturers apply various technologies. For example, when adding
basic engine technology such as variable valve timing, the manufacturer would generally convert
the entire production volume of a specific engine to this technology. Two different engines, one
with the technology and one without, would not be maintained. However, with more extreme
technologies, such as dieselization or hybridization, the manufacturer often maintains two
versions, one with and one without these technologies. By setting the threshold in between the
costs of these two examples, the model will reflect these two approaches to technology
application on the part of a manufacturer.
If the threshold is set to zero, the model simply backs off from any predicted over-compliance.
-------
The higher the threshold cost is set, the greater the degree of over-compliance which is accepted
in a model run. Since the value of the threshold cost is set by the user, its inclusion only
provides more flexibility.
The rebound effect has been evaluated in the literature in a number of different ways from a
variety of datasets. It is typically defined as the percentage change in per vehicle VMT divided
by the percentage change in the cost of driving one mile. Thus, it is a function of both fuel
economy and fuel price. As the base cost per mile of driving in the various studies varies, there
is some ambiguity in defining the rebound effect in this manner. Still, this is the norm used in
the literature and we apply it accordingly. The benefit calculation worksheet determines the
percentage in VMT per vehicle by multiplying the percentage change in fuel consumption per
mile by the rebound effect.
The rebound effect is included in the benefits calculation file, in cell B3 on the Exclusive Inputs
tab. It currently only applies to changes in fuel economy. However, future versions of the
benefits calculation file will apply it to changes in fuel price, as well. As Mr. German notes,
VMT per vehicle has also been observed to be increasing over time due to other factors, income
probably one of them. An input for a secular increase in VMT per vehicle will also be included.
We have modified out descriptions of the values which are represented on the Target tab of the
Scenario file to better describe their role in both the constrained logistic and segmented linear
standard curves. We also have added a description of the values to be entered on the Economics
tab of this file.
(I) Fuels Input File
The fuels file works fine for conventional gasoline and diesel. The Model Description does not
address biofuels, but if needed the Fuel Input and the Upstream Emissions worksheets should be
able to handle them.
Electricity is a special problem. A minor issue is that the Energy Density (column B), Mass
Density (column C), and Carbon density (column D) are different than for liquid fuels. Liquid
fuels are generally expressed in units per gallon. This doesn't work for electricity. The units for
electricity in the Fuels Input sheet need to be defined. Also, I'm not sure what Mass Density
would be for electricity - kg/kWh? And isn't carbon density meaningless, as the carbon is all
upstream?
More importantly, the energy density and mass density for electricity are not fixed, but are
dependent on battery construction. High-power Li-ion batteries for conventional hybrids may
only have about 15 Wh/kg energy density, while high-energy batteries for PHEVs and EVs may
have over 100 Wh/kg. In addition, start/stop systems and belt-alternator/starter systems may use
lead-acid batteries and some conventional hybrids may continue to use NiMH batteries through
the 2013-2015 timeframe. All will have different energy densities.
Minor suggestions:
The Model Description, line 6 page 6, says, "There is a small subset of fuel information not
-------
included in this file". This is not accurate. Appendix 5 contains upstream emissions, which
is an extremely important factor for fuels. This connection should be discussed in the Model
Description.
The appendices should be ordered to match the order they are discussed in the Model
Description (i.e. the fuels Appendix should be before the Scenario appendix).
Response: Please see our response to xx comments on the inclusion of renewable fuels in the
model. Mr. German is correct that the benefits calculation spreadsheet could be modified by the
user to accommodate any different costs or emissions from the use of other fuels in vehicles
which are certified on gasoline or diesel fuel.
The inputs for electricity in the Fuels file have been clarified in the model documentation. The
energy density value for electricity does not apply to that of the battery type being used on the
vehicle, so the variability in the latter value is not an issue. We have also modified our
description of fuel-related inputs, incorporating Mr. German's comments, as well as other
changes.
(J) Reference Data in Appendix 5
Downstream Criteria Pollutant Emissions:
The fields and the regressions as a function of age are appropriate. However, there is not enough
flexibility to handle differences in fuel, future emission standards, and future fuel sulfur control:
The model should be able to handle future reductions in emission control standards. This
means that the model should allow the user to specify effective years for future emission
standards and enter new regression coefficients.
SO2 emissions are almost entirely a function of the sulfur level in the fuel. Thus, the model
should also handle changes in fuel sulfur level. The model should allow the user to specify
effective years for future sulfur reduction and the fuel sulfur level for both current and future
fuels. If desired, the user would not have to enter regression coefficients for SO2, as there is
a fixed relationship between fuel sulfur, fuel consumption, and SO2 emissions (much like
CO2 to fuel consumption) that could be hard-coded in the model if the user specifies fuel
sulfur levels.
The regression coefficients will be different for gasoline, diesel, and electric vehicles.
Average coefficients can be used for the current fleet, but these will not be appropriate if
there is a substantial change in the future mix of diesels, PHEVs, or EVs. The model needs
to allow input of different coefficients for diesel and gasoline - and possibly biofuels.
Downstream emissions of electric operation should be zero and do not have to be input.
It appears that the model does NOT calculate downstream pollutant emissions as part of the
normal model accounting, only the additional emissions caused by the VMT rebound effect.
This is not appropriate. If there is a switch to diesels or EVs, the downstream pollutant
impact needs to be assessed by the model.
Upstream Emissions:
The upstream emission inputs are fine for gasoline and diesel, although addition rows will
likely be needed to handle biofuels and unconventional oils.
It is not clear if the efficiency of battery recharging is included in electricity upstream
-------
emissions. The model likely calculates only the mmBtu actually used by PHEVs and EVs
during use. However, the mmBtu draw from the utility will be larger due to losses in the
battery charger and in the battery chemical process. To ensure that the user handles this
properly, it would be best to add an input somewhere for charging efficiency. Otherwise, the
Model Description should explicitly state that the upstream grams/mmBtu for electricity
must be incremented to include the losses in the charger and battery.
Upstream emissions, both carbon and pollutant, for electricity will vary by region. While it
is the responsibility of the user to input proper factors, there is a potential issue with
stratification of PHEV and EV sales across the nation. Customers in urban areas are most
likely to buy PHEVs and EVs will likely be limited primarily to a few, dense urban cores. It
might be useful to have the Model Description briefly discuss the need for the user to input
upstream values for electricity that are consistent with utility emissions in the urban areas
most likely to purchase PHEVs and EVs.
Vehicle Age Data and historical data on average CO2 emissions and new vehicle sales:
These fields and inputs are fine.
Response: We agree with Mr. German's comments about the inability to reflect step changes in
the downstream emission equations. Future versions of the benefits calculation file will specify
downstream emissions by model year and age. Future versions will also include distinct
emission estimates for vehicles operating on different fuels, such as gasoline, diesel fuel and
electric vehicles. These estimates will apply to both base levels of VMT and rebound-related
VMT.
Regarding upstream emissions, we agree with Mr. German that the inclusion of an efficiency
value for battery changing (and electricity distribution) should be included so that the user can
input upstream emission estimates based on kw-hr of power generation at the power plant.
Changing the upstream emission calculations to reflect regional differences would involve
substantial changes throughout the benefit calculation worksheet, as regional vehicle sales, VMT
per vehicle, etc. would likely also differ. We believe that such regionalization of the model
should be performed by those knowledgeable of the particular region of interest. However, we
agree with Mr. German that the emissions input to the spreadsheet should reflect the emissions
from the incremental increase or decrease in the production of that fuel and not the average
emissions over the entire production of that fuel. We will modify the model documentation to
reflect this point.
(K) Other Reference Data
Externalities related to crude oil use:
The externalities in the Externalities worksheet of the Benefits Calculation are only listed for
imported oil. This is appropriate for military costs for protecting oil supplies, but it is not for the
economic impact of periodic price shocks (and possibly for monopsony effects as well). Oil is a
global commodity. Any reduction in oil use, either domestic or imported, will help reduce the
economic impact of periodic price shocks.
Rebound effects:
-------
The discussion of the rebound effects on lines 10-19 of page 3 and on pages 20-21 both imply
that rebound effects are NOT considered in assessing the societal benefits from reduced crude oil
use and GHG emission reductions. However, I would assume that these benefits are based upon
total fuel consumption, which includes the additional VMT from the rebound effect. If my
assumption is not accurate, then the social benefits associated with reduced crude oil use and the
value of GHG emission reductions must be revised to include the rebound effect. If the benefits
do include the additional VMT from the rebound effect, this should be clarified in the discussion
on both page 3 and page 20.
Response: We have removed the word Imports from the title of the Oil Externality Section of
the benefits calculation file. These externalities were applied to all reductions in crude oil use,
not just to reduced imports. To the degree that an externality only applies to imported oil, the
user should decrease the value of the externality by the ratio of the expected reduction in
imported oil to the expected reduction in total oil use.
We have corrected the discussion of rebound effect in the model documentation. The reductions
in crude oil use and GHG emissions always included the rebound effect.
Recommendations for Improved Model Functionality - beyond "future work":
(L) Recommendations for Short-Term Functionality
The functionality of the model is good. My only recommendations are those already described
above, for improved handling of leadtime (section C), ability to handle multi-path technology
inputs, (section D), and ability to calculate "maximum net social benefits" (section E).
Response: None required.
(L) Important Medium-Term and Long-Term Recommendations
1) By far the most important improvement is to use budgets for capitol expenditures to assess
leadtime. The need for this and suggestions on how to implement it were discussed in section
(C), above.
2) The rebound effect is impacted by both the price of fuel and household income. These
should be added to the model. The work has already been done by Small and vanDender. Their
equations should be added to the model, along with the necessary user input fields for future
household income. An option to skip the fuel and income effects can be maintained, but it is
important that the model be capable of properly calculating rebound effects.
The time value of congestion and vehicle refueling are also related to household
income. While this is of lesser importance than the rebound effect, it should be
relatively easy to add household income effects to the value of congestion and vehicle
refueling in conjunction with adding household income to the VMT rebound effect.
Response: We have added a secular growth rate to the calculation of VMT per vehicle to
represent the impact of real income and other factors which have been increasing total VMT over
-------
time beyond growth in the vehicle pool. At the present time, the rebound is still assumed to
constant over time. We are aware of the Small and vanDender study which has found that the
rebound effect appears to be decreasing over time. Fortunately, this is not a factor for analyses
which just evaluate one or two redesign cycles. Longer term analyses face even greater
uncertainties with VMT per vehicle and other factors. Still, we will consider modifying the
benefits calculation file to accommodate a changing rebound rate with time.
(M) Less Important Long-Term Suggestions
3) Inclusion of the city and highway fuel economy/CO2 values may help with assessing
market penetration caps, although this can be done externally. Also, separate city and highway
values could help calculate an appropriate in-use fuel economy/CO2 "gap" for different
technologies with different city/highway fuel economy ratios. Separate city and highway
numbers might also be useful for other purposes. EPA should consider adding these to the
model.
Response: It is not clear how tracking or regulating city and highway CO2 emissions separately
would address issues which Mr. German has raised related to the technology penetration caps.
