Peer Review of the Optimization Model
   for Reducing Emissions of Greenhouse
   Gases from Automobiles (OMEGA)
   and EPA's Response to Comments
United States
Environmental Protection
Agency

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                Peer Review of the Optimization Model
                for Reducing Emissions of Greenhouse
               Gases from Automobiles (OMEGA) and
                      EPA's Response to Comments
                               Assessment and Standards Division
                              Office of Transportation and Air Quality
                              U.S. Environmental Protection Agency
                                    Prepared for EPA by
                                 Southwest Research Institute
                                 EPA Contract No. EP-C-05-018
                                  Work Assignment No. 4-01
v>EPA
                 NOTICE

                 This technical report does not necessarily represent final EPA decisions or
                 positions. It is intended to present technical analysis of issues using data
                 that are currently available. The purpose in the release of such reports is to
                 facilitate the exchange of technical information and to inform the public of
                 technical developments.
United States                                       EPA-420-R-09-016
Environmental Protection                                 _  ^  ,  „„_
Agency                                          September 2009

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       In May, 2009, EPA contracted with the Southwest Research Institute (SwRI) to conduct a
peer review of a new model which evaluates the technology and cost associated with reducing
greenhouse gas (GHG) emissions from light-duty motor vehicles.  This model is currently
referred to as the Optimization Model for reducing Emissions of Greenhouse gases from
Automobiles (OMEGA).  When peer review was initiated, the model was referred to as the
Vehicle Greenhouse Gas Emissions Cost and Compliance Model (VECTOR).

       The three peer reviewers selected by SwRI were John German, Dr. Paul Leiby and Dr.
Rubin. EPA would like to extend its appreciation to all three reviewers for their efforts in
evaluating this model.  The three reviewers brought useful and distinctive views to all aspects of
the model's use. This included setting up the input files appropriately, running the model
efficiently, and understanding the model's outputs. There are two major sections to this report.
The first section contains the final SwRI report summarizing the peer review of OMEGA,
including the detailed comments of each peer reviewer and an overview of the most significant
comments compiled by SwRI. The SwRI report also contains the peer review charge letter.  The
second major section contains our responses to the peer reviewers'  comments. In this section,
we repeat the detailed comments from each  commenter and, after each section of comments,
provide our response. We have retained the organization reflected  in each reviewer's comments
to aid the reader in moving from the SwRI report to our responses.
Table of Contents

    1.  Peer Review of the EPA Optimization Model for reducing Emissions of Greenhouse
      gases from Automobiles (OMEGA) conducted by Southwest Research Institute
         I. Introduction
        II. Technical Discussion
       III. Summary
       IV. Appendicies
                  A. Resumes of Peer Review Panel Members
                  B. Charge Letter to Reviewers
                       Attachment 1 - EPA Vehicle GHG Emission Cost and Compliance
                       Model Description
                       Attachment 2 - Appendicies to GHG Model Description
                       Attachment 3 - Model Reference Guide
                       Attachment 4 - Benefits Calculations Instructions
                  C. John German' s Revi ew D ocument
                  D. Paul Leiby's Review Document
                  E. Jonathan Rubin's Review Document

    2.  EPA's Response to Peer Review Comments
                  A. Comments by John German
                  B. Comments by Paul Leiby
                  C. Comments by Jonathan Rubin

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SOUTHWEST   RESEARCH   INSTITUTEฎ

6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 • SAN ANTONIO, TEXAS, USA 78228-0510 • (210)684-5111 • www.swri.org
ENGINE, EMISSIONS, AND VEHICLE RESEARCH DIVISION                           HTTP://ENGINEANDVEHICLE .SWRI.ORG

FAX: (210) 522-3950                                                                 ISO 9001 Certified
                                                                              ISO 14001 Certified
               Peer Review of the EPA Optimization Model for
         reducing Emissions of Greenhouse gases from Automobiles
                                   (OMEGA)
                            Office of Transportation Air Quality
                           U.S. Environmental Protection Agency
                                     September, 2009
                                    SAN  ANTONIO,  TEXAS


                         HOUSTON, TEXAS • WASHINGTON, DC  • ANN ARBOR, Ml

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SOUTHWEST   RESEARCH  INSTITUTEฎ
6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 • SAN ANTONIO, TEXAS, USA 78228-0510  • (210)684-5111  • www.swri.org
ENGINE, EMISSIONS, AND VEHICLE RESEARCH DIVISION                           HTTP://ENGINEANDVEHICLE .SWRI.ORG
FAX: (210) 522-3950                                                                 ISO 9001 Certified
                                                                             ISO 14001 Certified
       In May, 2009, EPA contracted with the Southwest Research Institute (SwRI) to conduct a
peer review of a new model which evaluates the technology and cost associated with reducing
greenhouse gas (GHG) emissions from light-duty motor vehicles.  This model is currently
referred to as the Optimization Model for reducing Emissions of Greenhouse gases from
Automobiles (OMEGA). When peer review was initiated, the model was referred to as the
Vehicle Greenhouse Gas Emissions Cost and Compliance Model (VECTOR).

       The three peer reviewers selected by SwRI were John German, Dr. Paul Leiby and Dr.
Rubin. EPA would like to extend its appreciation to all three reviewers for their efforts in
evaluating this model.  The three reviewers brought useful and distinctive views to all  aspects of
the model's use. This included setting up the input files appropriately, running the model
efficiently, and understanding the model's outputs. There are two major sections to this report.
The first section contains the final  SwRI report summarizing the peer review of OMEGA,
including the detailed comments of each peer reviewer and an overview of the most significant
comments compiled by SwRI. The SwRI report also contains the peer review charge letter. The
second major section contains our responses to the peer reviewers' comments. In this  section,
we repeat the detailed comments from each commenter and,  after each section of comments,
provide our response. We have retained the organization reflected in each reviewer's comments
to aid the reader in moving from the  SwRI report to our responses.
                                   SAN  ANTONIO,  TEXAS

                         HOUSTON, TEXAS  • WASHINGTON, DC • ANN ARBOR, Ml

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SOUTHWEST   RESEARCH   INSTITUTE
6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 •
ENGINE, EMISSIONS, AND VEHICLE RESEARCH DIVISION
FAX: (210)522-3950
                               SAN ANTONIO, TEXAS, USA 78228-0510 •  (210)684-5111  • www.swri.org
                                                        HTTP://ENGINEANDVEHICLE.SWRI.ORG
                                                                       ISO 9001 Certified
                                                                      ISO 14001 Certified
                                                June 9, 2009
To:           Environmental Protection Agency
 Contracts             Management Division
              26 West Martin Luther King Drive
 Cincinnati,             OH 45268

Attention:    Ms. Almethyist A. Chambers
 Contracting             Officer

From:        Patrick M. Merritt
 Senior             Research Scientist
              Emissions Research and Development Department
 Southwest             Research Institute
 P.O.             Drawer 28510
              San Antonio, Texas  78228-0510

              Subject: Final Report for Work Assignment 4-1, "Facilitation of an Independent
              Peer Review Process for EPAs VGHG Model"

              Contract No. EP-C-05-018, under SwRI Project 03.14658.01
              Contract Title: "Testing and Analytical Support for Regulation of Motor Vehicles,
              Engines, Fuels, and Fuel Additives"
I.
INTRODUCTION
       On-road vehicles are the predom inant source of greenhouse gas (GHG) em issions in the
transportation sector (principally, CO2 and hydrocarbon emissions from vehicle air conditioners).
Of all on-road vehicles, light- duty passenger cars and trucks pr oduce the majority of these GHG
emissions. As EPA's Office of Transportation and Air Quality explores the regulation of CO2 and
other GHG emission control measures in on-road and non-road vehicles and equipment, there is
a need to evaluate the costs and benefits of any such regulations. As such, EPA has developed its
Vehicle Greenhouse Gas Emissions Cost and Compliance Model, or VGHG model, to facilitate
its analysis of the costs and benefits of th    e control of GHG e  missions from cars and trucks.
Broadly speaking, the primary cost of GHG emission control is the cost of adding technology to
the vehicles, while the p rimary benefit is the value of reduced fuel cons umption in those sam e
vehicles.
                                   SAN  ANTONIO,  TEXAS

                         HOUSTON, TEXAS  • WASHINGTON, DC • ANN ARBOR, Ml

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 4 of 8
       The EPA VGHG model is used to apply various technologies to a defined set of vehicles
in order to meet a specified GHG emission target, and to then calculate the costs and benefits of
doing so. The GHG target can be a flat standard app licable to all vehicles within a vehicle class
(e.g., cars, trucks or both cars and trucks) or the    'target' can be in the for m of a c urve which
varies the target as a function of a defined vehicle ' fleet.' GHG emission targets are specified in
terms of CO 2-equivalent emissions. They can simply be CO 2 emissions from the tailpipe or can
be a combination of tailpipe CO 2 and refrigerant emissions. Fleet wide average GHG e missions
can also be used to estim   ate a wide array of   societal  cos ts and benefits associated  with the
reduction of GHG emissions.

       To assure the highest quality science in   its p redictive as sessments, EPA has engaged
SwRI to facilitate an independent peer review of its model  for determining the costs and benefits
of changes to vehicle technology for the reduc  tion of GHG em issions from passenger cars and
trucks. EPA needs assurance that the proposed structure (and development process) of its VGHG
model will result in a model tha t is viable, accurate, and well-suited for the diversity of uses to
which it may be applied. This report documents the process followed towards that end.
II.     TECHNICAL DISCUSSION

       EPA's peer review gu idelines specify that all h ighly significant scientific and technical
work products undergo independent peer review per specific agency protocols. The first task was
to select panel members (three) who were qualified, interested, and had time available to devote
to an in-depth review.

       Selection of candidates was made from a list of persons familiar with the issues involved
in GHG emissions from ecological, socio-economic, regulatory, and manufacturing perspectives.
The panel m embers who were selected h ave impressive standings in their respective fields and
comprise a balanced an d diverse point of view. The peer review  panel consists of the following
individuals:

          •  John German, The International Council on Clean Transportation
          •  Paul Leiby, Oakridge National Laboratory
          •  Jonathan Rubin, University of Maine, School of Economics

Their resum es are presented in Appendix A. Fo   llowing selection and determ ination of their
availability,  consultancy agreements had to be put in place with each individual.
SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 5 of 8
       As soon as it was practical, the docum  ents and software were distributed to the review
panel members. The distribution was accomplished by preparing a charge letter d escribing what
was requested in detail, and attaching the supporting documents. Please see Appendix B.

       SwRI then arranged a teleconference between the peer reviewers and EPA technical staff
as a kick-off m eeting. In that c onference, held on May 1, 2009, th e charge to the reviewers was
discussed, and the presentation of the supporting documents was reviewed. As there were seven
attachments, it was i mportant to have assura nee that everyone understood how the docum  ents,
appendices, and attachments are related.

       During the kick-off m  eeting, an infor  mal  question dialog allowe d pa nel me mbers t o
interact with EPA' s work assignm ent m anager (WAM) and the technical staff who are m   ost
familiar with the GHG model. It was agreed that   any further questions would be subm itted in
writing to S wRI, and the question and EPA's r  esponse would be distributed to all reviewers.
Only one s uch questio n was sub mitted. Fina lly,  it was agreed tha  t each would attem  pt to
complete their work prior to the next teleconference, which was scheduled for May 28, 2009.

       The review documents of two of the three reviewers had been received and forwarded to
EPA before the teleconference held on May 28th. The third followed shortly thereafter. The May
28th teleconference was nonetheless productive, w ith discussion am ong EPA technical staff and
the panel members. Those documents are presented in Appendices C, D, and E.

