Interim Joint Technical Assessment Report:
Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standards
for Model Years 2017-2025
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
Office of International Policy, Fuel Economy, and Consumer Programs
National Highway Traffic Safety Administration
U.S. Department of Transportation
California Air Resources Board
California Environmental Protection Agency
September 2010
SEFA
California Environmental Protection Agency
0BAir Resources Board
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2017-2025 Technical Assessment
Table of Contents
Executive Summary v
1 Introduction 1-1
1.1 Purpose of this Report 1-1
1.2 National Program for Model Years 2012 - 2016 1-2
1.3 Standards for 2017 and Beyond 1-4
1.4 Future Technical Work and Analysis for the Joint Federal Rulemaking 1-5
Chapter 1 References 1-7
2 Technical Input from Stakeholders 2-1
2.1 Overview of Stakeholder Outreach Process 2-1
2.2 Input from Various Stakeholder Groups 2-1
2.2.1 Automobile Original Equipment Manufacturers 2-1
2.2.2 Automotive Suppliers 2-8
2.2.3 Non-Governmental Environmental Organizations 2-9
2.2.4 State and Local Government Organizations 2-10
2.2.5 Infrastructure Providers 2-11
2.2.6 Labor Unions 2-11
Chapter 2 References 2-13
3 Technology, Cost, Effectiveness and Lead-time Assessment 3-1
3.1 What technologies did the Agencies Consider? 3-1
3.2 How did the Agencies Determine the Costs and Effectiveness of Each of These
Technologies? 3-1
3.2.1 How are Cost and Effectiveness Estimates Different from the 2012-2016 Rule?... 3-1
3.2.2 Costs from Tear-down Studies 3-2
3.2.3 Costs ofHEV, PHEV, EV, andFCEV 3-4
3.2.4 Mass Reduction Impacts and Costs 3-7
3.2.5 Indirect Cost Multipliers 3-11
3.2.6 Cost Adjustment to 2008 Dollars 3-12
3.2.7 Costs Effects due to Learning 3-13
3.2.8 Cooled EGR Cost and Effectiveness 3-13
3.2.9 HEV Effectiveness 3-14
3.2.10 Ongoing Vehicle Simulation to Update Effectiveness 3-14
3.3 Vehicle Manufacturer Lead Time 3-15
3.4 Other Technologies Assessed 3-19
3.4.1 Types of engine technologies that improve fuel economy and reduce CO2 emissions
include the following: 3-19
3.4.2 Types of transmission technologies considered include: 3-22
3.4.3 Types of vehicle technologies considered include: 3-23
3.5 Technology Packages in OMEGA 3-27
Chapter 3 References 3-29
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4 Infrastructure Assessment 4-1
4.1 Overview 4-1
4.2 Electric Vehicle Infrastructure 4-2
4.2.1 DOE Charging Infrastructure Projects Underway 4-2
4.2.2 Home Charging Adequacy 4-6
4.2.3 Charging System Cost 4-9
4.2.4 Battery End-of-Life Value Assessment and Secondary Use Applications 4-12
4.2.5 Potential Impacts on the Electric Utility and Distribution Infrastructure 4-12
4.2.6 Voluntary Standards to Support PHEV & EV Infrastructure 4-14
4.3 Hydrogen Infrastructure Overview 4-17
4.3.1 Status Today 4-17
4.3.2 Prospects for Cost and Technology Improvement 4-21
4.3.3 Infrastructure Rollout Strategy 4-21
4.3.4 Policies and Partnerships 4-22
4.4 Conclusions 4-24
Chapter 4 References 4-25
5 Incentives and Flexibilities 5-1
5.1 Overview of Existing Incentives and Flexibilities in the MYs 2012-2016 Program 5-1
5.2 Potential Credit Programs, Incentives, and Other Flexibilities for 2017 and Later 5-4
5.3 Input on Non-regulatory Incentives from Stakeholders 5-7
Chapters References 5-10
6 Analysis of Scenario Costs and Impacts 6-1
6.1 Context 6-1
6.2 Analytic Approach 6-1
6.3 Development of Technology Pathways 6-6
6.3.1 Model Years Considered 6-6
6.3.2 Scenario Stringencies Assessed 6-7
6.3.3 Technology Pathways Considered 6-8
6.4 Other Key Inputs to the Analysis 6-11
6.5 Results of Analysis 6-13
6.6 PHEV and EV Battery Cost Sensitivity Assessment 6-28
Chapter 6 References 6-30
7 Other Key Factors 7-1
7.1 Potential Impacts on the Economy and Employment 7-1
7.1.1 Impacts on Auto Manufacturers, Suppliers, and Auto Industry Employment 7-1
7.1.2 Impacts on Vehicle Sales 7-2
7.1.3 Summary 7-2
7.2 Upstream GHG Emissions 7-3
Chapter 7 References 7-4
Appendix A: The Baseline and Reference Vehicle Fleet A-l
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Appendix B: Package Cost and Effectiveness B-l
Appendix C: Reserved C-l
Appendix D: Air Conditioning D-l
Appendix E: Key Inputs to the Analysis E-l
Appendix F: EPA Documentation of OMEGA model Analysis F-l
Appendix G: Infrastructure G-l
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2017-2025 Technical Assessment
Executive Summary
The Environmental Protection Agency (EPA) and the National Highway Traffic Safety
Administration (NHTSA, a modal administration within the Department of Transportation) ("the
agencies") are collaborating with the California Air Resources Board (CARB) to build on the
success of the first phase of the National Program to regulate fuel economy and greenhouse gas
(GHG) emissions from U.S. light-duty vehicles. The strong and coordinated first phase of
standards for model years (MY) 2012-2016 was completed in April 2010, ensuring that all
manufacturers can build a single fleet of U.S. vehicles to meet the new harmonized standards.
On May 21, 2010, the President called on the agencies to take additional coordinated
steps to bring about a new generation of clean vehicles.l Among other things, the agencies were
tasked with researching and then developing standards for MY 2017 through 2025 that would be
appropriate and consistent with EPA's and NHTSA's respective statutory authorities, in order to
continue to guide the automotive sector along the road to reducing its fuel consumption and
GHG emissions, thereby ensuring the corresponding energy security and environmental benefits.
During the public comment period for the MY 2012-2016 proposed rulemaking, many
stakeholders encouraged EPA and NHTSA to begin working toward standards for MY 2017 and
beyond that would maintain a single nationwide program. Several major automobile
manufacturers and CARB sent letters to EPA and NHTSA in support of a 2017 to 2025 MY
rulemaking initiative outlined in the President's May 21st announcement.
In his May 2010 memorandum, the President recognized that, by acting expeditiously,
our country could take a leadership role in addressing these global challenges. He stated that,
"America has the opportunity to lead the world in the development of a new generation of clean
cars and trucks through innovative technologies and manufacturing that will spur economic
growth and create high-quality domestic jobs, enhance our energy security, and improve our
environment." The effort described in the Presidential Memorandum represents a continuation
of the National Program to control GHGs and reduce oil consumption from the transportation
sector. As directed by the President, NHTSA and EPA, in close coordination with CARB are
working together under a carefully coordinated set of steps to further control GHG emissions and
reduce oil consumption from the transportation sector.
In response to the President's request and to craft a clear regulatory path for the
automobile industry, the agencies have collaborated with CARB to prepare this joint Technical
Assessment Report to inform the rulemaking process and provide an initial technical assessment
for that work. In accordance with the Presidential Memorandum, the agencies are also issuing a
joint Notice of Intent to Issue a Proposed Rulemaking (NOI). The NOI announces plans for
initiating a joint rulemaking which will be designed to improve the fuel efficiency and reduce the
1 Presidential Memorandum: "Improving Energy Security, American Competitiveness and Job Creation, and
Environmental Protection Through a Transformation of Our Nation's Fleet of Cars And Trucks," Issued May 21,
2010, published at 75 Fed. Reg. 29399 (May 26, 2010), also available at http://www.whitehouse.gov/the-press-
office/presidential-memorandum-regarding-fuel-efficiency-standards.
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GHG emissions of passenger cars and light-duty trucks built in MYs 2017-2025. The joint
federal rulemaking will undergo a full notice-and-comment process, consistent with law and
Administration policies on openness, transparency, and sound science.
EPA, NHTSA, and CARB are issuing this joint Technical Assessment Report in response
to Section 2(a) of the Presidential Memorandum. Section 2(a) of the Presidential Memorandum
requests that EPA and NHTSA "Work with the State of California to develop by September 1,
2010, a technical assessment to inform the rulemaking process, reflecting input from an array of
stakeholders on relevant factors, including viable technologies, costs, benefits, lead time to
develop and deploy new and emerging technologies, incentives and other flexibilities to
encourage development and deployment of new and emerging technologies, impacts on jobs and
the automotive manufacturing base in the United States, and infrastructure for advanced vehicle
technologies." This report provides an overview of key stakeholder input and addresses the
topics noted in the memorandum, and presents the agencies' initial assessment of a range of
stringencies of future standards. Chapter 1 of this report provides a further introduction and
overview of the light-duty vehicle related sections of the May 21, 2010 Presidential
Memorandum, and also of the final rule establishing CAFE and GHG standards for MYs 2012-
2016 light-duty vehicles.
During June through August 2010, EPA, NHTSA, and CARB held numerous meetings
with a wide variety of stakeholders to gather input to consider in developing this Technical
Assessment Report, and to ensure that the agencies had available to them the most recent
technical information. These stakeholders included the automobile original equipment
manufacturers (OEMs), automotive suppliers, non-governmental organizations, states and state
organizations, infrastructure providers, and labor unions. The agencies sought these
stakeholders' technical input and perspectives, consistent with the President's request, on the key
issues that should be considered in assessing a national program to reduce greenhouse gas
emissions and improve fuel economy for light-duty vehicles in model years 2017-2025.
The agencies requested the OEMs' input regarding several key areas including
technology development, key regulatory design elements, infrastructure issues, perspective on
the impacts on the U.S. manufacturing base and jobs, and potential regulatory incentives and
flexibilities. The OEMs presented detailed and confidential technical information to the agencies
addressing these topics. A common theme across the auto firms is they are all heavily investing
in advanced technologies including hybrids, plug-in hybrid electric vehicles, electric vehicles,
including fuel cell vehicles, next generation internal combustion engines, and mass reduction
technologies, and companies expect to increase their offerings and sales of these technologies
significantly in the future. The companies generally stated, however, that the degree to which
these advanced technologies will penetrate the U.S. market in the 2017-2025 time frame depends
upon a number of challenges and factors, as discussed in Chapter 2 of this report. EPA, NHTSA
and CARB also met with a cross section of automotive suppliers to seek their input on the
advanced technologies they are developing which could be implemented in the 2017-2025 time-
frame. The agencies further received input from infrastructure providers. Many of the
automakers and automotive suppliers provided input on the need for vehicle charging locations
needed for the electrical charging of EVs and PHEVs to support their introduction into the
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market. Chapter 2 aggregates and summarizes information gathered from the OEM, automotive
supplier, and infrastructure provider meetings and describes how the agencies used the
information to inform this report.
The agencies also received input from numerous non-governmental organizations,
including environmental organizations; representatives from the National Association for Clean
Air Agencies (NACAA), the Northeast States for Coordinated Air Use Management
(NESCAUM), and approximately 10 individual state and local governments; and the United
Auto Workers (the UAW). All of these stakeholders strongly supported the President's call for
continuing the National Program approach and setting new fuel economy and greenhouse gas
standards for light-duty vehicles for the 2017-2025 model years. Chapter 2 also provides an
overview of issues that were raised during discussions with the states, non-governmental
organizations, and the UAW.
As discussed in Chapter 3, the agencies have conducted an initial technology cost,
effectiveness and lead-time assessment for MYs 2017-2025. The agencies assessed the cost,
effectiveness, and availability of over 30 vehicle technologies that manufacturers could use to
improve the fuel economy and reduce CC>2 emissions of their vehicles during MYs 2017-2025.
The chapter describes technologies that are readily available today, but also other technologies
that are not currently in production but are beyond the research phase and under development,
and which are expected to be in production in the 2017-2025 timeframe. The technologies
considered in this report fall into five broad categories: engine technologies, transmission
technologies, vehicle technologies, electrification/accessory technologies, electric drive
technologies including hybrid technologies and mass reduction.
Consistent with stakeholder input obtained over the summer, Chapter 3 identifies how
electric drive vehicles can be an important part of the vehicle mix that will likely be used to meet
increasingly stringent fuel economy and GHG emission standards. Electric drive vehicles
including hybrid electric vehicles (HEV), battery electric vehicles (EVs), plug-in hybrid electric
vehicles (PHEVs) and hydrogen fuel cell vehicles (FCVs), can dramatically reduce petroleum
consumption and GHG emissions compared to conventional technologies. Additionally, given
their use of fuels that can eventually be derived from entirely renewable and zero carbon
resources, the agencies note that these technologies have significant potential to transform the
vehicles of the future to a low carbon fleet.
Stakeholders, particularly the OEMs, emphasized to the agencies that the future rate of
penetration of these technologies into the vehicle fleet is not only related to future GHG and
CAFE standards, but also to future gasoline fuel prices, future reductions in HEV/PHEV/EV
battery costs, the overall performance and consumer demand for the advanced technologies,
access to electric vehicle recharging locations and, for fuel cell vehicles the development of a
hydrogen refueling infrastructure. In the case of EVs and PHEVs, electric charging locations are
needed in the form of charging systems, most often at home, but potentially also at the workplace
and other locations such as stand-alone facilities and public parking locations in order to
facilitate significant, wide-spread penetration of these vehicle technologies. In the case of FCVs,
hydrogen fueling stations are needed to support commercialization. Chapter 4 provides a
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description and assessment of current activities and technologies, discussion of costs, and
prospects for technology improvement, as well as a summary of needs for successful
infrastructure deployment to support electric drive vehicle commercialization. The agencies
worked closely with the Department of Energy (DOE) in our assessment of electric vehicle
charging requirements and issues and DOE was a contributor to this Chapter, in addition to other
technical aspects of this report.
The final rule for MYs 2012-2016 provides for several flexibilities, including averaging,
banking and trading provisions for credit carry-forward and carry-back, various additional credits
opportunities, and advanced technology incentives. The MYs 2012-2016 program also includes
additional leadtime flexibilities under the CAA for smaller volume manufacturers. Several
stakeholders provided input on the need to continue many of these flexibilities for the MYs
2017-2025 program. Chapter 5 provides an overview of these flexibilities as they exist in the
MYs 2012-2016 rule as well as the stakeholder input the agencies have received regarding their
potential applicability in the MYs 2017-2025 program. Also, Chapter 5 provides an overview of
non-regulatory approaches that can promote the commercialization of low-GHG light-duty
vehicle technologies.
Chapter 6 presents an analysis of future levels of control of GHG emissions conducted
for this Technical Assessment Report.2 Four scenarios of future stringency are analyzed for
MYs 2020 and 2025, starting with a 250 gram/mile estimated fleet-wide level in MY 2016 and
lowering CO2 scenario targets at the rates of 3% per year, 4% per year, 5% per year, and 6% per
year, respectively. For each of those rates of increase in stringency, the agencies considered the
effects of the industry following four potential "technology pathways," "A," "B," "C," and "D."
The agencies developed these different technology pathways in order to capture both the current
levels of uncertainty regarding the potential rate of penetration of various advanced technologies
and to illustrate more than one approach that the auto industry could take in responding to future
targets. This approach was also informed by our meetings with the auto companies, whom are
pursuing a range of different technology paths for the future, with different companies placing
relative emphasis on different technologies. The agencies present the results of this assessment
in terms of six broad metrics: per-vehicle cost increase, net lifetime vehicle owner savings,
payback period to the consumer, net reduction in GHG emissions, net reduction in fuel
consumption, and vehicle technology penetration mix, as shown in the tables below. Chapter 6
presents the results of this initial analysis for projected costs, emissions reductions, and lifetime
fuel savings, and also provides the technology projections that were used in the analyses.
Chapter 6 also discusses the fact that this preliminary assessment does not include consideration
of all statutory requirements and other factors that will be assessed in the upcoming Federal
rulemaking. Consideration of these factors is expected to affect cost assessments and may affect
the proposed standards.
These GHG emissions levels can be translated to mpg-equivalent levels through simple math, but we note that they
would not necessarily translate directly into equivalent CAFE standards due to their inclusion of credits for A/C
improvements, which is permissible for CAA standards but not for CAFE standards.
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The following summary tables show the fundamental quantitative conclusions from this
initial assessment. As shown in Table ES-1, automotive technologies are available, or can be
expected to be available, to support a reduction in greenhouse gas emissions, and commensurate
increase in fuel economy, of up to 6 percent per year in the 2017-2025 timeframe. Greater
reductions come at greater incremental vehicle costs. The per vehicle cost increase ranges from
slightly under $1,000 per new vehicle for a 3 percent annual GHG reduction, increasing to as
much as $3,500 per new vehicle to achieve a 6 percent annual GHG reduction. Consumer
savings would increase with the lower GHG emissions and higher fuel economy. For the
different scenarios analyzed, the net lifetime savings to the consumer due to increased vehicle
efficiency range from $4,900 to $7,400. The initial vehicle purchaser will find the higher vehicle
price recovered in 4 years or less for every scenario analyzed.
Table ES-1: Projections for MY 2025 Per-Vehicle Costs, Vehicle Owner Payback,
and Net Owner Lifetime Savings *'2
Scenario
3%/year
4%/year
5%/year
6%/year
New Fleet
g/mile CO2
Target
(MPGe)2
190 (47)
173(51)
158 (56)
143 (62)
Tech
Path
A
B
C
D
A
B
C
D
A
B
C
D
A
B
C
D
Per- Vehicle
Cost
Increase ($)
$930
$850
$770
$1,050
$1,700
$1,500
$1,400
$1,900
$2,500
$2,300
$2,100
$2,600
$3,500
$3,200
$2,800
$3,400
Payback
Period
(years)
1.6
1.5
1.4
1.9
2.5
2.2
1.9
2.9
3.1
2.8
2.5
3.6
4.1
3.7
3.1
4.2
Net Lifetime
Owner
Savings ($)
$5,000
$5,100
$5,200
$4,900
$5,900
$6,000
$6,200
$5,300
$6,500
$6,700
$7,000
$5,500
$6,200
$6,600
$7,400
$5,700
1. Per-vehicle costs represent the increase in costs to consumers from the MY 2016 standards. Payback period and
lifetime owner savings use a 3% discount rate and AEO 2010 reference case energy prices. The gasoline price used
for this estimate is $3.49/gallon in 2025 and increases over time to a maximum of $4.34/gallon in 2050. Per-vehicle
costs represent the estimated cost to the consumer, including the direct manufacturing costs for the new
technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto
manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect
costs.
2. The targets evaluated were CO2 targets which could be meet through reductions in CO2 as well as through air
conditioning system hydroflurocarbon reductions converted to a CO2 equivalent value. MPGe is the equivalent
MPG value if all of the CO2 reductions came from fuel economy improvement technologies. Real-world CO2 is
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typically 25 percent higher and real-world fuel economy is typically 20 percent lower. Thus, the 3% to 6% range
evaluated in this assessment would span a range of real world fuel economy values of approximately 37 to 50 mpg,
which correspond to the regulatory test procedure values of 47 and 62 mpg, respectively.
As shown in Table ES-2, the increased vehicle efficiency would result in substantial
societal benefits in terms of the GHG emission reductions and the petroleum use reductions. In
the analyzed scenarios for 2025 model year vehicles, lifetime GHG emissions would be reduced
from 340 million metric tons (3 percent annual improvement scenario) to as much as 590 million
metric tons for a 6 percent annual improvement scenario. For the same range of scenarios,
lifetime fuel consumption for this single model year of vehicles would be reduced by 0.7 to 1.3
billion barrels.
Table ES-2: Estimated CO2e and Fuel Reductions for the Lifetime of MY 2025
Vehicles1'2
Scenario
3%/year
4%/year
5%/year
6%/year
Lifetime CO2e Reduction
(million metric tons, MMT)
340
410-440
440-530
470-590
Lifetime Fuel Reduction
(Billion Barrels)
0.7
0.9
1.1
1.3
1. Fuel reductions are the same for each of the four technology pathways, but CO2e reductions vary as a function of
the penetration of EVs and PHEVs in each of the four technology pathways evaluated (due to an increase in
upstream emissions).
2. For reference, the National Program in MY 2016 is projected to reduce 0.6 billion barrels of fuel and 325 MMT
CO2e over the lifetime of MY2016 vehicles.
Table ES-3 illustrates the levels of technology required to achieve the different GHG and
fuel economy levels that were analyzed by the agencies. The types of vehicle technologies sold
in 2025 to meet more stringent emission and fuel economy standards depends on the stringency
of the adopted standards, the success in fully commercializing at a reasonable cost emerging
advanced technologies, and consumer acceptance. The analysis for this report illustrates a wide
range of possible outcomes, and these will likely vary by vehicle manufacturer. The potential
fleet penetrations for gasoline and diesel vehicles, hybrids, plug-in electric vehicles, or electric
vehicles also may vary greatly depending on the agencies' assumptions about what technology
pathways industry choose.
As shown in Table ES-3, at the 3 or 4 percent annual improvement scenarios, advanced
gasoline and diesel powered vehicles that do not use electric drivetrains may be the most
common vehicle types available in 2025. In the 3 percent to 4 percent annual improvement
range, all pathways use advanced, lightweight materials and improved engine and transmission
technologies. Table ES-3 also shows that hybrid vehicle penetration under the 3 and 4 percent
annual improvement scenarios vary widely due to the assumptions made for each technology
pathway, ranging from roughly 3 to 40 percent of the market in 2025.
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2017-2025 Technical Assessment
Under the 5 or 6 percent annual improvement scenarios hybrids could make up from 40
percent to 68 percent of the market. In Paths A through C, PHEVs and EVs penetrate the market
substantially only at the 6 percent annual improvement scenario. In Path D, where a
manufacturer makes no improvement in gasoline and diesel vehicle technologies beyond MY
2016, PHEVs and EVs begin to penetrate the market at the 4 percent annual improvement rate
and may have as high as a 16 percent market penetration under the 6 percent annual
improvement scenario.
Table ES-3: Technology Penetration Estimates for MY 2025 Vehicle Fleet
Scenario
3%/year
4%/year
5%/year
6%/year
Technology
Path
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
New Vehicle Fleet Technology Penetration
Mass
Reduction1
15%
18%
18%
15%
15%
20%
25%
15%
15%
20%
25%
15%
14%
19%
26%
14%
Gasoline &
diesel vehicles
89%
97%
97%
75%
65%
82%
97%
55%
35%
56%
74%
41%
23%
48%
53%
29%
HEVs
11%
3%
3%
25%
34%
18%
3%
41%
65%
43%
25%
49%
68%
43%
44%
55%
PHEVs2
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2%
2%
0%
2%
EVs
0%
0%
0%
0%
0%
0%
0%
4%
1%
1%
0%
10%
7%
7%
4%
14%
1. Mass reduction is the overall net reduction of the 2025 fleet relative to MY 2008 vehicles.
2. This assessment considered both PHEVs and EVs. These results show a higher relative penetration of EVs
compared to PHEVs. The agencies do believe PHEVs may be used more broadly by auto firms than
indicated in this technical assessment.
Chapter 7 discusses other key factors for the MYs 2017-2025 light-duty vehicle
rulemaking that the agencies are considering, including the potential impact on the employment
and vehicle sales and upstream GHG emissions.