Regarding the gap between onroad and certification CO2 emissions or fuel economy, this gap
can theoretically vary between city and highway driving. However, as EPA described in its
supporting analysis to its 5-cycle fuel economy labeling rule, data on onroad fuel economy
during city and highway driving is very scarce. Thus, assessing the distinct impact of technology
on certification and onroad CO2 emissions during city and highway driving would have to be
based on vehicle simulation modeling. Such models are commonly used to simulate vehicle
operation over the EPA city and highway certification cycles at the test temperature of 75 F.
However, few vehicles, and even fewer control technologies have been modeled over other
driving cycles, such as the US06 high speed, aggressive driving test, the SC03 air conditioning
test and the standard test cycles at low ambient temperatures. Thus, at the present time, there are
insufficient data available to determine how various technologies would affect the "gap" over
city and highway driving. Until such information becomes available, the value of expanding the
model to include separate city and highway estimates of the gap would be of limited use. If such
information becomes available, it would be a simple task to add such capability to the benefits
calculation worksheet. Incorporating this into the core model would be a more significant task.
The primary requirements would be to input onroad city and highway gaps for each technology.
It would probably also require the use of separate effectiveness estimates for city and highway
emissions for each technology. Compliance would still be determined based on combined
city/highway emissions.
4) Value of time required to refuel vehicles:
The model handles this appropriately for liquid-fuel vehicles. However, PHEVs and EVs will
add refueling time, both because of the need to plug in and, in the case of EVs, the shorter range.
This should be added to the model. Ideally, it should also be added to the TARF assessment.
Response: Mr. German raises important points about PHEVs and EVs which need to be factored
into the consideration of their expanded use in the future. At present, the only consumer benefit
-------
which OMEGA includes in either of the TARFs is the value of fuel savings. Other effects, such
as a change in refueling time, are included in the calculation of societal benefits, but not the
TARF. There are other attributes of PHEV and EV use which will also affect their value to the
consumer. For example, the reduced range of EVs relative to conventional vehicles is a serious
limitation for some consumers, but not for others. Some PHEVs are designed to run most
efficiently on battery power and only resort to liquid fuel use when the battery has run out of
useful energy. Other PHEVs operate best on a mix of electricity and liquid fuel. However, even
these PHEVs eventually run out of stored battery power and convert to operation solely on liquid
fuel. Their operational cost varies depending on daily driving distance, as well as climate.
Unfortunately, there are significant uncertainties surrounding the details of how people drive and
how they would drive if they owned a PHEV or EV. Thus, limitations exist today regarding both
the appropriate inputs and modeling capability before these issues can be fully represented in an
automatic fashion in a model run. In the near term, users modeling GHG standards which
require or reflect significant levels of PHEV and EV penetration should take care to limit their
penetration to portions of the driving public whose driving patterns are compatible with the range
of these vehicles. Or, if the penetration of PHEVs is such that they would be driven significant
distances on all liquid fuel power, that their CO2 efficiencies reflect such use.
B. Comments by. Paul Leiby
Thank you for the opportunity to review this model and its documentation. This is an important
project, and the EPA team has made great progress in developing a coherent, informative, and
very usable system. I understand that this is a work in progress and, regrettably, many comments
can only refer to its current (May 1, 2009) state. Also most of the comments are in the form of
what might be changed or improved, with the hope that these might be most useful. I would like
to say at the outset that everything achieved so far is well worthwhile, and some features are
quite marvelous. Please also interpret statements below of the form "the model does/does not"
as meaning "as far as I could discern so far, it seems like the model does/does not." Statements
like "the model/documentation should" really mean "Perhaps it would be helpful if the
model/documentation were adjusted to...." In sum, this work is to be applauded and I look
forward to its next iteration. Comments are offered in order of the questions posed, and in
structured bullet form.
Questions to address:
1) Comments on: The overall approach to the specified modeling purpose and the
particular methodologies chosen to achieve that purpose;
This model fills an important need for an independent capability to assess how
manufacturers might respond to GHG emission regulations on light-duty vehicles.
There is much to recommend this model, which grapples with some key challenges of
assessing how progress toward tighter fuel use or GHG emissions standards can be
achieved through incremental vehicle technological change, and at what cost.
The essential approach of this model is consistent with others in a similar vein, with the
most notable predecessor being the NHTSA "Volpe Model." It describes the set of
technological possibilities for improving vehicle fuel economy, or reducing GHG
emissions, characterizing for each technology the cost and incremental change in
-------
emissions and fuel use. It determines a sequence of introduction for fuel-economy (or
fuel switching) technologies necessary to meet a fleet-average CO2 emission constraint
for each manufacturer. However it differs from some other approaches in significant
ways:
o 1. The sequence of discrete technologies that can be used for any single "Vehicle
Type" is exogenously specified by the user. Those fixed technology successions t,
t+l ... for each vehicle type v,essentially define a vehicle-type-specific supply
(marginal cost) curve for emissions reduction. The model determines the
sequence in vehicle types each separately progress in an orderly fashion down
their emissions reduction technology curve.
o 2. The model makes vehicle technology redesign decisions not annually, but for
each vehicle "design cycle," which is typically specified as a fixed number of
years.
o 3. The algorithm does not do a simultaneous choice of the set of technologies that
minimize vehicle net costs such that the GHG emission standard is met. Rather it
iteratively "dispatches" discrete new technologies by choosing which vehicle is to
progress next by one more step through its sequence of technologies. It repeats
this dispatching over vehicle types until the fleet average GHG emission standard
is finally met. The choice of which vehicle type is to receive more advanced
technology is based on one of two figures of merit, called "TARFs."
It is wisely stated that effective model design hinges on a careful definition of its purpose
or purposes, and an acknowledgement of its bounds and limitations. The documentation
could be much strengthened in this regard. Here is my impression of its suitability:
o This model is currently most suited to estimating the incremental net
technological cost of any single manufacturer achieving various GHG emission
levels, specified as an average for that manufacturer's new-car fleet. It accounts
for technology costs and lifetime fuel cost savings in its dispatching of
technologies for each manufacturer's fleet. Other attributes and societal impacts
may be monitored ex post (e.g. the extensive and somewhat disparate list on the
top half of p. 3, including criteria pollutant emissions, noise, congestion, refueling
time, etc.) but these are not considerations in the model's solution, i.e. in the core
algorithm that sequences the application of vehicle technologies.
o A compact way to describe the models approach is that, like the Volpe Model, its
solution has two phases: "manufacturer compliance simulation" (with cost-based
technology choice) and "effects estimation" (based on a diverse set of ex post
calculations).
o The model does not project vehicle sales, or sales mix, or aspects of vehicle
design and vehicle appeal to consumers, apart from altered lifetime vehicle capital
and fuel use costs. This is not mentioned as a flaw, but as an important design
choice that should be stated. Large changes in fuel economy and GHG emissions
could have important indirect impacts on the design and appeal of the vehicle,
particularly if tradeoffs are made in the areas of vehicle size, weight,
performance, range, and, for alternative fuels, fuel availability and convenience.
o The model treats each manufacturer's regulatory attainment problem
independently, and is not currently designed to model "flexible" emission
-------
standards that allow permit trading among manufacturers, permit banking or
borrowing, or economy-wide GHG trading systems.
Response: Dr. Leiby states that the current model is not able to reflect credit trading between
manufacturers when determining compliance, or banking of credits. We agree that the model
does not allow these types of credit programs to be modeled explicitly. However, completely
flexible credit trading between manufacturers can be simulated by labeling all vehicles as being
produced by a single manufacturer. The model then estimates the costs and benefits of bringing
the entire industry's new vehicle sales into compliance. Also, the flexibility to bank and borrow
credits within a redesign cycle is implicitly assumed by the model. OMEGA assumes that a
manufacturer's entire fleet of vehicles can be redesigned within one redesign cycle. (Actually,
less than 100% of vehicle sales can be assumed to be redesigned through the technology
penetration caps included in the Technology file.) However, rarely will a manufacturer redesign
exactly 20% of its vehicle sales in each of five straight model years. The base emissions and
emission reductions of the vehicles being redesigned will vary. Thus, the banking and borrowing
of credits will be needed to enable compliance with standards in the intermediate years of a
redesign cycle using the technology projected for the final year of the cycle, assuming that the
intermediate standards require gradual improvement each year.
Suitability of method
o To some extent the discussion of the manifold ancillary benefits and costs can be
a distraction, since a coherent and complete framework for their endogenous
analysis is currently outside the scope of this model. I suggest that the model
developers may wish to stay focused first on clearly and rigorously modeling the
fuel-economy technology choice and cost-effectiveness considerations, for
various GHG emission levels. Where possible, one reasonable design approach
might be to assume that other vehicle attributes are essentially held relatively
constant, for each vehicle size and type.
o Overall, the model documentation suggests that model developers may be hopeful
of doing too much soon, with many (over 10) stated intentions for future
extensions. Better and sounder results may follow from strategically limiting the
model scope, carefully testing the model (in full, with real datasets), and then
selectively adding features over time.
o One feature of this model approach is its comparative analytical simplicity but
heavy reliance on specialized data inputs (discussed further in Item 2 below).
This should be viewed as a model strength: its contribution need not rely on
analytical sophistication, but also on the coherent application of good quality,
widely reviewed data.
Response: The current model does not allow the vehicle sales mix to change as a function of
technology. When applying the model itself, EPA has developed effectiveness and cost
estimates for the various technologies which hold vehicle attributes such as size and performance
constant. Vehicle weight may change, as for example with dieselization or hybridization.
However, in these cases, the effectiveness of the technology should reflect the change in weight.
-------
Two major methodological points:
o In any model, particularly any model of markets with social externalities and
government intervention, it is essential to be very explicit about whose behavior
and objectives are being modeled. Otherwise there is danger that nobody is really
being described, or that we might impute particular knowledge and incentives to
market actors who actually have neither. Naturally a model can be both
normative, saying what should be done optimally, or descriptive, saying what we
think will be done by some actors in certain circumstances even if it is not clearly
optimal. And it can apply to what would or should best be done for different
agents: vehicle consumers, manufacturers, or the government/society as a whole.
I am a little unclear about whose behavior is being modeled in the succession of
technology decisions made. It appears the intent is to model market behavior of
competitive vehicle manufacturers facing cost-minimizing consumers and a firm-
wide emission constraint. But the objective of such a firm is not explicitly stated,
and the solution rules are not clearly mapped to that objective.
In this matter it seems that the Volpe Model has set a good example by
succinctly and specifically stating up-front whose behavior is being
modeled: "The system first estimates how manufacturers might respond to
a given CAFE scenario, and from that the system estimates what impact
that response will have on fuel consumption, emissions, and economic
externalities." [P. 1,
http://www.nhtsa.gov/staticfiles/DOT/NHTSA/Traffic%20Injury%20Cont
rol/Aiticles/Associated%20Files/811112.pdf!
Would a similar description not also apply to the EPA GHG model?
o Given this idea of modeling the behavior of particular actors, e.g. manufacturers,
in mind, the objectives of the actors should be reflected in the solution method or
optimization condition. Bearing this in mind, there are some concerns with each
of the two TARFs proposed as technology-dispatching figures of merit.