       Because the third docu ment had not been re  ceived before the teleco  nference, it was
determined that another teleconf erence would be held. The idea wa  s that all parties could have
additional time to read the comm ents of each of the p anel members and determine if there are
other topics or issues that need clarification or discussion. That discussion was also productive,
with discussion  of whether one equation had an error or if it simply needed more explanation, for
example. In addition, investm  ent costs of   technology with regards to tooling and plant
conversions, capital budgets, and lead time were also discussed.
III.    SUMMARY

       A very brief summary of each of the three reviewers' comments is presented below.
SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 6 of 8
Paul Leiby:

•   Stay focused first on clearly and rigorously   modeling the fuel-economy technology choice
    and cost-effectiveness considerations, for various GHG emission levels.
•   It is essential to be very explicit about whose behavior and objectives are being modeled.
•   Some confusing term s are includ ed in the TA  RF, m ost 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 annu al increase in  the value of CO2") in the discount factor is
    done without explanation or ju  stification.  (Is  it  meant to be the growth rate in GHG
    damages, abatement cost, or a CO2 tax?).
•   CostEff TARF would not seem   to be a cons   ideration f or vehicle manufacturers whose
    objective is to produce a new-car fleet m     eeting consum er needs and a GHG em   ission
    standard at least cost. What objective was intended with this hybrid aspect of the TARF?
•   Model Documentation:
          •   Restructure the presentation, perhaps folio  wing the pattern of a j ournal article
              (e.g., begin with stated purpose and b    ackground. Place this m   odel in the
              constellation of related models and indicate what is different and why.  Describe
              approach, data sources, sample results.)
          •   Bringing description of the "Core P rogram" and what the model does toward the
              front.
          •   Clarify and condense the model description
          •   State model objective (typically stating wh at is m aximized, minimized, or what
              final solution condition is sought)
          •   State model constraints
          •   State and discrim inate between principl e decision variables, exogenous inputs,
              parameters, and internally calculated  results
          •   State the solution algorithm and termination condition
          •   Be rigorous in use of notation.
          •   Use consistent variable names
          •   Clarify subscripts and carefully apply them
          •   Carefully state units.
•   Appropriateness and completeness of the contents of the sample input files:
          •   In all data input files, specify units
          •   The "Data Validation" capability and error report is a very useful feature
•   Fuels input file, Appendix 4
          •   This list does not yet reflect biofuels  or renewable fuels
          •   Some provision m ay be needed for th  e variable energy  and GHG content of
              gasoline
          •   Provision may also be needed for E 85, and the uncertain fraction of E85 used by
              FFVs.
SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 7 of 8
          •   The net fuel economy and emissions by PHEVs
•  Calculation of compliance to attribute-based standards:
          •   On page 7, equation for the logistic-based   footprint, there appears to b e a s ign
              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.
          •   No discussion or provision for m   arket-based (perm it trading) standards is yet
              made. This should at least be acknowledged.
          •   One strategy for doing m  ore flexible st andards would be to sim  ply m erge 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.
•  Clarity, co mpleteness, and accuracy of the     model's visualization output, in which the
   technology application is displayed:
          •   It would be very helpf  ul to have som  e graphical summ aries of the input and
              output results.
          •   All output files should embed clear documentation on the inputs used.
          •   The .log file does list names of the 4 input files, which is essential.
          •   The "Visualization Output" file does not   (yet) report the input files (but the
              information could be retrieve from the XML file).

John German:

•  "Accounting m odel" has advantage of si   mplicity, avoids "overm odeling."  However,!   t
   "requires a great deal more sophistication and work by anyone using the model to prepare the
   inputs properly."
•  Modeling by redesign cycles (rather than annually) is a good idea.
•  Leadtime issues modeled far too simplistically
          •   One of the most important issues in  standard setting
          •   Inappropriate to treat all m  anufacturers the sam e, regards potential penetration
              rates and costs for adding technologies (given differing experience)
          •   No such thing as a hard cap on technology penetration rates
•  Recommends handling leadtim  e  c onstraints and tech penetrati  on with an assessm ent of
   capital costs by each manufacturer, with a capital budget  each design cycle
          •   [Q:  How would that budget be set?]
•  Short-term: use manufacturer-specific caps on max penetration rate per year
•  Use m ax pe netration caps (total)  to reflect m arket re strictions (dem and lim its) r ather than
   leadtime constraints
•  Re: rank-ordering technologies for each vehicle type: "Requiring the user to input technology
   in rank order of cost-effectiveness" has some challenges.
          •   Requires a great d  eal of analysis to cr   eate m odel inpu ts: "real analyses and
              modeling are in these input files"


SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 8 of 8
          •  "It only works if the lear   ning rate is the same for    all technologies and if no
             technology changes effectiveness over time."
          •  "model must be able to handle multiple pathways" of technical progression
          •  Synergies depend on order of introduction  (?) and must be assessed according to
             different pathways
•  Very valuab le, perhap s ultim ately n ecessary for regulatory evaluation, to allow model to
   "maximize net social value"

Jonathan Rubin:

•  Be clear and explicit about "accounting stance"
          •  "costs to whom?"
•  Describe and report costs and benefits to as many as three groups (consumers, manufacturers,
   society)
          •  Account for subsidies and taxes
          •  Show component costs
          •  Allow distinct discount rates and treatment of risk for the three groups
•  Improve notation, consistent use of subscripts
•  Concerns about certain formulations in model equations
          •  1/i in FS equation
          •  Discounting factors used
•  Avoid discounting physical quantities, and mixing physical phenomena with economic costs
   and benefits
•  Need to account for environm ental and fuel econo my implications of al ternative fuels m ore
   carefully
          •  Renewable and biofuels
          •  Electricity
•  Future work:
          •  Significant enhancement: make probabilistic, reflecting uncertainty
          •  Account for hedonic (vehicle attribute)   implications of large changes in GHG
             emissions
          •  Consider implications for gas excise tax revenue
          •  User manual, describing impact and power of key assumptions
          •  Output in SI units
SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 9 of 8
IV.    CLOSING

       Southwest Research In stitute has p repared this final report to W ork Assignment 4-1 to
describe the process followed in the peer re view of the EPA's Vehicle Greenhouse Gas Model.
Please contact Patrick Merr itt at 210-522-5422 (e-m  ail pmerritt@swri.org) with any questions.
Thank you for this opportunity to be of service.
Prepared by:
 Reviewed by:
Patrick M. Merritt
Senior Research Scientist
Emissions Chemistry
Emissions Research and Development
 E. Robert Fanick
 Manager
 Emissions Chemistry
 Emissions Research and Development
Approved:
Jeff J. White, Director
Emissions Research and Development
Engine, Emissions and Vehicle
   Research Division
/tyd
       Christine Brunner, EPA NVFEL
       Kent Helmer, EPA NVFEL
       Richard Rykowski, EPA NVFEL
       Sherry Twilligear, SwRI Contracts
U:\Davison\wp\PROJECTS\14658 EPA FR WA 4-1 VGHG Model Peer Review PMM.doc
This report shall not be reproduced, except in full, without the written approval of Southwest Research
Institute.  Results and discussion given in this report relate only to the test items described in this report.
SwRI Project 03.14658.01 FR

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Ms. Almethyist A. Chambers
Environmental Protection Agency
June 9, 2009
Page 10 of 8
                         ATTACHMENT


Appendices                                      Number of pages

  A    RESUMES OF PEER REVIEW PANEL MEMBERS	17

  B    CHARGE LETTER TO REVIEWERS	2

        ATTACHMENT 1 - EPA VEHICLE GHG EMISSION COST AND
          COMPLIANCE MODEL DESCRIPTION	45
        ATTACHMENT 2 - APPENDICES TO GHG MODEL DESCRIPTION
        ATTACHMENT 3 - MODEL REFERENCE GUIDE
        ATTACHMENT 4 - BENEFITS CALCULATIONS INSTRUCTIONS

  C    JOHN GERMAN'S REVIEW DOCUMENT	11

  D    PAUL LEIBY'S REVIEW DOCUMENT	13

  E    JONATHAN RUBIN'S REVIEW DOCUMENT	8

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                APPENDIX A

RESUMES OF PEER REVIEW PANEL MEMBERS

John German, The International Council on Clean Transportation
Paul Leiby, Oakridge National Laboratory
Jonathan Rubin, University of Maine, School of Economics

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                                  John M. German
                         730 Brooks St., Ann Arbor, MI 48103
                      (734) 213-0537 (H)     (734) 222-5962 (W)
                          PROFESSIONAL EMPLOYMENT
January     SENIOR FELLOW, INTERNATIONAL COUNCIL ON CLEAN TRANSPORTATION
2009 to     • Primary responsibility for technology innovation and U.S. policy development.
present	• Managing project to track technology costs and benefits worldwide.	
February    MANAGER, ENVIRONMENTAL AND ENERGY ANALYSIS, PRODUCT REGULATORY
1998 to          OFFICE, AMERICAN HONDA MOTOR CORPORATION
January     • Provide policy and technical analyses on vehicle-related emissions and energy issues.
2009        • Liaison between Honda R&D, both in the U.S. and Japan, and external organizations,
                 including government agencies, environmental groups, other manufacturers,
                 academia, and state representatives.
              Primary Honda representative on fuel economy and global warming issues, including
                 testifying before Congress, writing testimony, writing responses to CAFE
                 rulemaking, and making presentations.	
October,     SENIOR TECHNICAL ADVISOR, u.s. EPA OFFICE OF MOBILE SOURCES. Supervised up to 8
1986 to          employees, managed development of regulations and guidance, and served as
January,          technical consultant on a wide variety of issues.
1998        • Technical manager for study on Tier II emission standards for cars and light trucks.
            • Designed and managed extensive research project evaluating in-use driving behavior
                 and its impact on emissions in support of revisions to the Federal Test Procedure.
                 Created and managed extensive usage of teams across organizational boundaries.
            • Managed the development of a nonroad emission inventory and the issuance of the
                 Nonroad Engine and Vehicle Emission Study.
            • Managed rulemaking for Cold Temperature Carbon Monoxide Standards.
            • Worked with transporatation planners to help create and develop a computer
                 simulation model for vehicle emissions.
            • EPA senior technical advisor on greenhouse gas and fuel economy issues, including
                 CAFE alternatives, in-use fuel economy factors, and advanced technology. Active
                 member of EPA global warming team and an inter-agency modeling team.
            • Developed initial concepts for On-Board Diagnostics.
            • Created and managed rulemaking assessing LOT CAFE test procedure adjustments.
            • Developed policy guidance for 48" roll electric dynamometer, driver-selectable
                 devices, mileage accumulation fuel requirements, coastdown procedures and
           	dynamometer power absorption settings, and model year definition and duration.
May, 1985   TEAM LEADER, U.S. EPA OFFICE OF MOBILE SOURCES.   Supervised 3 employees and
to Sept.,     managed manufacturer motor vehicle emissions compliance program.
1986        * Wrote guidance on numerous certification procedure issues.	

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December,
1981
to May,
1985
ENGINEERING SUPERVISOR, CHRYSLER POWERTRAIN. Supervised 6 engineers,
supported product planning, and developed strategies to optimize vehicle fuel economy
and to ensure compliance with all fuel economy requirements.
• Planned and coordinated activities of staff.
• Chrysler's principal technical advisor on fuel economy and methods to improve CAFE
• Provided technical analyses and written responses to proposed regulations.
• Represented Chrysler on fuel economy matters with EPA and NHTSA.
• Provided CAFE projections and analyzed impacts of future product changes on
    CAFE.
• Team leader on a project with all areas of engineering to implement Shift Indicator
Lights. Independently developed computer algorithms to eliminate cost of a sensor.
November,
1976 to
December,
1981
ENGINEER, CHRYSLER POWERTRAIN.  Designed and implemented, from scratch,
Chrysler's system to comply with extensive EPA fuel economy regulations issued in
1975. Also the corporate expert on fuel economy regulations, coordinated fuel
economy testing, served as liaison with EPA, helped write responses to proposed
regulations, and worked on special projects.
AWARDS and ADVISORY COMMITTEES
2008
2006
2004
2002-2003
2002-2003
2001-2002
1995
1994
1993
1992
1991
National Research Council - COMMITTEE FOR A STUDY OF POTENTIAL ENERGY
SAVINGS AND GREENHOUSE GASS REDUCTIONS FROM TRANSPORTATION
SAE Engineering Meetings Outstanding Oral Presentation Award, FOR "IT'S A HlGH-
MPG VEHICLE ISSUE, NOT A HYBRID ISSUE" AT SAE GOVERNMENT/INDUSTRY MTG.
Barry McNutt Award for Excellence in Automotive Policy Analysis
1ST RECEIPIENT OF ANNUAL AWARD FROM THE SAE
advisory board, ADVANCED POWER TECHNOLOGY ALLIANCE, CENTER FOR
AUTOMOTIVE RESEARCH, ANN ARBOR, MI
sae industrial lectureship program, TO PROMOTE INTERACTION BETWEEN PRACTICING
ENGINEERS AND FACULTY AND STUDENTS VIA CAMPUS VISITS
SILVER MEDAL, U.S. EPA for strategies to reduce air pollution from nonroad engines
EPA SCIENCE ACHIEVEMENT AWARD in Air Quality. Only person in EPA's Office of
Mobile Sources ever to receive this award.
OUTSTANDING TECHNICAL COMMUNICATION in the 1992-93 Society for Technical
Communication of Southeastern Michigan Technical Publications Competition, for
"Nonroad Engine and Vehicle Emission Study"
BRONZE MEDAL, U.S. EPA for the "Nonroad Engine and Vehicle Emission Study"
BRONZE MEDAL, U.S. EPA for the Cold Temperature Carbon Monoxide Rulemaking