In conclusion, the three agencies have received important input from a range of
stakeholders to inform the extension of the National Program to MYs 2017-2025. Auto
manufacturers, states, environmental groups and the United Auto Workers have expressed
support for a continuation of the National Program. All auto firms are heavily invested in
developing advanced technologies which can reduce fuel consumption and GHGs significantly
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beyond the MYs 2012-2016 standards. Manufacturers are developing many technologies that
would enable them to eventually achieve appreciable improvements in fuel economy levels,
including advanced gasoline engines, hybrid electric vehicles, EVs, and PHEVs. The three
agencies have performed an initial assessment of potential future standards (annual reductions in
the range of 3 to 6% per year, or 47 to 62 mpg in 2025 if the industry achieved all of the
increases through fuel economy improvements), which demonstrates that advanced technologies
can be used to achieve substantial reductions in fuel consumption and GHGs. The agencies
analyzed four technology pathway scenarios that the industry could pursue to achieve more
stringent targets, recognizing there are a wide range of pathways individual manufacturers could
pursue. One pathway scenario relied upon significant mass reduction and advanced next
generation gasoline vehicles, the second focused on hybridization and electrification of the fleet
(HEVs, PHEVs, EVs), and the third was a blend of the first two. The fourth pathway
emphasizes an EV and PHEV focused approach, with a lesser degree of emphasis on advanced
gasoline, HEV, and mass reduction approaches. Based on this analysis and the assumptions
employed, the agencies found that the per-vehicle cost increases for a 2025 vehicle ranged from
$770 to $3,500 across the range of stringency targets and technology pathways. The fuel savings
achieved by MY 2025 vehicles meeting these more stringent targets would result in a net lifetime
savings of between $4,900 and $7400. The GHG reductions ranged from 340 to 590 million
metric tons and fuel reduction ranged from 0.7 to 1.3 billion barrels over the lifetime of MY
2025 vehicles. We emphasize that this Technical Assessment Report reaches no specific
conclusions regarding the levels of stringency to propose for MYs 2017-2025. The report is an
important step in a continuation of the National Program, but significant work remains to be
done to support a future federal rulemaking.
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1 Introduction
1.1 Purpose of this Report
The Environmental Protection Agency (EPA) and the National Highway Traffic
Safety Administration (NHTSA, a modal administration within the Department of
Transportation) ("the agencies") are collaborating with the California Air Resources Board
(CARB) to build on the success of the first phase of the National Program to regulate fuel
economy and greenhouse gas (GHG) emissions from U.S. light-duty vehicles. The strong and
coordinated first phase of standards for model years (MY) 2012-2016 was completed in April
2010, ensuring that all manufacturers can build a single fleet of U.S. vehicles to meet the new
harmonized standards.
On May 21, 2010, following the completion of the first phase of the National Program,
the President called on the agencies to take additional coordinated steps to bring about a new
generation of clean vehicles.l Among other things, the agencies were tasked with researching
and then developing standards for MY 2017 through 2025 that would be appropriate and
consistent with EPA's and NHTSA's respective statutory authorities, in order to continue to
guide the automotive sector along the road to reducing its fuel consumption and GHG
emissions, and to ensure the corresponding energy security and environmental benefits.
Following the President's announcement, several major automobile manufacturers and CARB
sent letters to EPA and NHTSA in support of a 2017 to 2025 rulemaking initiative as outlined
in the President's Memorandum. In addition to the President's directive, many stakeholders
in their comments during the MYs 2012-2016 rulemaking encouraged EPA and NHTSA to
maintain a single nationwide program, and to extend the National Program beyond the first
phase by beginning to work toward standards for MY 2017 as soon as practicable.
The President called on the agencies to begin the next phase of the National Program
in response to the urgent and closely intertwined challenges faced by our nation of
dependence on oil, energy security, and global climate change. Reducing total petroleum use
by U.S. light-duty vehicles decreases our economy's vulnerability to oil price shocks.
Reducing dependence on oil imports from regions with uncertain conditions enhances our
energy security. The need to reduce energy consumption is more crucial today than it was
when the Energy Policy and Conservation Act was enacted in the mid-1970s. Net petroleum
imports now account for approximately 57 percent of U.S. domestic petroleum consumption,2
and the share of U.S. oil consumption for transportation is approximately 72 percent.3
Moreover, world crude oil production continues to be highly concentrated, exacerbating the
risks of supply disruptions and their negative effects on both the U.S. and global economies.
Light-duty vehicles also account for about 41 percent of all U.S. oil consumption,6 making
them the largest single oil-consuming transportation segment in the U.S. Light-duty vehicles
emit four GHGs—carbon dioxide (CO2), methane (CH/i), nitrous oxide (NOx), and
hydrofluorocarbons (HFCs) - and are responsible for nearly 60 percent of all mobile source
GHGs and over 70 percent of Section 202(a) mobile source GHGs. In 2007, CO2 emissions
represented about 94 percent of total GHG emissions from light-duty vehicles (including
HFCs), and the CO2 emissions measured by EPA fuel economy compliance tests represented
about 90 percent of all light-duty vehicle GHG emissions.4'5
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In his May 2010 memorandum, the President recognized that by acting expeditiously,
our country could take a leadership role in addressing these global challenges, stating that
"America has the opportunity to lead the world in the development of a new generation of
clean cars and trucks through innovative technologies and manufacturing that will spur
economic growth and create high-quality domestic jobs, enhance our energy security, and
improve our environment." NHTSA and EPA, in close coordination with CARB, have started
the process, through this report, to evaluate the potential for cleaner and more efficient
vehicles that would transform our nation's fleet of cars and trucks in the future. Our work
would extend the National Program and would entail a carefully coordinated set of steps to
further control GHG emissions and reduce oil consumption from the transportation sector.
To answer the President's call and to craft a clear regulatory path for the automobile
industry, the agencies have collaborated with CARB to prepare this Technical Assessment
Report to inform EPA's and NHTSA's upcoming rulemaking process and provide an initial
technical assessment for that work. Section 2 of the President's Memorandum states that this
Technical Assessment Report should reflect stakeholder input on relevant factors including:
"viable technologies, costs, benefits, lead time to develop and deploy new and emerging
technologies, incentives and other flexibilities to encourage development and deployment of
new and emerging technologies, impacts on jobs and the automotive manufacturing base in
the United States, and infrastructure for advanced vehicle technologies." This report
provides an overview of key stakeholder input received to date, and addresses the applicable
topics noted in the May 2010 Presidential Memorandum.
Section 2 of the President's Memorandum also states that EPA and NHTSA should
issue a joint Notice of Intent to Issue a Proposed Rulemaking (NO I) following the Technical
Assessment Report announcing plans to promulgate a next phase of standards for this sector,
including plans for "gathering any additional information needed to support regulatory
action." The NOI is also to include "potential standards that could be practicably
implemented nationally for the 2017-2025 model years and a schedule for setting those
standards as expeditiously as possible, consistent with providing sufficient lead time to
vehicle manufacturers."6 The joint federal rulemaking initiated with the NOI will be designed
to improve the fuel economy and reduce the GHG emissions of passenger cars and light
trucks built in MYs 2017-2025, and will follow the full notice-and-comment process,
consistent with law and Administration policies on openness, transparency, and sound
science.
1.2 National Program for Model Years 2012 - 2016
The National Program came about, in part, because of a historic agreement between
diverse interests to set in motion a national fuel efficiency policy announced by the President
on May 19, 2009.7 Several automakers and their trade associations also announced their
support for the National Program at that time. In collaborating between the public and private
sector, the United States has already shown leadership through enactment of the first-ever
harmonized GHG emissions and fuel economy standards for light-duty vehicles.
On April 1, 2010, NHTSA and EPA issued joint final rules establishing standards for
GHG emissions and fuel economy for passenger cars, light-duty-trucks, and medium-duty
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passenger vehicles ("light-duty vehicles"), which we referred to collectively as the National
Program.8 The agencies found that this first phase of the National Program will achieve
substantial reductions of GHG emissions and improvements in fuel economy from the light-
duty vehicle part of the transportation sector, based on technology that is already being
commercially applied in most cases and that can be incorporated at a reasonable cost.
EPA and NHTSA established two separate sets of standards, each under its respective
statutory authority. EPA set national CC>2 emissions standards for light-duty vehicles under
section 202 (a) of the Clean Air Act. These standards will require the fleet of vehicles to meet
an estimated combined average emissions level of 250 grams/mile of CO2 in model year
(MY) 2016, which the agencies explained is equivalent to a fuel economy level of 35.5 miles
per gallon if all the reductions were achieved through improvements in fuel economy,
although the CC>2 standards also gave credit for air conditioning improvements that reduced
GHGs other than carbon dioxide. NHTSA, in turn, set CAFE standards for passenger cars
and light trucks under EPCA, as amended by EISA.9 These standards will require
manufacturers of those vehicles to meet an estimated combined average fuel economy level of
34.1 mpg in model year 2016, which is the maximum feasible amount of improvement that
the agencies estimated could be required using fuel economy-improving technology alone,
without regard to the A/C credits permitted by EPA under the CAA. The standards for both
agencies begin with the 2012 model year, with standards increasing in stringency through
model year 2016. They represent a harmonized approach that will allow industry to build a
single national fleet that will satisfy both the GHG requirements under the CAA and CAFE
requirements under EPCA/EISA.
The MY 2012-2016 standards are together expected to result in approximately 960
million metric tons of total carbon dioxide equivalent emissions reductions and approximately
1.8 billion barrels of oil savings over the lifetime of vehicles sold in 2012 through 2016. In
total, the combined EPA and NHTSA 2012-2016 standards will reduce GHG emissions from
the U.S. light-duty fleet approximately 21 percent by 2030 over the level that would occur in
the absence of the National Program. These actions also will provide important energy
security benefits, as light-duty vehicles are about 95 percent dependent on oil-based fuels and
much of the petroleum consumed by the U.S. is imported.
The National Program for MYs 2012-2016 was developed in close coordination with
many key stakeholders including California and several other states. In 2004, CARB
approved standards for new light-duty vehicles, which regulate the emission of not only CC>2,
but also other GHGs. Since then, thirteen states and the District of Columbia, comprising
approximately 40 percent of the light-duty vehicle market, have adopted California's
standards. On June 30, 2009, EPA granted California's request for a waiver of preemption
under the CAA.10 The granting of the waiver permits California and the other states to
proceed with implementing the California emission standards. These standards apply to
model years 2009 through 2016.
To promote the National Program for MYs 2012-2016, in May 2009, California
agreed to accept compliance with the national standards as meeting its requirements. This
action allows the single national fleet produced by automakers to meet the two Federal
requirements and to meet California requirements as well.
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The MYs 2012-2016 standards adopted by NHTSA and EPA for passenger cars and
light trucks are attribute-based standards, specifically based on vehicle footprint. Each
manufacturer will have a GHG and a CAFE standard unique to its each of its fleets,
depending on the footprints of the vehicle models and the volumes produced by that
manufacturer. A manufacturer will have separate footprint-based standards for cars and light
trucks. With the footprint-based standard approach, EPA and NHTSA believe there should be
no significant effect on the relative distribution of different vehicle sizes in the fleet, which
should mean that consumers will still be able to purchase the size of vehicle that meets their
needs.
As described in the final rule, EPA and NHTSA expect that automobile manufacturers
will meet the MYs 2012-2016 CAFE and GHG standards by utilizing currently-available
technologies. Although many of these technologies are available today, the emissions
reductions and fuel economy improvements will involve more widespread use of these
technologies across the light-duty vehicle fleet. These include improvements to engines,
transmissions, and tires, increased use of start-stop technology, improvements in air
conditioning systems, increased use of hybrid and other advanced technologies, and the initial
commercialization of electric vehicles and plug-in hybrids. NHTSA's and EPA's assessment
of likely vehicle technologies that manufacturers will employ to meet the MYs 2012-2016
standards is discussed in the final rule and in the Joint TSD for the final rule.
The MYs 2012-2016 standards also provide a number of compliance flexibilities to
manufacturers. While the flexibilities vary in their compliance applicability based on whether
the manufacturer is meeting the CAFE standard or the GHG standard, both standards also
allow some of the same flexibilities. These flexibilities are discussed further in Chapter 5
below.
1.3 Standards for 2017 and Beyond
In response to the President's call to continue and expand a strong, coordinated
National Program, and in order to achieve critical additional reductions in oil consumption
and GHG emissions from light-duty vehicles, a number of stakeholders stepped up to offer
their support and commitment to fulfilling the President's vision. After release of the
President's May 2010 Memorandum, CARB issued a letter supporting the rulemaking process
to establish MY 2017-2025 standards.n In its letter, CARB committed to work in partnership
with EPA and NHTSA to: (1) evaluate technologies; (2) engage with manufacturers and other
stakeholders to fully explore the capability of technologies; (3) evaluate possible approaches
to increase in the marketplace the use of advanced technologies; and (4) identify potential
GHG emissions standards with the expectation that the annual rate of improvement would be
in the 3 to 6 percent range.
Several manufacturers also sent letters of support for the 2017-2025 rulemaking
initiative following the President's announcement, committing to engaging in a process to
continue a single national program beyond 2016.12 The letters generally stated the
manufacturers' agreement with a set of guiding principles, developed by the agencies, for the
rulemaking process. These guiding principles include: (1) that EPA and NHTSA will work to
develop strong, coordinated national GHG emissions and CAFE standards for light-duty
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vehicles manufactured in MY 2017-2025 that enable manufacturers to build a single light-
duty national fleet that satisfies all federal and state requirements; (2) that EPA and NHTSA
will seek input from an array of stakeholders including automobile manufacturers,
infrastructure providers, labor unions, and environmental organizations, and the agencies will
work with the State of California and other states in this process; (3) that the agencies and
CARB will develop a technical assessment to inform the rulemaking process; (4) that a mid-
term technology review would be appropriate; and, (5) that the future regulatory program
should enable consumers to still have a full range of vehicle choices.
The guiding principles also included a description of the process for developing this
Technical Assessment, including: (1) meeting with stakeholders individually to gather
currently available information on viable technologies, costs, benefits, lead times, incentives
and other flexibilities and to evaluate other relevant factors, such as infrastructure; (2)
evaluating emerging technologies to further reduce GHG emissions and improve fuel
economy; (3) identifying the capabilities to commercialize new and existing GHG and fuel
economy technologies, including potential costs and market barriers associated with such
technologies; and, (4) evaluating possible approaches to help establish in the marketplace an
increase in the use of advanced technologies, including, but not limited to, plug-in hybrid,
battery electric and fuel cell vehicles.
1.4 Future Technical Work and Analysis for the Joint Federal Rulemaking
This report represents EPA, NHTSA, and CARB's initial assessment of the costs,
effectiveness, and lead-time considerations for a range of advanced vehicle technologies that
can significantly increase fuel economy and decrease GHG emissions and it includes new
information that has been gathered since the 2012 - 2016 federal final rule. As discussed
above, and presented in the Executive Summary and in detail in Chapter 6, the report also
presents an analysis for a range of increasing levels of potential stringency for 2020 and 2025,
along with costs and benefits for using certain advanced technologies for achieving those
targets. This is an important first step for EPA and NHTSA in meeting the requirements of
the President's Memorandum, which will also include the agencies issuing a Joint Notice of
Intent, a Joint Notice of Proposed Rulemaking, and a Joint Final Rule in the future.
Being the first step, it is important to note that this Technical Assessment must be
viewed in the context of the additional work NHTSA and EPA will do going forward. The
two agencies have a number of significant, on-going projects which will inform the future
joint Federal rulemaking. As discussed in Chapter 3, these include: new technical
assessments of advanced gasoline, diesel, and hybrid vehicle technology effectiveness being
conducted with Ricardo, Inc.; several new projects to evaluate the cost, feasibility, and safety
impacts of mass reduction from vehicles; and an on-going project with FEV & Munro to
improve our cost estimations for advanced technologies; further consideration of battery life,
durability, cost and safety; consideration of several technology cost factors including Indirect
Cost Multiplier values, time based learning over extended periods of time; maintenance costs;
and further review of the leadtime needed to implement advanced technologies. An analysis
of the effects of mass reduction on vehicle safety has not been included in this Technical
Assessment. For the 2017-2025 NPRM, NHTSA and EPA will conduct an analysis of the
effects of the proposed rulemaking on vehicle safety, including societal effects. CARB is
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undertaking a study of the safety effects of a future vehicle designed for high levels of mass
reduction, and CARB is coordinating with EPA and NHTSA on that study. In addition, EPA
and NHTSA will continue to meet with and consider input from the full range of stakeholders
as we develop the joint Federal rulemaking. All of this future information will enhance the
accuracy of our technological assessment.
In addition, the assessment of scenarios and the accompanying results presented in
Chapter 6 of this report should be considered an initial analysis because it does not consider
the full range of factors which EPA and NHTSA must consider for a rulemaking under our
respective statutory authorities. As discussed in Chapter 6, these include (but are not limited
to): consideration of the full range of societal benefits, including consumer welfare effects,
specific evaluation of potential safety implications of future standards, consideration of the
costs and feasibility of the standards for individual automotive firms, and the development of
separate attribute-based standards for passenger cars and light-duty trucks for each model year
covered by the rulemaking.
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Chapter 1 References
1 Presidential Memorandum: "Improving Energy Security, American Competitiveness and Job Creation, and
Environmental Protection Through a Transformation of Our Nation's Fleet of Cars And Trucks," Issued May 21,
2010, published at 75 Fed. Reg. 29399 (May 26, 2010), also available at http://www.whitehouse.gov/the-press-
office/presidential-memorandum-regarding-fuel-efficiency-standards.
2 Source; Transportation Energy Data Book Edition 28
3 Source: El A Annual Energy Outlook 2010 released May 11, 2010.
4
U.S. Environmental Protection Agency. 2009. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-
2007. EPA 430-R-09-004.
U.S. Environmental Protection Agency (2010). Regulatory Impact Analysis: Final Rulemaking to Establish
Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards,
Chapter 2, page 2-4. EPA-420-R-10-009. Available at: http://www.epa.gov/otaq/climate/regulations.htm.
Presidential Memorandum, See Note 1.
7 Remarks by the President on National Fuel Efficiency Standards, May 19, 2009, available at
http://www.whitehouse.gov/the-press-office/president-obama-announces-national-fuel-efficiencv-policv. see
also http://www.whitehouse.gov/the-press-office/remarks-president-national-fuel-efficiency-standards
8 75 FR 25324 (May 7, 2010).
949U.S.C. 32902
10 74 FR 32744 (July 8, 2009).
11 The California Air Resources Board commitment letter is available at:
http://www.epa.gov/otaq/climate/regulations.htm.
12 The manufacturer commitment letters are available at: http://www.epa.gov/otaq/climate/regulations.htm.
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2 Technical Input from Stakeholders
2.1 Overview of Stakeholder Outreach Process
As mentioned above, the May 21, 2010 Presidential Memorandum requests that EPA
and NHTS A, working with the State of California, develop a Technical Assessment to inform
the rulemaking process "reflecting input from an array of stakeholders on relevant factors,
including viable technologies, costs, benefits, lead time to develop and deploy new and
emerging technologies, incentives and other flexibilities to encourage the development and
deployment of new and emerging technologies, impacts on jobs and the automotive
manufacturing base in the United States, and infrastructure for advanced vehicle
technologies...."13
To fulfill that request, during June through August 2010, EPA, NHTS A, and CARS
held numerous meetings with a wide variety of stakeholders to gather input to consider in
developing this Technical Assessment Report, and to ensure that the agencies had available to
them the most recent technical information directly from the stakeholders themselves. These
stakeholders included many automobile original equipment manufacturers (OEMs),
automotive suppliers, non-governmental organizations, states and state organizations,
infrastructure providers, and labor unions. For many of the meetings with the OEMs, as well
as labor unions, representatives from the federal Council of Environmental Quality and the
White House Office of Energy and Climate Change also participated. The agencies sought
these stakeholders' technical input and perspectives on the key issues that should be
considered, as the President's memo identified, in assessing a national program to reduce
greenhouse gas emissions and improve fuel economy for light-duty vehicles in model years
2017-2025. NHTS A and EPA anticipate continuing the productive dialogue with
stakeholders as our joint federal rulemaking to develop the new national program proceeds, in
order to continue to ensure that our analysis reflects the best available information.
2.2 Input from Various Stakeholder Groups
2.2.1 Automobile Original Equipment Manufacturers
EPA, NHTSA and CARB met with twenty different automotive OEMs to discuss the
development of a national program for MYs 2017-2025. As discussed below, these include
very large firms which sell large volumes of vehicles in the U.S. (and in most cases around
the world), small and medium sized firms who sell relatively low volumes of vehicles in the
U.S., and three relatively new "start-up" automotive firms whose business strategy for the
U.S. market is focused on the production of all electric vehicles and/or plug-in hybrid electric
vehicles. These meetings included senior management and staff from both the companies and
the three agencies.
EPA, NHTSA and CARB met with eleven of the manufacturers with the largest U.S.
vehicle sales volume to seek their input on both the key technical and policy issues that the
agencies should consider in developing the MYs 2017-2025 technical assessment. The
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agencies met individually with the following companies: General Motors, Ford, Chrysler,
Toyota, Honda, Nissan, Hyundai, Kia, Volkswagen, BMW, and Daimler. These
manufacturers account for more than 90 percent of the vehicles produced for sale in the
United States. While the views they expressed and the forecasts they shared for the future
vehicle market covered a considerable range, especially in terms of specific details, the
agencies view this range as unsurprising, considering uncertainty regarding key factors (e.g.,
fuel prices) in the 2017-2025 time frame, the relatively long-time frame over which requested
companies to consider (15 years into the future) and considering manufacturers' various
strategies for competing in the automotive market. A number of messages were stressed by
all or nearly all manufacturers and we have summarized those below. The agencies have
carefully considered the information and views these manufacturers have shared, and NHTSA
and EPA will continue to do so as part of the formal rulemaking process for post-2016 CAFE
and GHG emissions standards.
In addition, the agencies met with several medium to smaller volume manufacturers,
including Mitsubishi, Jaguar Land-Rover, Ferrari, Aston-Martin, Lotus, and McLaren. These
medium and smaller volume manufacturers may face unique compliance challenges because
they sell a limited number of vehicle types in the U.S., and/or they serve relative small market
segments that tend to value highly priced luxury vehicles with very high levels of vehicle
performance (e.g., vehicles with very rapid acceleration and top vehicle speeds) much more
highly than fuel economy, such that fuel-saving technologies (e.g., turbochargers), even when
applied, are often used to increase performance rather than to increase fuel economy. Several
of these manufacturers have traditionally been "fine-payers" under the CAFE system, and like
all manufacturers—including those that do comply with CAFE standards—are required to pay
"gas guzzler" taxes for specific models with especially low fuel economy levels. The input
from these medium and smaller volume manufacturers will be important to the agencies in
determining how to structure the national program for MYs 2017-2025.
The agencies also met with new entrants to the automotive industry who are focusing
on development of electric vehicles and/or plug-in hybrid electric vehicles, including Fisker,
Tesla, and BYD. These electric vehicle manufacturers provided input regarding the cost of
key EV technologies (e.g., batteries), the outlook for expanding the EV market, and the need
for infrastructure and public incentives to support PHEV and EV purchase and operation.
The agencies requested the OEMs' input in the following key areas, consistent with
the President's memorandum:
• Technology development status for MYs 2017-2025. For each major
technology development area we requested details regarding effectiveness,
costs, technology development and future product introduction plans, and
the anticipated market penetration in the 2017-2025 timeframe. The major
technology areas in which the agencies specifically sought information
included powertrain improvement for advanced gasoline and diesel engines
and transmissions, hybrid vehicles (HEVs), plug-in hybrid electric vehicles
(PHEVs) and electric vehicles (EVs) (with a focus on battery technology
for HEV/PHEV/EVs), fuel cell vehicles, and vehicle mass reduction, as
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well as thermal management technologies including air conditioning
improvements.