The "EffectiveCost" TARF is essentially the cost of each technology net
of its discounted lifetime fuel savings (omitting the problematic "FEE"
component, which seems mis-specified). Arguably, minimizing this
would be a correct objective of new-vehicle consumers who discount fuel
savings in the same way and given no change in non-cost vehicle
attributes. This could also be the objective of competitive firms acting on
behalf of prospective consumers. In a mixed integer program these costs
would be minimized subject to meeting the emission standard, and the
algorithm would choose the least cost combination of technologies. The
possible problem is that the EPA GHG Model algorithm sequentially
dispatches new technologies in order of EffectiveCost, but without regard
to their effectiveness in reducing GHGs. Some technologies with low net-
cost could do little for GHG reduction. In the limit a low EffectiveCost
technology, say using a high-GHG alternative fuel could even increase
GHGs (FFVs with coal-fired corn-ethanol?). Regardless, there is no
assurance that the suite of technologies finally assembled to reach the
-------
GHG standard in this way would be the low-cost suite. The authors may
wish to consider when they recommend that the first, EffectiveCost
TARF, is appropriate.
The "CostEff' TARF on the other hand leads to an algorithm sensitive to
both cost and cost-effectiveness for GHG reductions. Such a cost-benefit
ratio can lead to optimal selection rules for packing (knapsack or budget)
problems. But some confusing terms are included in the TARF, most
notably the non-standard way in which VMT is discounted for the
purposes of this TARF (See equation top of page 11, line 1). The
inclusion of "IR" ("the annual increase in the value of CO2") in the
discount factor is done without explanation or justification. While the
term IR is never really defined (is it meant to be the growth rate in GHG
damages, abatement cost, or a CO2 tax?). It inclusion seems to conflate
considerations of social benefit (value of GHG avoidance over time with
cost (of technologies). The vehicle manufacturer's cost of GHG
avoidance is already embodied in the TARF numerator. The denominator
should perhaps only reflect the quantity of GHGs avoided. As currently
written, this CostEff TARF would not seem to be a consideration for
vehicle manufacturers whose objective is to produce a new-car fleet
meeting consumer needs and a GHG emission standard at least cost. What
objective was intended with this hybrid aspect of the TARF?
o There are other important methodological points to raise, that are discussed below
in Section 3 on conceptual algorithms.
o At this point, please allow an extended comment on the model documentation.
Clearly it is in draft form only, and there would be much benefit from improving
and clarifying it. This is not simply a matter of fastidiousness, but is an essential
aspect of making the intellectual case for this model. As it stands, understanding
the model was much more work than need be. Some specific suggestions are:
Restructure the presentation, perhaps following the pattern of a j ournal
article. (E.g., begin with stated purpose and background. Place this
model in the constellation of related models and indicate what is different
and why. Describe approach, data sources. Sample results.)
Bringing description of the "Core Program" and what the model does
toward the front.
Clarify and condense the model description. Classically, this would
involve:
State model objective (typically stating what is maximized,
minimized, or what final solution condition is sought)
State model constraints
State and discriminate between principle decision variables,
exogenous inputs, parameters, and internally calculated results.
(This is not done in the variable list of Appendix 6, which also is
incomplete. It omits AIE, PF, CAP, TCO2, IncrementalCost,
-------
TechCost, TARF, VMT, SurvivalFraction, AnnualMilesDriven,
Leakrate, RefLeakage).
State the solution algorithm and termination condition
Rigorous use of notation. Currently, for example, the subscript /' usually
refers to "year" (eqns on page 10 and 11) but sometimes indexes
technology (eqns at line 10 on p. 12).
Use consistent variable names. For example, on pp. 16 and 17, it appears
that the same variable is called "ModelSales", "Sales,", and "Annual
Sales."
Clarify subscripts and carefully apply them. The principle subscripts that
seem to apply are:
t: technology number in sequence for each vehicle type
i: actually vehicle age, which is to be distinguished from year
y: year (which indexes, eg. fuel prices)
v: vehicle type
m: ma nufacturer
For example, equation at bottom of p. 12 is missing subscripts on
AIE and RLE (presumably t), while GWP in that equation is
indexed by technology t yet elsewhere (e.g. middle of page 11) it is
not.
Carefully state units. Physical equations cannot be fully understood
without a statement of the dimensions. For example, the equation in the
middle of page 11 can be more readily understood if "Leakrate" is known
to be in [g-GHG/yr], not [g-GHG/mi].
o Overall, the authors might wish to look at the documentation of the NHTSA
Volpe model as a helpful template.
That documentation is actually reasonably compact (35 pp plus an
extended guide to operation).
It gives an excellent, succinct prose summary of what the model does in
the first 3 pages (1-3), and much of the wording might be applicable to the
EPA model.
It clearly states what is being modeled:
There is a flow chart and a technology sequencing flow chart
Equations are then presented in orderly manner with consistent notation
and subscripting.
Response: The TARFs are intended to reflect the decision making of a manufacturer. Since the
manufacturer must satisfy its customers and regulatory mandates, a manufacturer's decision
making processes will reflect these needs, as well. More explicitly, the technology cost is the
full cost of that technology at the consumer level, including research and development costs,
amortization of capital investment, etc. This cost is generally the same cost as EPA estimates in
its regulatory support analyses when estimating the cost of new standards. This cost is not
-------
necessarily the increment in price that the manufacturer would charge for that technology, since
price is a function of many factors which can change fairly quickly depending on market
conditions. The fuel savings are those assumed to be valued by the customer, so they are based
on fuel prices including taxes and reflect the timeframe which a customer might consider when
purchasing a vehicle. The residual value of the added technology is not currently reflected in
either TARF, but could be added in the future. The rationale behind the TARFs will be clarified
in the model documentation to reflect these points.
The Effective Cost TARF was included in the OMEGA model since it is the equivalent of the
technology ranking process used in NHTSA's Volpe Model. It allows a user to match this aspect
of the Volpe Model when modeling equivalent standards using both models, if this is desired.
We agree with Dr. Leiby that this TARF does not factor in the degree to which adding a
technology will move a manufacturer's fleet toward the regulatory target. The CostEff TARF
was designed to incorporate this factor.
We agree with Dr. Leiby that the inclusion of discounted GHG emission reductions in the
denominator of the CostEff TARF is not consistent with the manufacturer focus of the numerator
of this TARF. Future versions of the model will remove the discounting. The use of lifetime
emission reduction in the denominator of this TARF will then be consistent with the standards
contained in the EPA vehicle GHG proposal, where car-truck trading is based on lifetime
emissions of each type of vehicle.
The discounting of CO2 emissions is more appropriate for a TARF whose focus is societal
effectiveness. Thus, we plan to add a third TARF which is similar to the CostEff TARF and
which retains the discounting of GHG emission reductions in the denominator. Newer versions
of the model allow for an increase in the real value of CO2 emissions per annum. Thus, we
believe that the discount rate used in this new TARF should reflect the difference between the
broad economic discount rate specified and the rate of increase in the value of CO2 emissions.
When this TARF is used, it will be most appropriate to value fuel savings over the life of the
vehicle and this will be suggested in the model documentation.
We have significantly revised the model documentation, including the consideration of all of Dr.
Leiby's comments above.
3) Comments on: The appropriateness and completeness of the contents of the sample
input files. (EPA staff are not seeking comment on the particular values of the contents
of the input files, which are samples only.)
First, an overall point on data. While the instructions urge reviewers to not consider the
particular values of sample data, it must be born in mind that models are essentially
datasets, the equations which link the data, and the algorithms for achieving the solution
of those equations. In this case the model equations (in the documentation) are
reasonably straightforward, although the algorithm for their solution is somewhat opaque
(not explicitly stated and embedded within a compiled module). Assuming a reliable
solution algorithm (something hard to test in this review and with limited data), model
-------
quality will then depend strongly on the quality of model data. This is particularly worth
mentioning because many of the data needed for this model are not readily available from
established sources. The model calls for detailed, specialized, knowledge about vehicle
technologies, their costs, incremental contributions and interactions, their availability
over time and across vehicle types, and the data-providers must determine the sequence
of technology application within each vehicle type. Ultimately, this dataset is likely to be
the most valuable and significant component of this model. Particularly if it becomes
publicly available, and serves as a standard. Thus the data issues should not be
minimized.
In all data input files, it would help minimize errors if units were specified. Kilograms or
grams, etc. The "Fuel" datasheet does not indicate the unit for price ($/gge, in nominal
$?. What are the units for electricity?)
The "Data Validation" capability and error report is a very useful feature. Ultimately the
modelers may wish to error check almost all inputs for acceptable range, if that is not
already done.
Response: EPA will publish a complete set of input files which it used in its OMEGA model
runs in support of its recent proposal to regulate GHG emissions from cars and light trucks.
These input files were developed from publically available data explicitly to allow their full and
complete release to the public for review, comment and use.
We agree that better descriptions of the input data are needed. Incorporating these into the input
file headings themselves involves changes to the core model. In the near term, we have included
detailed descriptions of each type of input value in the model documentation for easy reference
by the user.
The validation criteria included in each of the model's input files generally prevent the inclusion
of clearly inappropriate values (e.g., negative values where only positive values make sense).
The current criteria apply such restrictions to nearly all the input fields other than labels. In
addition, the criteria can be modified by the user to incorporate additional or more restrictive
criteria which are deemed helpful. This flexibility will be described in more detail in the model
documentation.
2a) The elements of the Market input file, Appendix 1, which characterize the vehicle
fleet;
This file describes vehicle sales by manufacturer and vehicle type, and provides the
attributes of those vehicle types.
No specific comments at this time.
2b) The elements of the Technology input file, in Appendix 2, that constrain the
application of technology;
-------
As discussed above, this could be said to be the heart of the model. It requires both
detailed technological knowledge and considerable judgment about the sequence, timing
and impact of each technology.
o It may be worth a special task just considering what range of technology attributes
can reasonably be specified, even by a technology or industry expert.
o The possible strong-sensitivity to data specification may also call for formal
method of risk or sensitivity analysis, given limits on the ability to refine the data.
How are technology interdependences across vehicle types represented? Given
outsourcing and the cost reductions from component sharing, would the application of a
technology for one vehicle type make it more likely to be applied to another vehicle type?
I could not discern how such considerations are represented in the data, and reflected in
the solution algorithm, if they are.
The data challenge is even greater if the stated goal of representing technological learning
is pursued. While ultimately technological progress (through autonomous gains from
R&D, scale economies and learning-by-doing) should probably be acknowledged in a
later model version, benchmarking that progress is never easy. Moreover, technological
learning and progress will be a function not of choices for each Vehicle Type (as the
spreadsheet organizations suggests), but of industry-wide developments across vehicle
types and manufacturers.
o In our models on new vehicle technology introduction, we have found it useful to
distinguish between 3 types of technological progress: autonomous progress over
time due to R&D; progress or cost reduction due to production scale (units
produced per plant); and progress from Learning By Doing (LED). All three of
these play a role, but the proper benchmarking of each is quite challenging. I
agree learning should be approached, but cautiously because its specification and
parameterization can have such a pronounced effect on model results.
Spot-checking these entries, I did not see any items associated with changing vehicle size
and weight. This may be a design choice rather than happenstance for the sample data:
technologies that substantially change the vehicle design and hedonic attributes for the
consumer would call for a more rigorous assessment of net-value to the consumer, and a
potential re-statement of objective (TARF sequencing rule).