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LEADERSHIP TRAINING
2000        Honda Leader's Program - Center for Creative Leadership
1997        Modeling and Computer Simulation of Internal Combustion Engine—U. of Mich, course
1996-7      Excellence in Government Fellows Program—Council for Excellence in Government
1995        Diversity Workshops - University of Michigan
1993        Total Quality Management
1992        Looking Glass Workshop: Leadership in Multilevel Organizations - Creative Leadership
1991        Use of Consultative Methods - EPA Institute
1990        Work Group Leadership - Conservation Foundation
1989        Regulation Development in EPA - EPA
1988        Planning Effective Meetings - EPA
1987        Zenger-Miller Supervision program on Behavior Modeling - EPA
1985        Personnel Management for Managers and Supervisors - OPM
1984        Interaction Management - Chrysler Institute
1982        Organizational Leadership and Productivity - Mansare Corp.
1982        Leadership Effectiveness Training - Chrysler Institute
1981        Supervisory Skills Training - Chrysler Institute

PUBLICATIONS
John German, " Leadtime, Customers, and Technology: Technology Opportunities and Limits on the
Rate of Deployment". Reducing Climate Impacts in the Transportation Sector. D. Sperling and J.
Cannon, Springer Press, 2008.
D. Greene, J. German, and M. Delucchi, " Fuel Economy: The Case for Market Failure ". Reducing
Climate Impacts in the Transportation Sector. D. Sperling and J. Cannon, Springer Press, 2008.
J. German, "Reducing Vehicle Emissions Through Cap and Trade Schemes". Driving Climate Change:
Cutting Carbon from Transportation. D. Sperling and J. Cannon, Elseview & Academic Press, 2006.
Hybrid Gaseoline-Electric Vehicle Development edited by John German, SAE PT-117, 2005.
John German, "Hybrid Electric Vehicles", Encyclopedia of Energy, Elsevier & Academic Press, 2004
John German, Hybrid Powered Vehicles, SAE Technology Profile T-l 19, book published by Society
of Automotive Engineers, Warrendate, Pa., 2003.
John German, "Hybrid Vehicles Go to Market", TRNews #213, March-April 2001.
K. Aoki, K. Nakano, J. German, S. Kajiwara, H. Sato, and Y. Yamamoto, "An Integrated Motor
Assist Hybrid System - Development of the Insight, a Personal Hybrid Coupe", SAE 2000-01-2216,
2000.
John German, "VMT and Emission Implications of Growth in Light Truck Sales", Air and Waste
Management Association Emission Inventory Conference proceedings, Oct. 1997.
J. Alson, J. German, K. Gold, R. Larson, and M. Wolcott, "Transportation Energy Demand Models:
Why They Underestimate Greenhouse Gas Emissions", Climate Change Analysis Workshop
Proceedings, June 6-7, 1996.
John German, "Off-Cycle Emission  and Fuel Efficiency Considerations", Asilomar conference on

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Transportation and Energy, 1995.
John German, "Observations Concerning Current Motor Vehicle Emissions", SAE 950812, Feb. 1995.
J. Koupal and J. German, "Real-Time Simulation of Vehicle Emissions Using VEMISS", CRC On-
Road Vehicle Emissions Workshop, April 1995.
S. Sheppard, J. Fieber, J. Cohen, and J. German, "Cold Start Motor Vehicle Emissions Model", Air
and Waste Management Association, Cincinnati, 1994.
P. Enns, J. German, and J. Markey, "EPA's Survey of In-Use Driving Patterns: Implications for
Mobile Source Emission Inventories", AWMA/CARB Specialty Conference on Emission Inventory,
Pasadena, CA, October, 1993.

EDUCATION
1980-1984   University of Michigan.  Completed 34 hours towards M.B. A.  GPA: 7.9 (A=8.0)

1970-1975   University of Michigan,  B.S., Physics (minor in Math).
            Honors: National Merit Finalist, Honors Program, Dean's List
            Activities: U. of Michigan Marching Band and Concert Band

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Leiby Paul N. resume_2.0page_2008May02.pdf

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Rubin%20CV.pdf

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       APPENDIX B




CHARGE LETTER TO REVIEWERS

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SOUTHWEST   RESEARCH  INSTITUTE
                                                                                        ฎ
6220 CULEBRA ROAD • POST OFFICE DRAWER 28510 • SAN ANTONIO, TEXAS, USA 78228-0510  • (210)684-5111 • www.swri.org
ENGINE, EMISSIONS, AND VEHICLE RESEARCH DIVISION                           HTTP://ENGINEANDVEHICLE .SWRI.ORG
FAX: (210) 522-3950                                                                 ISO 9001 Certified
                                                                             ISO 14001 Certified
Gentlemen:

       Thank you for agreeing to review EPA' s proposed vehicle emission effects model which
estimates the technology necessary for vehicle manufacturers to meet a specified greenhouse gas
(GHG) standard. The m   odel is contained in    the enclosed com   puter program and the
documentation, Description and Methodologies of the EPA Vehicle Greenhouse Gas Emissions
Cost and Compliance Model  and its appen dices. This report illu  strates the concepts an  d
methodologies behind EPA'  s proposed GHG model.   No independen t data analy sis will be
required for this review. Specifically, EPA staff are seeking your expert opinion on the concepts
and methodologies upon which the m odel relies and whether or not the model will  execute these
algorithms correctly. Toward this end, we as   k that you please review and comm    ent on the
following items:

       1)     The overall approach to the specifi    ed m odeling purpose and the particular
              methodologies chosen to achieve that purpose;
       2)     The appropriateness and completeness of the contents of  the sam pie input files.
              EPA staff are not seeking comment on the particular values of the contents of the
              input files, which are samples  only. Thes e input files are included as Appendices
              to the model description:
          a)  The elem ents of the Market input f ile, as shown in Appendix 1 of the m    odel
              description, which characterize the vehicle fleet;
          b)  The elem ents of the Technology input    file, in Appendix 2, that constrain the
              application of technology;
          c)  The definition of the standard  and econom ic conditions in the Scenario input file,
              as shown in Appendix 3;
          d)  The elements of the Fuels input file, as shown in Appendix 4, which characterize
              the fuel types, properties, and prices; and
          e)  The reference data contained in Appe ndix 5 which are currently  hard-coded into
              the model but, in the very near future, w ill be contained in a user contro lied input
              file.

       NOTE: The types of infor mation which can   be input to the m   odel point to both the
       flexibilities and constraints of the model.
                                SAN ANTONIO, TEXAS

                         HOUSTON, TEXAS • WASHINGTON, DC • ANN ARBOR, Ml

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       3)     The accuracy and app  ropriateness of the m  odel's conceptual algorithm  s and
             equations for technology application and calculation of compliance;
       4)     The congruence between the con    ceptual m ethodologies and the program
             execution;

       NOTE: Thi s can be verified by com   paring spreadsheet calculation  s to the outputs
       provided by EPA or by changing the input va  lues and exam ining the results with good
       engineering judgment.

       5)     Clarity, co mpleteness and accu  racy of th  e calcu  lations in the Benefits
             Calculations output file, in which costs and benefits are calculated;
       6)     Clarity, completeness, and accuracy of the model's visualization output, in which
             the technology application is displayed; and
       7)     Recommendations for any functionali  ties beyond what we   have described as
             "future work."

       In making your comments, you should disti nguish between recommendations for clearly
defined improvements that can be readily m ade based on data or literature reasonably available
to EPA and im provements that are more explor  atory or dependent on in  formation not readily
available to EPA.  Comm  ents should be suffici  ently clear and detailed to allow a thorough
understanding by EPA or other parties familiar with the  model. EPA requests that you not release
the peer review m aterials or you r comments until the Agency  makes its model and supporting
documentation public. EPA will  notify the reviewers when this occurs.

       If you have questions about what is required   in order to com plete this review or need
additional background m   aterial, please contact Patric    k Merritt at 210-522-5422 or
pmerritt@swri.org.  If you have any questions about the EPA peer review process itself, please
contact Ms.  Ruth Sche nk in EPA's Quality   Off ice,  National Vehic le and Fuel Em  issions
Laboratory by phone (734-214-4017) or through e-mail  (schenk.ruth@epa.gov).
                                    With best regards,
 Patrick                                    M. Merritt
                                    Senior Research Scientist
                                    Emissions Research and Development Dept.
Attachments (4)

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 i                                   ATTACHMENT 1
 2
 3     EPA Vehicle GHG Emission Cost and Compliance Model Description
 4
 5
 6
 7   Background and Overview
 8
 9          On-road vehicles are the predominant source of GHG emissions from the
10   transportation sector. Of all on-road vehicles, light-duty vehicles and light-duty trucks
11   (hereafter referred to as cars and trucks) produce the majority of the GHG emissions.
12   There are many methods for reducing GHG emissions from cars and trucks due to the
13   myriad of technology options available to improve the efficiency of vehicles. A detailed
14   analysis of the costs and benefits of various GHG emissions reduction requires a
15   specialized application that optimizes and accounts for all the promising technologies,
16   going beyond what can be accomplished with simple spreadsheet tools . Therefore,
17   EPA's Office of Transportation and Air Quality (OTAQ) has developed the Vehicle
18   Greenhouse Gas Emissions Cost and Compliance Model  (hereafter referred to as the
19   "EPA model") to  help facilitate the analysis of the costs and benefits of reducing GHG
20   emissions from cars and trucks..
21
22          Broadly speaking, the EPA model applies technologies with varying degrees of
23   cost and effectiveness to a defined vehicle fleet in order to meet a specified GHG
24   emission target and calculates the costs and benefits of doing so. The technologies are
25   combined into a series of vehicle "packages" over a series of model years, which defines
26   the fleet input file.
27
28          The vehicle fleet can be characterized very simplistically (one vehicle) or more
29   precisely (over a thousand vehicle models). Vehicle sales can vary over time in the
30   model.  The vehicle description includes the baseline level of GHG emissions along with
31   any other attribute used in setting the target GHG emission level, such as footprint, which
32   is discussed further below.
33
34          GHG control technology packages can be applied "one at a time" or in groups or
35   bundles. The costs and effectiveness of these technologies are assumed to be the same
36   for all vehicle models falling within a vehicle type category, such as midsize cars with V6
37   engines or minivans. The model considers whether a specific vehicle model already has
38   a specific technology package or whether a technology can or cannot be applied to it.
39   The volume of a specific vehicle model's sales which can receive a technology package
40   can be limited by  indicating a fraction of its baseline that already contains some
41   effectiveness and  cost of each specific technology package. The volume of a given
42   vehicle type's sales which can receive a specific technology package can also be limited
43   with a market penetration "cap", if desired.  The effectiveness and application limits of
44   each technology package can vary over time, if desired.
45
                               VGHG Model Documents Page 1 of 43