• Key regulatory design elements
• Infrastructure issues
• Perspective on the impacts on the U.S. manufacturing base and jobs
• Potential incentives and flexibilites
In response, the automotive OEMs presented detailed technical information to the
agencies addressing these topics, and requested confidential treatment for much of it. In order
to respect these requests for confidentiality, the agencies cannot reveal specific details of the
business information provided at these meetings, but taken in the aggregate, the following
summarizes information gathered from the OEM meetings. It is important to note that while
we requested information for the 2017-2025 time frame, nearly every manufacturer indicated
that they do not have detailed product development and launch plans which extend 15 years
into the future. In general, the firms' plans for 2010-2015 are fairly well defined, most firms
do have product plans which extend into the 2016-2020 time frame, and no firm had product
plans of any significant detail which cover the 2021-2025 time frame. Below we summarize
the general trends we heard from the OEMs in the following broad areas: advanced
gasoline/diesel engine and transmission technologies; vehicle mass reduction technologies;
HEV, PHEV, EV technologies; fuel cell vehicle technologies; air conditioning and other
technologies; regulatory program design; electric vehicle charging infrastructure, and;
perspectives on US manufacturing and automotive-related jobs.
Advanced gasoline/diesel engine and transmission technologies
Nearly universally, the manufacturers agreed with the agencies' projections in the
MYs 2012-2016 final rule that the following technologies will be much more prevalent in
2016 and beyond than they are today. These unclude more efficient turbocharged direct
injection downsized gasoline engines (turbo-GDI engines) as well as, for larger displacement
engines, a mix of turbo-GDI engines and some products with GDI coupled with cylinder
deactivation and advanced valve timing control - all matched with more efficient 6+ speed
/-i
automatic or dual-clutch transmissions. However, beyond this particular combustion and
transmission technologies, OEM feedback with regard to what technologies would be
employed to meet future more stringent CAFE and GHG standards was mixed. Companies
indicated that they intended to pursue a variety of different strategies, including diesel, lean
burn gasoline direct injection, homogeneous charge compression ignition, high Brake Mean
Effective Pressure (BMEP)D turbocharged/cooled exhaust gas recirculation systems, and
c See, e.g., id. at 25621-25624.
D Brake Mean Effective Pressure is the average amount of pressure in pounds per square inch (psi) that must be
exerted on the piston to create the measured horsepower. This indicates how effective an engine is at filling the
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other advanced engine configurations. Some of these technologies are still in development,
and OEM comments usually noted that while they remain promising advanced powertrains,
further development will still be needed to bring them to production. For example, while
manufacturers were often optimistic about upcoming advanced gasoline engine technologies,
some also cited concerns such as launch performance of highly-downsized turbocharged
engines (though most of those manufacturers also stated they are working to resolve this
issue), or the sensitivity of emission controls on lean-burn engines to gasoline sulfur content.
Several manufacturers also indicated that nationwide increases in gasoline minimum octane
levels could be important to attain the maximum potential fuel efficiency and GHG emissions
improvements for advanced gasoline engines while avoiding driver dissatisfaction with not
being able to use regular octane fuel. While there was general consensus that more can be
done for gasoline engines, there was no general consensus, and in some cases no projections
were provided, regarding the projected costs of these technologies in the 2020 to 2025 time
frame.
Vehicle mass reduction technologies
Nearly all OEMs had strategies for reducing the mass of their vehicles, that in many
cases were described as a new or improved technical approach. Some firms stated that they
would also be taking advantage of opportunities to reduce engine size without compromising
vehicle power/weight ratios and thus maintain or increase vehicle performance. The majority
of manufacturers stated that they were making every effort to remove weight from their
vehicles through careful redesigns, material substitution, and mass reduction compounding
going forward. Nearly every automotive firm indicated that vehicle mass will actually
decrease over the 2010 to 2025 time frame, though the level predicted level of mass decrease
varied significantly across the firms. Nevertheless, several OEMs indicated that vehicle
safety technologies, both those driven by regulation and those planned by the firms to meet
internal company objectives or voluntary standards, would add mass to vehicles in the future
and this would partially off-set the gains they would see if the focus were only on mass
reduction and the current status-quo with respect to vehicle safety related technology. A few
firms also speculated that future criteria pollutant emission standards may also result in a
small increase in mass that would partially offset the other mass reduction technologies being
considered by the companies.
Manufacturers cited varied plans to change vehicle designs and/or increase the use of
high-strength steel (HSS), ultra-high strength steel, aluminum, composites, and/or other
materials in order to offset these increases and achieve further mass reduction.
Manufacturers generally indicated that universal material substitution (such as a
complete switch from steel to aluminum body-in white structures) would not be feasible to
implement across the majority of their high volume vehicle product lines in the 2017-2025
time frame due to cost constraints as well as many other engineering and manufacturing
challenges. Therefore, while more lighter-weight materials might be seen in the future, most
combustion chamber with an air/fuel mixture, compressing it and achieving the most power from it. A higher
BMEP value contributes to higher overall efficiency.
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OEMs expressed that they still saw the need to continue utilizing steel on many of the
structural components of vehicles. Also, most manufacturers indicated they either currently
use significant levels of HSS and/or plan to increase use of HSS in response to recently-
promulgated MYs 2012-2016 standards, which some emphasized could mean that further
mass reduction through MYs 2017-2025 would necessitate more aggressive (and, therefore,
potentially more expensive) strategies. Balancing all of these factors, most manufacturers
generally estimated the potential to reduce actual vehicle mass ranges from 10% to 15%
between today (2010) and 2025.
A number of firms also discussed the more advanced light-weight materials such as
carbon fiber and magnesium. While these materials can offer very significant mass reduction,
in general these materials are only used on more exotic luxury or high performance vehicles.
There are, of course, examples of vehicles today which use carbon fiber, but they tend to be
very expensive, ultra-high performance vehicles (such as the limited edition Ferrari Enzo, or
the Mercedes SLR MacLaren) or in other cases the amount of carbon fiber in the vehicle is for
a few select components (such as in the high performance Corvette ZR1 or the high
performance Lexus ISF). A number of automotive firms are exploring the ability to produce a
less expensive automotive grade carbon fiber, but in general companies did not see carbon
fiber, or for that matter magnesium, as playing a major role in the 2017-2025 time frame.
HEV. PHEV. EV technologies
Virtually all of the manufacturers are planning for greater electrification of their fleet,
although there were varying degrees of this: from 12 volt stop-start systems, to full hybrid
electric vehicles (HEV), to plug-in HEVs (PHEV), to electric vehicles (EV). OEMs stated
that the relative penetration of these technologies varied greatly depending on a number of
factors, including, future gasoline fuel prices, future decreases in battery costs, anticipated
regulatory fuel economy/GHG requirements. In particular for PHEV and EVs, OEMs also
identified the charging infrastructure development and costs as well as external (federal, state
and local) incentives, and consumer demand/acceptance of vehicles requiring recharging and
which may have reduced range (in the case of EVs) as additional factors which will impact
the future penetration of these technologies. For example, with regard to consumer demand, a
number of OEMs expressed reservations regarding the potential, without government
assistance, to increase significantly the market for PHEVs and EVs, much beyond the likely
first-adopters who have already indicated interest in purchasing these vehicles. Nevertheless
a number of the firms suggested that in the 2020 time frame their U.S. sales of HEVs, PHEVs,
and EVs combined could be on the order of 15-20% of their production, and while not all
firms provided forecasts out to 2025, some did indicate that this percent of production could
grow to be on the order of 40-50%, depending on the factors described above. Other firms
provided lower projections for the 2020 to 2025 time frame, or no projection at all.
All of the major OEMs recognize that for PHEV and EV vehicles, the battery costs are
by far the most significant contributor to the cost increase over a gasoline vehicle.
Universally the OEMs believe that large-format lithium-ion batteries offer the most promising
trade-off between battery performance, weight, size, and costs. A large number of lithium-ion
battery chemistries and designs are being explored and considered for commercialization.
With respect to costs, there also was a wide range in OEM-projected battery-pack cost in the
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2020 to 2025 timeframe, with the majority of estimates in the $300/kW-hour to $400/kW-
hour range for 2020 and $250 to $300/kW-hour range for 2025.
Fuel cell vehicle technologies
A number of the larger automotive firms described active research and product
development programs they have underway with respect to fuel cell vehicles. Several
companies have planned limited product introductions for California within the next several
years. The companies that discussed such programs identified two major challenges for fuel
cell vehicles: reducing vehicle system costs and the development of a refueling infrastructure.
With respect to costs, several of the firms had specific technology development
roadmaps which they estimated could significantly lower the costs of fuel cell vehicles over
the next ten to fifteen years, which they indicated could potentially make fuel cell vehicle
incremental costs competitive with all electric vehicles in the 2020 to 2025 time frame.
With respect to infrastructure, while the OEMs noted that California is actively
working to develop and expand a hydrogen refuel infrastructure centered in Southern
California, they also stressed that without a significant development in other regions of the
U.S., fuel cell vehicles will not be able to penetrate the market beyond limited, centrally
fueled fleet programs.
For the U.S. market, most major firms expressed a belief that fuel cell vehicles will
play a significant role in the longer-term. Several firms expect that this will be in the time
frame beyond 2025 for the nation as a whole, outside of specific geographic areas (such as
California) where a refueling infrastructure is being developed.
Air conditioning and other technologies
Many of the OEMs stated that they were anticipating switching air conditioner (A/C)
refrigerant from the current R134a (with its high global warming potential, GWP) to the much
lower HFO1234yf as soon as they could, with most firms projecting this would occur between
now and approximately 2018. Many OEMs noted, however, that this switch is dependent on
EPA SNAP approval,E as well as availability and price from suppliers for the new refrigerant.
Manufacturers noted that these two issues had the potential to delay much of the switchover to
F£FO1234yf, with the period of the delay depending upon the specifics of EPA's future action
and how the market place forces play out with respect to the supply and demand for the new
refrigerant..
With regard to other vehicle technologies, each of the companies had their own suite
of other technologies that would improve efficiency based on their unique expertise and
E The Significant New Alternatives Policy (SNAP) Program is EPA's program to evaluate and regulate
substitutes for the ozone-depleting chemicals that are being phased out under the stratospheric ozone protection
provisions of the Clean Air Act (CAA). Before any new or substitute refrigerant can be utilized in mobile A/C
applications, EPA must receive a SNAP submission and reach a determination. If EPA finds the substitute
acceptable, its use must comply with conditions set forth in the SNAP determination.
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product plans. These included aerodynamic improvements, friction reduction, further
reductions in tire rolling resistance, and a number of other technologies that cannot be
described in detail given confidentiality restrictions.
Regulatory program design input
Specific company suggestions for the appropriate design of regulatory programs, often
relating to OEM-specific strategies for coming into compliance under various scenarios and
their particular desired program flexibilities, were considered to be confidential business
information by all of the manufacturers. These suggestions varied greatly depending on the
specific company, as did manufacturers' plans for future compliance. However, there was
universal consensus that a national program should continue, and that a single national fleet
should be able to comply with California and federal GHG standards as well as federal CAFE
standards.
Several OEMs also discussed the importance of a mid-term technology review which
would occur after the 2017-2025 standards are promulgated. The May 19, 2010 support
letters from all of the OEMs and the two major automotive trade associations also supported
the concept of a mid-term technology review. In addition, several OEMs were supportive of
the continuation of attribute-based standards and of separate standards for cars and trucks.
Electric vehicle charging systems
A number of the automakers provided input on the electrical vehicle charging systems
needed for EVs and PHEVs. The OEMs generally agreed that most charging will occur at
home and will be Level 1 or Level 2, with a greater likelihood of Level 2 charging as vehicle
range and size increases.17 OEMs suggested that workplace charging, if available, could
significantly increase the vehicle's daily driving range (under the assumption the vehicle can
be charge two times in a day, once at home in the morning, and once at work during the day)
and may help to increase market appeal of EVs and PHEVs. OEMs also indicated that public
charging (Level 2 or Level 3 quick charging) could provide additional comfort to EV/PHEV
owners and may help to facilitate the mass adoption of these vehicles. OEMs also generally
agreed that costs of electric vehicle service equipment installation will vary widely by the age
of the house, location of the charging equipment, and difficulty of installation. Some urban
locations without dedicated parking, such as apartments and townhouses with street parking,
may present charging challenges. These issues are discussed in more detail in Chapter 4
below.
A number of OEMs also indicated that they believe that federal and state incentives
are helpful in encouraging charging system development and charge point deployment. In
addition, stakeholders emphasized that standardization of charging facilities and codes for
F Details regarding EV and PHEV charging levels are included in Chapter 4 of this report. In general, Level 1
charging uses a lower voltage than Level 2. Level 1 chargers require more time for battery charging than Level
2. As discussed in Chapter 4, there is also a Level 3 charging approach, sometimes called "quick charging",
which uses even higher voltages and takes even less time than Level 1 or Level 2.
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installing equipment will streamline and encourage the widespread deployment of charging
infrastructure and promote the adoption of PHEVs and EVs. Some OEMs also suggested that
so-called "smart metering" equipment and strategies could enable consumers and utilities to
choose the best time to charge vehicles for the lowest cost while maintaining maximum
vehicle availability.
Perspectives on US manufacturing and automotive-related jobs
Not all manufacturers discussed potential impacts on jobs and the U.S. manufacturing
base, but of those that did, many were optimistic about the opportunities to build fuel-efficient
cars in the United States and the concurrent boost to the U.S. job market. Most OEMs were
predicting significant increase in sales after the drop in 2009, and further sales increases into
2017+, with concomitant increases in U.S. manufacturing jobs. Further, OEMs stated that
increased technological content in vehicles will likely require more development, testing, and
additional manufacturing requirements and thus potentially lead to more jobs in the supplier
chain, both in the U.S. as well as abroad. Several manufacturers noted that Federal
government stimulus bill investments, as well as additional incentives provided by a number
of state and local governments, were an important factor in locating manufacturing operations
for electrification components (including new battery, electric motor, and power electronic
manufacturing facilities) in the U.S., and that continuation of this type of investment would be
an important consideration to locating future facilities in the U.S.
2.2.2 Automotive Suppliers
EPA, NHTSA and CARB met with a cross section of automotive suppliers to seek
their input on a number of key technical issues. Suppliers conduct their own research and
development on a wide variety of automotive products that directly and indirectly influence
the fuel economy and CO2 emissions of vehicles. The agencies met individually with the
following companies and associations: Delphi, Bosch, Denso, Borg Warner, Honeywell,
Valeo, Johnson Controls, A123, BYD, Dupont, the American Iron and Steel Institute and a
number of their member companies, the Aluminum Transportation Group (a part of the
Aluminum Association) and a number of their member companies, and the Rubber
Manufacturers Association and a number of their tire manufacturing company members. We
note that there are a very large number of automotive suppliers, making it impossible to meet
with even all of the major companies given the time frame for this technical assessment
report. The companies and associations with whom we met represent a small but significant
fraction of these suppliers, given their importance in the market and/or the uniqueness of their
product offerings.
The agencies requested input in the following key areas: expected technology
development status for MYs 2017-2025, cost, effectiveness, and potential limitations of
technologies, and impact on jobs. In response, as with the automotive OEMs, the supplier
companies presented detailed technical information to the agencies addressing these topics,
and requested confidential treatment for much of it. In order to respect these requests for
confidentiality, the agencies cannot reveal specific details of the business information
provided at these meetings, but taken in the aggregate, the following summarizes information
gathered from the supplier meetings.
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In general, the suppliers were optimistic that supplier-developed advanced
technologies could play a critical role in 2017-2025 vehicles, and they were actively engaged
with OEMs for not only application of near-term technologies but also collaborative
development of production road maps for technologies currently in the R&D phases within
their organizations. Generally the suppliers stated that future R&D activities would allow
them to decrease costs, increasing production capacity, and produce innovative solutions for
OEM needs. However, suppliers also independently discussed some of OEMs key issues —
such as the potential future penetration and challenges for large market adoption of HEVs,
PHEVs, EVs, and FCVs. Some suppliers' cost estimates were more consistent with or even
lower than the figures used by the agencies in the present analysis. The steel and aluminum
industry emphasized that weight can be reduced in vehicles without sacrificing safety,
although the agencies note that the assessment of safety identified by these industries does not
include the type of detailed aggregate societal impacts assessment that NHTSA and EPA will
conduct for the upcoming joint Federal rulemaking.
On the issue of potential job impacts, suppliers strongly supported the recent federal
funding for advanced battery development. Suppliers stated that this has already led to many
engineering and manufacturing jobs created in the U.S., in part due to Federal stimulus
funding, and expressed confidence that this sector will continue to grow.
On the issue of infrastructure, some of the suppliers did discuss issues regarding
EV/PFIEV vehicle infrastructure. In general, their themes on this topic were consistent with
what we also heard from the OEMs discussed above.
2.2.3 Non-Governmental Environmental Organizations
The agencies also received input from numerous environmental organizations,
including the Natural Resources Defense Council, Union of Concerned Scientists,
Environmental Defense, Sierra Club, the American Council for an Energy-Efficient Economy,
Safe Climate Campaign, Environment America, and the National Wildlife Federation. These
environmental organizations stated that they are very supportive of the President's call for
setting new fuel economy and greenhouse gas standards for light-duty vehicles for the 2017-
2025 model years. These groups believe this will help to cut U.S. oil dependency and move
the nation toward a clean energy economy. The groups stated that they support setting
standards at the maximum technically feasible level in order to bring new technologies to the
marketplace, calling on the agencies generally to establish future standards which would push
efficiency limits on conventional internal combustion engine vehicles, bring hybrids into
mainstream commercial production, and pull advanced electric-drive vehicles into the market.
These organizations requested that the agencies establish standards for 2017-2025 which
would put light-duty vehicles on a path to achieve an 80 percent reduction (from 2005 levels)
in global warming emissions by 2050. The groups also encouraged EPA and NHTSA to work
quickly to propose and finalize the new standards.
The environmental groups emphasized that the rulemaking process be open and
transparent to the public. They commended the transparency of the process thus far, and
expect it to be continued moving forward. The environmental groups stated that transparency
is critical in several specific areas, including manufacturers' compliance, test data, technology
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costs, modeling of technology adoption (e.g., EPA's OMEGA model and NHTSA's Volpe
model), vehicle safety assessments, assumptions of advanced vehicle adoption, and
accounting for electric vehicle upstream emissions and other off-cycle factors.
Another issue raised by the environmental groups was the concept of a mid-term
technology review, as indicated in the auto manufacturers' letters supporting the President's
memorandum. The environmental groups emphasized that any mid-term technology review,
if conducted, should not undermine innovation, should be very narrow in scope, and be a one-
time review after 2020. They stated that a technology review should not create uncertainty
regarding the requirements established by the agencies, or be considered an "escape route" to
delaying requirements. They also stated that a technology review may be unnecessary if the
2017-2025 standards can be achieved by using multiple technology pathways, as opposed to a
single, "silver-bullet" technology.
The environmental groups requested that EPA and NHTSA continue to rely on what
they characterized as reasonable discount rates when evaluating the consumer benefits of fuel
savings, so as to not undervalue the consumer benefits of higher fuel economy standards.
The groups reiterated prior arguments that discount rates higher than the 3 and 7 percent rates
recommended in OMB guidance documents are inappropriate, due to the highly imperfect
automobile market, with limited information, uncertainty of future gasoline prices, and a
limited set of options with regard to fuel economy. The groups expressed interest in working
on the discount rate issue with EPA, NHTSA, and others during the upcoming joint federal
rulemaking process.
These groups stated that the standards should rely on an updated and accurate safety
analysis, consistent with EPA and NHTSA's discussion of this issue in the final rule for the
MY2012-2016 standards. The environmental groups stated that their understanding of the
analysis in the MYs 2012-2016 rule is that vehicle mass reduction can be applied in a way
that saves lives while also cutting fuel consumption and GHG emissions. The groups
expressed support for the commitments made by NHTSA in the MYs 2012-2016 final rule, as
discussed below in Chapter 3, to collaborate with EPA, CARB and the Department of Energy,
in conducting further safety and mass reduction research.
Finally, the environmental groups stated that the tailpipe compliance calculation for
electric-drive vehicles should account for upstream GHG emissions due to electricity and
hydrogen generation. Their concern is that if manufacturers are allowed to treat EVs (or the
electric portion of a PHEV) as 0 grams of CO2/mile for compliance purposes, they may be
able to meet the standards through producing only a small number of electric-drive vehicles,
while avoiding fuel economy improvements in conventional vehicles. Further discussion of
this issue is contained in Chapter 7.
2.2.4 State and Local Government Organizations
The agencies met with representatives from the National Association for Clean Air
Agencies (NACAA), the Northeast States for Coordinated Air Use Management
(NESCAUM), and approximately 10 individual state and local governments. The state and
local organization stressed broad objectives, and generally expressed strong support of the
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agencies' efforts to develop a national program for the 2017-2025 timeframe. The states
emphasized, consistent with California's letter supporting the Presidential memorandum, that
the agencies should evaluate a range of potential standards of 3 to 6 percent annual increases
in stringency for the 2017-2025 time frame. The states expressed a strong preference toward
the higher stringencies in that range, stating that the standards must be technology forcing in
order to help them achieve their individual and regional GHG reduction goals.
The states also strongly supported the collaborative process in which EPA, NHTSA,
and CARB are engaging in order to assess the technical information going into the 2017-2025
assessment. Several states mentioned activities they have underway to develop the
infrastructure needed to support electrified vehicles. The states also expressed support for
transparency in the process of developing the technical assessment, and the eventual proposed
rulemaking, and an interest in continued dialogue.
2.2.5 Infrastructure Providers
The agencies met with representatives from the Electric Power Research Institute
(EPRI) and charging infrastructure providers. EPRI believes the focus for EV and PHEV
charging systems should be on home charging, with a goal of a seamless installation process
(permitting, electrical installation, inspection) for homeowners. However, EPRI recognizes
that home charging infrastructure is expensive, estimating an average cost of about $1,500 for
home charging installations. Some charging infrastructure providers see a more important role
for public charging, which could expand EV/PHEV markets to people who live in apartments,
condominiums, or otherwise do not have garage access for convenient home charging. EPRI
believes more work is needed to assess how workplace and public charging infrastructure
should be developed, both in terms of where to best locate stations for consumers'
convenience and who should own the them (e.g., municipalities, private sector, employers,
utilities).
EPRI believes that overall electric utilities will be able to support the rollout of EVs
and PHEVs. However, there is a possibility of isolated impacts on some residential
transformers, particularly in neighborhoods with older distribution systems. To mitigate these
potential impacts, EPRI suggests that early notification to the local utilities of EV/PHEV
charging plans would help the utilities assess any potential need for upgrades to the electric
power delivery system. EPRI also believes that potential stresses on power delivery systems
can be mitigated by the wise application of smart charging, which has the potential to even
out charging loads. Charging infrastructure providers generally agreed with this assessment.
EPRI is currently examining these issues.
2.2.6 Labor Unions
EPA, NHTSA and CEQ met with representatives of the United Auto Workers (the
UAW). The UAW was supportive of continuing the National Program for 2017 and beyond.
The UAWs overarching concern was how the future development and market penetration of
advanced vehicle technologies will impact automotive industry manufacturing employment in
the United States. The UAW stated their general belief that a high percentage the sub-
systems and vehicle assembly for hybrid electric vehicles sold in the U.S. today are not
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manufactured in the United States. The UAW is concerned that this trend could continue, and
that the potential future introduction of plug-in hybrid electric vehicles and electric vehicles in
addition to the potential future expansion of hybrid electric vehicles could results in an overall
decline in the automotive manufacturing jobs in the United States. The UAW stated that the
government funding for advanced technology vehicles had made an important difference in
the past year, resulting in many companies deciding to manufacturer batteries, electric motors,
and vehicle assembly plants in the U.S.; the UAW was concerned that without the continued
economic support from the federal government, future manufacturing facilities for these
advanced technology vehicles may not occur in the U.S.