Response: Cost reductions due to learning are not yet incorporated into the model. Thus, there
are currently no connections between the costs of technologies applied to different vehicle types.
When learning is added to the model, the user will likely be able to specify whether this learning
is based on the number of vehicles which receive this technology by manufacturer or industry-
wide. The latter approach will provide a connection between technology costs across vehicle
types. We will consider the suggestions provided by Dr. Leiby as we develop the learning
related algorithms for future versions of the model. Prior to the inclusion of learning, the user
can input technology costs which reflect the anticipated use of a technology across vehicle types
and manufacturers. These projections can be compared to the results of model runs and adjusted
accordingly.
-------
As mentioned above, the current model does not allow the vehicle sales mix to change as a
function of technology. Holding vehicle attributes such as size and performance constant when
applying technologies simplifies the treatment of hedonics. A user could include a technology
which included a change in vehicle size or other attribute. In this case, the user should adjust the
cost of the technology to reflect the anticipated change in the vehicle's value from a consumer
perspective. However, the limitation of this approach is that it would not adjust the applicable
footprint-based GHG standard if the reduction in vehicle size would actually change the
vehicle's footprint. There is currently no mechanism included in the OMEGA model for
changing a vehicle's footprint from its base value. The model would also not reflect any change
in sales which might accompany such a change in vehicle size or other attribute. The user could
project a change in vehicle size in future redesign cycles and estimate the technology and cost
necessary to bring this adjusted fleet into compliance. The cost of the change in vehicle size
could then be added outside of the model. EPA does not have any plans in the near term to
incorporate a change in vehicle size and resultant changes in consumer choice into OMEGA in
the near future. One researcher, David Greene, recently concluded that, given time for vehicle
redesign, on the order of 95% of the fuel economy improvement induced by feebates is likely to
be achieved through the application of improved technology rather than a shift in vehicle sales
patterns.l Thus, ignoring changes in the fleet mix may not be a substantial limitation.
2c) Scenario input file, definition of the standard and economic conditions (Appendix
3)
2d) The elements of the Fuels input file, Appendix 4
This list does not yet reflect biofuels or renewable fuels, which are a growing
consideration, in no small part due to recent law and EPA RFSs.
Some provision may be needed for the variable energy and GHG content of gasoline,
as the ethanol content varies over time.
Provision may also be needed for E85, and the uncertain fraction of E85 use by FFVs.
The net fuel economy and emissions by PHEVs remains an area of continued study.
EPA is well aware that fuel use by fuel type and resulting emissions depend on PHEV
design (AER), consumer use patterns, time of recharging, and the fuel used for
regional grid generation. Nonetheless, some simplified representation of the
alternative PHEV designs will be needed soon. I was unable to ascertain what
progress EPA has made in this area.
2e) The reference data contained in Appendix 5. (Implied flexibilities and constraints
of the model)
No specific comments
Response: The current version of OMEGA focuses on gasoline, diesel fuel and electricity
because the vast majority of current vehicle sales are certified on these fuels. Very few
dedicated alternative fueled vehicles are sold and flex fuel vehicles are certified on either
1 "Feebates, footprints and highway safety," Transportation Research Part D 14 (2009): pp. 375-
384.
-------
gasoline or diesel fuel and numerical adjustments made to their fuel economy or emissions to
reflect incentivizing regulatory credits. Future versions of the model will allow the user to
include an anticipated level of FFV credits by manufacturer and by redesign cycle which will
effectively adjust the required level of fuel economy or GHG emission control.
Current legislation and enabling EPA regulations encourage the use of renewable fuels.
However, to date, these requirements are not integrated with the regulations governing vehicle
fuel economy, nor the standards contained in the EPA vehicle GHG proposal. Thus, the primary
place which they intersect with the OMEGA model is in the calculation of benefits. As this is
done in a spreadsheet, the user could easily modify the calculations to reflect an anticipated use
of renewable fuels over time. EPA may develop a standard version of the benefits calculation
spreadsheet in the future which facilitates this use. However, as suggested by Dr. Leiby above,
this is not the first priority at this time.
We agree that gasoline quality changes over time, but these changes are relatively small. We
will consider including a varying quality for gasoline and diesel fuel over time in the benefits
calculation spreadsheet as improvements are made to it.
At present, the model assumes that PHEVs will be driven like any other vehicle. Given the
difference in the economics of their use when driving over short and long distances, it is possible
that PHEVs will be driven differently than other vehicles. Unless this is reflected in GHG
regulations, however, the core model should treat PHEVs like any other vehicle. They could be
treated differently in the benefits calculation spreadsheet. This difference could be reflected by
the user using information already included in the spreadsheet (i.e., emission and sales per
vehicle after the application of technology). EPA will consider incorporating the potential for
such a difference once better estimates of how the operation of PHEVs might differ from
conventional vehicles becomes available.
3) The accuracy and appropriateness of the model's conceptual algorithms and equations
for technology application and calculation of compliance;
Equations for technology application:
o The sequence of technology application, and timing and extent of application, for
each vehicle type, is exogenous.
o Modelers acknowledge that "This approach puts some onus on the user to develop
a reasonable sequence of technologies." As noted, the onus may in fact be quite
substantial. Therefore, it is helpful that the model "produces information which
helps the user determine when a particular technology or bundle of technologies
might be 'out of order.'" [p. 7] Any such capability to assist the user with stage-1
exogenous technology sequencing for individual vehicle types is worthy of further
development and greater prominence in the documentation and model.
o The Volpe model seems to currently offer more facility for specifying the
structured sequences introduction of technologies or groups of technologies. The
EPA GHG Modelers may also wish to develop some tools that make it easier for
users to group and sequence technologies, perhaps even with logical diagrams that
-------
map to or from the Technology.xls dataset. This would help experts represent
their best judgement about technologies can or would be applied.
o While this model allows for substantial technological detail, there will always
arise further, potentially important, complexities. In this review I could not
determined the degree to which the model can account for cross-vehicle-type, or
cross-manufacturer, interactions in the selection and sequencing of technologies.
For example, various forms of hybridization are mentioned as technology options.
We already see that one manufacturer, Toyota, develops a hybridization
technology for one vehicle it quickly spread to other vehicles from that
manufacturer, and that same technology is also sourced to other manufacturers
(Nissan). Can this be represented in some way?
o P. 17 says: "Finally, the model determines the order in which technology
packages are added to vehicles. The model first compares the TARFs
corresponding to technology package 1 on all of the different vehicle types in the
fleet and chooses the combination with the lowest TARF."
What does "combination" mean here? I understand it to mean the model
chooses a combination (pair) of particular vehicle v and technology step t
(advancing from t-l to t).
o Technical points on the TARF-based rules for technology application (Equations
p. 14):
As mentioned, net cost ("EffCost") alone would not seem to be adequate
for sequencing GHG-reduction technologies
The inclusion of a FEE for non-compliance has some issues (admittedly,
the Volpe Model does something like this as well, but the justification is
not compelling):
It embeds the cost of non-compliance in an algorithm that ends
only with compliance. Hence the fee should ultimately be zero. Is
the intent here to employ some sort of penalty-function based
algorithm for constrained optimization?
"Non-compliance" is a manufacturer-wide condition, and cannot
be associated with a specific individual vehicle or technology
(Note: I believe the TARF measures should be subscripted with
m,v, and t, to highlight that they are specific at that level).
As written, the FEE is applied to the change in fuel economy
(mi/gge, MPG) for that particular technology step. This is not a
measure of non-compliance, and its essential effect is to exaggerate
the relative importance of fuel savings. Note that the fuel-savings
term is proportional to (FCt-i - FCt) while the Fee term is
proportional to (l/FCt - l/FCt-i), essentially a monotonic non-
linear transformation of fuel-savings. So even though there will be
compliance an no fee, the effect will be to boost the weighting of
fuel savings in a non-linear way.
A maintained assumption is that fuel economy technology will not alter
sales volume or share. But does or could vehicle sales volume influence
the choice of technology introduction? I only noted "Sales" being
referenced in the post-processing calculations, and it is used in the tests for
-------
compliance. But sales is not a consideration in the TARF for a vehicle-
technology pair, nor in the terms leading up to it, so the technology
sequencing is based entirely on per-vehicle cost analysis. This approach is
taken in other models and is not unreasonable. But if technology learning
or scale economies matter, for example, the choice of which vehicle to
apply the next technology to could be related to the sales volume of
particular vehicle-types.
As mentioned, the non-standard adjustment of VMT discounting in the
denominator of the CostEff TARF should either be eliminated or more
explicitly and rigorously motivated. As it stands it seems to either mix
social benefits of GHG reduction with the manufacturer's objective of
meeting the emission standard.
o On p. 13, the equation for Fuel Savings (FS) seems to be in error. Fuel price (FP)
is divided by /', which denotes the age of the vehicle (year after its production). Is
this simply a typographical error and a discount factor was intended (e.g.
(1+DR)1?)
In all cases where the lifetime value of fuel savings in considered, the
challenge is to be clear about whose valuation of fuel savings is being
calculated. It is widely observed that consumers, when making new
vehicle purchase, may "undervalue" fuel savings either with a higher
discount rate or a short planning period than actual vehicle operating life.
I understand that these issues are probably behind the formulation used
here, but it would help to be more explicit. If manufacturer decisions are
being modeled, the relevant question seems to be "How many years of
discounted fuel savings would the manufacturer assume it will be able to
recover from the consumer through the vehicle sale price?"
With respect to the flexibility afforded by the Volpe Model, the Volpe Model separates
technologies by the aspect of the vehicle being modified (e.g., engine, transmission, accessories,
vehicle (aerodynamic drag), etc.). A path is specified for the application of technology within
each group. These paths are embedded in the model code and cannot be modified by the user.
In contrast, with OMEGA, the user can modify the order in which technology is applied.
We agree with Dr. Leiby that the development of the technology steps is both integral to the
model's operation and a challenging task. EPA will consider developing spreadsheet tools and
procedures which will assist a user in developing such inputs. However, since modifying a
vehicle is a complex engineering task, developing model inputs which reflect such changes will
never be simple. EPA will publish its Technology input file which was used in its OMEGA
modeling to support its recent proposal of GHG standards. The regulatory support documents to
this proposal also describe how EPA developed these inputs. In general, the cost of the
flexibility afforded by the approach taken in this area is greater responsibility with regard to the
technological inputs to the model.
The OMEGA model applies technology to one vehicle at a time, but does so by evaluating the
costs and benefits of technology applicable to a manufacturer's entire vehicle line. This is
possible, since essentially every vehicle model is redesigned once during every redesign cycle.
-------
This causes OMEGA to apply more consistent levels of technology to all of a manufacturer's
vehicles. Thus, OMEGA would generally not predict the application of hybrid technology to one
vehicle, while applying little or no more conventional technology to another vehicle. The
exception would be if the TARF for the hybrid technology was less than that for the conventional
technology, meaning that the former was generally more cost effective than the latter. Models
evaluating compliance annually can sometimes apply very disparate levels of technology from
one year to the next based on the number of vehicles which can receive major technological
change in each year. Also, in our analyses in support of the EPA vehicle GHG proposal, EPA
grouped vehicles by platform and engine size. This avoids applying one level of technology to
the sedan configuration and another to the coupe configuration of a vehicle built on the same
platform.