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 1          Technology is applied to individual vehicles using a ranking process. Within a
 2    vehicle type, the order of technology packages is set by the user. Across vehicles,
 3    technology is applied to that vehicle with the lowest Technology Application Ranking
 4    Factor (hereafter referred to as the TARF). The TARF considers the cost of the
 5    technology, the value of any reduced fuel consumption considered by the vehicle
 6    purchaser, and the mass of GHG emissions reduced over the life of the vehicle. Fuel
 7    costs by calendar year and annual vehicles travelled per vehicle are provided by the user.
 8
 9          Technology is applied to vehicles until all the technologies have reached their
10    caps or until the sales-weighted GHG emission average of a given manufacturer's
11    vehicles complies with the specified GHG emission target or stringency. The GHG target
12    can be a flat standard applicable to all vehicles within a vehicle class (e.g., cars, trucks or
13    both cars and trucks). Or, the GHG target can be in the form of a linear or logistic
14    function, which varies the target as a function of vehicle footprint (vehicle track width
15    times wheelbase).
16
17          The GHG emission target can vary over time, but not on a model or  calendar year
18    basis.  One of the fundamental features of the EPA model  is that, over a specified vehicle
19    redesign cycle, a manufacturer has the capability to redesign any or all of its vehicles.
20    The EPA model does not attempt to determine exactly which vehicle will be redesigned
21    by each manufacturer in any given model year.  Instead, it focuses on the GHG emission
22    goal several model years in the future, reflecting the capability of longer term planning
23    on the part of auto manufacturers.  Any need to further restrict the application of
24    technology can be affected through the caps on the application of technology to each
25    vehicle type mentioned above. Approximate costs and benefits of complying with
26    gradually decreasing GHG emission targets within the endpoints of a redesign cycle are
27    produced via linear interpolation, despite that in reality these functions may  resemble step
28    functions more closely for any given vehicle.
29
30          GHG emission targets are specified in terms of CO2 equivalent emissions. They
31    can simply be CO2 emissions from the tailpipe or a combination of tailpipe  CO2
32    emissions and air conditioner refrigerant emissions. In the case of the latter, the
33    descriptions  of vehicles and technologies must include baseline refrigerant emissions and
34    the effectiveness of each technology in reducing these emissions.
35
36          Once technology has been added so that every manufacturer meets the specified
37    targets (or exhausts all of the available technologies),  average costs per vehicle by
38    manufacturer and industry fleet are determined.  Fleet-wide average GHG emissions are
39    also approximated for each calendar year and are used to estimate a wide array  of societal
40    costs and benefits associated with the GHG emission control.
41
42          The model outputs the costs and the benefits of the control scenario.  The primary
43    cost of GHG emission control is the cost of the added technology as compared to the
44    baseline.  The primary benefit is the value of reduced  fuel consumption and  can be
45    sensitive to the user assumed price of fuel. However,  the value of a number of other
46    costs and benefits are also evaluated, as listed below:
                                VGHG Model Documents Page 2 of 43

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 1
 2       1) The reduction or co-benefits in VOC, CO, NOx, sulfur dioxide (SOx), and PM
 3          emissions associated with reduced fuel production are estimated, as well as their
 4          value to society,
 5       2) Societal benefits associated with reduced crude oil use which are not reflected in
 6          the price of crude oil,
 7       3) The value of reduced time necessary to refuel vehicles, and
 8       4) The value of GHG emission reductions.
 9
10          GHG emission control tends to encourage technologies that improve vehicle fuel
11    efficiency and reduces the cost of driving, which in turn can result in more driving.  This
12    feedback effect is commonly referred to as the "rebound effect", the extent of which can
13    be specified by the user.  Estimates are made of a number of potential costs and benefits
14    associated with driving, as follows:
15
16       1) The increase in vehicular VOC, CO, NOx, SOx, and PM emissions,
17       2) The increased vehicular noise, congestion, and accidents,
18       3) The value of the increased driving,  and
19       4) The cost of fuel required by the increased driving.
20
21          Where the EPA model differs from other similar models is that it adds technology
22    to vehicles on a redesign cycle basis.  Some models try to predict the model year when
23    each vehicle model (of hundreds) will be redesigned and then adds technologies to each
24    vehicle on its redesign year. In reality, the timing of vehicle redesign is difficult to
25    predict, because it is constantly adjusting to changes in the market, corporate needs, or
26    government regulations, which these other models are not able to capture. In addition,
27    since there are hundreds of specific vehicle models being sold in any given model year,
28    the technology application process becomes computationally intensive. This
29    methodology creates a situation where the model attempts to achieve a level of precision
30    greater than its accuracy.
31
32          The EPA model avoids these two issues by taking a mid to long term approach to
33    vehicle redesign, assuming a 5+ year planning horizon.. In this methodology, the user
34    designates a redesign cycle length (currently this is hard-coded as 5 years, but in the
35    future this will be a user input), and the model redesigns the entire fleet in the final model
36    year of the redesign cycle.  This philosophy is based on the assumption that vehicles
37    undergo redesign at a rate consistent throughout the fleet. In addition, the EPA model
38    looks much further into the future than other models, with the capability of adding
39    technology to vehicles over four redesign cycles.  Because it is next to impossible to
40    determine each vehicle model's subconfiguration (there are over 1000) 20+ years in the
41    future, the methodology of adding technologies incrementally to each vehicle model by
42    model year does not add value to the model results. Moreover, the EPA model avoids
43    "overmodeling" by allowing for the simplification of the fleet by dozens (or fewer)
44    representative vehicles, rather than  the hundreds that are currently forecasted by
45    manufacturers.
46
                                VGHG Model Documents Page 3 of 43

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 1
 2   Input Files
 O
 4          The EPA model is designed to be flexible in almost every respect.  Very little data
 5   is hard-coded in the model; since the model relies heavily on its input files, the user can
 6   alter them at will to create new vehicle models, types, and technologies, or to change the
 7   model's operating parameters for sensitivity analysis or "what-if' scenarios.  For example
 8   the following can all be modified by the user: vehicle descriptions, the technologies
 9   which are available to be applied to each vehicle, as well as their costs and effectiveness.
10
11   Vehicle Fleet Characterization
12
13          The sample input file, "Market-1", contains a list of the vehicle models that
14   describe the vehicle fleet and five different categories of data that describe them: 1)
15   Vehicle efficiency data, such as baseline fuel economy and GHG emissions (columns N
16   and O); 2) Vehicle attribute data that the model uses in its technology ranking and
17   compliance calculations, such as footprint, weight, and refrigerant type (columns P, Q,
18   and AB respectively); 3) Vehicle attribute data that the model will eventually use when
19   calculating output statistics, such as engine displacement, horsepower, and drive type,
20   although output statistics are not calculated in the current version (columns R, S, and W);
21   4) Vehicle sales data, which is presented in the form of annual sales in the baseline and in
22   the final "redesign" year of each redesign cycle (columns E through M); 5) An indication
23   of whether a technology package exists in the reference case, and if so, to what degree  the
24   technology package effectivenesses and costs are reflected. An example of the Market
25   input file is in Appendix  1.
26
27          Reference case technology is tracked to avoid double counting technology costs
28   and GHG improvement.  Columns AD through AW represent the fraction  of the
29   technology package effectiveness for  the different vehicles that is present in the reference
30   case; for example, a value of 35% for technology package 1 means that 35% of the
31   effectiveness of technology package 1 on that vehicle type is already present in the
32   reference case. Columns AY through BQ represent what fraction of the technology
33   packages' cost is reflected in the reference case.  Likewise, a value of 75% in any of
34   these columns means that 75% of the  technology package's cost on the particular vehicle
35   has been included in the reference case. This is to prevent double counting of
36   technologies that are already in the baselines.
37
38   Technology Characterization
39
40          EPA designed the model to allow the user to add GHG reducing technologies one
41   at a time or in packages or bundles that would reasonably and likely be added by
42   manufacturers within a redesign cycle. In addition, the user can combine similar vehicle
43   models into "vehicle type" groups which are likely to receive the same list of technology
44   packages. For each vehicle type, the user must rank the technology packages in order of
45   how the EPA model  should add them  to that specific vehicle type. This approach puts
46   some onus on the user to develop a reasonable sequence of technologies.  However, the
                                VGHG Model Documents Page 4 of 43

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 1    model also produces information which helps the user determine when a particular
 2    technology or bundle of technologies might be "out of order". The approach also
 3    simplifies the model's calculations and enables synergistic effects among technology
 4    packages to be included to the fullest degree possible.
 5
 6          The sample input file entitled "Technology-1" defines the technology packages
 7    that are available for the model to add to the fleet.  The data in this file can be categorized
 8    in three ways: 1) Parameters the model uses to calculate CO2 improvement, such as
 9    effectiveness and market penetration cap (the latter being the cap of sales for each vehicle
10    model of a vehicle type that can receive a technology package) (columns D through T);
11    2) Data the model uses to calculate technology costs, such as the package cost and cost
12    learning coefficients (columns X through AC); 3) Properties of the technology package,
13    such as refrigerant type and fuel type (columns U through W).
14
15          Each worksheet in the file contains a user-defined list of technology packages for
16    a different vehicle type. In order to avoid the complexity of synergistic effects, the user
17    must record this list within each worksheet from  top to bottom in the order of how the
18    model should add them to the particular vehicle.  Since the user defines the technology
19    packages contained in the input file,  technologies are dynamic (user defined) and not
20    "hard-coded" within the model. Values in columns L through S represent the Average
21    Incremental Effectiveness (AIE) of the technology  package over the previous package (or
22    over the baseline in the case of technology package 1) which the user can adjust on a
23    redesign cycle basis.  For example, a value of 7.0% in the AIE column would denote a
24    7.0% tailpipe CO2 improvement beyond any CO2 improvements already realized.
25    ("Tailpipe CO2" refers to the CO2 emitted over a test cycle - that relates it to vehicle
26    efficiency.) This value of 7% would include any synergistic effects that components of
27    the technology package may have with technologies that have already been added to the
28    vehicle type.  Currently, the refrigerant effectiveness noted in column T is based on the
29    fraction reduction in direct refrigerant leakage emissions and is separate from tailpipe
30    CO2.  An example of the Technology input file is in Appendix 2.
31
32          When technology is sufficiently new, or the leadtime available prior to the end of
33    the redesign cycle is such that it is not reasonable to project that it could be applied to all
34    vehicle models that are of the same specific vehicle type, for example, all minivans, the
35    user can limit its application to minivans through the use of a market cap of less than
36    100% in columns D through K. This cap can vary by redesign cycle.  When a technology
37    package is applied to fewer than 100% of the sales  of a vehicle model due to the market
38    cap, the effectiveness of the technology group is  simply reduced proportionately to reflect
39    the total net effectiveness of applying that technology package to that vehicle's sales.
40    The EPA model does not create a new vehicle with the technology package and retain the
41    previous vehicle which did not receive the technology package, splitting sales between
42    the old and new vehicles. If subsequent technology packages can be applied to the
43    vehicle, the user should consider whether in reality the new technology would likely be
44    applied to those  vehicles which received the previous technology or those which did not,
45    or a combination of the two. The effectiveness of adding the subsequent technology may
46    depend on which vehicles are receiving it.
                               VGHG Model Documents Page 5 of 43

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 1
 2    Fuel and Energy Prices
 3
 4    The Fuels-1 input file contains data relevant to fuel and electricity, including energy,
 5    mass, and carbon density (columns B through D in the Fuel tab), and annual price
 6    forecasts for up to 20 years (columns E through X).  There is a small subset of fuel
 7    information not included in this file that has been hard-coded into the model, which
 8    reflects the societal cost of importing fuel, which is discussed briefly below and in the
 9    section on benefits calculations. An example of the Fuels-1 file is in Appendix 4.
10
11    Regulatory Scenarios
12
13           The Scenario input file contains all data specifying the number and types of
14    model runs. The Scenarios tab acts as  a directory for different model runs, where the user
15    can create an entry for any number of runs that the model can perform in succession. At
16    present, the model is only capable of performing one scenario at a time, but in the future,
17    it will be capable of batch processing.  In the Scenarios tab, the user must specify the
18    base year, type of compliance target (CO2 or MPG), type of compliance function
19    (universal = 1, linear attribute = 2, or logistic attribute = 3), the number of redesign
20    cycles,  and the names of the other input files that describe the vehicle fleet, technology
21    packages, and fuel properties.  At present, the model is limited to a CO2 standard, but our
22    future plans include the capability to analyze an MPG standard as well. These elements
23    are entered in the Scenario input file in columns C through K, and the user can create a
24    name for the run in column B.
25
26           As stated above, there are three options for compliance targets.  The universal
27    target option is simply a numerical designation which the manufacturers' average fleet
28    CO2 cannot exceed. In contrast, the attribute-based linear target function is described by
29    up to four coefficients and has the following piecewise linear mathematical form:
30
31
32
33
34
35
36
37                                        x:  Vehicle footprint
38
39
y = \
      ' Y < Y
      , A ^ A.mm
       B-A
               _  _  mm       max
     x   — x
      max    min
           Where A: CO2 minimum
           B: CO2 ceiling
< x < x     xm;n: Intersection of lower asymptote with slope
           xmax:  Intersection of upper asymptote with
           slope
                      VGHG Model Documents Page 6 of 43