In addition to this important issue, the UAW made two specific requests which they
would like the federal government to consider in the development of the 2017-2025 joint
federal rulemaking. The UAW believes it is important for the agencies to analyze and report
the net domestic employment effects of any future proposed standards. In addition, the UAW
requested that future regulations include provisions with respect to GHG emissions from
automobiles other than the CO2 captured by the CAFE program for the eventual integration
of those emissions regulations with any broader national GHG program that might be
developed by Congress or that may be proposed by EPA under the Clean Air Act in the
future. Specifically the UAW was referring to methane, nitrous oxide, and hydroflurocarbon
emissions, as well as CO2 emissions related to a vehicles air conditioning system operation,
which is not capture under today's CAFE test procedures. Finally, the UAW raised some
concerns with the future projections contained in the Energy Information Administration's
Annual Energy Outlook reports and the accuracy of those reports projections regarding future
improvements in fuel economy absent new standards.
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Chapter 2 References
13 75 Fed. Reg. 29399 (May 26, 2010).
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3 Technology, Cost, Effectiveness and Lead-time Assessment
3.1 What technologies did the Agencies Consider?
The agencies assume, in this analysis, that manufacturers will add a variety
technologies to each of their vehicle model platforms in order to improve their fuel economy
and GHG performance. In order to analyze a variety of regulatory control scenarios (as we
do in this report), it is thus essential to understand what is feasible within the timeframe of the
rule. Technical feasibility of potential standards requires a thorough study of the technologies
available to the manufacturers. This study includes an assessment of the cost, effectiveness,
as well as the lead time of the technologies. The lead time relates to the availability,
development time, and manufacturability of the technology within the normal redesign
periods of a vehicle line (or in the design of a new vehicle). As we describe below, lead time
issues can in turn affect the cost as well as the technology penetration rate (or caps) that are
assumed in the analysis.
The agencies considered over 30 vehicle technologies that manufacturers could use to
improve the fuel economy and reduce CC>2 emissions of their vehicles during the 2017-2025
timeframe. A majority of the technologies described in this chapter are readily available
today, are well known, and could be incorporated into vehicles once product development
decisions are made. These are "near-term" technologies and are identical to those applied in
the 2012-2016 light-duty rule. Other technologies considered may not currently be in
production, but are beyond the initial research phase, under development and are expected to
be in production in the next few years. These are technologies which can, for the most part,
be applied both to cars and trucks, and which are capable of achieving significant
improvements in fuel economy and reductions in CC>2 emissions at reasonable costs in the
2017 to 2025 timeframe. The agencies did not consider technologies that are currently in an
initial stage of research because of the uncertainty involved in the lead time available to
implement the technologies with significant penetration rates for this assessment.
3.2 How did the Agencies Determine the Costs and Effectiveness of Each of These
Technologies?
3.2.1 How are Cost and Effectiveness Estimates Different from the 2012-2016 Rule?
Virtually all of the technologies considered in this analysis are identical to those
described in the 2012-2016 light-duty CAFE and GHG final rule. Those that are new or
modified are described in greater detail in this chapter. In general, the costs of fuel
consumption improvement technologies considered in this assessment are taken straight from
the 2012-2016 light-duty CAFE and GHG final rule, with six exceptions that impact
individual technology costs in different ways. The first exception is that the agencies have
reconsidered the costs for several technologies for which extensive tear-down studies were
completed during development of the MYs 2012-2016 final rule. These teardown studies
were conducted under the continuing EPA contract with FEV and Munro in support of that
rulemaking and were discussed in detail in the Technical Support Document.14 The second
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exception is that the agencies have reconsidered the costs for hybrid electric vehicles (HEV),
plug-in hybrid (PHEV), electric vehicles (EV), and fuel cell electric vehicles (FCEV), due in
part to the rapid changes taking place in battery technology and cost estimation methods
based on the expert judgment of the Department of Energy (DoE), EPA, CARB, and NHTSA
and using updated costs as compared to the 2012-2016 light-duty rule. The third exception is
that the agencies have updated the cost for mass reduction based on more recent studies. The
fourth exception is that the indirect cost markups (ICM) used in the 2012-2016 light-duty
rulemaking and have added an additional factor of 0.06 to each. This factor has been added to
reflect return on capital of 6% in the automotive industry, described further below.15 The fifth
exception is that cost estimates have been updated to reflect 2008 dollars while the 2012-2016
light-duty rule expressed costs in terms of 2007 dollars. This update was done using a ratio of
GDP price deflators in a manner consistent with the procedure used in the 2012-2016 light-
duty rule. The sixth exception is that learning effects have been allowed to continue beyond
the 2016 model year so that the individual piece costs in the 2017 and later model years will,
in general, be lower than the costs estimated for the 2012-2016 model years. We note,
however, that the type of learning - volume-based or time-based, as described in the 2012-
2016 light-duty rule - has not changed. Each of these exceptions is discussed in more detail
below and in Appendix B.
Most of the effectiveness numbers of the technologies have also not changed from the
previous final rule. The few changes that were made are also described below. The agencies
are pursuing additional work to update the effectiveness of virtually all of the technologies
listed in this chapter.
3.2.2 Costs from Tear-down Studies
The agencies have updated costs of certain technologies that had been based on tear-
down studies conducted during the 2012-2016 rulemaking. The agencies believe that the best
method to derive technology cost estimates is to conduct studies involving tear-down and
analysis of actual vehicle components. A "tear-down" involves breaking down a technology
into its fundamental parts and manufacturing processes by completely disassembling vehicles
and vehicle subsystems and precisely determining what is required for its production. More
details about tear down studies can be found in the studies supporting the 2012-2016 light-
duty rule as well as the FEV and Munro Associates report for EPA.16'17 This tear-down
method of costing technologies is often used by manufacturers to benchmark their products
against competitive products. Historically, vehicle and vehicle component tear-down has not
been done in large scale by researchers and regulators due to the expense required for such
studies.
To-date, such tear-down studies have been completed on the six technologies listed
below. These completed tear-down studies provide a thorough evaluation of the component
or system cost relative to their baseline (or replaced) technologies. A more detailed
description of these technologies can be found in the Technical Support Document prepared
for the 2012-2016 light-duty final rule.14 For these technologies, the agencies have relied on
the tear-down data available and scaling methodologies used in EPA's ongoing study with
FEV. Note, this costing methodology has been published and has been peer reviewed.18
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1. StoichiometricG gasoline direct injection and turbo charging with engine
downsizing (T-DS) for a large DOHC (dual overhead cam) 4 cylinder engine to a
smaller DOHC 4 cylinder engine.
2. Stoichiometric gasoline direct injection and turbo charging with engine
downsizing for a SOHC (single overhead cam) 3 valve/cylinder V8 engine to a
SOHC V6 engine.
3. Stoichiometric gasoline direct injection and turbo charging with engine
downsizing for a DOHC V6 engine to a DOHC 4 cylinder engine.
4. 6-speed automatic transmission replacing a 5-speed automatic transmission.
5. 6-speed wet dual clutch transmission (DCT) replacing a 6-speed automatic
transmission.
In addition, FEV and EPA extrapolated the engine downsizing costs for the following
scenarios that were based on the above study cases:
1. Downsizing a SOHC 2 valve/cylinder V8 engine to a DOHC V6.
2. Downsizing a DOHC V8 to a DOHC V6.
3. Downsizing a SOHC V6 engine to a DOHC 4 cylinder engine.
4. Downsizing a DOHC 4 cylinder engine to a DOHC 3 cylinder engine.
In the 2012-2016 light-duty rule, the agencies relied on the findings of FEV in part for
estimating the cost of these technologies. However, for some of the technologies, NHTSA
and EPA modified FEV's actual estimated costs. This was done because FEV based their
costs on the assumption that these technologies would be mature when produced in large
volumes (450,000 units or more). The agencies believed that there was some uncertainty
regarding each manufacturer's near-term ability to employ the technology at the volumes
assumed in the FEV analysis with fully learned costs. There was also the potential for near
term (earlier than 2016) supplier-level Engineering, Design and Testing (ED&T)H costs to be
in excess of those considered in the FEV analysis because existing equipment and facilities
need to be converted to the production of new technologies and may lead to stranded capitall
if done too rapidly. The agencies consider the FEV results to be generally valid for the 2017-
2025 timeframe because the factors considered in the 2012-2016 light-duty rule should no
longer exist and sales volumes of 450,000 units are likely due to, at least in part, the new
GHG and fuel economy requirements. More detail on which specific technologies are
G Stoichiometric Gasoline Direct Injection refers to a gasoline fueled spark-ignition internal combustion engine
with direct fuel injection into the combustion chamber that is designed to operate primarily at a chemically
balanced ratio of air and fuel thus allowing the effective use of standard precious-metal based (Rh combined
with Pd and/or Pt) three-way exhaust catalysts for control of criteria pollutants
H Product Development Costs are the ED&T costs incurred for development of a component or system. These
costs can be associated with a vehicle specific application and/or be part of the normal research and development
(R&D) performed by companies to remain competitive. In the cost analysis, the product development costs for
suppliers are included in the mark-up rate as ED&T suppliers.
1 Stranded Capital is defined as manufacturing equipment and facilities owned by a vehicle manufacturer that
cannot be used in the production of a new technology.
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impacted by this change is presented in Appendix B. The agencies will continue to review the
FEV results and methodology as necessary in the upcoming federal rulemaking.
3.2.3 Costs of HEV, PHEV, EV, and FCEV
The agencies have also reconsidered the costs for HEVs, PFIEVs, EVs, and FCEVs as
the result of two issues: The first issue is that there is a rapid development taking place on
electrified vehicle technologies and an effort has been made to capture the results from the
most recent analyses. The second issue is that the 2012-2016 rule employed a single $/kWhr
estimate and did not consider the specific vehicle and technology application for the battery
when we estimated the cost of the battery. Specifically, batteries used in HEVs versus EVs
need to be considered appropriately to reflect the design differences and differences in cost
per kW-hr as the power to energy ratio of the battery changes for different applications. For
this assessment, the agencies have used a battery cost model developed by Argonne National
Laboratory (ANL) for the Vehicle Technologies Program of the U.S. Department of Energy
(DoE) Office of Energy Efficiency and Renewable Energy. The model developed by ANL
provides unique battery pack cost estimates for each of the three major types of electrified
vehicles. The DoE has established long term industry goals and targets for advanced battery
systems as it does for many energy efficient technologies. ANL was funded by DoE to
provide an independent assessment of Li-ion battery costs because of their expertise in the
field as one of the primary DoE National Laboratories responsible for basic and applied
battery energy storage technologies for future FIEV, PHEV and EV applications. A basic
description of the ANL Li-ion battery cost model and initial modeling results for PHEV
applications were published in a peer-reviewed technical paper presented at EVS-2419. ANL
has extended modeling inputs and pack design criteria within the battery cost model to
include analysis of manufacturing costs for EVs and FIEVs as well has PHEVs.20 A complete
peer-review of the model and its inputs and results for FIEV and EV applications is pending,
and ANL expects to have a peer review completed within 1 year. NHTSA and EPA will
consider the results of the peer review as we develop the future joint federal notice of
proposed rulemaking. The agencies expect to continue to work with DOE and ANL (as well
as battery manufacturers, OEMs, and other stakeholders) to get the most up to date
information for the upcoming NPRM.
The agencies have decided to use the ANL model for estimating large-format lithium-
ion batteries for this assessment for the following reasons. The ANL model has been
described and presented in the public domain and does not rely upon confidential business
information (which would therefore not be reviewable by the public). The model was
developed by scientists at ANL who have significant experience in this area. The model uses
a bill of materials methodology which the agencies believe is the preferred method for
developing cost estimates. The ANL model appropriately considers the vehicle applications
power and energy requirements, which are two of the fundamental parameters when designing
a lithium-ion battery for an HEV, PHEV, or EV. The ANL model can estimate high volume
production costs, which the agencies believe is appropriate for the 2025 time frame. Finally,
the ANL model's cost estimates, while generally lower than the estimates we received from
the OEMs, is consistent with some of the supplier cost estimates the agencies received from
large-format lithium-ion battery pack manufacturers. A portion of the data was received from
on-site visits done by the EPA.
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The ANL battery cost model is based on a bill of materials approach in addition to
specific design criteria for the intended application of a battery pack. The costs include
materials, manufacturing processes, the cost of capital equipment, plant area and labor for
each manufacturing step as well as the design criteria include a vehicle application's power
and energy storage capacity requirements, the battery's cathode and anode chemistry, and the
number of cells per module and modules per battery pack. The model assumes use of a
laminated multi-layer prismatic cell and battery modules consisting of double-seamed rigid
containers. The model also assumes that the battery modules are air-cooled. The model takes
into consideration the cost of capital equipment, plant area and labor for each step in the
manufacturing process for battery packs and places relevant limits on electrode coating
thicknesses and other processes limited by existing and near-term manufacturing processes.
The ANL model also takes into consideration annual pack production volume and economies
of scale for high-volume production.
The cost outputs from the ANL model used by the Agencies to determine 2025 HEV,
PHEV and EV battery costs were based upon 500,000 packs/year production volume and the
use of a common cathode and anode chemistry, LiMn2O4-spinel for the cathode and graphite
for the anode. The agencies assumed a change in battery state of charge (% SOC) of 50% for
HEVs, 70% for PHEVs and 80% for EVs in 2025. The agencies also estimated 2020 HEV,
PHEV and EV battery costs based upon the same battery chemistry and a production volume
of 100,000 packs/year. EPA considered one other battery chemistry, LiFePO4-graphite. While
it is expected that other Li-ion battery chemistries with higher energy density, higher power
density and lower cost will likely be available in the 2017-2025 timeframe, the specific
chemistry used for the cost analysis was chosen due to its known characteristics and to be
consistent with publicly available information on current and near term HEV, PHEV and EV
91 99 9^ 94
product offerings from Hyundai, GM and Nissan. ' ' ' The cost of active materials is
somewhat higher for LiMn2O4-spinel than for LiFePO4, but battery pack costs are generally
higher for LiFePO4 when comparing battery packs with the same energy and power
requirements. This is due primarily to the lower energy density of LiFePO4 relative to
LiMn2O4-spinel. We expect that incremental improvements in battery energy density will
continue through 2025 and thus the higher energy density represented by the choice of a
LiMn2O4-spinel cathode/graphite anode within the ANL cost model is more appropriate for
determining the future cost of batteries in the 2017-2025 timeframe. Examples of the cost
outputs from the ANL model used by the agencies in this analysis are shown in Table 3.2-1
and Table 3.2-2. A more detailed discussion of battery pack costs is contained in Appendix
B. The agencies note that costs used in the analysis are lower than the costs generally
reported in stakeholder meetings, which ranged from $300/kW-hour to $400/kW-hour range
for 2020 and $250 to $300/kW-hour range for 2025. Because of uncertainty with regard to
future battery costs, the agencies also conducted a sensitivity study using PHEV and EV
battery pack costs approximately $100/kW-hr higher and $50/kW-hr lower than the costs
estimates from the ANL battery cost model. Further details regarding the sensitivity analysis
are described Chapter 6 of this report and in Appendix B, section B4.2.1.3.
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Table 3.2-1: Direct Manufacturing Costs on a $/kWh-basis for Large Car HEVs, PHEVs
and EVs (2008 dollars, markups not included).
Application
P2HEV Battery Pack
PHEV20 Battery Pack
PHEV40 Battery Pack
EV75 Battery Pack
EV100 Battery Pack
EV1 50 Battery Pack
Direct Manufacturing Cost, MY2020
(100,000 packs/year volume)
$
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$/kW-hr
$1,214
$324
$238
$217
$191
$175
Direct Manufacturing Cost, MY2025
(500,000 packs/year volume)
$
$641
$2,333
$3,428
$4,678
$5,954
$8,804
$/kW-hr
$971
$259
$190
$173
$153
$140
Table 3.2-2: Direct Manufacturing Costs on a $/kWh-basis for subcompact HEVs,
PHEVs and EVs (2008 dollars, markups not included).
Application
P2HEV Battery Pack
PHEV20 Battery Pack
PHEV40 Battery Pack
EV75 Battery Pack
EV100 Battery Pack
EV1 50 Battery Pack
Direct Manufacturing Cost, MY2020
(100,000 packs/year volume)
(D
J>
$541
$2,187
$3,244
$4,013
$5,143
$7,666
$/kW-hr
$1,177
$347
$251
$197
$184
$170
Direct Manufacturing Cost, MY2025
(500,000 packs/year volume)
(D
J>
$433
$1,749
$2,595
$3,211
$4,115
$6,133
$/kW-hr
$941
$278
$201
$157
$147
$136
The potential for future reductions in battery cost and improvements in battery
performance will play a major role in determining the overall cost and performance of future
PHEVs and EVs. The U.S. Department of Energy manages major battery-related R&D
programs and partnerships, and has done so for many years, including the ANL model utilized
in this report. DOE has reviewed the battery cost projections underlying today's TAR. DOE
supports the cost projections, and while the overall projections are in some cases optimistic,
DOE believes they are reasonable for a long-term, technology-based assessment as utilized in
this report. In addition, as discussed above, DOE intends to work with ANL to ensure the
ANL model undergoes a thorough peer review. Finally, DOE recommends that the agencies
consider evaluating a range of assumptions for rulemaking, including the evaluation of other
battery cost estimation models as appropriate. NHTSA and EPA intend to conduct additional
analysis for the NPRM and final rule that is consistent with these recommendations from
DOE.
The agencies have also carefully reconsidered the power and energy requirements for
each electrified vehicle type, which has a significant impact on the cost estimates for HEVs,
PHEVs, and EVs as compared to the estimates used in the 2012-2016 rulemaking. In
addition, the agencies have considered battery pack costs separately from the remainder of the
systems added to each type of electrified vehicle. The advantage of separating the battery
pack costs from other system costs is that it allows each to carry unique indirect cost
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2017-2025 Technical Assessment
multipliers and learning effects which are important given that battery technology is an
emerging technology, while electric motors and inverters are more stable technologies. We
note that, for this analysis, the agencies have assumed batteries will be capable of lasting the
lifetime of the vehiclej, which is consistent with what manufacturers have shared with us are
the expected customer demands from this technology. Manufacturers have acknowledged,
however, that there may be some performance degradation in the batteries over time. For the
NPRM, the agencies may analyze the maintenance cost differences among technologies,
including batteries. Lastly, the agencies have focused attention on an emerging HEV
technology known as a P2-hybrid, a technology not considered in the 2012-2016 light-duty
rule.
A P2 hybrid is a vehicle with an electric drive motor coupled to the engine crankshaft
via a clutch. The engine and the drive motor are mechanically independent of each other,
allowing the engine or motor to power the vehicle separately or combined. This is similar to
the Honda HEV architecture with the exception of the added clutch, and larger batteries and
motors. Examples of this include the soon-to-be sold Hyundai Sonata, Elantra and the Nissan
Fuga (expected to be rebadged as an Infmiti product for the North American market). The
agencies believe that the P2 is an example of a "strong" hybrid technology that is typical of
what we will see in the timeframe of this rule. The agencies could have equally chosen the
power-split architecture as the representative HEV architecture. These two HEV's have
similar average effectiveness values (combined city and highway fuel economy), though the
P2 systems may have lower cost due to the lower number of parts and complexity.
The effectiveness used for vehicle packages with the P2-hybrid configuration within
this analysis reflects a conservative estimate of system performance. Vehicle simulation
modeling of technology packages using the P-2 hybrid configuration is currently underway
under contract with Ricardo Engineering. The agencies plan to update the effectiveness of
hybrid electric vehicle packages using the new Ricardo vehicle simulation modeling runs
prior to the NPRM.
The agencies have also considered, for this analysis, the costs associated with in-home
chargers expected to be necessary for PHEVs and EVs. Further details on in-home chargers
and their estimated costs are presented in Section 4.2.3 and Appendix B. Details of the
updated HEV, PHEV, EV and FCEV costs are presented in Appendix B.
3.2.4 Mass Reduction Impacts and Costs
Mass reduction encompasses a variety of techniques ranging from improved design, and
increased component integration to the application of lighter and higher-strength materials.
Initial mass reduction can be further compounded by reductions in engine power and ancillary
systems (transmission, steering, brakes, suspension, etc.) to provide increased vehicle mass
reduction overall. The agencies recognize there is a wide diversity and range of complexity
1 Median life of a passenger vehicle is 13.8 years and 14.5 years for light trucks. Lu, S., NHTSA, Regulatory
Analysis and Evaluation Division, "Vehicle Survivability and Travel Mileage Schedules," DOT HS 809 952, 8-
11 (January 2006). Available at http://www-nrd.nhtsa.dot.gov/Pubs/809952.pdf (last accessed March 1, 2010).
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for mass reduction and material substitution technologies, and that there are many techniques
that automotive and other industry suppliers and manufacturers are using or plan to use to
achieve the levels of this technology that the agencies model in our analysis. Manufacturers'
opinions in stakeholder meetings over the summer varied widely as to how much mass
reduction could be realized and at what cost in the time frame of 2017-2025, ranging from
some mass increase to 10-15 percent mass reduction. While the agencies limited the amount
of mass reduction in our analysis for the MYs 2012-2016 final rule to 10 percent, for the
purposes of this Technical Assessment Report the agencies have considered three levels of
mass reduction that could be achieved in 2025 compared to a baseline 2008 vehicle: one
pathway with less aggressive mass reduction of 15 percent, one with 20 percent mass
reduction, and one with technology forcing mass reduction of 30 percent. The agencies
assume, as part of these reduction amounts, that vehicle size and full functionality are
maintained. We note the ability of the industry to reduce mass beyond 20% while
maintaining vehicle size and functionality is an open technical issue, which the agencies are
carefully evaluating and will continue to as we move forward. We also note, as discussed in
the MYs 2012-2016 final rule, that the agencies believe that the effects of vehicle mass
reduction on safety should be evaluated from a societal perspective (including an analysis or
fatalities and casualties), which could affect the maximum levels used for rulemaking. This
analysis has not been included in this report. NHTSA and EPA will include a thorough safety
assessment of mass reduction for the upcoming joint federal NPRM and final rule.
With respect to the feasibility of reducing mass by 15-30 percent by 2025, the
agencies discussed the application of mass reduction technologies at length in meetings with
vehicle manufacturers in preparation for this Technical Assessment Report. One of the
challenges the manufacturers identified with respect to mass reduction was the feasibility of
substituting some lower density materials for higher density materials. These material
substitution issues included material availability, forming, joining, painting, corrosion,
reparability, and impact performance. The agencies have established a collaborative team
among DOT/NHTSA, DOE and EPA to address vehicle mass reduction and mass/safety
issues generally, and have undertaken work on several tasks to begin addressing these
particular issues identified by the manufacturers, including 1) a peer review of the Lotus
Engineering report25 regarding holistic vehicle mass reduction opportunities, 2) a 2nd phase of
analysis by Lotus Engineering using computer aided engineering (CAE) to assess phase 1
designs for functional and safety performance, to modify designs as necessary to achieve
performance levels similar to the baseline vehicle, and to determine the mass reduction that is
feasible, 3) a DOE funded project investigating the amount of mass reduction that is
technologically feasible, and 4)a DOE funded project consisting of an actual vehicle build
(Multi Material Vehicle - MMVK). NHTSA and EPA may fund other studies to explore the
feasible amount of mass reduction and cost for MY 2017-2025 separately from the study
contracted to Lotus engineering by CARB. Computer Aided Engineering (CAE) tools would
be used to analyze the structure of the vehicle. The proposed design should meet at least the
K DOE Notice of Intent to Issue Funding Opportunity Announcement N.:DE-FOA-000239.
http://www.netl.doe.gov/business/solicitations/NOTICE%20OF%20INTENT.pdf
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2017-2025 Technical Assessment
same functional objectives as the baseline vehicle. If funded, this study would be finished in
time for the final rule for MYs 2017-2025.