At the same time, OMEGA would predict that Toyota, to use Dr. Leiby's example, might
hybridize the sales of the Camry up to the cap set for hybridization of this vehicle type and none
of the Corolla sales. In reality, Toyota might choose to hybridize a portion of both vehicles.
EPA does not believe that any model can predict the precise use of technology on every vehicle
for a given fuel economy or GHG standard. Models such as OMEGA produce a reasonable
estimate of the total application of various technologies and their overall cost. The user must
interpret the results at this level and avoid putting too much confidence in the model's
predictions for any specific vehicle.
Manufacturers can also introduce technologies for various reasons. Some technologies, such as
the early hybrid models, were introduced for marketing purposes and to develop experience.
Some technologies were developed for overseas markets and are sold in small numbers in the
U.S. A model which uses economic efficiency as its primary tool for applying technology will
not be able to capture these vagaries in technological application except by including them in the
baseline fleet (i.e., as being outside of the impact of the GHG controls being evaluated).
Incorporating manufacturer-based learning into the cost estimation will help somewhat, as this
will lower the cost of technology for those companies which have already applied certain
technologies in the past. However, again using Dr. Leiby's example, no regulatory model would
predict that Toyota would introduce hybrids over a number of their vehicle lines, as the use of
this technology was not driven by regulation.
On page 17 (of the model documentation), "combination" referred to a combination of vehicle
and the next technology available to that vehicle. This has been clarified.
The CAFE compliance fee is included so that the user can match this aspect of the DOT Volpe
Model if desired. As discussed in Section H of John German's comments, such a fee or fine is
not applicable to an EPA GHG standard and would normally be set to zero by the user. We
agree that the calculation of the impact of the CAFE fee was performed incorrectly in the version
of the model which was reviewed. This has been corrected.
Regarding the potential impact of sales volume on the TARF, this will need to be considered
when EPA incorporates learning into the model. Some projection of the sales volume over
which a technology might be applied will likely have to be made when calculating the TARFs.
Then, at the end of the model run, the technology cost can be adjusted to reflect the actual use of
-------
each technology. If the TARF is based on the level of technology use up to that point in the
model run, the cost of the same technology could decrease (for TARF calculation purposes)
during a run when in fact it is the same. Manufacturers can generally be assumed to be forward
looking when deciding to apply technology, considering the sales volume which will receive the
technology over at least a full redesign cycle of all of their vehicles. Of course, if the learning is
occurring at the supplier level, costs will decrease based on total industry sales, which will not
bear any semblance to the level of application occurring to the first manufacturer's vehicles. In
this case, the model output could even be dependent on the order in which the model evaluated
the various manufacturers, which is not desirable. Thus, it will likely be best to predict the
market share of various technologies, learn costs accordingly, calculate TARFs, apply the
technology and adjust costs as necessarily to reflect lesser or greater application of each
technology.
The model documentation on page 13 has been corrected.
The fuel savings are those believed to be valued by the consumer when purchasing a new
vehicle. The user sets these savings primarily through the payback period. The model then
discounts the savings using the standard economic discount rate used elsewhere in the model. If
the user believes that a consumer discounts fuel savings at a greater or lesser rate, she or he can
adjust the estimated payback period to reflect the fact that the model uses a different discount
rate in this calculation.
Calculation of compliance to Attribute-based standards:
o An overarching feature of the methodology is that progress in reducing
GHGs/fuel-use occurs by advancing drivetrain technology and other attributes
largely transparent to the consumer. Technologies are sequenced based per-
vehicle figures of merit, assuming no impact on vehicle designs (apart from fuel
use technology) and constant vehicle sales shares. One issue to consider is
whether these assumptions of unchanged vehicle and unchanged sales mix
become less defensible for attribute standards like the footprint standard.
o On page 7, equation for the logistic-based footprint, there appears to be a sign
error in the denominator (should be l+exp((x-C)/D) not l-exp((x-C)/D)). This is
likely a typo in the documentation alone.
Calculation of compliance to possible market-based standards
o No discussion or provision for market-based (permit trading) standards is yet
made. This should at least be acknowledged.
o One strategy for doing more flexible standards would be to simply merge the
datasets and technology-sequence stage for all manufacturers and vehicle types in
a trading group. However, this would not provide information about potential
permit prices and burdens across manufacturers.
Response: EPA believes that the vehicle sales mix will actually be less affected by attribute-
based standards compared to universal or flat standards. A universal standard encourages
smaller vehicles. An attribute-based standard applies a more stringent standard to smaller
vehicles, negating some or all of the natural reduction in GHG emissions which comes with
reducing vehicle size and weight. In either case, the relationship between consumer purchase
-------
preferences, vehicle cost and fuel economy is very complex and not well assessed. A number of
models have been developed to simulate these relationships, but they appear to differ
substantially, especially regarding consumers' valuation of fuel economy. EPA may incorporate
such effects into future versions of OMEGA. However, a first step in this direction would be to
couple the two types of models and run them iteratively and see if they converge.
The documentation of the constrained logistic curve formula has been corrected.
The inclusion of permit-based trading beyond the light-duty vehicle market is currently beyond
the scope of the model. We agree with Dr. Leiby that the user could simulate the net impact of
flexible credit trading across manufacturers by labeling all vehicles with the same manufacturer
name. In addition, examination and analysis of the compliance cost per vehicle should provide
sufficient information to estimate the permit prices implied. However, the user would have to
develop these algorithms.
4) The congruence between the conceptual methodologies and the program execution
(examining the results with good engineering judgment)
This is difficult to assess and a careful validation of this model's execution would require
further examination. The results appear generally reasonable, but that is a weak test.
I was only able to experiment with cases for one design cycle. The longer-term cases
involving multiple design cycles are more challenging. It has been noted the model
solves for design cycles independently of one another. So it would be worthwhile to test
what this implies for the sequence of technologies used from one cycle to the next.
One observation is that the inclusion of the non-compliance FEE does affect the model
solution and choice of technologies. As mentioned above, the theoretical justification for
this is not well formed, given that all manufacturers are typically assumed to end in
compliance. However, I did not that the impact of including the FEE is modest, only
changing per-vehicle costs by a few dollars. However, for at least one manufacturer (#9)
the cost and technology sequence changes significantly. I am not sure this is a desirable
outcome.
Also, simple tests with the sample dataset show a relative insensitivity to the choice of
TARF. This was surprising, and needs more investigation.
Response: The limited role of the FEE was discussed earlier. We assume that Dr. Leiby is
referring to an insensitivity of the TARF to a change in the value of the FEE. This is not
surprising, since the CAFE fine of $55 per mpg is much smaller than the fuel savings associated
with a 1 mpg change in fuel economy. The level of the FEE has little effect on the order of
technology application since it tends to reduce the value of the TARF for all technologies
roughly proportionately to the fuel savings already included in the TARF calculation.
5) Clarity, completeness and accuracy of the calculations in the Benefits Calculations output
file, in which costs and benefits are calculated;
This system produces a large number of useful side calculations.
Again, further investigation is necessary to investigate their accuracy.
Overall, a careful independent validation of the two phases of this model's execution
(manufacturer compliance simulation and effects calculation) would be well worthwhile.
-------
The code for compliance simulation is compiled and not visible. Working through the
logic in the post-processing calculations of the BenefitsCalculation spreadsheet would
take a bit of time. But it would be worthwhile. Overall a useful validation effort could
probably be complete in about a week of focused attention.
Response: The inclusion of a value in the benefits calculation is not meant to automatically
convey accuracy. This will be clarified in the model documentation. The user is ultimately
responsible for all input values used in the modeling. Of course, if the user uses an input file
published by EPA in some context other than simply providing an example, then the EPA
analysis referencing that model run will support the choice of values used. As Dr. Leiby noted
above, review of the inputs to the model or benefits calculation spreadsheet was not part of the
peer review charge.
EPA's publishing of the results of its OMEGA modeling and estimated benefits of the proposed
vehicle GHG standards should accomplish much of the task referred to in Dr. Leiby's last
comment, as such inputs and outputs will be subject to a full review by the public during the
comment period for that proposal.
6) Clarity, completeness, and accuracy of the model's visualization output, in which the
technology application is displayed; and
The XML format for data transfer and display is a very good design choice, allowing
flexibility, modern data-exchange capability, ready output to internet, and easy extension
of the report.
This display in the visualization output is useful overall, but it seems more oriented
toward "expert users" who are willing to wade through details to find understanding and
the information they need.
o TechPack are reference by number only, but perhaps could easily be labeled with
the full name or 4-character abbreviation, or cross-reference by hyperlink to a
description of the technology.
o Additionally, hyperlinks could be added that would allow the user to easily jump
to the table for a particular manufacturer or vehicle type.
It would be very helpful to have some graphical summaries of the input and output
results.
All output files should embed clear documentation on the inputs used. E.g.
o The .log file does list names of the 4 input files, which is essential.
o The "Visualization Output" file does not (yet) report the input files (but the
information could be retrieve from the XML file).
EPA has improved the formatting of the output files, including better labeling of technology
packages which have been applied. We will consider the use of hyperlinks and graphical outputs
in the future. Output files now include date and time stamps plus the names of the input files
used.
7) Recommendations for any functionalities beyond what we have described as "future
work."
-------
Clearly defined improvements that can be readily made based on data or literature reasonably
available to EPA
o First I note that there were multiple references to "future work." It may be helpful for
EPA to construct a list of these prospective improvements, and establish priorities and
a staged, progressive approach for revision. Specific releases of the model with
carefully specified functionality will allow prospective users at EPA and elsewhere be
clear about what the model is and can do at any point in time.
o While the model has a number of valuable aids to execution and reporting (input
validation, automated generation of run logs, XML data, and "Visualization" tables
for web/browser display), more could be done here to improve usability and provide
greater insight about each case run. Comparatively simple revisions and extensions
to the operational procedures and output could be well worthwhile.
Provision for side-by-side case comparisons, reporting or graphing difference.
Case management and logging facilities.
Currently the system labels every file with generic name concatenated
to a time-date stamp. Very quickly a directory can be cluttered with
cryptically named log, xml, htm files.
A case archiving facility, that compresses all input and output files to
document the case, might be useful
The ability to specify a CaseName in the Scenario file, that then
becomes part of each output file, would also be helpful.
When the VGHG.exe file reads a scenario file, it does not record, or at
least display, the name of the file read. It is easy to forget which case
was read if you step away, or are doing many cases.
Relatedly, the purpose of the VGHG.exe's separate menu options is
not yet clear to me.
o It seems that once a scenario and the associated datafiles are
read, execution would be the logical next step. The scrollable
tables from data input are really too constrained a view to
allow useful review or verification of the data.
o Once the case is run, it seems "Save" to XML might be
automatic, otherwise one is limited to the text-based log files,
that omit summary information. "Saving" seems needed for
Visualization and Benefits Calculation in the spreadsheet.
o So perhaps VGHG.exe might load-run-save in one step,
although I may be missing something important.