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                        Example of Footprint-Based CO2 Piecewise Linear Target Function
1
2
3
4
5
6
7
 9
10
11
12
13
14
15
     E
     3
     d
     o
                                               Footprint (fr)
    The footprint-based logistic curve (shown below) is described by four coefficients and
    has the mathematical form described below.
           (B-A)
                       x-C
                   1-e
    Where A: CO2 minimum
    B:  CO2 maximum
    C:  Midpoint
    D:  A sort of "inverse slope"
     x:  Vehicle footprint
                             VGHG Model Documents Page 7 of 43

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                              Example of Footprint-Based CO2 Logistic Target Function
 2
 O
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
       E
       2
       d
       o
                                            Footprint (ft2)

       The Scenario input file also contains the economic parameters that the model uses
to calculate the Technology Application Ranking Factors (TARFs), which are the
optimization equations that determine the order of technology application (See the Model
Logic section below). Such economic data includes the discount rate, vehicle payback
period, cafe fine cost, the "gap" between on-road CO2 and test cycle CO2, 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), and the
increase in price of CO2 over time.  The user enters these economic values into columns
B through G in the Economics tab of the Scenario file. An example of the Scenario input
file is in Appendix 3.
Input data "hard-coded" into the model

       There is a set of data that has been hard-coded into the model in the development
phase, which will be moved to a new "References" input file in the very near future. This
data is illustrated in Appendix 5 and is comprised of vehicle age data, scrappage rate,
vehicle miles travelled, upstream criteria pollutant emissions from fuel/energy
production, storage, and distribution, regression coefficients for downstream criteria
                               VGHG Model Documents Page 8 of 43

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 1    pollutant emissions, emissions damage cost (cost per ton), economic cost of importing
 2    fuel, external costs of driving, and global warming potentials for various GHGs.
 3    Model Operation
 4
 5          Because the model depends so heavily on the input files, the current graphic user
 6    interface (GUI) is simple to operate. After installing the program and double clicking on
 7    the VGHG icon, click on the file menu and choose "Open," and a window will appear
 8    with a set of input files.  Click on the sample "Scenario" and it loads the data. The
 9    Scenario file indicates which of the other input files are to be used in the run, and a
10    portion of the scenario description is shown in the top box of the GUI.  The Market and
11    Technology input files identified in the Scenario file are shown in the two boxes below.
12    When everything is loaded, the car icon turns green. Mouse click on the car button to run
13    the program. In less than a minute, a text file showing the sequence of technology
14    addition by manufacturer and by redesign cycle appears. This file is automatically named
15    Results-"date-time".  This file can be saved by the user with a more descriptive name, if
16    desired, by simply using the standard Windows "File", "Save As" actions. There is an
17    additional saved output file entitled "Tarf = "date-time", which includes the results of the
18    TARF calculations for each vehicle type-technology package combination for each
19    redesign cycle. Go back  to the file menu in the GUI, and click on "Save," which is
20    necessary to enable the "visualization" function. In the file menu, now click on
21    "visualization" to examine the results of the technology application process for each
22    vehicle model in the market data file. In the near future, the information in the
23    visualization will be generated directly in an output  spreadsheet, but at present it is only
24    available in the visualization,  and if desired, the user can copy and paste the results
25    manually. Economic costs and benefits can be loaded in a spreadsheet file entitled
26    "Benefits Calculations," located in the "Output" folder.  Open the "Benefits
27    Calculations" excel file, and in the "Load" tab, press the "Load" button to get the
28    economic impact results.
29
30
31    Model Logic
32
33          The model's programming is organized  into three main sections. At first, a pre-
34    processing section reads in the input files and performs intermediate calculations to get
35    the input data into the desired form for calculations in the second section, the "core"
36    calculations.  The core model backs out the existing technology from the baseline, and
37    calculates the Technology Application Ranking Factor (the TARF) for each vehicle type-
38    technology package combination and determines the order to which technology packages
39    should be added to vehicles. The core model then adds the effectivenesses and the costs
40    of the technology addition until  each manufacturer has met the standard or until all
41    technology packages have been exhausted. Finally, a post-processing section computes
42    the societal costs and benefits of the GHG emissions reduction scenario, including the
43    tons of CO2 reduced and the gallons of fuel saved and outputs these results in a
44    Microsoftฉ Excelฉ file.
45
                                VGHG Model Documents Page 9 of 43

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 1          Before the model runs the optimization algorithms, a the user can validate the data
 2    in the input files, and the model then reads in the data.  Each redesign cycle "starts from
 3    scratch" in that every vehicle will include only those technologies present in the base
 4    year.
 5
 6          The model then executes three time loops in the following order: 1) A calendar
 7    year loop that interpolates the annual sales in between redesign cycles; 2) A redesign
 8    cycle loop adds technology packages to vehicles until the fleet is in compliance (the
 9    "core" programming); 3) A final loop calculates the costs and benefits of the CO2 or
10    MPG program and exports the economic impact results to a Microsoft Excel file (a post
1 1    processing step).
12
13          EPA provided the contractor with the equations and conceptual methodologies for
14    the model with a series of spreadsheets, and the contractor developed the program. These
15    equations and methodologies are outlined after the variable and parameter definitions,
16    below.
17
18
19    Pre-processing:
20
21
22    1)  The user can validate the data in the spreadsheets, if desired.
23    2)  Read in the input files
24    3)  Perform calculations to convert input data into useful form for later calculations:
25
26          A) First, the model calculates the annual per-vehicle VMT from the survival
27              fraction and annual miles driven for cars and trucks provided in the Reference
28              file.
29
30                       VMT = SurvivalFraction * AnnualMilesDriven
31
32          B) The model then calculates the discounted annual VMT and discounted
33              refrigerant leakage (RCO2) for year 1 through the vehicle's useful life
34              according to the following equations. The subscript, i, represents the specific
35              year of calculation. DR is the discount rate and IR is  the annual increase in
36              value of CO2.
37
38                 i. Discounted VMT for fuel savings calculations
39
41
42                 ii. Discounted VMT for GHG calculations
43
                               VGHG Model Documents Page 10 of 43

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                                                  1+
                                                     DR-IR
 2
 3
 4
 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
                               VMT
                                   D C02 ,.
                                    '   '
                                                 (l + DR-IRj
             in.  Discounted refrigerant leakage
                           RefLeakage. = LeakRatei
                                                     1 +
                                                        DR-IR
                                                    (l + DR-IRj
       C) Finally, the model calculates the approximate per-mile refrigerant leakage
          emissions in CO2 equivalents from the discounted leakage rate (calculated
          above), the Global Warming Potential (GWP) of the refrigerant provided in
          the Reference file, and the discounted VMT (calculated above).
Lifetime
(years)
2] RefLeakage, .xGWP
Lifetime
[years) )
i=l
Lifetime
(years)
z
1=1
LeaL
Lifetime
(years)
z
1=1
DR-IR
Po/jP -•'
(\ + DR- IR)'
\ HDR-IR
T/7UT - 2
xGWP
LifetimeLeakage x GWP

(I + DR- IR)'
LifetimeVMT
       D) At this point, the model will linearly interpolate the sales in between redesign
          cycles in order to estimate intermediate annual sales.  The final version will
          incorporate cost learning based on sales volume. Since the current version of
          the model does  not account for cost learning, this calculation is currently
          performed in the start of the "post processing" section of code, which
          calculates the social costs and benefits of the modeled regulation, rather than
          in the core code. Therefore, it will be discussed in the section below on post
          processing.
 Core Program:

       The core program is divided into two main parts: The first part determines the
order in which the model must add technology packages to vehicle types, and the second
part is the technology application until all manufacturers have met the standard provided
in the Scenarios input file (or the penetration caps have been met). The core code
contains the baseline technology accounting, the technology application ranking
optimization, the technology application and cost calculations, and whether the
manufacturers have met the standard.  Subscripts (t-1) and (t) indicate vehicle conditions
before and after technology package "t" addition, respectively.
                               VGHG Model Documents Page 11 of 43

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 1    1)  Determine the order of technology application
 2
 3       A) First, the model "backs out" any advanced technology that might have been
 4          present in the baseline. This step ensures that costs and benefits aren't double
 5          counted when the model is optimizing the order of technology package
 6          application.  This is done for both Tailpipe and Refrigerant CO2. The subscript, i,
 7          refers to the current technology package and the subscript, n is the final
 8          technology package for the vehicle type.
 9
10

                                       H C02REP x (l - AIE^ (Cap^ x 7ฃBM ))
11                    BackedoutCO2  = -i	-,	r	
                                              1 - AIE,.x (Capt.x TEBt)
12
13
14                                        l\C02REF x (1 - RIE^ (Cap^ x 7ฃBM ))
I5                      BackedoutRCO21=^	-.	r	
16                                               1 - RIEJ x (Capt x ^EB^)
17
18
19             whereas AIE is the average incremental effectiveness of the technology
20             package, RIE is the refrigerant incremental effectiveness of the technology
21             package, CAP is the market cap, and TEB is the percent of the technology
22             package's benefit that has been reflected  in the baseline.  The RIE reflects
23             either a change in refrigerant or a reduction in refrigerant leaks, as opposed to
24             an improvement in A/C efficiency resulting in a fuel efficiency gain (from a
25             smaller compressor, for example) are reflected in the AIE.   The backed-out
26             CO2 is calculated for each technology package on each vehicle.
27
28       B) Intermediate calculations for each vehicle type-technology package combination:
29
30                 i.  Calculate the new tailpipe and refrigerant CO2 after technology is
31                    added to the baseline fleet (any advanced technology in the baseline
32                    has been removed via the "backout" calculations) and thus CO2t-i and
33                    RC(92f_7 are equivalent to the BackedoutCO2t and BackedoutRCO2j
34                    from above.
35
36                              CO2t = CO2t_, x (l -  AIE)

37                        RCO2t =RCO2t ,x(l-RIE)
                                          t-i  v      ;

38
39                  The model uses this "backed out" CO2 in the equations above because it
40                  helps compare the effectiveness of the various vehicle-technology
41                  package combinations on a level playing field. If the model did not back
                              VGHG Model Documents Page 12 of 43

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 1                   out the effectiveness of the technology in the baseline, the model would
 2                   not be able to appropriately compare the effectiveness of the vehicle-
 3                   technology package combinations, and the technology application order
 4                   would not be as robust.
 5
 6                 ii. Calculate the fuel consumption (FC) before and after technology
 7                    addition:
                                         CA-ix
10                                FC,=-
                                                  UgC
                                              C02t
                                              _  UgC
11
12                    Whereas CDt_i and CDt represent the carbon density of the liquid fuel.
13                    The model does not use the equation,  since it does not account for a
14                    change in fuel type. The electric consumption of the vehicle before
15                    and after technology addition is a direct input from the Market and
16                    Technology file, respectively.
17
18                iii.  Calculate the fuel  savings (FS). Vehicles can have up to two separate
19                    energy sources, which are distinguished by subscripts  1 and 2.
20                    Currently, the model recognizes the subscript "1" as the liquid fuel and
21                    "2" as electricity, for plug-in hybrid vehicles.
22

23         FS =

24
25                    Since the fuel price (FP) changes from year to year, the fuel savings
26                    will be calculated  based on the average fuel price from the year of
27                    manufacturer to a  "Payback Period" (PP), specified by the user.
28
29       C) The model then calculates the Technology Application Ranking Factors (TARFs),
30          which are used to compare the effectiveness technology packages on the different
31          vehicle types, and optimize the order in which the model should add technology
32          packages to the fleet. At this point, the model calculates one TARF for every
33          technology package-vehicle type combination.
34
35              Currently, there are two TARF equations from which the user can choose:
36              "Effective  Cost" and "Cost Effectiveness - Manufacturer."
37
38                 i.  The "Effective Cost" TARF is defined as the cost of the technology
39                    (variable plus amortized fixed) minus the discounted fuel savings over
                               VGHG Model Documents Page 13 of 43

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 1                    a specified payback period of vehicle use minus the implicit reduction
 2                    in CAFE non-compliance fee.  Quantitatively, it is defined as follows:
 3
                                        pp r         i      1            (  1       1^1
 4              EffCost = TechCost - FS x Y \VMTn ™ ,. x -- FEE x
                                                        -
 5
 6                    Where the GAP is the difference between real-world and test cycle
 7                    CO2 and the FEE is a fee for non-compliance, both of which are inputs
 8                    to the model.  Appendix 7 contains the full equation form (without
 9                    intermediate steps).
10
11                 ii.  The Cost Effectiveness-Manufacturer incorporates the effective cost
12                    (illustrated above) but also accounts for the GHG benefit. It is defined
13                    as the cost of the technology minus the discounted fuel savings over a
14                    specified payback period minus the implicit reduction in CAFE non-
15                    compliance fee (which is the "effective cost" definition), all divided by
16                    the amount of lifetime GHG emission reduction in kg of CO2
17                    equivalent. It is represented quantitatively as the following:
18
19
20
21
22