With respect to cost, in the MYs 2012-2016 final rule, NHTSA and EPA applied a
cost of $1.32 per pound of mass reduction, and the limit of mass reduction (penetration cap)
was set to 10%14. This cost estimate was based on three studies: 2002 NAS report26, Sierra
Research27, and MIT28. For the purposes of this Technical Assessment Report, however, the
agencies expect based on the meetings this summer with OEMs, that manufacturers will be
capable of mass reduction levels greater than 10 percent net in the 2017-2025 timeframe. The
agencies recognize that higher percentages of mass reduction may result in higher costs and
that these costs are likely to increase non-linearly with increasing mass reduction levels.
Furthermore, the agencies and OEMs also recognize that there is some initial amount of mass
reduction which can be accomplished with zero or very little cost (much lower than that
estimated in the 2012-2016 rule). Thus, in this report, the agencies have begun updating their
mass reduction cost model to reflect this progressively increasing level of cost. A preliminary
non-linear cost model employed for this current analysis is shown in the figure below. The
figure shows the present cost model in comparison to the costs used for the 2012-2016 final
rule. The agencies have relied on a parabolic shape for the cost curve - where the cost per
pound increases as the square of the percentage mass reduction. The endpoint of the model is
based on an average of the final rule costs and the results from the Lotus Engineering mass
reduction study. A more complete description of how this cost model was developed is
described in Appendix B. For the purposes of the upcoming federal rulemaking, the agencies
intend to improve the model using additional studies that are expected to be complete before
the NPRM and final rule - the agencies do not intend for this preliminary model to be the
final cost model used. The federal interagency mass/safety team has initiated several work
tasks to inform and update the cost model, including meeting with vehicle manufacturers,
updating DOE's 2007 study on feasibility and cost, and EPA funding a 3rd party cost
assessment of the Lotus Report.
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u
$1.50
$1.00
$0.50
0%
8 $(0.50)
•o
c
3
Q- $(1.00)
OJ
Q.
$(1.50)
$(2.00)
$(2.50)
5%
10%
15%
Lotus Results
2012-2016 Cost Model
2017-2025 Cost Model
0%
25%
30%
35%
40%
%Mass Reduction
Figure 3.2-1: Mass Reduction Cost Model in Dollars per Pound in Model Year 2020
Compared to the Lotus Results and 2012-2016 Final Rule Cost.
With respect to the effects of net vehicle mass reduction amounts of 15-30 percent on
overall societal safety, the federal interagency mass/safety group has been meeting several
times a week since shortly after the MY 2012-2016 rule was released to coordinate study of
the effects of mass reduction and vehicle size on societal safety. This work will be used to
update the safety model for future federal rulemaking. The agencies are conducting several
statistical studies using a common database with updated historical crash data (MY 2000-
2007 PARS data, common state accident data and updated vehicle attributes). The studies
include an updated NHTSA study of the relationship between vehicle mass, size and safety,
two separate DOE funded fatality and casualty vehicle mass, size and safety analyses to be
performed by Lawrence Berkeley National Laboratory, and peer reviews of the
methodologies used in over 20 significant reports published.
NHTSA is also looking into conducting two additional studies of crash compatibility
that may help inform the effects of mass reduction and design on societal safety. If
conducted, these studies may use vehicle models developed for the CARB funded Lotus
phase 2 study and/or the potential NHTSA and EPA study for the feasible amount of mass
reduction and cost for MY 2017-2025. These studies may inform how designs that
incorporate lower density or higher strength materials, meet FMVSS regulations, and
perform well in NCAP and IIHS tests, affect vehicle crash compatibility. The findings may
be used to help inform the effects of mass reduction on societal safety. Because this study
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2017-2025 Technical Assessment
cannot begin until the Lotus or NHTSA/EPA studies have been completed, and this study
requires significant modeling work, there is some risk the study will not be completed in time
to inform a final rule.
3.2.5 Indirect Cost Multipliers
Since the 2012-2016 rulemaking, the agencies have reconsidered the indirect cost
multiplier approach and believe it to be more appropriate to include in the ICM a factor to
reflect return on invested capital. In the automotive industry, this is on the order of 6%.29 To
account for this, the agencies added a 0.06 factor added to the ICMs used in the rulemaking.
These values are shown in Table 3.2-3. A note of clarification on the table, the low, medium
and high complexity levels are meant to account for the complexity of integrating a
technology into a vehicle. For example, adding variable valve timing to an engine is
relatively not difficult and, for that reason, we would consider it a low complexity technology.
By contrast, converting to a hybrid powertrain is considerably more complex to do and, for
that reason, we would consider it a high complexity technology. The indirect costs are higher
for the high complexity technology given the higher level of effort (and therefore costs) that
would be incurred to implement the technology. The near term and long term values reflect
the way that indirect costs are expected to change over time as new technologies are
implemented. In the near term, the indirect costs are highest because the development effort
is underway, the warranty costs are higher, etc. In the long term, many of these costs are no
longer attributable to regulatory changes and, therefore, are no longer applied. Similarly, the
warranty costs, while still present, have come down because the technology has achieved
mature status and those costs have returned to an average level. For this assessment, the near
term and long term cutoff points are different for different technologies. In short,
conventional gasoline technologies are considered long term beginning in 2017, hybrid
technologies are considered long term beginning in 2020, advanced gasoline technologies and
both range extended and full electric vehicles are considered long term beginning in 2022.
Table 3.2-3 Comparison of Indirect Cost Multipliers used in the 2012-2016 Rulemaking
versus this Assessment Report
Complexity
Low
Medium
Highl
High 2
2012-2016 Rulemaking
Near term
1.11
1.25
1.45
1.64
Long term
1.07
1.13
1.26
1.39
Assessment Report
Near term
1.17
1.31
1.51
1.70
Long term
1.13
1.19
1.32
1.45
For this analysis, the indirect costs are estimated by applying indirect cost multipliers
(ICM) to direct cost estimates. ICMs were developed by EPA during the 2012-2016 light-
duty rulemaking as a basis for estimating the impact on indirect costs of individual vehicle
technology changes that would result from regulatory actions. Separate ICMs were derived
for low, medium, and high complexity technologies, thus enabling estimates of indirect costs
that reflect the variation in research, overhead, and other indirect costs that can result from the
application of various technologies in direct response to a regulatory action.
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Previous NHTSA and EPA rulemakings applied a retail price equivalent (RPE) factor
to estimate indirect costs and mark up direct costs to the retail level. Retail Price Equivalents
are estimated by dividing the total revenue of a manufacturer by their direct manufacturing
costs. As such, it includes all forms of indirect costs for a manufacturer, regardless of
whether all of those costs change in response to the regulatory action and assumes that the
ratio applies equally for all technologies. ICMs, in contrast, are based on RPE estimates that
are then modified to reflect only those elements of indirect costs that would be expected to
change in response to a regulatory action. For example, warranty costs would be reflected in
both RPE and ICM estimates since new technologies, whether added in response to a
regulatory action or other reason, will almost always incur some level of warranty expense.
In contrast, marketing costs might only be reflected in an RPE estimate and not an ICM
estimate for a particular technology if the new technology added in response to a regulatory
action is not one expected to be expressly marketed to consumers. Because the ICMs
developed for the 2012-2016 rulemaking are for individual technologies, many of which are
relatively simple to implement (e.g., variable valve timing), they often reflect a subset of RPE
costs; as a result, the RPE is typically higher than an ICM. This is not always the case, as
ICM estimates for complex technologies may reflect higher than average indirect costs due
perhaps to increased R&D and/or integration demands, with the resulting ICM larger than the
averaged RPE for the industry.
Precise association of ICM elements with individual technologies based on the varied
accounting categories in company annual reports is difficult. Hence, there is a degree of
uncertainty in the ICM estimates. The agencies are continuing to study ICMs and the most
appropriate way to apply them, and it is possible revised ICM values may be used for the
upcoming NPRM. For that reason, the agencies have considered the range of data in the
survey responses used to develop the ICMs used in the 2012-2016 rule.30 The survey data
showed a standard deviation of 0.14 to 0.21 on the short term ICMs against average values
ranging from 1.16 (for the low ICM) to 1.64 (for the high ICM). The coefficient of variance
(the standard deviation divided by the average) would then be roughly 12% for the low ICM
and 13% for the high ICM. Based on these results, the ICM values could range from 13%
lower to 13% higher than the primary ICM values. Using the range of cost estimates
presented in Chapter 6 for future potential scenarios, this range of ICMs could result in an
approximate change in 2025 costs between +/- $100 to as much as +/- $450, depending on the
overall level of the 2025 targets analyzed.
As mentioned earlier, the agencies have also conducted some sensitivity surrounding
the issue of battery costs. A more complete discussion of this is presented in Chapter 6.
3.2.6 Cost Adjustment to 2008 Dollars
As noted above, the costs presented in the 2012-2016 rule have been updated from
2007 dollars to 2008 dollars using the Gross Domestic Product (GDP) Price Deflator. The
GDP Price Deflator is one means of adjusting the value of the dollar in different years. The
data we have used, which is indexed to 2005, shows that it takes $1.062 in 2007 dollars and
$1.085 in 2008 dollars to purchase a $1 item in 2005.31 Therefore, we have adjusted all of
the 2012-2016 costs, valued in 2007 dollars, by a factor of 1.022 (1.085/1.062) to express
costs in 2008 dollars.
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2017-2025 Technical Assessment
3.2.7 Costs Effects due to Learning
The agencies have also reconsidered learning effects. For this assessment, we
continue to reflect the phenomenon of volume-based learning curve cost reductions in our
modeling using two algorithms - "volume-based" for newer technologies and "time-based"
for mature technologies. The observed phenomenon in the economic literature which supports
manufacture learning cost reductions are based on reductions in costs as production volumes
increase, and the economic literature suggests these cost reductions occur indefinitely, though
the absolute magnitude of the cost reductions decrease as production volumes increase (with
the highest absolute cost reduction occurring with the first doubling of production).32 The
agencies use the terminology "volume-based" and "time-based" to distinguish among newer
technologies and more mature technologies, and how we apply learning cost reductions in our
assessment. Our volume-based learning algorithm applies for the early, steep portion of the
learning curve and is estimated to result in 20 percent lower costs after two full years of
implementation (i.e., a 2014 MY cost would be 20 percent lower than the 2012 and 2013
model year costs for a new technology being implemented in 2012). Our time-based learning
algorithm applies for the flatter portion of the learning curve and is estimated to result in 3
percent lower costs in each of the five years following first introduction of a given
technology. Once two volume-based learning steps have occurred (for technologies having
volume-based learning applied), time based learning would begin. For technologies to which
time based learning is applied, learning would begin in year 2 at 3 percent per year for 5
years. Beyond 5 years of time-based learning at 3 percent per year, 5 years of time-based
learning at 2 percent per year, then 5 at 1 percent per year become effective. Going forward,
the agencies intend to investigate industry learning curves in more detail including to what
extent "volume-based" and "time-based" come from the same observed phenomenon and
whether learning should continue to be applied indefinitely, or whether cost reductions due to
learning should go to zero after some period of time. The learning curve used in this
assessment may be modified for the rule making.
3.2.8 Cooled EGR Cost and Effectiveness
While not considered in the 2012-2016 light-duty rule, the agencies have considered
an emerging technology referred to as cooled exhaust gas recirculation (cooled-EGR) as
applied to downsized, turbocharged GDI engines. The agencies have considered this
technology as an advanced gasoline technology since, as noted, it is emerging and not yet
available in the light-duty gasoline market. While a cooled or "boosted" EGR technology was
discussed in the 2012-2016 light-duty rule, the technology considered here is comparatively
more advanced than the one considered previously, and as such, the agencies have considered
new costs and new effectiveness values for it. The details behind those updated costs and
effectiveness values are presented in Appendix B. The effectiveness values used for vehicle
packages with cooled EGR within this analysis reflect a conservative estimate of system
performance at approximately 24-bar BMEP. Vehicle simulation modeling of technology
packages using the more highly boosted and downsized cooled EGR engines (up to 30-bar
BMEP) with dual-stage turbocharging is currently underway as part of EPA's contract with
Ricardo Engineering as described below. The agencies plan to update the effectiveness of
vehicle packages with cooled EGR using the new Ricardo vehicle simulation modeling runs
prior to the NPRM.
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Chapter 3
3.2.9 HEV Effectiveness
At time of this publication, the effectiveness of HEVs requiring equivalent towing
capacity to their traditional, gasoline powered counterpart (large pick-up trucks for example)
is similar to those used in the 2012-2016 light-duty rule for vehicles. For several other
subclasses, the agencies increased HEV effectiveness by approximately 2% based on
published data for new HEVs that have entered production since the last study was complete
(including the new Toyota Prius, Ford Fusion hybrid and othersL). In addition, for the Large
Car, Minivan and Small Truck subclasses, the agencies further increased HEV effectiveness
by assuming that towing capacity could be reduced from their current ratingM to
approximately 1,500 pounds for some vehicles in these subclasses without significantly
impacting consumers' need for utility in these vehicles.N The agencies believe that the
towing capacity in these HEV classes was maintained at an overly stringent performance level
in the technical analysis of the 2012-2016 rule. The agencies believe that consumers who
require higher towing capacity could acquire it by purchasing a vehicle with a more capable
non-hybrid powertrain (as they do today).0 Moreover, it is likely that some fraction of
consumers who purchase the larger engine option do so for purposes of hauling and
acceleration performance, not just maximum towing.
A reduction in towing capacity allows greater engine downsizing, which increases
estimated overall HEV system incremental effectiveness by 5 to 10 percent and brings
estimated absolute HEV system effectiveness to approximately 30 percent for Large Cars,
Minivans, and Small Trucks, similar to the HEV effectiveness value assumed for Small Cars
and Compact Cars.p Refer to Appendix B for a more detailed summary of the effectiveness
values assumed for both towing and relaxed towing HEVs.
L The agencies will continue to evaluate hybrid effectiveness estimates through vehicle simulation research
currently underway but will not be completed as of the publication of this NOI and TAR.
M Current small SUVs and Minivans have an approximate average towing capacity of 2000 Ibs (without a towing
package), but range from no towing capacity to 3500 pounds.
N We note that there are some gasoline vehicles in the large car/minivan/small truck segments sold today which
do not have any towing rating.
0 The agencies recognize that assuming that certain consumers will choose to purchase non-hybrid vehicles in
order to obtain their desired towing capacity could lead to some increase in fuel consumption and CO2 emissions
as compared to assuming that towing capacity is maintained for hybrid vehicles across the board and all vehicles
are therefore hybrids. However, the agencies think it likely that the net improvement in fuel consumption and
CO2 emissions due to the increased numbers of hybrids available for consumers to choose will offset any
potential increase in fuel consumption and CO2 emissions resulting from consumers selecting the higher-
performance non-hybrid powertrain vehicles.
p The effectiveness of HEVs for heavier vehicles which require conventional towing capabilities is markedly less
because the rated power of the 1C engine must be similar to its non-hybrid brethren. As such, there is less
opportunity for downsizing with these vehicles.
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3.2.10 Ongoing Vehicle Simulation to Update Effectiveness
The other critical factor in the assessment of the cost-effectiveness of technologies is
the effectiveness valueQ associated with a particular technology. The agencies have, in
general, used the same effectiveness estimates used in the 2012-2016 light-duty rule.
To assess the effectiveness of emerging technologies and advances in conventional
technologies in the 2017 to 2025 timeframe, EPA also commissioned an extension of earlier
vehicle simulation modeling work with Ricardo, Inc. Besides updating the technology
effectiveness estimates of the previous work, the present study substantially broadened the
scope to include two new vehicle classes and several advanced technologies, including P2 and
other HEVs. Among the major additions:
1. Two new vehicle classes intended for use in EPA's OMEGA model: a
subcompact car and a light heavy-duty truck
2. Highly-boosted and significantly downsized direct injection gasoline engines,
including lean-burn11 and stoichiometric/cooled-EGR variants
3. 8-speed automatic and dual-clutch transmissions
4. Advanced hybrids, including P2 and powersplit8 hybrids
5. Vehicle mass reduction, in conjunction with engine downsizing
The Ricardo study has not been completed to a degree that allow results to be used for
this analysis, but EPA and NHTSA expect to use the findings from this work to inform the
estimates of technology effectiveness used for the model year 2017-2025 NPRM.
3.3 Vehicle Manufacturer Lead Time
With respect to the practicability of the standards in terms of lead time, during MYs
2017-2025 manufacturers are expected to go through the normal automotive business cycle of
redesigning and upgrading their light-duty vehicle products, and in some cases introducing
entirely new vehicles not in the market today. This assessment allows manufacturers the time
needed to incorporate technology to achieve GHG reductions and improve fuel economy
during the vehicle redesign process. This is an important aspect of the assessment, as it
avoids the much higher costs that would occur if manufacturers need to add or change
technology at times other than their scheduled redesigns. This time period also provides
manufacturers the opportunity to plan for compliance using a multi-year time frame, again
consistent with normal business practice. Over these 9 model years, there will be an
opportunity for manufacturers to evaluate, presumably, every one of their vehicle model
platforms and add technology in a cost effective way to control GHG emissions and improve
fuel economy. This includes all the technologies considered here and redesign of the air
R Lean-burn simply means less fuel per unit air than would be used under stoichiometric combustion. Lean burn
operation is a way to reduce throttling losses and allows for higher compression ratios and, thus, better
performance and/or fuel efficiency.
s This is the HEV architecture initially developed by Toyota and now more widely used in several models.
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Chapter 3
conditioner systems in ways that will further reduce GHG emissions and improve fuel
economy. Most vehicles would likely undergo two redesigns during this period.
Even with multiple redesign periods, it is still likely that some of the more advanced
and costly technologies (such as cooled boosted EGR engines, or advanced (P)HEVs) may
not be able to be fully implemented within the timeframe of this rule. These limitations are
captured in "maximum technology penetration rates" within the modeling analysis.
In order to assess the four technology pathways, we developed "Maximum
Technology Penetration Rates" which we could implement within the OMEGA model in
order to represent the four pathways. Each technology path was defined by these maximum
technology penetration rates, which were specified as the maximum modeled fleet penetration
of classes of technology into the new vehicle fleet in MY 2020 and MY 2025 (these broad
classes of technology as described in detail below). We developed these penetration rates
based on agency expert judgment with regard to a number of factors such as manufacturer
production capacity, vehicle suitability, technical feasibility considerations, as well as our
goal of purposely analyzing multiple potential pathways for this technical assessment. The
maximum technology penetration rates serve as exogenous limits on technology application
within the OMEGA model and are shown in Table 3.3-1.
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2017-2025 Technical Assessment
Table 3.3-1 Scenario Maximum Technology Penetration Rates
Technology
Conventional SI
Advanced SI
Hybrid vehicles
Electric Vehicle
Plug-in Hybrid
Mass
Reduction1'2
MY 2020j
Path A
100%
10%
40%
4%
4%
15%
PathB
100%
30%
30%
4%
4%
15%
PathC
100%
40%
40%
8%
8%
25%
MY 2025
Path A
100%
50%
75%
8%
8%
15%
PathB
100%
75%
50%
8%
8%
20%
PathC
100%
100%
75%
15%
15%
30%
PathD
100%
0%
60%
20%
20%
15%
1 The mass reduction shown is with respect to the 2008 MY.
2 The mass reduction shown is not an actual phase-in cap, but the maximum amount of mass reduction which
could be allowed on any vehicle.
technology Path D was not run in MY 2020, please see chapter 6 for a discussion of this topic.
The broad technology classes evaluated for purposes of this analysis are defined below
and a brief discussion of the limiting factors considered are presented. For a more detailed
discussion of any individual technology, please see the joint Technical Support Document for
the 2012-2016 rule and Appendix B of this report:
• Conventional Spark Ignition (SI) - This technology category includes all technologies
that are not contained in other categories such as gasoline direct injection engines,
cylinder deactivation, six and eight speed automatic and dual clutch transmissions, and
start-stop micro-hybrid technology. Most of these technologies were anticipated as
being available in the MY 2012-2016 time frame in the recent NHTSA and EPA final
rule, and it is expected manufacturers could expand production to all models by model
year 2025, and therefore the maximum technology penetration rate is set at 100% for
all four pathways.
• Advanced SI - This technology includes gasoline spark ignition engines which are
currently under development by OEMs and suppliers and are not anticipated to be
widely used in the 2012- 2016 time frame. For purposes of this analysis, based on
agency expert judgment to define these advanced SI engines, we modeled a direct
injection gasoline engine with cooled exhaust gas recirculation, and with a larger
degree of engine downsizing and higher level of turbocharging as compared to the
turbo-downsized engines included in our analysis for the MYs 2012-2016 final rule.
This technology is discussed in more detail above and the appendix B, and is similar
to the technologies that many OEMs indicated were underdevelopment and which they
anticipate will be introduced into the market in the 2017-2025 time frame. As there
are no production vehicles presently using these technologies, we set the maximum
technology penetration rate for these technologies at less than 100% in MY 2025 for
Paths A and B.
• Hybrid - While the agencies recognize there are many types of full-hybrids either in
production or under development, for the purposes of this analysis we have
specifically modeled two types of hybrids, P-2 and 2-Mode type hybrids. These
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technologies are discussed in detail in Chapter 3. While the agencies expect the
proliferation of these vehicles to increase in this timeframe, the maximum technology
penetration rate are set at less than 100% due to potential battery supply constraints, as
well as industry-wide engineering and capacity constraints, for converting the entire
new vehicle fleet to strong hybrids in this time frame. The four path ways using
varying levels in order to capture both the current uncertainty with how rapidly these
technologies can penetrate into the new vehicle fleet in the 2017-2025 time frame as
well as the potentially different strategies auto companies may choose with respect to
the degree of HEV penetration they may pursue.
• Plug-in Hybrid (PHEV) - This technology includes PHEV's with a range of 20 and 40
miles and is discussed above. The maximum technology penetration rates are set at
less than 100% due to the same general potential constraints as listed for the HEVs,
but are lower for PHEVs due to the current status of the development of these
advanced vehicles. Further, as discussed in Appendix B, we project that PHEV
technology is not available to some vehicle types, such as large pickup. While it is
possible to electrify such vehicles, there are tradeoffs in terms of cost, electric range,
and utility that would reduce the appeal of the vehicle to a narrower market.
• Electric Vehicle (EV) - This technology includes vehicles with actual on-road ranges
of 75, 100, and 150 miles. The actual on-road range was calculated using a projected
30% gap between two-cycle and on-road range. These vehicles are powered solely by
electricity and are not powered by any liquid fuels. The maximum technology
penetration rates are set at less than 100% due to the same general potential constraints
as discussed for PHEVs. Further, as with PHEVs, and as discussed in Appendix B,
we assume that EV technology is not available to some vehicle types, such as large
pickups. While it is possible to electrify such vehicles, there are tradeoffs in terms of
cost, range, and utility that would reduce the appeal of the vehicle to a narrower
market. These trade-offs are expected to reduce the market for other vehicle types as
well, and for this analysis we have considered this in the development of the
maximum technology penetration rates we use for the four pathways. Although the
agencies have assumed that range limitations would entail no loss in value to EV
owners, we will further consider the reasonableness and applicability of this
assumption, and will conduct our analyses for the forthcoming NPRM accordingly.1
• Mass Reduction - This technology includes material substitution, smart design, and
mass reduction compounding. The actual amount of reduction from the 2008 baseline
was determined based on confidential business information provided by vehicle
manufacturers, assessments provided by material suppliers, and existing studies in the
literature, including the 2010 report from Lotus Engineering. As discussed above as
well as in Chapter 1 and Appendix B, NHTSA and EPA intend to conduct a thorough
T If the agencies determine that the loss of range does entail some loss in value to vehicle owners, we anticipate
that accounting for this loss in value would affect our estimates of potential EV application rates and our
estimates of the private and social benefits of new standards that could lead to increases in EV application rates.
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assessment of the levels of the levels of mass reduction that could be achieved which
is both technologically feasible and which can be implemented in a safe manner for
the joint federal NPRM.