Graphical capabilities [more thought required here about exactly what graphs
would be most useful. But there are many data in the tables, and they are not
simple to process mentally.]
Improvements that are more exploratory.
o Extension to accommodate flexible/market-based emission or fuel-economy
regulations.
-------
Permit trading extensions, constructed by pooling selected vehicle
types/classes, and/or manufacturers, during the compliance phase of the
analysis.
Ex post calculation of implied permit prices based on marginal costs of
compliance (measured by the cost/GHG reduction of the final technology
pack applied).
Ex post calculation of economic implications for individual manufacturers, by
comparing results with and without trading/pooling, and accounting for the
implied costs and revenues from permit exchanges between manufacturers.
o Extensions to consider endogenous (standards-induced) changes in vehicle attributes.
These are a higher challenge, but would be very valuable for an improved
understanding of the market responses to regulations.
Endogenous changes in sales volume/mix
Endogenous changes in vehicle size/footprint
Response: EPA appreciates these suggestions and will consider them for future model
development activities
C. Comments by Dr. Jonathan Rubin
I would like to congratulate the EPA for undertaking to build this tool which will be very useful
for possible regulatory compliance and anticipated and unanticipated policy analyses. The
construction of such a tool requires extensive expertise, professional judgment, necessary
compromises and assumptions. The validity of the output will of course depend on these factors
as well as the data available to populate the model.
My comments are based on my review of the materials provided to me by Southwest Research
Institute: the EPA vehicle GHG Emission Cost and Compliance Model Description and
associated attachments and appendices and the VGHG model and the associated spreadsheets.
These comments reflect my understanding of EPA's possible use for this model for regulatory
compliance as well as use by external researchers and policy analysts who may use the model for
analyses of state and regional policies.
My comments below respond to the particular questions posed in the transmittal letter from
Southwest Research Institute.
Overall Approach to the specified modeling purpose and the particular methodologies
chosen to achieve that purpose
The authors have clearly put in a great deal of work on this challenging project and should be
commended for an excellent start. That said, more effort and thought needs to go into what I call
the accounting stance. On page 2, line 42-43 (p. 2,1. 42-3) the documentation states that "The
primary cost of the GHG emission control is the cost of the added technology compared to the
baseline." My question is: "cost to whom?" Costs to consumers will differ from costs to society
or costs to manufacturers. At times, the documentation reads as though these are costs to
-------
manufacturers - since CAFE fines are considered; other times the costs seem to be towards
consumers or society. These accounting stances will differ for several reasons: 1) private and
social discount rates differ, 2) social and private risk differs (on average technology performs as
well as expected, but not for each vehicle), 3) subsidies to purchase plug-in vehicles or other
advanced technology vehicles drive a wedge between private and social costs, 4) subsidies to
biofuels and electricity at the state level (exemption for some or all road-use tax) mean that
consumer costs are not equal to full resource costs. Clarifying the accounting stance is a high
priority, because many further calculations rely on its clear definition.
Since the potentially regulated agents are vehicle manufacturers, my recommendation is to
define costs as the costs to manufacturers of incremental technology and vehicle re-design costs.
The net costs to manufacturers are equivalent to the incremental costs of fuel economy
technology less any increase in retail prices that manufacturers can charge for more fuel efficient
vehicles. This should be equal to some portion of the expected fuel savings plus any changes in
the hedonic value of vehicles due to changes in vehicle performance, noise, size, and refueling
time (more on this later). By separating out manufacturing costs more clearly from consumer
valuation of vehicles, the presentation will be more transparent. This also will make clearer the
distinctions between consumers' rates of discount from manufacturers' costs of capital from
society's rate of time preference.
Additionally, I recommend that the net costs clearly incorporate and identify all subsidies (for
electric or plug-in hybrid vehicles and alternative fuels) but display costs and benefits separately
to private agents (manufacturers, consumers) and society. These will generally not be the same.
For example, the benefit calculation spreadsheet "Externalities" adds together consumer money
saved on fuel with savings from lower oil imports. I would be very surprised to learn that the
assumptions of the discount rate or risk premium or both in the calculation of benefits of reduced
crude oil imports are the same as consumers' discount rates for expected future gasoline savings.
Response: Broadly speaking, the model is designed to project the application of technology
which is controlled by the manufacturer of the vehicle, but which is also influenced by consumer
preferences and governmental requirements. Then, once this technology has been selected, the
model sums up the costs and benefits associated with the application and use of this technology
from the view of society in the benefits calculation spreadsheet. This is consistent with EPA's
approach to the estimation of costs and benefits in its mobile source rulemaking analyses,
including the recently proposed vehicle GHG standards. EPA often evaluates costs and benefits
using two or more discount rates, reflecting the time value of money from different perspectives
(e.g., private and public). The user of the OMEGA model can perform this task by modifying
the discount rate in the benefits calculation worksheet after the results for any particular
OMEGA model run have been loaded. In the analyses supporting the proposed vehicle GHG
rule, EPA developed technology costs which are based on piece costs, the cost of assembly plus
an intermediate markup factor which accounts for indirect corporate level costs and a reasonable
level of profit. These costs were used in the OMEGA model to estimate the average cost of
added technology per vehicle for the rule. Thus, they were used to represent the cost per vehicle
from both manufacturers' and society's perspective. As EPA develops the OMEGA model
further, particularly if the explicit treatment of capital investment requirements is incorporated in
to the technology application process, it may be more important to explicitly treat technology
-------
costs differently depending on entity experiencing the cost (e.g., manufacturer, consumer,
society).
A special case where such separate treatment of costs could be very important is the availability
of subsidies of the purchase of vehicles equipped with certain technologies (e.g., plug in hybrids,
electric vehicles, etc.). As discussed further below, if sizeable subsidies apply to vehicles
equipped with technologies which are being added by the model, these should be reflected in the
manufacturer's choice of technology. Currently, the model does not facilitate the availability of
purchase subsidies. Their existence must be addressed by using different costs per vehicle when
technology is being selected and when societal costs are being determined.
In addition to the use of these costs when summing up the cost of technology at the vehicle,
manufacturer and industry levels, the model also uses the same technology costs to calculate the
TARF, which is in turn used to decide which technologies get applied to specific vehicles. The
TARF does not necessarily reflect the perception of costs by society. The two TARFs currently
included in the model are intended to reflect the decision making of a manufacturer and thus,
reflect costs from the point of view of the manufacturer. Since the manufacturer must satisfy its
customers and regulatory mandates, a manufacturer's decision making processes will reflect
these needs, as well. More explicitly, the technology cost is the full cost of that technology at the
consumer level, including research and development costs, amortization of capital investment,
etc. This cost is generally the same cost as EPA estimates in its regulatory support analyses
when estimating the cost of new standards. This cost is not necessarily the increment in price
that the manufacturer would charge for that technology, since price is a function of many factors
which can change fairly quickly depending on market conditions. The fuel savings are those
valued by the customer, so they are based on fuel prices including taxes and reflect the
timeframe which a customer might consider when purchasing a vehicle. The residual value of
the added technology is not currently reflected in either TARF, but could be added in the future.
The rationale behind the TARFs will be clarified in the model documentation to reflect these
points.
The same technology costs are used in summing up the cost of all the technology which is
applied to vehicles in benefits calculation worksheet. This is consistent with the treatment of
technology costs in regulatory analyses supporting recent EPA rulemakings, including the
recently proposed vehicle GHG standards. These analyses often develop the consumer level
costs from material costs, labor, capital investment and profit at the supplier and manufacturer
level.
The current OMEGA model does not account for the availability of subsidies toward the
purchase of certain types of vehicles, such as PHEVs or EVs. Such subsidies clearly affect the
consumer's valuation of these vehicles and the likelihood that manufacturers would implement
these technologies. In terms of the model's proceses, these subsidies change the cost of
technology as perceived by the consumer as reflected in the TARF. A user could reflect this by
including the subsidy in the cost of these technologies in the Technology file. The OMEGA
model would then apply the technology considering the subsidized price. The user would then
have to add the value of the subsidy to the costs as estimated in the benefits calculation
-------
spreadsheet (and other output formats) in order to fully estimate societal costs. This limitation
does not affect EPA's use of the OMEGA model in support of its proposed vehicle GHG
standards, as none of the technologies projected to be required currently receive subsidies.
However, this issue could be important for analyses evaluating vehicle GHG standards further
out into the future. EPA will consider ways to incorporate such subsidies into future versions of
OMEGA.
2) The appropriateness and completeness of the contents of the sample input files.
d) The elements of the Market input file, as shown in Appendix 1 of the model description,
which characterize the vehicle fleet
If the data are available, it would be useful to have the cross-price elasticities for makes and
models or model segments such that mix-shift impacts could be taken into account as vehicle
prices rise in response to additional technology packages.
Some of the market data are interesting, but do not seem necessary. For example, what is the use
of knowing a vehicle's structure (e.g., unibody) or the maximum seating capacity?
Does the market spreadsheet contain data for mid-size trucks, gross vehicle weight 8,500 -
10,000? If not, I would think it should, given that they are now covered under the revised light
truck CAFE rules.
Response: EPA agrees that it would be desirable at some point to incorporate the impact of
increased vehicle cost, improved fuel economy and other factors on vehicle sales. However, this
is beyond the scope of the OMEGA model at this point. The relationship between consumer
purchase preferences and vehicle cost and fuel economy is very complex and not well assessed.
A number of models have been developed to simulate these relationships, but they appear to
differ substantially, especially regarding consumers' valuation of fuel economy. EPA may
incorporate such effects into future versions of OMEGA. However, a first step in this direction
would be to couple the two types of models and run them iteratively and see if they converge.
As mentioned in Section G of Mr. German's comments, the current market file format includes
several vehicle parameters, such as weight, seating capacity, etc., which are not currently used by
the model. These aspects of the vehicle were included in the Market file as place holders for
potential attribute based standards which could be based on these factors. We will modify the
model documentation to clarify that these data fields are not used by the model.
The example market file provided the peer reviewers does not necessarily include all vehicle
classes potentially addressed by future GHG regulations. The OMEGA market file which will
be published as part of EPA's proposed vehicle GHG rule will include medium-duty passenger
vehicles which are above 8500 pounds GVWR.
e) The elements of the Technology input file, in Appendix 2, that constrain the application
of technology
-------
Are the incremental costs shown in column X retail or wholesale? What do they assume about
the volume of production? If I read the file correctly the incremental price for plug-in hybrid
technology often has a low first cycle cap of 5%. Is the incremental cost of this technology
consistent with its use on 5% of a market segment of a given manufacturer? It is important to
clearly define the relationship between scale of use and incremental technology cost. The
columns "a", "Decay", "seedV", "kD", and "cycle learning available" need further clarification.
P. 2,1. 14 notes that the GHG target can be set as a function of vehicle footprint. The technology
input file does not show an indication of how down-weighting and changes in footprints may be
used to meet a set of given standards. This may not be able to be accomplished immediately
given available data, but it should be considered as more experience with the footprint standards
is gained from CAFE compliance.
Response: Please see the response under Section #1 above for a discussion of how technology
costs are treated in the model. As described in the peer review charge, the specific inputs
provided to the reviewers were for example purposes only. Therefore, they do not represent any
particular sales volume. EPA has published the Technology file which it used in its OMEGA
modeling in support of its proposed vehicle GHG standards. This file contains official EPA cost
estimates and the Draft Joint Technical Support Document for the proposed rule describes how
they were developed.