23
ZJ
24
25                    Appendix 7 contains the full equation form (without intermediate
26                    steps).
27
28             Finally, the model determines the order in which technology packages are
29             added to vehicles. The model first compares the TARFs corresponding to
30             technology package 1 on all of the different vehicle types in the fleet and
31             chooses the combination with the lowest TARF. (The lowest effective
32             cost/most cost effective combination is represented by the smallest TARF,
33             whereas  a negative TARF indicates a negative cost.)
pp r i i f i
- - C-^) W
L,osmjjMFR .+35
z
This equation can be rewritten as:
C^n vtT^ff —
Y [iy/?rV)9 RCD7 \ + (CC)7 Cm ^\\yVA/fT 1\
/ j li\ ?-l 1 / \ ?-l ? /J D,CO2,i J
z
1 1
FCt_J
1
(l-Gop)
1
'(l-Gop)
                               VGHG Model Documents Page 14 of 43

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 1
 2       D) Application of technology packages and compliance calculations
 3
 4          At this point, the model has determined the optimal order of technology
 5    application and must apply the technologies'  effectivenesses and costs until each
 6    manufacturer has achieved compliance or exhausted all technology package options.
 7
 8          A) Starting with the vehicle type-technology package combination having the
 9             lowest TARF, the model adds the technology package and calculates the new
10             vehicle CO2 emissions according to the following equations:
11
12                    i.  First, the model calculates the tailpipe CO2 (TCO2); i.e., this is the
13                       CO2 the vehicle would emit on a test cycle.
14
15                           TCQ2  _TC02t_lx(l-CAPxAIE)
                                           \-AIExTEB
16
17                       Where TEB is the "Technology Effectiveness Basis," which is the
18                       percent of the technology package's effectiveness that is reflected
19                       in the baseline for the vehicle to which it is being applied.
20
21                    ii.  The model  also calculates the refrigerant CO2  (RCO2), which is
22                       based on improvements in leakage or a change in refrigerant

24                      RC02, = RCO^l-CAP
                                       \-RIExTEB             _
25
26                    iii. The model  must then calculate the cost this technology addition. It
27                       calculates average incremental cost, the average per-vehicle cost
28                       (averaged over a manufacturer's fleet), and the cumulative cost up
29                       to this point for all manufacturers.
30
31                       The average incremental cost is performed for each technology
32                       addition (but is not reported). It is the cost of the technology  added
33                       up to its market cap minus the cost of the technology present in the
34                       baseline.
35
36                       IncrementalCost = TechCost * (CAP - CEB)
37
38                       Where CEB is the "Cost Effectiveness Basis,"  which is the amount
39                       of the technology package's cost that is in the baseline for the
40                       particular vehicle.
41
42                       Next, the average vehicle cost for each manufacturer is calculated
43                       and reported.
                              VGHG Model Documents Page 15 of 43

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 1
                                            TechCost * ModelSales
MFR
 2
                                           _    TotalFleetSales
 3
 4                       The model then updates the cumulative costs of the program. In
 5                       future versions of the model this can also be expressed in terms of
 6                       cost per redesign cycle.
 7
                                   (Compliance                \
                                     ^ AvgVehicleCostMpx x TotalFleetSales ^^
                                     r=i                  J
 9                    whereas T is the number of the technology package.
10
1 1                    iv. The next step is to add the tailpipe and refrigerant CO2 equivalent.
12                       The result is the vehicle's total CO2 and is used in the calculation
13                       for compliance.
14
15                                CO2t =TCO2t  +RCO2t
16
17          B)  The model must then recalculate the fleet CO2 for each manufacturer that
18              produces the vehicle type that received the technology package.
19
20                             FleetCO2 =
                                           Models
                                                ^
                                                ^ Sales
                                              MFKModels
21
22              The model must calculate this value for each manufacturer and compare the
23              result with the standard that the user has indicated for that manufacturer in the
24              Scenario file input. If the manufacturer has not met the standard, the model
25              iterates back and compares the remaining TARFS for technology package 1
26              along with the TARF for technology 2 on the same vehicle type to which the
27              previous technology package was just added. The model then repeats the
28              process of choosing the next lowest TARF out of the new group, applying the
29              technology package effectiveness and cost values, calculating the new total
30              CO2, and recalculating the new fleet averages.  The model performs this loop
3 1              until each manufacturer has met the standard or until the technology packages
32              have been exhausted.
33
34    Appendix 6 contains a compilation of variable definitions used in this section.
35
36    Post-Processing - Calculation of Costs and Benefits
37
38          The model estimates discounted costs and benefits on both calendar year and
39    model year bases. We describe these calculations on a calendar year basis first, followed
40    by that for an entire model year's vehicle sales. In both cases, the discount rate is
                               VGHG Model Documents Page 16 of 43

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 1   specified by the user, as described above. Except for technology costs, all costs and
 2   benefits are estimated on a fleetwide basis.  Industry fleetwide technology costs are
 3   estimated, but they are also estimated on a disaggregated basis by manufacturer.
 4
 5   Costs and Benefits by Calendar Year
 6
 7          A list of the types of costs and benefits evaluated by the EPA Model was provided
 8   in the Background and Overview section above.  The first step in estimating these costs
 9   and benefits is to develop estimates of vehicle costs, GHG emissions and fuel
10   consumption by model year.  This is done by linearly interpolating vehicle sales, the cost
11   of GHG emission control per vehicle, GHG emissions per mile, and fuel consumption per
12   mile between the baseline case and the first redesign cycle and subsequently between
13   redesign cycles. For example, if the baseline year is 2010, redesign year 1 is 2015 and
14   redesign year 2 is 2020, we linearly interpolate between the 2010 and 2015 sales to
15   estimate annual sales for years 201 1-2016.  Likewise, we linearly interpolate between the
16   2015 and 2020 sales to estimate annual sales for years 2016-2019.  The same is done for
17   the other factors.  The following equation depicts the arithmetic involved.
18
1 „               ,      ,0 ,        0 ,               redesignyear2
1 9              AnnualSales    = Sales    , +          gy
                                                    .               .
                                               redesignyear2 - redesignyearl
20
21          With an estimated cost per vehicle and vehicle sales by model year, the cost of
22    added technology is simply the product of these two values. For simplicity, we assume
23    that all the sales of a given model year's vehicles occurs in the calendar year of the same
24    value.
25
26          Most of the other costs and benefits depend on an estimation of the amount of
27    VMT occurring in each calendar year by vehicles of a certain model year vintage.  As
28    reduced fuel consumption per mile can lead to increased driving, the amount of VMT in
29    the baseline and control cases can differ and increases the complexity of the calculations.
30    Thus, the next step, conceptually, is to estimate the percentage increase in VMT that
3 1    might result from reduced driving costs.
32
33    The rebound effect is defined as the ratio of the percentage change in VMT to the
34    percentage change in incremental driving cost, which is typically assumed to simply the
35    incremental cost of fuel consumed per mile. As mentioned above, the economic concept
36    is that as driving becomes cheaper, people tend to drive more. Since VMT increases with
37    a reduction in fuel consumption, the sign of the rebound effect is negative. The rebound
38    effect (REB) is an input on the "Economics" worksheet of the "Scenario.xls" file.  The
39    percentage increase in VMT for a given change in fuel consumption per mile is
40    calculated as follows:


42

43
                                                 FleetFCold
                               VGHG Model Documents Page 17 of 43

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 1    Since fuel consumption changes by model year, each model year's vehicles will reflect a
 2    different change in VMT.  This change in VMT is assumed to continue throughout the
 3    life of the vehicle, since fuel economy is assumed to be constant throughout vehicle life.
 4
 5          Only new vehicles are affected by the additional technology.  Thus, in any given
 6    calendar year, some of the VMT will be by vehicles whose GHG emissions and fuel
 7    consumption has changed and the remainder will be by vehicles which were unaffected
 8    by the addition of technology. The model estimates this split by predicting each model
 9    year's vehicles contribution to total VMT in each calendar year.
10
11          The model currently contains estimates of annual VMT  per vehicle by vehicle
12    age, as well as the fractions of new vehicles still on the road as  a function of age. These
13    estimates are taken from EPA's MOBILE6 model and are contained in cells M1:Q39 of
14    the Shared Inputs worksheet of the Benefits Calculation spreadsheet. The values for
15    these two parameters are currently hard-coded in the model. However, they will soon be
16    made a part of a References spreadsheet and modifiable by the user.  For the purposes of
17    benefit calculation, the user can already change these values in  the Benefits Calculation
18    spreadsheet and the changes will  flow through to the calculation of fuel consumption and
19    VMT-related costs and benefits.
20
21          The total VMT by a specific model year's vehicles in specific calendar year is
22    determined by multiplying 1) new vehicle sales for that model year, 2) the fraction of
23    new vehicles remaining on the road according to the age of those vehicles in that calendar
24    year and 3) the annual VMT for that vehicle class at that age. Historic vehicle sales are
25    currently hard-coded in the model, like annual VMT and survival fractions. However,
26    they will soon be made a part of a References spreadsheet and modifiable by the user.
27    For the purposes of benefit calculation, the user can already change these values in the
28    Benefits Calculation spreadsheet and the changes will flow through to the calculation of
29    fuel consumption and VMT-related costs and benefits.  Vehicle sales starting with the
30    baseline year are input to the model through the Market spreadsheet,  as described above.
31    Historic sales are shown in cells V2:W39 of the Shared Inputs worksheet of the Benefits
32    Calculation spreadsheet. Vehicle sales starting in the baseline year are shown on the
33    Benefits2 (Sales) worksheet of the Benefits Calculation spreadsheet.
34
35          These VMT values for each combination of model year  and calendar year are then
36    multiplied by fuel consumption per mile and emission  factors and summed by calendar
37    year to determine total fuel consumption and emission levels by calendar year both
38    before and after GHG emission control. Fuel consumption per  mile and CO2-equivalent
39    emissions before and after control are direct outputs of the compliance model.  Pre-
40    control levels are specified in the Market spreadsheet, while post-control values are a
41    direct function of the GHG standard specified. The resultant fuel consumption and
42    emission levels are presented on the Emissions_Fuel_Consv worksheet of the Benefits
43    Calculation spreadsheet. Intermediate calculations are performed on the VMT_Lookup
44    and VMT_Rebound_Effect worksheets of the Benefits Calculation spreadsheet.
45
                               VGHG Model Documents Page 18 of 43