3.4 Other Technologies Assessed
In addition to the technologies already mentioned, the technologies generally
considered in the agencies' analysis are briefly described below. They fall into five broad
categories: engine technologies, transmission technologies, vehicle technologies,
electrification/accessory technologies, hybrid technologies and mass reduction. For a more
detailed description of each technology and their costs and effectiveness, we refer the reader
to Chapter 3 of the Joint TSD, Chapter III of NHTSA's FRIA, and Chapter 1 of EPA's final
RIA.33 Technologies to reduce CO2 and HFC emissions from air conditioning systems are
discussed in Appendix D. We note that not all of these technologies were actually modeled in
the analysis for this Technical Assessment Report given the agencies' decision to simplify
that analysis as discussed further below in Section 3.5 and in Chapter 6, but all of the
technologies will be available for the models in the upcoming rulemaking analysis.
3.4.1 Types of engine technologies that improve fuel economy and reduce CC>2
emissions include the following:
• Low-friction lubricants - low viscosity and advanced low friction
lubricants oils are now available with improved performance and better
lubrication. If manufacturers choose to make use of these lubricants, they
would need to make engine changes and possibly conduct durability testing
to accommodate the low-friction lubricants. The cost and GHG and fuel
economy effectiveness is unchanged from estimates used for 2016 model
year vehicles in the 2012-2016 final rule.
• Reduction of engine friction losses - can be achieved through low-tension
piston rings, roller cam followers, improved material coatings, more
optimal thermal management, piston surface treatments, and other
improvements in the design of engine components and subsystems that
improve engine operation. The cost and GHG and fuel economy
effectiveness is unchanged from estimates used for 2016 model year
vehicles in the 2012-2016 final rule.
• Conversion to dual overhead cam with dual cam phasing - as applied to
overhead valves designed to increase the air flow with more than two
valves per cylinder and reduce pumping losses. The GHG and fuel
economy effectiveness is unchanged from estimates used for 2016 model
year vehicles in the 2012-2016 final rule. The cost has changed only in
that learning effects have continued to decrease piece costs.
• Cylinder deactivation - deactivates the intake and exhaust valves and
prevents fuel injection into some cylinders during light-load operation.
The engine runs temporarily as though it were a smaller engine which
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substantially reduces pumping losses. The GHG and fuel economy
effectiveness is unchanged from estimates used for 2016 model year
vehicles in the 2012-2016 final rule. The cost has changed only in that
learning effects have continued to decrease piece costs.
• Variable valve timing - alters the timing of the intake valve, exhaust valve,
or both, primarily to reduce pumping losses, increase specific power, and
control residual gases. The GHG and fuel economy effectiveness is
unchanged from estimates used for 2016 model year vehicles in the 2012-
2016 final rule. The cost has changed only in that learning effects have
continued to decrease piece costs.
• Discrete variable valve lift - increases efficiency by optimizing air flow
over a broader range of engine operation which reduces pumping losses.
Accomplished by controlled switching between two or more cam profile
lobe heights. The GHG and fuel economy effectiveness is unchanged from
estimates used for 2016 model year vehicles in the 2012-2016 final rule.
The cost has changed only in that learning effects have continued to
decrease piece costs.
• Continuous variable valve lift - is an electromechanical or electrohydraulic
system in which valve timing is changed as lift height is
controlled.34'35'36'37 This yields a wide range of performance optimization
and volumetric efficiency, including enabling the engine to be valve
throttled. The GHG and fuel economy effectiveness is unchanged from
estimates used for 2016 model year vehicles in the 2012-2016 final rule.
The cost has changed only in that learning effects have continued to
decrease piece costs.
• Stoichiometric gasoline direct-injection technology - injects fuel at high
pressure directly into the combustion chamber to improve cooling of the
air/fuel charge within the cylinder, which allows for higher compression
ratios and increased thermodynamic efficiency. The GHG and fuel
economy effectiveness is unchanged from estimates used for 2016 model
year vehicles in the 2012-2016 final rule. The costs for this technology
differ from those used in the 2012-2016 light-duty rule (refer to Table 3.2-
1).
• Turbocharging and downsizing - increases the available airflow and
specific power level, allowing a reduced engine size while maintaining
performance. Engines of this type use gasoline direct injection (GDI) and
dual cam phasing. This reduces pumping losses at lighter loads in
comparison to a larger engine. The GHG and fuel economy effectiveness
changed from estimates used for 2016 model year vehicles in the 2012-
2016 final rule. The current estimates reflect engines that are now entering
the light-duty vehicle market38 or are under advanced development.39'40'41
We now estimate an effectiveness of approximately 15% relative to a 2008
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baseline engine technology. The costs for this technology also differ from
those used in the 2012-2016 light-duty rule (refer to Table 3.2-1).
• Turbocharging and downsizing with cooled exhaust-gas recirculation
(EGR) - additional charge dilution reduces the incidence of knocking
combustion and obviates the need for fuel enrichment at high engine
power. This allows for higher boost pressure and/or compression ratio and
further reduction in engine displacement and both pumping and friction
losses while maintaining performance. Engines of this type use GDI and
both dual cam phasing and discrete variable valve lift. The EGR systems
considered in this assessment would use a dual-loop system with both high
and low pressure EGR loops and dual EGR coolers. The engines would
also use single-stage, variable geometry turbocharging with higher intake
boost pressure available across a broader range of engine operation than
conventional turbocharged SI engines. Such a system is estimated to be
capable of an additional 5% effectiveness relative to a turbocharged,
downsized GDI engine without cooled-EGR.39'42'43 The agencies are also
considering a more advanced version of such a cooled EGR system that
would employ very high combustion pressures by using dual stage
turbocharging. The agencies have at our disposal only very preliminary
effectiveness estimates for this approach as modeling efforts are ongoing
via vehicle simulation modeling by Ricardo Engineering. The simulation
modeling is similar to work that Ricardo conducted for EPA for its 2008
staff report on GHG effectiveness of light-duty vehicle technologies.44 The
agencies will reconsider this more advanced cooled EGR approach in the
upcoming NPRM when the Ricardo simulation work should be complete.
The costs for the cooled EGR system considered in this assessment (i.e.,
single stage turbocharging) are presented in Appendix B.
• Diesel engines - have several characteristics that give superior fuel
efficiency, including reduced pumping losses due to lack of (or greatly
reduced) throttling, and a combustion cycle that operates at a higher
compression ratio and with a very lean air/fuel mixture relative to an
equivalent-performance gasoline engine. This technology requires
additional enablers, such as a NOx adsorption catalyst system or a
urea/ammonia selective catalytic reduction system for control of NOx
emissions during lean (excess air) operation. For purposes of this current
assessment, we have not included advanced diesel engines in our modeling
scenarios. During our meetings with the automotive companies, a few
companies did indicate that diesel technology would represent a
meaningful portion of their future product offerings in the US, and these
companies commented that there are opportunities for improving the fuel
economy/reducing CC>2 from diesel in the 2017 to 2025 time frame which
they are pursuing. For today's assessment, the three agencies did not have
sufficient time to further investigate these potential improvements for
diesels, both the improvements in effectiveness and the potential costs
associated with those improvements. Therefore, we did not include diesel
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engines in our modeling assessment presented in Chapter 6. This does not
mean that the agencies do not see a role for diesels in the future fleet since
we fully expect some manufacturers will rely on diesels as part of their
future strategy. We intend to continue to work on this area of our
assessment and expect to perform additional evaluations in the future
regarding diesel engine technology.
3.4.2 Types of transmission technologies considered include:
• Improved automatic transmission controls - optimizes shift schedule to
maximize fuel efficiency under wide ranging conditions, and minimizes
losses associated with torque converter slip through lock-up or modulation.
The GHG and fuel economy effectiveness is unchanged from estimates
used for 2016 model year vehicles in the 2012-2016 final rule. The cost has
changed only in that learning effects have continued to decrease piece
costs.
• Six-, seven-, and eight-speed automatic transmissions - the gear ratio
spacing and transmission ratio are optimized to enable the engine to
operate in a more efficient operating range over a broader range of vehicle
operating conditions. While a six speed transmission application was most
prevalent for the 2012-2016 final rule, eight speed transmissions are
expected to be readily available and applied in the 2017 through 2025
timeframe. We applied the six speed transmission GHG and fuel economy
effectiveness estimates used from 2016 model year vehicles in the 2012-
2016 final rule. We plan to conduct further analysis to determine the
effectiveness of increasing the number of available gear ratios beyond six
speeds and increasing the ratio spread prior to the 2017-2025 notice of
proposed rulemaking. The costs for a 6-speed automatic transmission
differ from those used in the 2012-2016 light-duty rule (refer to Table 3.2-
1). The agencies have estimated new costs for an 8-speed automatic
transmission, which are presented in Appendix B.
• Dual clutch or automated shift manual transmissions - are similar to
manual transmissions, but the vehicle controls shifting and launch
functions. A dual-clutch automated shift manual transmission uses
separate clutches for even-numbered and odd-numbered gears, so the next
expected gear is pre-selected, which allows for faster and smoother
shifting. The 2012-2016 final rule limited DCT applications to a maximum
of 6-speeds. We applied the GHG and fuel economy effectiveness
estimates used from 2016 model year vehicles in the 2012-2016 final rule.
We plan to conduct further analysis to determine the effectiveness of
increasing the number of available gear ratios beyond six speed and
increasing the ratio spread prior to the 2017-2025 notice of proposed
rulemaking. The costs for a DCT differ from those used in the 2012-2016
light-duty rule (refer to Table 3.2-1).
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• Continuously variable transmission - commonly uses V-shaped pulleys
connected by a metal belt rather than gears to provide ratios for operation.
Unlike manual and automatic transmissions with fixed transmission ratios,
continuously variable transmissions can provide fully variable and an
infinite number of transmission ratios that enable the engine to operate in a
more efficient operating range over a broader range of vehicle operating
conditions. CVTs have not been considered in this assessment.
• Manual 6-speed transmission -offers an additional gear ratio, often with a
higher overdrive gear ratio, than a 5-speed manual transmission. The GHG
and fuel economy effectiveness is unchanged from estimates used for 2016
model year vehicles in the 2012-2016 final rule. The cost has changed only
in that learning effects have continued to decrease piece costs.
3.4.3 Types of vehicle technologies considered include:
• Low-rolling-resistance tires - have characteristics that reduce frictional
losses associated with the energy dissipated in the deformation of the tires
under load, thereby improving fuel economy and reducing CO2 emissions.
The costs and GHG and fuel economy effectiveness is unchanged from
estimates used for 2016 model year vehicles in the 2012-2016 final rule.
This is conservative as reducing rolling resistance in tires is something that
can likely continue to improve. The agencies may consider adding a
second level of improvement in tire rolling resistance for the upcoming
NPRM.
• Low-drag brakes - reduce the sliding friction of disc brake pads on rotors
when the brakes are not engaged because the brake pads are pulled away
from the rotors. The costs and GHG and fuel economy effectiveness is
unchanged from estimates used for 2016 model year vehicles in the 2012-
2016 final rule.
• Front or secondary axle disconnect for four-wheel drive systems - provides
a torque distribution disconnect between front and rear axles when torque
is not required for the non-driving axle. This results in the reduction of
associated parasitic energy losses. The costs and GHG and fuel economy
effectiveness is unchanged from estimates used for 2016 model year
vehicles in the 2012-2016 final rule.
• Aerodynamic drag reduction - This can be achieved via two approaches,
either reducing the drag coefficients or reducing vehicle frontal area. To
reduce drag coefficients, skirts, air dams, underbody covers, and more
aerodynamic side view mirrors can be applied. In addition to the standard
aerodynamic treatments, the agencies have included a second level of
aerodynamic technologies which could include active grille shutters, rear
visors, and larger under body panels. The GHG and fuel economy
effectiveness is unchanged from estimates used for 2016 model year
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vehicles in the 2012-2016 final rule. This second level of aerodynamic
technologies was not considered in the 2012-2016 light-duty rule and, as
such, the estimated costs are new and are presented in Appendix B.
• Mass Reduction - Already mentioned above.
Types of electrification/accessory and hybrid technologies considered include:
• Electric power steering (EPS)/ Electro-hydraulic power steering (EHPS) -
is an electrically-assisted steering system that has advantages over
traditional hydraulic power steering because it replaces a continuously
operated hydraulic pump, thereby reducing parasitic losses from the
accessory drive. Manufacturers have informed the agencies that full EPS
systems are being developed for all light-duty vehicles applications,
including large trucks. The GHG and fuel economy effectiveness is
unchanged from estimates used for 2016 model year vehicles in the 2012-
2016 final rule. The cost has changed only in that learning effects have
continued to decrease piece costs.
• Improved accessories (IACC) - may include high efficiency alternators,
electrically driven (i.e., on-demand) water pumps and cooling fans. This
excludes other electrical accessories such as electric oil pumps and
electrically driven air conditioner compressors. The GHG and fuel
economy effectiveness is unchanged from estimates used for 2016 model
year vehicles in the 2012-2016 final rule. The cost has changed only in that
learning effects have continued to decrease piece costs.
• Air Conditioner Systems - These technologies include improved hoses,
connectors and seals for leakage control. They also include improved
compressors, expansion valves, heat exchangers and the control of these
components for the purposes of improving tailpipe CO2 emissions and fuel
economy as a result of A/C use. The GHG and fuel economy
effectiveness is unchanged from estimates used for 2016 model year
vehicles in the 2012-2016 final rule. We have estimated new costs for A/C
systems which are presented in Appendix D.
• 12-volt micro-hybrid (MHEV) - also known as idle-stop or start-stop and
commonly implemented as a 12-volt belt-driven integrated starter-
generator, is the most basic hybrid system that facilitates idle-stop
capability. Along with other enablers, this system replaces a common
alternator with a belt-driven enhanced power starter-alternator, and a
revised accessory drive system. These systems incorporate an additional
battery, ELDC or other subsystems to prevent voltage-droop on restart, one
of the shortcomings of previous 12V micro-hybrid sytems relative to
higher voltage systems. Such a system is estimated to be capable of
roughly 1.5% to 2.5% effectiveness. The cost has changed only in that
learning effects have continued to decrease piece costs.
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• Higher Voltage Stop-Start/Belt Integrated Starter Generator (BISG) -
provides idle-stop capability and uses a higher voltage battery with
increased energy capacity over typical automotive batteries. The higher
system voltage allows the use of a smaller, more powerful electric motor.
This system replaces a standard alternator with an enhanced power, higher
voltage, higher efficiency starter-alternator, that is belt driven and that can
recover braking energy while the vehicle slows down (regenerative
braking). The GHG and fuel economy effectiveness is unchanged from
estimates used for 2016 model year vehicles in the 2012-2016 final rule.
The cost has changed only in that learning effects have continued to
decrease piece costs.
• Integrated Motor Assist (IMA)/Crank integrated starter generator (CISG) -
provides idle-stop capability and uses a high voltage battery with increased
energy capacity over typical automotive batteries. The higher system
voltage allows the use of a smaller, more powerful electric motor and
reduces the weight of the wiring harness. This system replaces a standard
alternator with an enhanced power, higher voltage, higher efficiency
starter-alternator that is crankshaft mounted and can recover braking
energy while the vehicle slows down (regenerative braking). The GHG and
fuel economy effectiveness is unchanged from estimates used for 2016
model year vehicles in the 2012-2016 final rule. The cost has changed only
in that learning effects have continued to decrease piece costs.
• P2 Hybrid - A newly emerging hybrid technology that uses a transmission
integrated electric motor placed between the engine and a gearbox or CVT,
much like the IMA system described above except with a wet or dry
separation clutch which is used to decouple the motor/transmission from
the engine. In addition, a P2 Hybrid would typically be equipped with a
larger electric machine. Engaging the clutch allows all-electric operation
and more efficient brake-energy recovery. Disengaging the clutch allows
efficient coupling of the engine and electric motor and, when combined
with a DCT transmission, reduces gear-train losses relative to PSHEV or
2MHEV systems. This technology was not included in the 2012-2016
GHG and CAFE rulemaking technical analysis. We have estimated new
costs for this technology which are presented in Appendix B.
• 2-mode hybrid (2MHEV) - is a hybrid electric drive system that uses an
adaptation of a conventional stepped-ratio automatic transmission by
replacing some of the transmission clutches with two electric motors that
control the ratio of engine speed to vehicle speed, while clutches allow the
motors to be bypassed. This improves both the transmission torque
capacity for heavy-duty applications and reduces fuel consumption and
CO2 emissions at highway speeds relative to other types of hybrid electric
drive systems. The GHG and fuel economy effectiveness is unchanged
from estimates used for 2016 model year vehicles in the 2012-2016 final
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rule. We have estimated new costs for this technology which are presented
in Appendix B.
• Power-split hybrid (PSHEV) - a hybrid electric drive system that replaces
the traditional transmission with a single planetary gearset and a
motor/generator. This motor/generator uses the engine to either charge the
battery or supply additional power to the drive motor. A second, more
powerful motor/generator is permanently connected to the vehicle's final
drive and always turns with the wheels. The planetary gear splits engine
power between the first motor/generator and the drive motor to either
charge the battery or supply power to the wheels. Power-split hybrids have
not been considered in this assessment.
• Plug-in hybrid electric vehicles (PHEV) - are hybrid electric vehicles with
the means to charge their battery packs from an outside source of
electricity (usually the electric grid). These vehicles have larger battery
packs with more energy storage and a greater capability to be discharged
than other hybrid electric vehicles. They also use a control system that
allows the battery pack to be substantially depleted under electric-only or
blended mechanical/electric operation and batteries that can be cycled in
charge sustaining operation at a lower state of charge than is typical of
other hybrid electric vehicles. The GHG and fuel economy effectiveness is
unchanged from estimates used for 2016 model year vehicles in the 2012-
2016 final rule. We have estimated new costs for this technology which are
presented in Appendix B along with estimates of their electricity usage per
mile. Battery costs assume that battery packs for PHEV applications will
be designed to last for the full useful life of the vehicle at a useable state of
charge equivalent to 70% of the nominal battery pack capacity.
• Electric vehicles (EV) - are vehicles with all-electric drive and with
vehicle systems powered by energy-optimized batteries charged primarily
from grid electricity. While the 2016 FRM did not anticipate a significant
penetration of EV's, in this analysis, EV's with several ranges have been
included. The GHG and fuel economy effectiveness is unchanged from
estimates used for 2016 model year vehicles in the 2012-2016 final rule.
We have estimated new costs for this technology which are presented in
Appendix B along with estimates of their electricity usage per mile.
Battery costs assume that battery packs for EV applications will be
designed to last for the full useful life of the vehicle at a useable state of
charge equivalent to 80% of the nominal battery pack capacity.
• Fuel cell electric vehicles (FCEVs) - utilize a full electric drive platform
but consume electricity generated by an on-board fuel cell and hydrogen
fuel. Fuel cells are electro-chemical devices that directly convert reactants
(hydrogen and oxygen via air) into electricity, with the potential of
achieving more than twice the efficiency of conventional internal
combustion engines. High pressure gaseous hydrogen storage tanks are
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used by most automakers for FCEVs that are currently under development.
The high pressure tanks are similar to those used for compressed gas
storage in more than 10 million CNG vehicles worldwide, except that they
are designed to operate at a higher pressure (350 bar or 700 bar vs. 250 bar
for CNG). We have estimated new costs for this technology which are
presented in Appendix B. Due to the uncertainty of the future availability
for this technology, FCEVs were not included in any OMEGA runs.
3.5 Technology Packages in OMEGA
The large number of possible technologies to consider and the breadth of vehicle
systems that are affected mean that consideration of the manufacturer's design and production
process plays a major role in assessing the ability of the US fleet to achieve various GHG
levels and fuel economy, and the costs associated with achieving those levels. Vehicle
manufacturers typically develop their many different individual vehicle models by basing
them on a limited number of vehicle platforms. Several different models of vehicles may be
produced using a common platform, allowing for efficient use of design and manufacturing
resources. The platform typically consists of common vehicle architecture and structural
components, such as the underbody, chassis and suspension. Given the very large investment
put into designing and producing each vehicle model, manufacturers cannot reasonably
redesign any given vehicle every year or even every other year, let alone redesign all of their
vehicles every year or every other year. At the redesign stage, the manufacturer will typically
upgrade or add all of the technology and make all of the other changes needed so the vehicle
model will meet the manufacturer's plans for the next several years. This includes meeting all
of the fuel economy, emissions, safety, and other requirements that would apply during the
years before the next major redesign of the vehicle. This is in contrast to what would be a
much more costly approach of trying to achieve small increments of reductions over multiple
years by adding technology to the vehicle piece by piece outside of the redesign process.
However, making all of these changes at once typically involves significant
engineering, development, manufacturing, and marketing resources to create a new product
with multiple new features. In order to leverage this significant upfront investment,
manufacturers plan vehicle redesigns with several model years' of production in mind.
That said, vehicle models are not completely static between redesigns as limited
changes are often incorporated for each model year. This interim process is called a "refresh"
of the vehicle. It generally does not allow for major technology changes although more minor
ones can be done (e.g., aerodynamic improvements, valve timing improvements), usually
aimed at improving the vehicle's market appeal. We note, though, that more major
technology upgrades that affect multiple systems of the vehicle thus occur at the vehicle
redesign stage and not in the time period between redesigns.
In determining the projected technology needed to meet the standards, and the cost of
those technologies, EPA is using an approach that accounts for and builds on this redesign
process and bundles technologies into "packages" to capture synergistic aspects and reflect
progressively larger CC>2 reductions with additions or changes to any given package. As an
input to this approach, EPA groups technologies into packages of increasing estimated cost
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and effectiveness. EPA determined that 19 different vehicle types provided adequate
resolution required to accurately model the entire fleet. We discuss the approach to
developing packages and how those packages are used in the OMEGA model in Appendix B.
For the reader's reference, we note that NHTSA's CAFE Compliance and Effects
Model (often referred to as "the Volpe model"), which NHTSA uses for CAFE rulemaking
analysis was not used for purposes of this Technical Assessment Report, also assumes
manufacturers add most technology to vehicles as part of the vehicle redesign and freshening
process. While the CAFE model considers technologies similar to those considered by EPA's
OMEGA model, the CAFE model accumulates discrete technologies incrementally, taking
into account model-estimated cost effectiveness, as well as engineering and other constraints.
While the CAFE model does not require that packages be determined exogenously, in the
analysis supporting the MYs 2012-2016 CAFE standards, the CAFE model often formed
packages similar to those included in EPA's analysis supporting the MYs 2012-2016 GHG
emissions standards. Although NHTSA is not, in today's report, presenting analysis
performed using the CAFE model, the agency will do so in support of the upcoming NPRM
for post-MY 2016 CAFE standards.
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Chapter 3 References
14 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE
Rule. EPA-420-R-10-901, April, 2010.
15
Rogozhin, A., et al, Using indirect cost multipliers to estimate the total cost of adding new technology in the
automobile industry. International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031.
16
75 FR 25324, 25382-396, May 7, 2010.
17 U.S. Environmental Protection Agency, "Light-Duty Technology Cost Analysis Pilot Study," Contract No.
EP-C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-
11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; "Light-duty
Technology Cost Analysis - Report on Additional Case Studies," EPA-HQ-OAR-2009-0472-11604
18 U.S. Environmental Protection Agency, "Light-Duty Technology Cost Analysis Pilot Study," Contract No.
EP-C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-
11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; "Light-duty
Technology Cost Analysis - Report on Additional Case Studies," EPA-HQ-OAR-2009-0472-11604
19 Nelson, P.A., Santinit, D.J., Barnes, J. "Factors Determining the Manufacturing Costs of Lithium-Ion Batteries
for PHEVs," 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24,
Stavenger, Norway, May 13-16, 2009 (www.evs24.org).
20 Santini, D.J., Gallagher, K.G., and Nelson, P.A. "Modeling of Manufacturing Costs of Lithium-Ion Batteries
for HEVs, PHEVs, and EVs," Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric
Vehicle Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010 (www.evs25.org).