We agree with Dr. Rubin that the model documentation did not describe how the Initial
Incremental Cost, a, Decay, seedV, kD, and Cycle Learning Available fields are used in the
model. These inputs are related to the prediction of cost reductions due to learning, which has
not yet been implemented in the model. These columns appear in the Technology file as place
holders for future version of the model.
Weight reduction can be a technology which is input to the model or part of a broader
technology package input to the model. The effectiveness and cost of this weight reduction is
estimated in the same manner as any other technology. EPA included weight reduction in the
technology packages which it evaluated in support of its recent proposed vehicle GHG standards.
In doing so, EPA held vehicle size, footprint, utility and performance constant.
It is currently not possible to include a technology in the model which changes a vehicle's
footprint. The TARF for such a technology would be quite complex, since both the
manufacturer's corporate-wide emission standard and the vehicle's emissions would change
simultaneously. It is possible that the technology could move the manufacturer further from
compliance. Such a change would also likely change a vehicle's utility and its perceived value.
Thus, this would be a step towards projecting a change in sales mix as a function of technology
-------
cost, which is currently beyond the scope of the model. It is possible that such capability could
be added in the future.
f) The definition of the standard and economic conditions in the Scenario input file, as
shown in Appendix 3
As per my earlier comments, I think there ought to be a place for 3 different discount rates:
consumers, manufacturers and society. Similarly, their ought to be a places for payback periods
for consumers and society.
Response: As mentioned above, the TARF calculation focuses on the point of view of the
manufacturer. As discussed in Section 1 above, a manufacturer may view technology costs
differently than society. This difference can be reflected in the development of the per vehicle
technology cost (i.e., the amortization of any capital equipment or other investment required to
implement the technology). In the TARF calculation, the technology cost occurs at the time of
vehicle purchase, so it is not affected by the discount rate assumed. The treatment of the
increased cost of vehicles across model years occurs in the benefits calculation spreadsheet. The
costs and benefits addressed there are intended to reflect those of society. Thus, use of societal
discount rate is appropriate at that point.
The primary place where a consumer discount rate comes into play is in the value of the fuel
savings in the TARF calculation. It is likely that the typical new vehicle purchaser discounts fuel
expenditures differently than society. However, the user also has the flexibility to set the
payback period over which these fuel savings are determined. To the degree that the consumer
discount rate differs from the societal discount rate, the user can adjust the otherwise appropriate
payback period to compensate.
d) The elements of the Fuels input file, as shown in Appendix 4, which characterize the fuel
types, properties, and prices
It would be useful to reference the data sources for many/most of the data items. For example,
energy density - please see EIA report XYZ. The value shown for gasoline, for example, at
115,000 is different than that published by the USDOE, Transportation Energy Data Book v 27
(Davis, Diegel, Boundy, 2008, Table B4), which shows a (lower heating) value of 115,400
Btu/gallon.
The units should also be displayed for all inputs. Again, using the gasoline example, being
familiar with the data, it is clear that the unit of analysis is Btu/gallon (lower heating value). For
other data, the units are less obvious. For electricity, the input file or the documentation, or both,
should give the assumed conversions from kilowatts to energy density or motive energy such that
users can adjust for different end-use efficiencies. Also for electricity, the assumed grid mix
should be given with conversion rates such that users can make appropriate adjustments for
different policy analyses.
I do not see a statement indicating whether the fuel price data is in nominal or real dollars.
-------
I do not see a row for ethanol giving its energy density, mass, and density. I am assuming that
fuel type "EL" is electricity. Also, should you not have at least two types of ethanol - corn and
cellulosic - with different price paths?
As I indicated in my earlier comments, I think it is important to explicitly note the role of
subsidies when determining costs. Given this assertion, the fuels data file ought to explicitly note
federal and state average subsidies (i.e., the federal blender's tax credit and foregone state excise
taxes) for ethanol and other alternative fuels. As I note below in 7) Extended Functionality,
accounting for foregone taxes is a logical addition to the model, especially when considering
plug-in electric hybrid vehicles.
Response: We will attempt to document the values contained in the input files distributed with
the model. This has been done for the input files published with the proposed GHG vehicle
standards. However, some of the inputs are for example only. This will be indicated in the
model documentation.
Incorporating the units of the various input fields into the input file headings themselves involves
changes to the core model. In the near term, we have included detailed descriptions of each type
of input value in the model documentation for easy reference by the user.
Fuel prices are intended to be in terms of real dollars. This will be clarified in the model
documentation.
The current version of OMEGA focuses on gasoline, diesel fuel and electricity because the vast
majority of current vehicle sales are certified on these fuels. Very few dedicated alternative
fueled vehicles are sold and flex fuel vehicles are certified on either gasoline or diesel fuel and
numerical adjustments made to their fuel economy or emissions to reflect incentivizing
regulatory credits.
Current legislation and enabling EPA regulations encourage the use of renewable fuels.
However, to date, these requirements are not integrated with the regulations governing vehicle
fuel economy, nor the recently proposed vehicle GHG standards. Thus, the primary place which
they intersect with the OMEGA model is in the calculation of benefits. As this is done in a
spreadsheet, the user could easily modify the calculations to reflect an anticipated use of
renewable fuels over time. EPA may develop a standard version of the benefits calculation
spreadsheet in the future which facilitates this use. However, as suggested by Dr. Leiby, this is
not a first order priority at this time. It is not clear, however, that two types of ethanol would be
needed. The price of ethanol in each calendar year would simply have to reflect the price
expected given the two sources of ethanol. The upstream emissions would also reflect the mix of
the two production paths.
The model currently does not convert electrical energy into liquid fuel energy or vice versa. The
two types of energy are tracked separately. The benefits calculation spreadsheet currently only
tracks gasoline use. The capability to track diesel fuel and electricity use will be added soon.
-------
We plan to reflect fuel excise taxes in the benefits calculation in the near future. Changes in
these taxes could then be tracked separately from changes in fuel costs from a societal
perspective.
e) The reference data contained in Appendix 5 which are currently hard-coded into the
model but, in the very near future, will be contained in a user controlled input file.
The Exclusive Inputs spreadsheet anticipates E10 and E85. It would seem fairly straightforward
to allow for other blends such as El 5. The proportion of the ethanol that comes from cellulosic
sources in each year should be accounted for such that upstream CC>2 emissions can be properly
credited, similarly for petrodiesel and biodiesel.
Response: EPA agrees that when ethanol blends and other renewable fuels are added to the
benefits calculation spreadsheet, it would be reasonable to include the annual split of ethanol
from corn and cellulosic feedstocks.
3) The accuracy and appropriateness of the model's conceptual algorithms and equations
for technology application and calculation of compliance;
On p. 9, 1. 40, the documentation states: "The core model then adds the effectivenesses and the
costs of the technology addition until each manufacturer has met the standard or until all
technology packages have been exhausted." Given that existing law allows credit averaging
across all vehicles sold by a manufacturer, this requires that compliance would be checked
through an iterative routine. Please describe this routine including mechanisms to prevent
cycling so that convergence is assured.
p. 10. VMT is given by: ^r = SurvivalFraction * AnnualMilesDriven z believe this is this
done by vehicle class (from the data file). The documentation should index the function with
separate subscripts.
p. 10. Discounted VMT. I have two issues with this calculation. The first is mechanical. Why
DR
1
VMT =VMT
' ly-L-L D,FS,i ylyi-Li
^ ' does the numerator have the term l+DR/2? Is the discount rate not
understood to be the simple annual rate? (Also what do the indices D and FS represent?).
Conceptually, however, I do not think this VMT should be discounted. Costs and benefits are
appropriately discounted, but I think it is a mistake to discount a physical calculation. It blurs the
distinction between consumer and society valuation of VMT and can lead to misleading outputs.
This point is further emphasized by calculation of VMT for GHG calculations (p.l 1)
DR-IR
1 +
\ + > , where VMT is enhanced by the rate in change in the value of
-------
CC>2, IR. I strongly suggest that this equation be re-done to separate out measurement of
physical units (VMT) from cost and value calculations.
p. 11.RCO2
RCO2(glmi) =
Lifetime
(years)
2]RefLeakage, .xGWP
i-l
Lifetime
(years))
i=l
Lifetime
(years)
Z
1=1
LeaL
Lifetime
(years)
Z
1=1
1-f
(1 +
1
raff'"(i
Z)/?-//?
2
ฃ>/? - IR)'
DR-IR
\
2
xGWP
LifetimeLeakage x
+ DR- IR)'
GWP
LifetimeVMT
I have two comments. First, it seems to me that, as with VMT, the numerator ought to be
multiplied by the survival function. Second, as with VMT, the leakage rate ought not to be
adjusted by DR and IR. Also, again, I do not understand the form of the adjustment - why
multiply the numerator by 1+ (DR-IR)/2? Should not the GWP be indexed by i?
p. 12. Determine the order of Technology Application. On the previous page the subscript /'
represented "year" here it represents technology package. The use of subscripts should be unique
throughout the documents.
P. 12. Intermediate calculations for each vehicle type. It appears that the subscripts have changed
again. CO2 is indexed by t and AIE, RIE are missing subscripts altogether.
p. 13. Calculate the fuel consumption before and after technology additions.
C02._,
44gCO2
UgC
. Given that CD is in units of carbon, this equation looks unit-less
(CO2/CO2). Where do gallons per mile units come in?
P. 13,1. 18. In step iii, calculating fuel savings we see the following equation.
pp
FS = FC,
FC,
pp pp
*1 -t -t o
- > ฑ-
PP
PP
, rr<
+ FC-, x
Z7P
9
First, why is FP divided by /'? Second, where is the adjustment for vehicle age? How does this
equation account for consumers' choosing to drive more miles using one fuel v. another?
(Consumer's may want to maximize the time they spend in electric power mode.) Even if the
data do not exist to parameterize the model yet, I suggest that the functionality be built in to
allow for consumers' choosing to use one fuel type or another.
P. 20,1. 38-46. In calculating the impact of the reduced time required to refuel vehicles, I do not
see a mention of the estimated driving that will occur using electricity in PHEVs.
-------
Response: The model does not currently require any iteration to determine compliance after
each step of technology addition. Prior to technology addition, the model determines the
corporate average standard for the manufacturer's fleet of vehicles. The model then checks to
see if the manufacture complies with its baseline vehicles coupled with vehicle sales in that
redesign cycle. If so, the model does not add any technology. If not, the model begins to add
technology to individual vehicles using the TARF to make it decisions. After each step of
technology addition, the model recalculates the manufacturer's corporate average emission level
to determine if compliance has been achieved. This continues until compliance is achieved or
there is no more technology to apply.
The issue of discounting the CO2 emission reduction is discussed in Section 1 of Dr. Leiby's
comments. Discounting has been removed from the CostEff TARF which takes the point of
view of the manufacturer. However, we are considering leaving the discounting in for a third
TARF, which would take the viewpoint of society. In theory, it is the value of CO2 emissions
which is being discounted. However, since the base value of CO2 emissions would be the same
for each TARF, its inclusion in the formula has no effect on the relative TARF ranking. Thus,
we will continue to simply discount emissions. This will be explained in the model
documentation.