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 1          The model also estimates the additional emissions of CO, VOC, NOx, PM and
 2    SOx which result from the rebound effect. The emission factors for these pollutants are
 3    currently hard-coded in the model, like annual VMT and survival fractions. However,
 4    they will soon be made a part of a References spreadsheet and modifiable by the user.
 5    For the purposes of benefit calculation, the user can already change these values in the
 6    Benefits Calculation spreadsheet and the changes will flow through to the calculation of
 7    social costs and benefits. These emissions are currently specified as a function of age
 8    using either linear or quadratic equations.  The coefficients for these emission factors are
 9    taken from EPA's MOBILE6 emission model and are shown in cells HI :R11 of the
10    Exclusive Inputs worksheet of the Benefits Calculation spreadsheet. The resultant
11    emission levels are presented on the Emissions_Fuel_Consv worksheet of the Benefits
12    Calculation spreadsheet.
13
14          The value of the change in fuel consumption is determined by simply multiplying
15    the change in fuel consumption by calendar year by the price of fuel less taxes. Fuel
16    prices are input to the model via the Fuels spreadsheet, as described above.  They are
17    shown in cells Dl :E44 of the Shared Inputs worksheet of the Benefits Calculation
18    spreadsheet. Fuel taxes are not currently input to the model, but are simply part of the
19    Benefits Calculation spreadsheet. We plan to add these taxes by fuel type to the Fuels
20    spreadsheet. Fuel taxes are assumed to be constant over time and are shown in cells
21    AE2:AF2 of the VMT Adj Costs worksheet of the Benefits Calculation spreadsheet.  The
22    value of fuel savings are shown on column E of the Externaties worksheet of the Benefits
23    Calculation spreadsheet, and also carried forward to the Non-Tech Costs and All Costs
24    worksheets.
25
26          The model also estimates the value of externalities related to crude oil use. These
27    externalities include, for example, monopsony effects within the crude oil market, the
28    economic impact of periodic price shocks, and military costs related to protecting oil
29    production and supply overseas. These values are all in terms of $ per gallon. They are
30    currently hard-coded in the model, like annual VMT and survival fractions. However,
31    they will soon be made a part of a References spreadsheet and modifiable by the user.
32    For the purposes of benefit calculation, the user can already change these values in the
33    Benefits Calculation spreadsheet and the changes will flow through to the calculation of
34    costs and benefits. The value of crude oil  related externalities are shown on column F of
35    the Externaties worksheet of the Benefits Calculation spreadsheet, and also carried
36    forward  to the Non-Tech Costs and All Costs worksheets.
37
38          The value of the changes in CO2 and other pollutant emissions are based on
39    estimates of the value of these pollutants per ton  of emission.  The value of CO2 emission
40    reductions is input to the model through the Scenario spreadsheet. This value in real
41    terms can vary over time (e.g.,  increase at 2.4% per year in real dollars). The values for
42    the other pollutants are currently hard-coded in the model, like annual VMT and survival
43    fractions. However, they will soon be made a part of a References spreadsheet and
44    modifiable by the user.  They are shown in cells A15:B23 of the Shared Inputs worksheet
45    of the Benefits Calculation spreadsheet.  For the purposes of benefit calculation, the user
46    can already change these values in the Benefits Calculation spreadsheet and the changes
                               VGHG Model Documents Page 19 of 43

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 1    will flow through to the calculation of costs and benefits. The value of changes in
 2    vehicle emissions are shown on the DownstreamCosts ($) worksheet of the Benefits
 3    Calculation spreadsheet, and also carried forward to the Non-Tech Costs and All Costs
 4    worksheets.
 5
 6           The model also estimates the amount of emission reduction related to reduced fuel
 7    production and distribution.  The estimates of the emissions of each pollutant associated
 8    with the production and distribution of each fuel are currently hard-coded in the model,
 9    like annual VMT and survival fractions.  However, they will soon be made a part of a
10    References  spreadsheet and modifiable by the user.  They are shown in Columns E and F
11    of the Shared Inputs worksheet of the Benefits Calculation spreadsheet.  For the purposes
12    of benefit calculation, the user can already change these values in the Benefits
13    Calculation spreadsheet and the changes will flow through to the calculation of costs and
14    benefits. The value of changes in upstream emissions are shown on the UpstreamCosts
15    ($) worksheet of the Benefits Calculation spreadsheet, and also carried forward to the
16    Non-Tech Costs and All Costs worksheets.
17
18           The model estimates five additional vehicle related costs and benefits.  Three are
19    related  to the additional VMT resulting from reduced fuel consumption: noise, congestion
20    and accidents.  The values for these factors are expressed in terms of $ per mile.  Thus,
21    their total values are simply the  product of these per mile values and the additional VMT
22    resulting from the reduced fuel consumption.  The values of these three vehicle related
23    impacts are currently hard-coded in the model, like annual VMT and survival fractions.
24    However, they  will soon be made a part of a References spreadsheet and modifiable by
25    the user. They  are shown in cells Al 1 :B14 of the Exclusive Inputs worksheet of the
26    Benefits Calculation spreadsheet. For the purposes of benefit calculation, the user can
27    already change these values in the Benefits Calculation spreadsheet and the changes will
28    flow through to the calculation of costs and benefits. The value  of changes in these
29    vehicle impacts on society are shown on the External VMTCosts ($) worksheet of the
30    Benefits Calculation spreadsheet, and also carried forward to the Non-Tech Costs and All
31    Costs worksheets.
32
33           The fourth vehicle related impact is related to the time required to refuel vehicles.
34    As fuel consumption per mile decreases, if fuel tank size doesn't decrease, or at least
35    does not decrease proportional to fuel consumption, the number of vehicle refuelings will
36    decrease. The parameters involved in estimating the reduction in refuelings are not
37    currently input  to the model, but are simply part of the Benefits Calculation spreadsheet.
38    We plan to add these parameters to the References spreadsheet.  The value of the
39    reduction in the number of refueling is estimated as the product of:
40
41    1) The reduction in fleetwide fuel consumption for a specific calendar year,
42    2) Average fuel tank size,
43    3) Average refueling volume, as a percentage of fuel tank capacity,
44    4) Ratio of the change in fuel tank size to the change in fuel consumtion,
45    5) Average time required to refuel a vehicle,
46    6) Value of time to the driver and other occupants,
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 1    7)  The number of total occupants in the vehicle, including the driver.
 2
 3    The input values and the annual benefits are in columns H and I of the
 4    ExternalVMTCosts ($) worksheet of the Benefits Calculation spreadsheet, and also
 5    carried forward to the Non-Tech Costs and All Costs worksheets.
 6
 7           The final vehicle related benefit category is the value of the increased driving
 8    associated with the rebound effect. People decide to drive more because the value of
 9    travelling somewhere exceeds the cost.  This value consists of two components. The first
10    is the sum of the direct costs of the additional driving. This is assumed to be cost of fuel
11    consumed plus that of the additional congestion caused.  The additional  noise and
12    accidents are not considered to be direct costs. Noise is primarily experienced by non-
13    drivers and therefore not considered by  drivers in their decision to take an additional trip.
14    While accidents tend to be proportional to mileage, especially for a given driver, we
15    assume that most of the cost of accidents is borne by insurance, where there is only a
16    weak association with mileage driven. Congestion, on the other hand, is totally
17    experienced by drivers and experienced fully each trip.
18
19           The second component of the value of the additional driving is the change in the
20    consumer surplus of the demand for VMT versus the cost of driving.  We estimate this
21    change in surplus as one half the change in VMT times the change in the cost of driving,
22    which here is the reduction in fuel cost per mile.  All of these terms have already been
23    estimated for other purposes within the Benefits Calculation spreadsheet. The value of
24    the additional driving is calculated and shown in column I of the ExternalVMTCosts ($)
25    worksheet of the Benefits Calculation spreadsheet, and also carried forward to the Non-
26    Tech Costs and All  Costs worksheets.
27
28           The first step in loading the Benefits Calculation model is to "save" the results of
29    a model run (click on "File", then "Save" in the menu bar of the model window). This
30    saves the model results in an ".html" file, whose name is the current date/time stamp.
31    The next step is to open the Benefits Calculation spreadsheet (if it is not already opened),
32    go to the Load worksheet,  and click on the Load button.  From the list of files available to
33    load, choose the last one on the list.  This loads the latest model results into the
34    spreadsheet and updates all the cost and benefit estimates.
                               VGHG Model Documents Page 21 of 43

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i                              ATTACHMENT 2
2
3                     Appendices to GHG Model Description
                          VGHG Model Documents Page 22 of 43

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1
2
Appendix 1: Examples of Market input file (Vehicle Fleet Characterization)
                     ^^
il*) File  idlt View Insert Format lools Data Window Help

U ,^ J J J JL " *i,  A  -J A - /    ^ -  A Z - ll il
                                                               i Centur i Gothlc
                                                                                    , ir if ^
AE9 - f, 0%
1
T"
3
4
5
6
1
8
Vehicle Index No I >
1
2
3
4
5
6
7
•3 8
10
Tf
12
13
"if
_
16
9
10
11
12
13
14
15
17 | 16
18 | 17
19
20
21
18
19
20
22 | 21
23
24
22
23
25 24
26
_
213
29
30
31
32~
33
34
35
36
26
27
28
29
30
31
32
33
34
35
36
37 37
38
"39"
38
39
40 | 40
Manufacturer j CD
MFR1
MFR1
MFR1
MFR1
MFR1
MFR1
MFR1
MFR1
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
1.
i
MFRl Specialty Auto >=VS>5 6k
MFR1 Specialty Auto V6 >40k
MFR1 Small CarV6
MFR1 SubCompact V6
MFR1 SubCompacf 14
IViFRl Midsize MPVV6&V8< 6001 GVWAWD4WD
MFR1 Large MPVV8 > 6000 GVW
MFR1 Large MPVV6> 6000 GVW
MFR2 Large CarVS
MFR2 Large CarV6
MFR2 Midsize Car V6
MFR2 Midsize Car 14
MFR2 Small Car 14
MFR2 Large Truck +Van V8
MFR2 Large MPV V6< 6001 GVW AWD 4WD
MFR2 Midsize MPVV6 &. VS =c 6001 GVWAWD4WD
MFR2 Small MPV VI4  6000 GVW
IV1FR2 Large MPVV6> 6000 GVW
MFR3 Large Truck +Van V8
MFR3 Small MPVVi4> 6000 GVW
MFR3 Large MPV V8 < 6001 GVW AWD 4WD
MFR3 Large MPV V6 < 6001 GVW AWD 4WD
MFR3 Midsize MPVV6&VS=: 6001 GVWAWD4WD
MFR3 Midsize MPVVI4< 6001 GVW AWD 4WD
MFR3 Small MPVV6< 600! GVWAWD4WD
MFR3 Small MPV VI4 < 6001 GVW AWD 4WD
MFR3 Car Uke Midsize MPV V6 & V8 < 6001 GVW 2WD FWD RWD
MFR3 Large Truck* Van V6
MFR3 Car Uke Midsize MPVVI4< 6001 GVW2WD FWD RWD
MFR3 Car Uke Small MPVV6< 6001 GVW 2WD FWD RWD
MFR3 Car Uke Small MPV VI4 =c 6001 GVW 2WD FWD RWD
MFR3 Large MPV V8 > 6000 GVW
MFR3 Large MPVV6> 6000 GVW
D
Vehicle Type Ho
6
5
4
4