Advance draft provided by D.J. Santini, Argonne National Laboratory, August 24, 2010.
21 "Hyundai ups tech ante with Sonata Hybrid," Automotive News, August 2, 2010.
22 "Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty," GM Press release
(http://media.gm. co m/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/Jul
y/0714_volt_battery)
23 "Nissan's new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6," SAE Automotive Engineering
Online, February 15, 2010.
24 "Lithium-ion Battery," Nissan Technological Development Activities (http://www.nissan-
global.com/EN/TECHNOLOGY/INTRODUCTION/DETAILS/LI-ION-EV/). 2009.
25 Lotus Engineering, Inc. "An Assessment of Mass Reduction Opportunities for a 2017 - 2020 Model Year
Vehicle Program," Published by the The International Council on Clean Transportation and available on the
Internet at http://www.theicct.org/2010/03/lightweight-future/. March 30, 2010.
26 Effectiveness and Impact of Corporate Fuel Economy Standards, NAS, 2002.
27 Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel
Economy Standard, Sierra Research, 2008.
28 The Impact of Mass Decompounding on Assessing the Value of Vehicle Lightweighting, MIT 2008.
29 Rogozhin, A., et al., Using indirect cost multipliers to estimate the total cost of adding new technology in the
automobile industry. International Journal of Production Economics (2009), doi:10.1016/j.ijpe.2009.11.031.
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30 Gloria Helfand and Todd Sherwood, "Documentation of the Development of Indirect Cost Multipliers for
Three Automotive Technologies," Office of Transportation and Air Quality, U.S. EPA, August 2009 (Docket
EPA-HQ-OAR-2009-0472).
31 Bureau of Economic Analysis, US Department of Commerce, National Income and Product Accounts Table
1.1.4; accessed via www.bea.gov on May 27, 2010.
32
See "Learning Curves in Manufacturing", L. Argote and D. Epple, Science, Volume 247; "Toward Cost Buy
down Via Learning-by-Doing for Environmental Energy Technologies, R. Williams, Princeton University,
Workshop on Learning-by-Doing in Energy Technologies, June 2003; "Industry Learning Environmental and the
Heterogeneity of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA Anderson School of
Management, December 2006, Discussion Papers, Center for Economic Studies, Washington DC.
33 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE
Rule. EPA-420-R-10-901, April, 2010; Regulatory Impact Analysis, U.S. EPA, EPA-420-R-10-009, April 2009.
34 Luttermann, C., Schunemann, E., Klauer, N. "Enhanced VALVETRONIC Technology for Meeting SULEV
Emission Requirements," SAE Technical Paper Series, No. 2006-01-0849, 2006.
35 Murphy, T. "Fiat Breathing Easy with MultiAir," Wards Auto, March 26, 2010.
36 "Fiat Multiair," SAE Automotive Engineering International, June 2009, p. 48.
37 Battistonic, M., Foschini, L., Postrioti, L., Cristiani, M. "Development of an Electro-Hydraulic Camless WA
System," SAE Technical Paper Series, No. 2007-24-0088, 2007.
38 Yi., J., Wooldridge, S., Coulson, G., Hilditch, J., Iyer, C., Moilanen, P., Papaioannou, G., Reiche, D., Shelby,
M. VanDerWege, B., Wearver, C., Xu, Z., Davis, D., Hinds, B., Schamel, A. "Development and Optimization of
the Ford 3.5L V6 EcoBoost Combustion System," SAE Technical Paper Series, No. 2009-01-1494.
39 Turner, J.W.G., Pearson, R.J., Curtis, R. Holland, B. "Sabre: a cost effective engine technology combination
for high efficiency, high performance and low CO2 emissions," Low Carbon Vehicles 2009: Institution of
Mechanical Engineers conference proceedings, May 2009.
40 Lumsden, G. OudeNijeweme, D., Fraser, N., Blaxill, H. "Development of a Turbocharged Direct Injection
Downsizing Demonstrator Engine," SAE Technical Paper Series, No. 2009-01-1503, 2009.
41 Kirwan, J.E., Shost, M., Zizelman, J. "3-Cylinder Turbocharged Gasoline Direct Injection: A High Value
Solution for Low CO2 and Low NOx Emissions," SAE Technical Paper Series, No. 2010-01-0590, 2010.
42 Kaiser, M., Krueger, U., Harris, R., Cruff, L. "Doing More with Less - The Fuel Economy Benefits of Cooled
EGR on a Direct Injected Spark Ignited Boosted Engine," SAE Technical Paper Series, No. 2010-01-0589.
43 Kapus, P.E., Fraidl, O.K., Prevedel, K., Fuerhapter, A. "GDI Turbo - The Next Steps," JSAE Technical Paper
No. 20075355, 2007.
44 "EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty
Vehicle Carbon Dioxide Emissions," EPA420-R-08-008, March 2008, Docket EPA-HQ-OAR-2009-0472-0132.
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4 Infrastructure Assessment
4.1 Overview
The May 21, 2010 Presidential Memorandum specifically requests that the EPA,
NHTSA, and CARB's joint technical assessment include an assessment of infrastructure for
advanced technology vehicles. Section 3 of the Memorandum requests the Department of
Energy (DOE) to promote the deployment of advanced technology vehicles by providing
technical assistance to cities preparing for deployment of electric vehicles, including plug-in
hybrids and electric vehicles. The Memorandum also asks DOE to work with stakeholders on
the development of voluntary standards to facilitate the robust development of advanced
vehicle technologies and coordinate these efforts with DOT/NHTSA and EPA. Because of
DOE's key role in these areas, EPA, NHTSA, and CARB have closely collaborated with DOE
in developing our assessment of infrastructure issues, and DOE contributed significantly to
this chapter.
This technical assessment report identifies electric drive vehicles as an important part
of the vehicle mix that will likely be used to meet fuel economy and GHG emission reduction
standards. Electric drive vehicles, including battery electric vehicles (EVs), plug-in hybrid
electric vehicles (PHEVs), and hydrogen-fueled fuel cell electric vehicles (FCEVs), have the
potential to dramatically improve fuel economy and reduce GHG emissions compared to
conventional technologies. Further, given their use of fuels that eventually could be derived
from entirely renewable and zero carbon resources, they have a large potential to transform
the vehicle future to a low carbon fleet and significantly reduce U.S. petroleum imports.
These technologies require new infrastructure to become a significant part of the
vehicle fleet. In the case of EVs and PHEVs, electric charging infrastructure is needed in the
form of charging stations, most often at home, but also at the workplace or other public
locations, such as parking lots or retail stores. While at present, few public charging points
are available, there are significant projects underway to deploy new electric-drive vehicle
charging infrastructure across the U.S. and to collect data to facilitate analyses of future
needs. In the case of FCEVs, hydrogen fueling stations analogous to gasoline stations are
needed to support commercialization.
DOE has begun efforts to support a shift to electric-drive vehicles by coupling a long
history of advanced vehicle research and development with more recent efforts to develop a
holistic view of electric-vehicle infrastructure by compiling internal expertise, seeking input
from outside experts and stakeholders and identifying areas where further investigation is
needed. These combined efforts indicate that most electric vehicle owners will charge at
home using equipment they pay to install and electricity from a grid that utility providers are
capable of upgrading, where necessary, to meet charge demand. It is expected that 97 to 99%
of charging energy will be delivered at home.45 Home charging capability is not seen as a
hurdle to electric vehicles in the near future. However, driver demand for and interaction with
public infrastructure is not as well understood, so several DOE-supported projects will deploy
public charging stations and collect data to inform an analyses of the role that public
infrastructure will play nationally. These projects are currently underway and will be
completed within the next 3-4 years. Additionally, DOE is coordinating government
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interaction with cities to share best practices. DOE is further coordinating with both national
and international organizations, and with other federal agencies, to ensure that the
development of codes and voluntary standards for electric-vehicles and support infrastructure
happens as smoothly and quickly as possible.
This chapter provides an assessment of both electric charging infrastructure needed to
support electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs) and the
hydrogen infrastructure needed to support fuel cell electric vehicles (FCEVs). The electric
vehicle infrastructure section summarizes current activities to demonstrate and deploy electric
recharging infrastructure, the current availability and future potential of home recharging, the
costs of charging systems, the potential impacts on the electric grid and distribution network,
and government cooperation in developing voluntary codes and standards. The hydrogen
infrastructure section discusses the current status of hydrogen fueling stations, the costs of
hydrogen and refueling stations, prospects for cost and technology improvement, a strategy
for how a hydrogen infrastructure could roll out to support fuel cell vehicle introductions, and
potential policies and public/private partnerships that could further facilitate infrastructure
development.
4.2 Electric Vehicle Infrastructure
A shift from petroleum-powered to electric-drive vehicles will involve a parallel shift
in refueling: Where gasoline and diesel fuel vehicles refill at a gas station, electric-drive
vehicles recharge at a charging station. Three charging levels are currently under
consideration.46 Level 1 charging uses a standard 120 volt (V), 15-20 amps (A) rated (12-16
A usable) circuit and is available in standard residential and commercial buildings. Level 2
charging uses a single phase, 240 V, 20-80 A circuit and allows much shorter charge times.
Level 3 charging—sometimes colloquially called "quick" or "fast" charging—uses a 480 V,
three-phase circuit, available in mainly industrial areas, typically providing 60-150 kW of off-
board charging power.
This electric vehicle infrastructure section summarizes current activities to
demonstrate and deploy electric recharging infrastructure, the current availability of home
recharging, the cost of electric vehicle support equipment (EVSE), the potential impacts on
the electric grid and distribution network, and government cooperation in developing
industry-recognized electric vehicle support equipment standards.
4.2.1 DOE Charging Infrastructure Proj ects Underway
The Department of Energy (DOE) recognizes the importance of the variety of factors
that will contribute to the success of grid-connected vehicles and is currently undertaking
numerous activities to study and address them. Through the American Recovery and
Reinvestment Act of 2009 (ARRA), DOE has awarded cost-shared grants to companies under
the Transportation Electrification Initiative to establish development, demonstration,
evaluation, and education projects to accelerate the market introduction and penetration of
advanced electric drive vehicles. The Transportation Electrification Initiative, its component
projects, and other DOE electric-drive vehicle infrastructure activities are discussed below.
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4.2.1.1 American Recovery and Reinvestment Act: Transportation Electrification
Initiative
Funded through the ARRA, the Transportation Electrification Initiative provides
approximately $400 million in federal funding, leveraged through cost-shared grants with
industry and educational institutions, to develop, demonstrate, and evaluate electric drive
vehicles and charging infrastructure. Through the projects funded under this activity, over
13,000 electric-drive vehicles will be deployed in conjunction with nearly 23,000 charging
stations, starting in 2010 and to be completed in the next 3-4 years, in residential, commercial,
and public locations, in numerous and diverse geographic locations nationwide.
The majority of the vehicles deployed through Transportation Electrification projects
will be privately-owned light-duty vehicles; however, many medium-duty trucks
incorporating advanced electric and plug-in hybrid electric powertrains will be developed and
demonstrated in a wide range of geographic, climatic, and operating environments.
Additionally, the vast majority of electric vehicle charging infrastructure deployed through
these projects will be Level 2 (220V), 3.3-6.6 kW charging stations, though several hundred
Level 3 DC "fast" chargers will also be deployed along corridors linking cities within
deployment areas. For privately-owned vehicles and commercial fleet vehicles, Level 2
chargers will be installed at the vehicle owners' residences or the central fleet parking area,
where the vehicles will most likely be domiciled for overnight charging. Many more Level 2
charging stations will be deployed in commercial and public locations, which may provide
vehicle owners the opportunity to travel in expanded geographic areas without the "range
anxiety" that could otherwise limit electric vehicles' utility. The effect of charging station
availability (Level 1, 2 and 3) on driver behavior will be studied as part of this initiative.
Some researchers believe the duration of a driver's experience with an EV has more to do
with reducing range anxiety than public charging, and that public charging may reduce
"purchase anxiety" instead.47
The coordinated deployment of electric drive vehicles and charging infrastructure
under the Transportation Electrification Initiative will facilitate DOE's collection and analysis
of a comprehensive set of data from both the vehicles and the charging stations.u Vehicle
data collected will include parameters such as vehicle miles driven, battery state-of-charge,
GPS location, and, in the case of PHEVs and FCEVs, the liquid fuel consumption.
Infrastructure data collected will include parameters such as charger connect/disconnect
times, charge event start/stop times, average and peak power delivered, and total energy
delivered per charge event. Evaluation of this data, managed by Idaho National Laboratory,
will provide critical information regarding the influences on vehicle and charging
infrastructure use, performance, and location suitability. These data collection and analysis
activities will identify how consumers use electric drive vehicles; where, when, and how
frequently they charge the vehicles; how usage and charging behavior impact the performance
of the vehicle; what the impacts are to the electric grid; how consumers respond to pricing
signals with respect to vehicle charging; and a myriad of other questions related to consumer
u A condition of participating in the program will be that participants agree to data collection.
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acceptance and market viability of grid-connected vehicles. After the projects are completed
in the 2013-2014 timeframe, this information will then be used to guide the much broader
deployment of electric drive vehicles and charging infrastructure in the future.
A summary of infrastructure-related projects funded through the Transportation
Electrification Initiative follows in Table 4.2-1, which shows, for each project: the number of
charging stations and electric vehicles to be deployed, the targeted locations and timeframe
for deployment and data collection, and the intended benefit of the data to be collected.
Additional information about each of these projects is in Appendix G.
Table 4.2-1 ARRA Transportation Electrification Initiative and Clean Cities Projects
Summary
Project
ECOtality
North
America
($115M)
Coulomb
Technologies
($15M)
Navistar
($39M)
General
Motors
($30M)
Smith
Electric
Vehicles
($32M)
South Coast
Air Quality
Management
District
($45M)
Level 2
Charging
Stations
Deployed
14,850
(and 320
Level 3)
5,000
950
650
500
378
Vehicles
8,500
light-
duty cars
2,600
light-
duty cars
950
medium-
duty
trucks
125 light-
duty cars
500
medium-
duty
trucks
378
medium-
duty
trucks
and
shuttle
Location
AZ, CA, DC,
OR, TN, TX
CA, DC, FL, MI,
NY, TX, WA
CA
CA, FL, MI, NY,
NC, SC, TX,
VA, DC
CA, GA, MO,
NJ, NY, OH,
OR, TX, DC
CA, CT, GA, HI,
KY, LA, MD,
MI, MO, NJ,
NY, OH, OR,
PA, TN, TX, WI,
DC
Time-
frame'1
2010-
2013
2010-
2014
2010-
2013
2010-
2013
2011-
2013
2010-
2013
Data Collected
operational and
charging behavior of
electric-drive vehicle
owners
operational and
charging behavior of
electric-drive vehicle
owners
performance and
suitability of medium-
duty electric vehicles
and support
infrastructure required
light-duty vehicle
usage and operational
needs, supporting
vehicle design and
infrastructure planning
applicability of
electric-drive
powertrains in
vocational medium-
duty trucks
PHEV technologies
for Class 4/5 vehicles
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Chrysler
Group LLC
($48M)
Clean Cities
($115M)
153
500-550
buses
153 light-
duty
trucks
100 light-
duty and
280
heavy-
duty
vehicles
AZ, CA, CO, HI,
MA, MI, MO,
NV, NY, ND,
TX
CT, IL, MI, MO,
NC, NY, OH,
TX, UT, WA,
WI
2011-
2013
2010-
2011
real -world product
viability and
quantified benefits
charging station usage
a Timeframe is approximate. More details about all Transportation Electrification Initiatives are found in
Appendix G.
Smart Grid
The ARRA authorizes DOE's Office of Electricity to administer the Smart Grid
Investment Grant (SGIG), which supports projects to update today's electric grid to a "smart
grid"—a modernized electric grid utilizing real-time two-way communication for improved
reliability, efficiency, security, and safety and the possibility of dynamic pricing and even
vehicle-to-grid energy exchange (in which a charged vehicle battery provides energy to the
grid). As part of the projects supported with these grants, 12 awardees plan to deploy
approximately 100 charging stations. Additionally, under DOE's Smart Grid Regional
Demonstrations, electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs) are part
of several smart grid technology demonstrations projects. In most of the regional
demonstration projects, grid-connected vehicles are integrated in broader smart grid
technology deployment activities. Because EV/PHEVs are a relatively nascent technology,
their contribution to the overall smart grid technology deployment and regional demonstration
activities is likely to be small, particularly in the early years of the multi-year deployment and
demonstration programs.
4.2.1.2 Other Projects
Through its national laboratories, DOE also supports other various projects aimed at
overcoming barriers related to electric drive vehicles and their interaction with the electric
grid. These projects target the development of codes and standards that govern the vehicle-
grid interface, including communications between the vehicle, the charging infrastructure, and
the electric grid. Additional projects are intended to streamline the process of deploying
electric vehicle charging infrastructure and minimize the impact on electricity generation,
transmission, and distribution resources. Together, activities conducted through the national
laboratories will help speed the wide-spread adoption of electric drive transportation
technologies.
Many stakeholders have expressed the need for timely and standardized local
permitting procedures for installing electrical vehicle supply equipment. The National
Electric Vehicle Infrastructure Permitting Project at the National Renewable Energy Lab
(NREL) seeks to standardize local permitting procedures to speed the deployment of EVSE
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across the U.S. NREL has drafted a National Electric Vehicle Charging Station Permit
template,48 which conforms to Article 625 of the National Electric Code, and is engaging
select cities to promote the use of this permit to streamline the process of installing electric
vehicle supply equipment. This draft permit is intended to establish a mechanism for local
jurisdictions to provide a simplified approval process for the installation and operation of
electric vehicle charging equipment, rather than the existing wide variety of permitting
procedures that currently exist at the local level. Adoption of the draft permit could reduce
the typical administrative delays that might otherwise impede the deployment of charging
infrastructure and slow the market adoption of grid-connected vehicles. This draft permit was
created with input from industry and electrical contractors, and will allow electric vehicle
charging stations to be installed quickly and safely in the municipalities where the process is
adopted. Other organizations have published similar documents: Pacific Gas & Electric's
(PG&E) released an "Electric Vehicle Infrastructure Installation Guide" in 1999,49 and the
Electric Power Research Institute (EPRI) published "Plug-in Electric Vehicle Infrastructure
Installation Guidelines" in 2009.50
4.2.2 Home Charging Adequacy
Charging availability affects consumer value and the development of the EV/PHEV
market.51'52 Understanding the number of American consumers who can plug-in a vehicle at
home is instructive in estimating the number of who might choose to own an electric drive
vehicle. More charging points enable more potential EV/PHEV buyers, but the role of an
additional charging point depends on whether it is attached to a home, a workplace or a public
place. A home charging point may enable a new EV/PHEV buyer, while a workplace charge
point may make the prospective car buyer who already has home charging availability more
determined to own a PHEV or EV. Availability of adequate home recharging will likely have
the most impact on deployment, because home is usually where a vehicle parks the most often
and longest, resulting in more recharging energy and fuel-saving benefit. Based on past
experience, 97%-99% of charging energy is delivered at home.53 Even with available
workplace or public charging, consumers will probably feel it is more convenient and less
stressful to charge at home. Surveys show that consumers state stronger preferences for home
recharging.54 Other surveys show that EV users with home recharging rarely use public
recharging55 and some PHEV users choose not to use available public recharging during
weekdays because of the inconvenience they perceive.56
There may be opportunities for supplemental charging outside the home. Public
charging stations with Level 2 or Level 3 charging, possibly offered by restaurants,
supermarkets, gyms, or health centers, can extend the electric range in an equivalent sense,
which may be especially important for a EV driver in an unexpected long distance trip. The
ability of a charging point to extend the electric range depends on both the length of available
charging time and the charging speed. Higher charging speed may be more necessary in
public places where consumers usually do not park their vehicles as long as at home or the
workplace. But for consumers with home charging and typical driving patterns, topping off
partially a depleted battery can be more desirable than recharging a fully depleted one, which
reduces the need for high charging speed. For home or workplace charging, the usual long
parking time makes expensive upgrades to faster charging less necessary, especially for
PHEVs with a small battery.
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As described above, three charging levels are currently under consideration.57 Level 1
charging uses a standard 120 V, 15-20 amps (A) rated (12-16 A usable) circuit and is
available in standard residential and commercial buildings. Level 1 charging for 7-9 hours of
home nighttime is sufficient to fully charge a small PHEV20.V'W Level 2 charging uses a 240
V, 20-80 A circuit, enabling a much shorter charge time. With Level 2 charging, a full
recharge requires less than 4 hours for a PHEV40 SUV and about half hour for a PHEV10
small car. Level 3 charging uses a 480 V, three-phase circuit, typically providing 60-150 kW
of off-board charging power. Level 3 charging for PHEVs is probably not necessary due to
small battery capacity and the vehicles' internal combustion engine range extended design.
For this reason, it is not envisioned that manufacturers will equip all PHEVs with capability
for accepting Level 3 charging. In addition, due to the relatively small battery when
compared to an EV, battery charge can be completed at home or workplace where vehicle
parking duration is normally long. High cost, lack of 3-phase power, and potential safety
concerns also make Level 3 implementation in these places unlikely, at least for the near term.
Nevertheless, Level 3 charging may be more beneficial to EV owners who lack the
hybrid-drive backup of a PHEV. An EV midsize car with 150-mile driving range will likely
require more than 10 hours of Level 2 charging to reach a full recharge, but only 2-3 hours
with Level 3 charging. Fast-charging an EV with 100-mile driving range can provide 80
miles of urban-driving range in less than 30 minutes.58 In commercial places where drivers
park and conduct personal or business activities, 1-2 hours of Level 3 charging is sufficient to
"V SQ
provide an 80% recharge ' for most EVs.
Level 1 charging may prove to be appropriate for a significant fraction of the initial
EV market. Tesla has reported that, based on their experience, there is potential for
approximately 25% of the 244-mile range Tesla Roadster EV to make use of Level 1
charging.60 It may also be more appropriate to consider average charge times that correspond
to normal daily use instead of what is required for the exceptional circumstance to charge a
fully depleted EV. At the national average of 28 miles of driving per day, a small EV would
only require ~7 kWh to charge. This would require less than 5 hours with a standard Level 1
cordset. An important feature available on many Level 1 cordsets or grid-connected vehicles
is the ability for the user to select a lower-than-usual charge rate so that users may make use
of lower-capacity, non-dedicated Level 1 circuits until a dedicated circuit is installed.
v For the purposes of estimating charging times, it is assumed that a small EV consumes -200 AC Wh/mile,
mid-size EV or PHEV is 300 AC Wh/mile, and larger PHEV SUV is 350 AC Wh/mile; Level 1 charging power
is assumed to be 1.44 kW nominal; Level 2 is 3.3 kW nominal on 20 A rated circuits (208 x 16); and Level 2
charging is 6.6 kW nominal on 40 A circuits (208 x 32).
w A PHEV20 is a PHEV with a 20-mile charge-depleting range, or, the range of battery operation over which
energy is consumed from the battery at a greater rate than it is recharged through regenerative breaking. Once
the battery is sufficiently depleted, the vehicle operates in charge sustaining mode, during which time the energy
captured through regenerative breaking is roughly equivalent to the rate of battery energy consumption; this
mode is identical to the operation of a grid-independent HEV. The nomenclature is analogous for PHEV with
larger (e.g., PHEV40 has a 40-mile charge-depleting range) or smaller (PHEV10 has a 10-mile charge-depleting
range) batteries.
x OEMs have indicated that fast charging is expected to replace 80% of max state-of-charge
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Currently, there are approximately 1,000 charging stations in the United States.61
Most of these stations allow public access, while the rest are restricted for workplace use.
Home charging, which is not included in this count, is considered more important for
EV/PHEV market success,62 which is understandable since home is where a vehicle parks the
most often and longest.