The inclusion of the factor of one plus one half of the discount rate is to discount to the middle of
the year, to recognize that emissions occur throughout the year and not at the end of the year.
CO2 emissions from the tailpipe occur in proportion to VMT. Thus, the measurement or
calculation of CO2 emissions per mile is straightforward. Refrigerant emissions do not occur in
proportion to VMT. These emissions can be placed on a per mile basis, but only by measuring
or calculating refrigerant emissions over a period of time and dividing by the typical amount of
driving occurring over that period of time. Also, due to gradual vehicle scrappage and a gradual
reduction in VMT per year as vehicles age, CO2 emissions are somewhat front-loaded towards
the beginning of a vehicle's life. In contrast, refrigerant leakage is near zero when the vehicle is
new and increases as the system ages and begins to leak. Therefore, when putting lifetime
refrigerant emissions on a per mile basis, it is important not to simply divide by the vehicle's
lifetime miles, but to also consider the timing of these miles through discounting. This places a
unit g/mi reduction in both tailpipe CO2 and refrigerant emissions (in terms of their CO2
equivalent) on a comparable basis. The suggested changes to model documentation have been
made.
The equation for fuel consumption (FC) is correct. CO2 represents CO2 emissions per mile and
CD represents grams of carbon per gallon of fuel. Thus, the units of FC are gallons of fuel per
mile.
The equation for fuel savings in the model documentation is incorrect. (The equation in the
model itself is correct.) The fuel price should not be divided by i. Instead, it should be divided
by the payback period. Also, the fuel price should be a function of calendar year (i.e., be
subscripted with "i". This will be corrected in the model documentation.
-------
The reduction in refueling time does not yet consider the impact of recharging PHEV batteries.
This will be noted in the model documentation. Future versions of the model will reflect an
estimate of the time that it takes to connect and disconnect the vehicle to an outlet, probably each
action performed once per day.
4) The congruence between the conceptual methodologies and the program execution;
As suggested, I made changes to input values in the spreadsheets and re-ran the model. The
changes as displayed in the benefits calculation spreadsheet were what I had qualitatively
expected.
5) Clarity, completeness and accuracy of the calculations in the Benefits Calculations
output file, in which costs and benefits are calculated;
Please see my comments in the beginning of the document. I believe that the benefits
calculations should more clearly reflect benefits and costs to three different agents:
manufacturers, consumers and the nation.
Recognizing that the benefits data (Benefits Calculation workbook) is subject to change, it would
be really useful to list the data sources for all inputs. For example, if the VMT data is coming
from MOBILE6, the VMT_Lookup spreadsheet should clearly state MOBILE6 as its source and
similarly for the other inputs and spreadsheets.
Similar to the formula used to discount VMT, the spreadsheet "ExternalVMTCosts($)" discounts
r\
externalities using the formula: -; - ^-- . My question is why? Most commonly used discount
factors are simple -, - r- annual rates. In some senses it does not really matter because the
(l + DRj
user can set the discount rate, but by using a non-standard discount rate this is likely to lead to
unnecessary confusion.
In the "Benefits Calculation" workbook, the worksheet, "Emissions_Fuel Conservation" shows
upstream savings from NOx, VOC, CO, PM, and SOx. These emissions savings are all
calculated based on upstream conventional gasoline emission savings. I would think that either:
1) these should be based on a weighted average of gasoline, diesel, ethanol, and electricity
upstream emissions, or 2) the gallons saved should have been weighted gallons. I cannot readily
determine if the saved gasoline gallons are weighed by the proportion of gasoline, electricity,
ethanol and diesel (and the weights would be emission-gallon weights.) This needs to be clarified
or corrected.
In the "Benefits Calculation" workbook, the worksheet, "ExternalVMTcosts($)" displays the
discount factor applied to future costs as the common discount factor used throughout the model.
As I earlier suggest, society's rate of discount for accidents costs (human life) are not likely to be
the same as consumers' rate of discounting future gasoline savings. These should be separate
inputs.
-------
In the "Benefits Calculation" workbook, the worksheet, "DownstreamCosts($)", the units on
CO2 are shown as "$/ton". I believe that the label is missing the modifier, "metric".
In the "Benefits Calculation" workbook, the worksheet, "UpstreamCosts($)" shows benefits
determined for CO, VOC, NOx, SO2, PM2.5 all based on emission factors for conventional
gasoline. As per my earlier comment, I think these ought to use separate emission factors for
each fuel.
In the "Benefits Calculation" workbook, the worksheet, "All Costs" shows costs in aggregate for
the nation. It would be useful to also display the average, per vehicle costs.
Response: Dr. Rubin's comments referring to the calculation of costs and benefits to
manufacturers, consumers and society, referencing input values, and discounting procedures are
addressed in previous sections. As mentioned above, the primary focus of the benefits
calculation spreadsheet is the estimation of societal costs and benefits.
The benefits calculation spreadsheet currently assumes that all changes in fuel consumption are
in terms of gallons of gasoline. The properties of and emissions from the production and use of
this fuel can and should consider that "gasoline" in the U.S. includes a substantial volume of
ethanol. This is clearly an approximation, but a reasonably good one for the light-duty motor
vehicle fleet in the U.S. The explicit consideration of the cost and emission impacts related to
other fuels will be added to a future version of the benefits calculation spreadsheet.
Labeling of units in the benefits calculation spreadsheet has been made more specific. "Metric"
has been added, where appropriate. We agree that displaying the average cost per vehicle would
be useful. Other model output files show this figure, but the benefits calculation spreadsheet
should, as well.
6) Clarity, completeness, and accuracy of the model's visualization output, in which the
technology application is displayed; and
In displaying the results Average Incremental Costs, please round to the nearest dollar; showing
two digits to the right of the decimal point gives a false sense of precision and makes the output
harder to read.
Response: We agree that showing costs in terms of dollars and cents is overly precise. This will
be revised.
7) Recommendations for any functionalities beyond what we have described as "future
work."
The model (VGHG) window box should be made larger - perhaps fill the screen. It is really too
small to perform step 4 in running the model (i.e., Verify that the correct data has been populated
into the VGHG model). There is also no side-to-side scroll to see the whole data field.
-------
Given the renewable and advanced biofuel requirement in the Energy Independence and Security
Act of 2007, it would seem that the model ought to have data input fields to allow users to
specify the quantities (or proportions of total fuel) of ethanol and biodiesel used in each year.
Moreover, the proportion of biofuels which come from cellulosic sources should also be able to
be specified. Accordingly, the GHG emission accounting framework will need to capture that
proportion of the reductions due to changes in vehicles and that proportion due to changes in
fuels. In anticipation of future developments in the biofuels market, it may be worthwhile to
build in placeholder functionality to account for domestic versus imported biofuels or biofuel
feedstocks.
The model would be significantly enhanced if it were made probabilistic. Given that input data
contains underlying uncertainty (What is the actual cost of a given technology? What will be the
price of gasoline in 5 years?), the model should be made to run hundreds or thousands of times
using Monte Carlo analysis on some of the key input data to generate a distribution of outcomes.
Even if this is not done in the near term, having the output columns show results for "high and
low" cost/interest rate scenarios would be convenient. It would save having to run the model
multiple times and pulling the results in to some other summary worksheet.
The documentation notes (p. 2) that the primary cost of the GHG emission control is the cost of
the added technology as compared to the baseline. I do not think this is a valid presumption for
large changes in GHG emission control. The NRC's study on CAFE assumed that vehicles were
hedonically equivalent. Given the likely wide-spread adoption of diesel technology and, quite
possibly, plug-in hybrid vehicles (PHEVs), vehicle driving experiences are not likely to be the
same. Quite possibly, PHEVs will provide a superior level of driving satisfaction. If vehicle
manufacturers downsize or reduce performance (acceleration) to meet compliance, vehicle
satisfaction could diminish. I do not have a good suggestion on how to adjust for these possible
hedonic costs or benefits. Perhaps the model could incorporate placeholder equations that would
allow users to specify hedonic gains and losses. Nonetheless, the model documentation should be
forthright in acknowledging this limitation.
The model should provide for an estimate of the likely gasoline excise tax implications for
different levels of GHG emission reduction. Particularly useful would be to present this
information in the context of different compliance strategies. For example, with tax credits for
PHEVs, and no change in federal gasoline excise tax policy, the revenue losses could be
significant. This functionality could be very useful for policymakers.
As described in the documentation, the model development foresees an increased ability for
users to change input assumptions. Changes to these assumptions may have significant impacts
on costs and GHG emission reductions. It would be useful for the Model Reference Guide
accompanying this model to describe in qualitative terms the impact of or assumptions behind
choosing to adjust certain parameters. For example, the user manual could indicate that lowering
the years of payback for technology would be consistent with a view that consumers only value
the first years of fuel economy gains or place little or no value on GHG emission reduction that
occur near the end of a vehicle's lifetime. If practicable, it would also be useful to point out
inconsistent choices.
-------
It would be very useful to have the model output be available in units that are used
internationally - grams CO2 /kilometer or grams CO2 equivalent/KM.
Clearly falling into the work for the future, would be to have a time profile of upstream CO2
emissions for conventional gasoline and diesel reflecting regional or national low carbon fuel
standards.
Response: EPA agrees that the dialog box would be more useful if it were larger and included
the ability to scroll through the entirety of each input file.
The capability to perform probabilistic modeling runs is planned for the future. Of course,
accurately reflecting the uncertainties involved in the cost and effectiveness of future
technologies is a significant challenge aside from enabling the model to reflect such
uncertainties. The modeling of discrete options, like several discount rates has already been
made easier. The latest model version includes the ability to run multiple scenarios with one
model run. Creating several Scenario files with differing emission standards, discount rates,
payback periods, etc. is fairly simple. Comparing the results from these multiple cases still
requires opening a separate output file from each run. EPA is considering an output file which
would compare the output from several cases automatically. However, given the common
format of the output, a user may also be able to develop a single spreadsheet which refers to the
relevant cells of several output files and provides a quick comparison of the output of interest for
several cases automatically.
The difficulty in simply and accurately reflecting changes in vehicle desirability and utility has
already been discussed above. We will note this limitation in the model documentation when we
describe the fact that the model holds the mix of vehicles constant during any particular model
run.
The treatment of excise taxes was already discussed above under Section 2.d.
We appreciate Dr. Rubin's desire to have the model documentation aid the user in making good
choices regarding input values. We will consider adding suggestions at various parts of the
model documentation. This is certainly needed for the development of the values of TEB and
CEB in the market file and the ordering of technology in the Technology file. However,
OMEGA is not a model which is designed to be used by someone not experienced in the area of
motor vehicle fuel economy and emissions and environmental and economic analysis. It will not
be possible to provide a complete tutorial on all these topics in one model's documentation. If a
user decides to modify a value from that which was published and supported by EPA, the user
will have to support the appropriateness of that modification.
We agree that there would be some value to the presentation of emissions in international units.
However, given the complexity of the benefits calculation spreadsheet using just one set of units,
it would seem most appropriate to create a separate file which used a different set of units
throughout.
-------