16
18
17
6
5
5
3
2
12
17
16
13
9
8
11
7
3
18
17
12
13
18
17
16
15
14
13
8
1
7
4
3
18
17
Baseline Sales im
42,61 1
64,844
90,477
11,769
90,882
26,330
8,086
25,636
54,124
191,67!
25,288
71,840
210,337
183,617
1 3,222
102,623
150,279
3,777
101,993
132,563
43,183
23,082
46,653
285,679
608,548
11,927
807
8,387
134,075
71,94!
4,999
26,195
127,787
177,914
89,190
4,997
37,215
33,41 6
19,069
Annual Sales - Cycle 1 1 -r\
49,028
74,608
104,10!
13,54!
104,566
25,107
7,712
24,493
62,274
220,533
29,096
82,657
242,009
1 75,085
12,607
97,855
1 43,296
3,602
97,254
126,404
41,177
22,010
44,485
272,405
580,27!
11,372
769
7,997
127,845
68,598
4,766
24,977
12!, 849
169,647
85,046
4,764
35,486
31,863
18,183
G
I
a
c
53,78!
81,842
114,195
14,854
114,705
23,414
7,192
22,84!
68,312
241,916
31,917
90,672
265,474
163,278
11,757
91,256
133,632
3,359
90.695
! 1 7,879
38,400
20,525
41,485
254,035
54!, 139
10,656
717
7,458
119,224
63,972
4,445
23,293
113,632
158,207
79,311
4,443
33,093
29,714
1 6,957
H
c
59,196
90,082
125,692
1 6,350
126,254
24,646
7,571
24,043
75,190
266,272
35,130
99,801
292,203
171,870
12,376
96,058
140,664
3,536
95,468
! 24,083
40,420
21,606
43,663
267,403
569,616
11,164
755
7,850
125,498
67,338
4,679
24,519
) 19,61 2
1 66,532
83,484
4,677
34,834
31,278
1 7,849
Annual Sales - Cycle 4t —
66,852
101,732
141,947
18,464
142,582
26,896
8,262
26,238
84,914
300,707
39,673
112,707
329,991
187,561
13,506
104,828
153,507
3,859
104.184
135,411
44,111
23,578
47,655
291,816
621,620
12,183
824
8,567
136,955
73,486
5,106
26,757
1 30,532
181,736
91,106
5,104
38,014
34,133
19,479
J
Annual Sales - O,
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
K
u
c
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
L
N
Annual Sales - Q
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
M
i
u
c
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
N
2
Combined FE (rr
23.3
25.0
25.8
27.3
33.4
21.9
21.2
20.7
22.3
26.0
27.8
32.0
31.9
20.9
21.5
22.3
29.3
22.1
24.2
21.1
28.5
30.9
19.3
24.7
20.2
27.7
19.8
22.0
24.5
31.7
22.0
24.2
24.4
19.3
28.9
22.4
25.4
19.5
21.5
0
Tailpipe Co2 (g
380.8
356.1
344.9
325.9
266.3
406.0
419.4
429.4
397.6
342.2
319.8
277.7
278.5
425.3
413.3
398.5
303.1
402.1
367.9
421.3
311.8
287.3
460.4
360.2
438.9
321.1
449.4
404.5
363.4
280.4
404.3
366.5
363.9
459.8
308.0
397.1
349.3
456.1
412.8
P
Footprint (ft2
49.6
46.3
43.3
40.2
38.8
46.1
47.4
47.8
52.5
52.5
46.7
46.7
43.1
63.7
47.1
46.3
43.1
47.1
48.6
49.9
49.0
43.1
-49.5
53.8
664
47.9
50.1
50.1
47.1
43.7
47.8
47.8
50.1
51.5
44.4
47.8
47.0
50.4
50.1
Q R S T
Cyrb Weight (lb.)
4103.046906
3465.533105
3404.007246
2980.607444
2661
3950
4950
4700
4125.541852
3772.65404
3443.4
3308
3144.559827
5253.299499
4497
4232.958082
3376.343946
4325
41 1 1 .464934
4247.234924
3790
3226.606482
5049.453852
4563.906726
5112.562216
3973
4727
4561.65741
3819.664068
3605.117861
3929
3929
3943.530692
4589 23521 7
3443.010016
3710
3609.669678
5697.92506
4740
No, of Cylinders
8
6
6
6
4
6
8
6
8
6
6
4
4
8
6
6
4
6
6
6
4
4
8
6
8
4
8
6
6
4
6
4
6
6
4
6
4
8
6
(5
4.5
2.9
2.6
2.5
1.6
2.9
4.4
3.0
5.8
3.1
2.9
2.4
2.1
5.2
3.7
3.7
2.4
3.7
3.5
3.8
2.4
2.4
5.4
3.5
5.2
2.0
4.4
3.2
3.4
2.5
3.7
2.3
3.4
3.9
2.5
3.7
2.4
4.9
3.2
i
328.0
230.4
193.4
184.0
143.2
216.3
271.8
225.0
351.1
223.5
201.9
172.0
161.8
333.5
210.0
217.8
172.0
210.0
219.3
203.2
172.0
170.9
356.8
234.8
311.2
137.0
311.0
238.0
262.6
163.9
270.0
162.4
251.0
212.7
163.0
270.0
164.7
384.2
238.0
U V IWj X
!







































j
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
*
.B
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
i
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Unibody
Y
Internal Volume
45
45
45
45
45.0
45.0
45.0
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
45
Z
Q.
1
E
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Combined EC ;
(kWh/mi) IS
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
00
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
00
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
< < > >i \Market Data/ Vehicle Type / Refri f < > <
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1
2
3
4
5
6
7
a
9
1U
11
12
13
14
15
16
17
18
19
2U
22
23
24
25
2b
2/
28
29
3U
31
32
33
34
35
36
3/
38
39
40
A
1
2
3
4
5
6
7
8
9
10
11
12
13
14
li
16
17
18
19
20
21
22
23
24
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Manufacturer i DD
MFR1
MFR1
MFR1
MFR1
MFR1
MFR1
MFR]
MFR]
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR2
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
MFR3
C
3
MFR! Specialty Auto>=V8>S6k
MFR! Specialty Auto V6 >-40k
MFR! Small CarV6
MFR1 SubCompacfV6
MFR! SubCompacf 14
MFR! Midsize MPV V6&V8=c 6001 GVWAWD4WD
MFR! Large MPVV8 > 6000 GVW
MFR! Large MPVV6> 6000 GVW
MFR2 Large Car VB
MFR2 Large Car V6
MFR2 Midsize Car V6
MFR2 Midsize Car 14
MFR2 Small Car 14
MFR2 Large Truck +Van V8
MFR2 Large MPV V6< 6001 GVW AWD 4WD
MFR2 Midsize MPV V6&V8< 6001 GVWAWD4WD
MFR2 Small MPV VI4< 6001 GVW AWD 4WD
MFR2 Car Like Large MPV V6< 6001 GVW 2WD FWD RWD
MFR2 Car Like Midsize MPV V6 & V8 * 6001 GVW 2WD FWD RWD
MFR2 Large Truck* Van V6
MFR2 Car Like Midsize MPVVI4< 6001 GVW 2WD FWD RWD
MFR2 Car Like Small MPV VI4 < 6001 GVW 2WD FWD RWD
MFR2 Large MPVV8 > 6000 GVW
MFR2 Large MPVV6> 6000 GVW
MFR3 Large Truck +Van V8
MFR3 Small MPVVI4> 6000 GVW
MFR3 Large MPV V8< 6001 GVWAWD4WD
MFR3 Large MPV V6 < 6001 GVW AWD 4WD
MFR3 Midsize MPV V6&V8< 6001 GVWAWD4WD
MFR3 Midsize MPV VI4 < 6001 GVW AWD 4WD
MFR3 Small MPVV6< 6001 GVW AWD 4WD
MFR3 Small MPVV!4< 600) GVW AWD 4WD
MFR3 Car Like Midsize MPV V6&V8< 6001 GVW 2WD FWD RWD
MFR3 Large Truck* Van V6
MFR3 Car Like Midsize MPVVI4< 600) GVW2WD FWD RWD
MFR3 Car Like Small MPV V6< 6001 GVW 2WD FWD RWD
MFR3 Car Like Small MPV VI4 < 6001 GVW 2WD FWD RWD
MFR3 Large MPVV8 > 6000 GVW
MFR3 Large MPVV6> 6000 GVW
AB
a
I


R134a
R134a
R134C!
R1340
R1340
R1340
R134C!
R134C!
R134C!
R134a
R134a
R134a
R134a
R134a
R134a
R134a
R134CI
R1340
R1340
R1340
R1340
R134a
R1340
R134a
R134C!
R134a
R134CI
R134a
R134a
R134a
R134a
R134a
R134a
R134a
R134a
R1340
R134a
R1340
R134a
AC
| 5
C 0
1!
V
O.I
O.I
0.1
0.1
0.1
0.1
0.1
O.I
O.I
0.1
01
0.1
0.1
0.1
O.I
O.I
0.1
0.1
0.1
0.1
0.1
0.1
0,1
0,1
O.I
O.I
0.1
0.1
0.1
0.1
01
O.I
O.I
O.I
0.1
0.1
0.1
01
01
AD
s
is
24%
24%
19%
19%
17%
24%
33%
24%
8%
3%
9%
27%
12%
19%
24%
7%
12%
24%
31%
3%
22%
12%
1.7%
9%
34%
11%
41%
24%
24%
21%
23%
29%
30%
23%
23%
23%
27%
45%
24%
AE
S
iS
0%
0%
88%
74%
0%
0%
0%
0%
33%
0%
0%
0%
0%
47%
0%
0%
0%
0%
0%
0%
0%
0%
72%
57%
0%
0%
0%
0%
17%
0%
0%
0%
0%
10%
1%
0%
0%
0%
0%
AF

is
95%
31%
0%
0%
53%
43%
44%
44%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
18%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
AG
€
s
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
4%
0%
0%
0%
0%
1%
0%
0%
0%
0%
AH
0
s
e
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
t)%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
38%
0%
0%
0%
0%
12%
0%
0%
0%
0%
Al
0
s
6
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
A!
d

is
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
AK
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-------
1
2
    Appendix 2: Technology input file (technology package characterization)
E Microsoft Excel - Technology- 1
jrfl] File Edit Slew Insert Format Tools Date
ijjdj jj.fii A -j ,a • / i
Window
„ . , 5
Help
i z -

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       R25

1
2
3
4
5
B
7
8
y
A
Tech.
Pkg. No.
1
2
3
4
5
6
7
B
101 9
11
\1
13
14
16
10
11
12
13
14
16 IS
17
18
19
2U
21
22
__
_
25;
26
~7J
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~29
IfJ
~31~
32"
33
34"
35'
"36
37
38
39
40
TT
__
_
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16
17
IB
19
20
B
Technology Package Desciipfion
Fricf ion/ Lubrication/ Aerodynamics/Tires
A/C Rl 52a Low Leak, High Efficiency
Pumping (VT-CCP and lift DWq
Automated Manual Transmission
Accessor! es + ISO
Gasoline HCCI -Dual mode
Diesdilation
Full Hybrid (Power Split)
Plug-in Hybrid











C
Abbi.
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]
100%
100%
100%
20%
100%
0%
15%
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E
Cap
Cycle
2
100%
100%
100%
50%
100%
10%
25%
50%
25%











F
Cap
Cycle
3
100%
100%
100%
100%
100%
30%
50%
75%
50%











G
Cap
Cycle
4
100%
100%
100%
100%
100%
75%
75%
100%
75%











H
Cap
Cycle
i
100%
100%
100%
100%
100%
100%
100%
100%
100%











1
Cap
Cycle
i
100%
100%
100%
100%
100%
100%
100%
100%
100%











J
Cap
Cycle
7
100%
100%
100%
100%
100%
100%
100%
100%
100%











K
Cap
Cycle
a
100%
100%
100%
100%
100%
100%
100%
100%
100%











L
All
Cycle
1
6.80%
2.00%
7.00%
B.00%
9.50%
0.00%
5.00%
1 7.30%
35.40ซ











M
AIE
Cycle
2
6.80%
2.00%
7.00%
8.00%
9.50%
9.00%
500%
9.10%
35.40%











N
AIE
Cycle
3
680%
2.00%
700%
800%
950%
9.00%
500%
9.10%
35.40%











0
AIE
Cycle
4
6.80%
2.00%
7.00%
8.00%
9.50%
9.00%
500%
9.10%
35.40%











P
AIE
Cycle
S
6.80%
2.00%
7.00%
8.00%
9.50%
9.00%
5.00%
9.10%
35.40%











Q
AIE
Cycle
6
6.80%
2.00%
7.00%
8.00%
9.50%
9.00%
S.00%
9.10%
35.40%











R
AIE
Cycle
7
6.80%
2.00%
7.00%
8.00%
9.50%
9.00%
5.00%
9.10%
35.40%











S
AIE
Cycle
g
6.80%
200%
700%
800%
9.50%
9.00%
500%
9.10%
3540%











T
Retiig
Effect
0.0%
50.0%
0.0%
00%
00%
0.0%
00%
0.0%
00%











u
Retrig
Type
NC
R152a
NC
NC
NC
NC
NC
NC
NC











V
Primary
Fuel
G
G
G
G
G
G
D
G
G











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i / Vehicle Type 4 / Vehicle Type 5 / Vehicle Type 6 / Vehicle Type 7 / Vehicle Type S / Vehicle Type 9 / Vehicle Type 10 / Vehicle Type 11 / Vehicle Type
.'.'BS;.A.' = -SJ Ja
4
5
6
    Appendix 3: Scenario input file

-------
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1




































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Market-l xk




































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Appendix 4:  Fuels input file
       jijfj] File  Edit View Insert  Format  Tools Data  Window  Help

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3.65
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-------
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
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0,2
1
•™i'ซi™™iซi'''™iii''™™ซ™™ii''™™"
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0,5 1 1
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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

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   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

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   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

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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

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(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

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        APPENDIX D




PAUL LEIBY'S REVIEW DOCUMENT

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                                                                          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

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       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

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       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

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          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

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       •   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

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                 •  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

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•  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

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          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

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       •   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

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                    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

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   •   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

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                 •  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

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Appendix D-13 Paul Leiby Review

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           APPENDIX E




JONATHAN RUBIN'S REVIEW DOCUMENT

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                                        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

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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

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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

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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

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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

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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.

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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

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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.

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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

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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

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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

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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

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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

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   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

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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

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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

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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.)

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•  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.

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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.

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(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

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•  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

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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

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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.

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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

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   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

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   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:

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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

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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

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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

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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

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              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.

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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

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          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,

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                           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

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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

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       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;

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   •   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.

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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.

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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

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   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

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                    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.

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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

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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

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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.

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       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."

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•  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.

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              •   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

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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

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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

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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

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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

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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.

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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.

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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

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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.

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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.

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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.

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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.

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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.

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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.

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