Although there is not clear data indicating home charging capacity, two indicators of
charging readiness are the availability of a garage or carport, where the electric circuit is
usually equipped, and the proximity of an electrical outlet. Having a garage or carport does
not necessarily mean charging readiness, as a garage may lack parking functionality.Y For
example, garages in old homes can be too small to hold today's large vehicles, forcing the
owners to park their vehicles on the driveway, and some garages may mainly be used for non-
parking purposes. One alternative measurement of home charging readiness is the availability
of an electric outlet where the vehicle is usually parked when arriving home. According to a
survey conducted by University of California, Davis (UCD),63'64 61%, 52%, 44%, and 36% of
the U.S. new vehicle buying households have an electric outlet within 50, 25, 15, and 10 feet,
respectively, from the home parking location.2 These percentages are slightly lower than the
garage ownership share in the American Housing Survey or the share of detached single
house in the 2001 National Household Travel Survey data.
The home charging availability for a specific consumer will need to be differentiated
among EV/PHEVs with different battery capacity. The electric outlets in existing homes are
most likely ready for Level 1 charging, which is about sufficient for fully recharging a
PHEV20 SUV during normal nighttime, provided the outlet is not being heavily utilized by
other loads. Shorter available charging time or owning a vehicle with a larger battery make
the capability to fully charge overnight with a Level 1 system less likely, but upgrading to a
Level 2 system in such cases will allow full recharge to happen more quickly.
The DOE-supported infrastructure projects described above in section 4.2.1 will
collect data that significantly improve the understanding of how consumers interact with
electric-vehicle support infrastructure. With respect to the availability of home charging,
these data collection and analysis activities will identify how consumers use electric drive
vehicles and infrastructure and how consumers respond to pricing signals with respect to
vehicle charging as well as a myriad of other questions related to consumer acceptance and
market viability, which can eventually be used to guide the much broader deployment of
electric drive vehicles and charging infrastructure in the future.
Y Based on the 2001 National Household Travel Survey (NHTS), 63.8% of the U.S. households live in detached
single houses. According to the American Housing Survey (AHS), 62.5% of homes in the U.S., regardless of
home type, include a garage or carport. The share is a little higher (65.4%) for year-round occupied homes, much
lower (45.1%) for vacant homes and much higher (81.5%) for new constructions up to 4 years old. The closeness
between the share of detached single houses from the 2001 NHTS data and the share of garage ownership from
the AHS data should not be interpreted as that the form of detached single house is an equivalent indicator of
garage ownership. The estimation closeness is more likely a coincidence, since not all detached houses include a
garage or carport, and some homes with a garage or carport are attached homes.
z These estimates are based on the one-day 24-hour travel diary completed by respondents from 2,373 U.S.
households that represent U.S. new vehicle buying households.
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4.2.3 Charging System Cost
Charging an electric vehicle or plug-in hybrid will generally require specialized
equipment, including:
A charger that converts electricity from alternating current (AC) from the electricity
source to direct current (DC) required for the battery, and also converts the incoming 120 or
240 volt current to 300 or higher volts. Grid-connected vehicles carry an on-board charger
capable of accepting AC current from a wall plug (Level 1 circuit) or, from a Level 2
charging station. On-board charger power capability ranges from 1.4 to 10 kW and is usually
proportional to the vehicle's battery capacity.^ The lowest charging power,BB 1.4 kW, is
expected only when grid-connected vehicles are connected to 120 volt (Level 1) outlets, and
all currently known PHEV and EV on-board chargers are expected to provide at least 3.3 kW
charging when connected to a Level 2 (220 volt, 20+ A) charging station. The latest SAE
connection recommended practice, J1772, allows for delivery of up to -19 kW to an on-board
vehicle charger. For higher capacity charging, a charging station that delivers DC current to
the vehicle is incorporated off-board in the wall or pedestal mounted.
The charging station needed to safely deliver energy from the electric circuit to the
vehicle, called electric vehicle support equipment (EVSE). The EVSE may at a minimum, be
a specialized cordset that connects a household Level 1/120V socket to the vehicle; otherwise,
the EVSE will include a cordset and a charging station (a wall or pedestal mounted box
incorporating a charger and other equipment). Charging stations may include advanced
features such as timers to delay charging until off-peak hours, communications equipment to
allow the utility to regulate charging, or even electricity metering capabilities. Stakeholders
are working on which features are best located on the EVSE or on the vehicle itself, and it is
possible that redundant capabilities and features may be present in both the vehicle and
EVSEs in the near future until these issues are worked out. EVSE and vehicle manufacturers
are also working to ensure that current SAE-compliant "basic" EVSEs are charge-compatible
with future grid-connected vehicles.
Some public charging stations will likely include fee collection equipment or will be
networked with nearby fee-collection equipment already in use for parking fee collection.
Under some local regulations, owners of charging stations cannot resell electricity;00 unless
the utility itself owns the stations or can directly bill the vehicle owner, the station owner can
only charge a flat or time-based fee to the vehicle driver. This may require credit/debit card
readers, pay-to-park kiosks or standard parking meters (in a commercial parking lot, kiosks or
meters could already be available, so no additional equipment may be needed), or radio-
frequency ID cards linked to a subscription service. For the utility to directly bill the vehicle
^ Current mini-e's and Tesla Roadsters presently have 11-19 kW on-board charger capability, though such high
on-board power levels are not expected to be common in the majority of upcoming EV/PHEVs.
BB Some EVs will have an 840W charge setting to allow for a shared Level 1 circuit
cc One exception is provided by the California Public Utilities Commission; it concluded in July 2010 that
companies that sell electric vehicle charging services to the public will not be regulated as public utilities.
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owner, the charging station or vehicle must include a communication link to the utility that
will identify the vehicle or owner.
An electric circuit located close to where the vehicle parks. A Level 1 circuit is
standard household current, 120V AC, rated at 15 or 20 A (12 or 16 A usable). A Level 2
circuit is rated at 208 to 240V and up to 80 A and is similar to the type of circuit that powers
electric stoves (up to 50 A) and dryers (usually 30 A). Generally, level 1 and 2 circuits used
for electric vehicle recharging must be dedicated circuits,DD i.e., there cannot be other
appliances on that circuit. For a Level 2 circuit, the homeowner or other user must install a
charging station and will need a permit.
Optionally, separate metering (EUMD, end use measuring device) for the EV charger
to allow time-of-day rates for EV recharging; otherwise, homeowners may choose to pay
standard rates for EV charging or to have all household electricity on time-of-day rates, either
option with a single meter.
Protection for the charging stations, including wheel stops, protective bollards, etc.
Where vandalism is a concern, additional costs may be incurred for fencing or security
equipment.
In addition to the costs of purchasing and installing charging equipment, charging
station installation may include the costs of upgrading existing electrical panels and installing
the electrical connection from the panel to the desired station location. These costs may be
dramatically lowered if new construction incorporates the panel box and wiring required for
charging stations, or even includes charging stations or outlets for charging stations as
standard equipment.
In addition to Level 1 and 2 charging stations, "Level 3" commercial recharging
stations may be installed in areas where 3-phase power is available; these can deliver 300V-
600V, 3-phase 150-400 A DC power for rapid charging of EVs. These may be viewed as
equivalent to gas station pumps due to a similar look.
The current costs of charging stations are highly variable depending on the level of
service (Levels 1 through 3, and alternative power capabilities within these categories),
location (individual residence, grouped residences, retail or business, parking lot or garage),
level of sophistication of the station, and installation requirements, including electrical
upgrading requirements. Estimated costs for charging stations are included in table below.
Table 4.2-2 Estimated Costs for Charging Stations65'66'67'68'3
Level
Location
Equipment
Installation
DD Some manufacturers are planning for lower-power level 1 charging which can be accomplished on a shared
120V circuit.
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1
2
2
O
Single
Residence
Residential,
Apartment
Complex,
or Fleet
Depotb
Public
Public
$30- $200 (charge cord only,
included at no cost to consumer
with EV/PHEV) when an
accessible household plug (e.g.,
in a garage or adj acent to a
driveway) with a ground fault
interrupter is already available
3.3 kW EVSE (each): $300-
$4,000
6.6 kW EVSE (each): $400-
$4,000
$400-$3,800+ for each EVSE
$400-$ 1000+ may be necessary
depending on difficulty of
installing a new circuit at the
desired location, but in most
cases, owners with sufficient
panel capacity would opt for a
more capable 220 VAC Level 2
installation instead of a Level 1
dedicated circuit because the
additional installation cost is
only marginally higher
3.3- 6.6 kW installation cost:
$400-$2,300 without
wiring/service panel upgrade, or
$2,000-$5,000 with panel
upgrade
$3,000- $7,000+ installation
cost, varying significantly with
distances from service entrance
and number of EVSEs installed
$8,000-$50,000
a Detailed information on charger cost for each charging level and location and specific sources for cost
estimates are available in Appendix G.
b Level 2 EVSE installation costs vary considerably for single-family residences, multi-family residences, and
fleet depots, depending upon the need for wiring and service panel upgrades. The range depicted here reflects
the anticipated variability of these costs. However, EPRI estimates that the typical residential Level 2
installation costs to be approximately $1,500. See Appendix G for additional information.
For the 2017-2025 period, there is a major potential for cost reduction in EVSEs if
either or both PHEVs and EVs enter the market in substantial numbers - particularly if strong
markets for these vehicles develop, as expected, in Europe and Asia and EVSEs are
manufactured globally and compete for market share in this country. Although the reduction
potential for installation costs would likely be somewhat smaller than for equipment costs,
installation costs may also be reduced by incorporating EV requirements into building codes
for new construction, and through standardization of procedures and better training and
availability of installers. For purposes of the analysis presented in Chapter 6, the agencies'
estimated costs for Level 1 and Level 2 in-home charging equipment for the 2017 to 2025
time frame is within the range of the values shown above and is detailed in Appendix
B4.2.2.6.
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4.2.4 Battery End-of-Life Value Assessment and Secondary Use Applications
At the end of an EV/PHEVs useful life, the battery will likely not be fully exhausted
and could be used for a number of other tasks. Such a used battery would have a secondary
use value and this expected value could be applied to the original purchase price of the
vehicle (minus an appropriate discount rate) to lower the overall cost, making electric vehicles
more affordable for the American public. These batteries could be used in utility peak load
reduction and management, substation upgrade deferrals, and grid stabilization applications,
as well as renewable energy installations to store solar and/or wind power.69 Several electric
utilities currently use large sodium-sulfer (NaS) batteries for these purposes and are exploring
used EV/PHEV batteries as substitutes. These applications have specific requirements that
could possibly be met by used automotive batteries.
This is a field being intensely studied at the present time and there is some uncertainty
as to the extent of the market, as well as the value to the original vehicle purchaser. A
summary of one such forthcoming study supported by DOE is in Appendix G.
4.2.5 Potential Impacts on the Electric Utility and Distribution Infrastructure
The overall distribution system capacity is expected to be adequate for EV charging.
However, the effect of EV charging on specific circuits within the localized distribution
system has not been fully evaluated and the impacts are not clearly understood; though, this
issue is under study by EPRI, DOE, and several electric utilities.70 Understanding the
relationships between EV charging and the distribution system allows utilities to plan for
additional stresses placed upon their systems as a result of EV charging.
Distribution system components which may be at risk due to the increased loading are
substations, primary and laterals feeders, and distribution transformers. Distribution
transformers are of primary concern. Distribution transformers may be impacted by several
factors, including total EV penetration, EV clustering, time of charging, ambient operating
conditions and thermal characteristics of the transformer, the prevalence of air conditioning,
and the topography and age of the distribution system. These factors affect the cumulative
thermal history of transformers, leading to their increased "thermal aging" and potential loss
of transformer life. DOE and others are studying the effect of PHEV/EV charging on thermal
aging of distribution transformer insulation.
Transformers are also impacted differently under Level 2 versus Level 1 charging.
With more OEMs making public announcements to offer EVs, which are generally more
likely to utilize Level 2 charging than PHEVs, there is further discussion of potential impacts
to the infrastructure. Since Level 2 charging allows for charging power up to 14 times that of
Level 1 charging, the distribution system impacts could be much more severe under Level 2
charging assumptions.
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Load diversityEE becomes an issue further upstream in radial distribution systems.
With diversified load profiles, peaks by individual loads are averaged out. The secondary
transformer is the first distribution system component that will be exposed to the large
current. Thus, it is expected that EV/PHEV charging will have the greatest impact on those
components. The diversity of distribution system component vintages, sizing, and design
practices varies greatly across the U.S. Older distribution systems, which were initially
designed to support lower per-customer demand, are more likely to be affected by PHEV/EV
charging than newer distribution systems, which were designed to support higher per-
customer demand.
Potential distribution system impacts reported in the literature indicate that overall
and, particularly, in newer residential developments (30 years and younger) and rural areas,
distribution system capacity is expected to be adequate for EV charging. However, the
potential for distribution system overloading exists with higher concentrations of charging
vehicles in older residential neighborhoods, such as those in some coastal or mid-western
metropolitan areas.71 These areas may be of concern to utility infrastructure planners.
Time-of-use (TOU) rates^7 may incentivize customers to delay charging to off-peak
periods later at night. While TOU rates are likely to shift loads, they will not alleviate
potential negative impacts on the distribution infrastructure. Smart load control technologies
may be required in order to sequence charging or to perform load coordination strategies for
charging vehicles in order to mitigate possible distribution transformer impacts.
The preceding discussion yields several important conclusions about the potential
impacts on the electric utility and distribution infrastructure:
• The overall electrical distribution system capacity is expected to be
adequate for EV/PHEV charging.
• There is some potential for localized impacts on distribution transformers,
especially in older neighborhoods, depending on EV/PHEV charging load
concentrations. However, the success of electric vehicles will not be
limited by possible disruptions in the distribution system. Additional
research is required to understand the magnitude and extent of the issue.
• Smart load control technologies that include sequencing and coordinating
the charging of vehicles for Level 2 charging could help mitigate possible
transformer impacts.
EE Load diversity refers to electric loads which come online at random times. Non-diversified loads come online
at the same time. So, if EV owners come home at 6:00 PM and plug in to charge, the load is not diversified.
FF TOU pricing is a special electric rate feature under which the price per kilowatt-hour depends on the time of
day; prices can be adjusted upward during periods of peak demand and downward during off-peak periods.
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4.2.6 Voluntary Standards to Support PHEV & EV Infrastructure
DOE has several ongoing activities to support the development of voluntary standards.
These activities can be expected to accelerate under the May 21, 2010 Presidential
Memorandum's request for DOE to work with stakeholders on the development of voluntary
standards and coordinate its efforts with the Department of Transportation, NHTS A, and the
EPA.72 While these efforts on voluntary standardization are important in enhancing long-
term success of EV/PHEVs, they are not a prerequisite for a successful near-term market
launch.
On a conceptual level, electric-drive vehicles differ from conventional gasoline
vehicles in the way they are repowered: conventional vehicles are refueled and electric
vehicles are recharged. But, on a practical level, the means by which repowering happens is
also very different. Where gasoline pumps and measurement standards are already well
established, the equipment and measurement devices facilitating and governing electric-drive
vehicle recharging are still being discussed. Coordination of the means by which EVs and
PHEVs communicate with the grid—both in terms of hardware and software—offers the
benefit of assuring that all electric-drive vehicles can plug in almost anywhere.
The primary link between the DOE vehicle technology activity and industry standards
is the Society of Automotive Engineers (SAE). The most significant development to date has
been the adoption of the voluntary standard SAE J1772, specifications for the electrical
connector between EV/PHEVs and electric vehicle supply equipment (Levels 1 and 2
charging). DOE national laboratories have provided expertise, development and testing
resources to support new SAE standards, as discussed further in the following sections.
4.2.6.1 Opportunities for Voluntary Standardization
There are numerous opportunities for standardization (or harmonization) in the plug-in
vehicle-grid system, including hardware, software, communication and the human-machine
interface (the device through which a driver interacts with the smart grid and/or charging
device) - as exemplified in the following figure:
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Grid Operators
Opportunities for Standardization/Harmonization
in the Plug-in Vehicle-Grid System
Electric Vehicle Supply Equipment (EVSE)
Streamlined residential permitting and installation process;
Consistent application of National Electrical Code (NEC)
Human Machine Interface (HMI)
In-vehicle and remote communication;
u Behavioral feedback
Back office software
Comprehends vehicle roaming;
Integrates vehicles in smart grid;
Balances supply and demand
Grid operator-home-vehicle communication
Protocols for 2-way secure communication
-Vehicle ID, location, charge requirements/preferences
-Power available, price, charge time, recommendations
Comprehends smartgrid interoperability standards
Universal communication technologies
Wired (Power Line Communication-PLC);
Wireless (e.g., GPRS, internet, Software Defined Radio-SDR)
Charge couplers
Configuration;
Functionality;
Global interoperability
Compact metrology
Low cost revenue-grade
sub-metering
Figure 4.2-1 Opportunities for Standardization/Harmonization in the Plug-in Vehicle-
Grid System
Several opportunities for standardization/harmonization are identified in the preceding
simplified concept of vehicle-grid interaction (and, others are possible). Starting from the
vehicle and moving upstream to the utility, the first opportunity is the charge coupler—the
physical connector and vehicle receptacle for hybrid and electric vehicle charging and the
means by which the vehicle interacts with EVSE. Several additional opportunities are within
the EVSE: first, the permitting process to facilitate the installation of EVSEs, to be
coordinated at the local government level; second, the compact metrology, or small device the
EVSE uses to measure energy consumption; and, third, the method of communication—both
in terms of hardware (wired and wireless universal communication technologies) and
software/protocols (grid operator-home-vehicle communication). At the utility, software can
be standardized or harmonized to facilitate grid-wide smart management with targeted goals
such as balancing supply and demand and sequencing vehicle charging.
4.2.6.2 Defining voluntary standards
"Voluntary" standards, i.e., those not required by regulation,60 address essentially all
aspects of automobiles and are issued by several organizations around the world; for example
the Society of Automotive Engineers (SAE) in the US, the International Organization for
GG Although voluntary in some regions of the US, SAE J1772 is essentially a regulatory requirement in
California and many other states that have adopted the CA ZEV Regulation because California requires vehicles
to comply with J1772 in order to earn ZEV credit.
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Standardization (ISO) or the International Electrotechnical Commission (LEG) in Europe and
the Japan Automobile Research Institute (JARI) in Asia. The electrical content of
automobiles adheres to standards developed by the Institute of Electrical and Electronics
Engineers (IEEE) and, as plug-in vehicles and EVSE utilize the electric power grid, they are
subject to standards by Underwriters Laboratories (UL) as well as the fire and building safety
standards by the National Fire Protection Association (NFPA) including the National
Electrical Code (NEC).
4.2.6.3 Standards for Electric Vehicle to Grid Interface
The Grid Interaction Technical Team (GITT) was initiated in 2009 to identify issues
regarding vehicle electrification and related grid impacts, set functional requirements for the
vehicle-grid interface and cooperate on key issues/projects to enable plug-in vehicles (PHEVs
and EVs). The members include DOE (the Vehicle Technologies Program and the Office of
Electricity Delivery and Energy Reliability), the domestic auto industry and selected electric
utilities. Current DOE-funded projects under the auspices of the GITT focus on some of the
immediate needs of the vehicle-grid interface, including:
• A draft national template to streamline the permitting and installation
process of electric vehicle supply equipment
• The human-machine interface (HMI) for charger-grid communication
standards validation
• Technology development to support universal vehicle-grid communication
• Standards for PHEV/EV Communications Protocol
4.2.6.4 SAE Standards Development
SAE is working with stakeholders to develop EV/PHEV and infrastructure-related
standards. SAE J1772 is a standard for the "Electric Vehicle and Plug-in Hybrid Electric
Vehicle Conductive Charge Coupler," and describes the physical, electrical, functional, and
performance requirements for all grid-connected vehicles in North America. Work is also
progressing towards the development of improved grid connectivity for electric vehicle
charging infrastructure through lower cost, secure, universalized wired and wireless
communications technologies.
SAE is working with organizations and consortia such as the International
Organization for Standardization (ISO), International Electrotechnical Commission (IEC),
utility companies, the Institute of Electrical and Electronics Engineers (IEEE), Electric Power
Research Institute (EPRI), ZigBee Alliance, HomePlug Power Alliance, automotive OEMs
and suppliers, and many others in the development of specifications and standards to address
the requirements of the SmartGrid strategy. Several national laboratories directly support the
committee activities, including Argonee National Lab, Idaho National Lab, National
Renewable Energy Lab, Oak Ridge National Lab, and Pacific Northtwest National Lab.
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A full list of applicable SAE standards—both completed and upcoming—is provided
in Appendix G.
4.2.6.5 International Cooperation and Activities
Increasingly, vehicles are being developed to compete in a worldwide market. A
manufacturer can realize significant cost savings by building a large number of standardized
vehicles in several countries. International harmonization of EV/PHEV charging equipment
and protocols can help speed the market penetration of these vehicles by more rapidly
lowering the costs of these components.
International cooperation relies on the members and projects of the joint DOE-auto
industry-utility Grid Interaction Tech Team (see previous section) as well as national
laboratory personnel that directly support the SAE standards committees to interact to
promote global vehicle-grid interoperability through outreach and programmatic support for
harmonization of US, European and Asian codes & standards in selected international venues.
Specific support is provided to the Administration's EU and China initiatives1™ as well as the
Departments of Commerce and State.11 As mentioned in the preceding description of the SAE
activities, there are U.S. Technical Advisory Groups (USTAGS) to the ISO activities, with all
the groups listed on the SAE website.JJ
4.3 Hydrogen Infrastructure Overview
When run on hydrogen, fuel cell electric vehicles (FCEVs) produce zero tailpipe
emissions making hydrogen an attractive alternative fuel. When produced from the
reformation of natural gas (the method used for the vast majority of H2 currently produced)
hydrogen reduces well-to-wheel (WTW) GHG (CC>2 equivalent) emissions by approximately
50 percent.73 Unlike infrastructure for EVs and PHEVs, where the option of home charging
exists, the successful rollout of FCEVs depends on the early and strategic placement of
publicly accessible infrastructure to enable market penetration. This section of the report
includes discussion on hydrogen infrastructure status today, costs and projections for
technology improvement, rollout strategies, policies, and conclusions.
4.3.1 Status Today
4.3.1.1 Infrastructure Technologies
Hydrogen is produced through a variety of processes. Some are more suited for large
scale centralized production; others are more often associated with on-site distributed
production at traditional fueling stations. Most common technologies utilized today include:
™ e.g., Smart Grid-EV Working Group of the EU-US Energy Council, EU-US Transatlantic EV Workshop, US-
China Vehicle and Battery Technology Workshop
11 e.g., EU 'green' trade mission, COP 15 and COP 16 UN Framework Conventions on Climate Change
11 See http://www.sae.org/servlets/works/
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Chapter 4
• Steam methane reformation - The U.S produces over 9 million tons of hydrogen annually.
Ninety Five percent of that amount is produced from natural gas by steam methane
reformation (SMR) at large scale centralized plants. Most is used at petroleum refineries,
for food processing and other industrial uses. Renewable hydrogen may also be reformed
from biogas, landfill gas and ethanol for example. High daily throughput stations (100+
kg/day) with ample space can utilize onsite steam reforming on-site.
• Electrolysis - Electrolysis systems use electricity to split water into hydrogen and oxygen.
The technology is compact, reliable, and has been used for decades in industrial, military
and space applications. Today's typical station electrolyser produces 60 kg/day and
requires approximately 55kW-hr of electricity to generate a kilogram of hydrogen. A
clean, renewable electricity source (such as hydro, wind, photovoltaic or natural gas fired
plant) can minimize upstream GHG emissions from electrolysis.
• Delivery - For those stations not producing hydrogen onsite, typically high pressure
gaseous product can be delivered to the site in batches that can supply the station for a few
days or even weeks, depending on station throughput. This method is easy to build but
needs refilling regularly. Another common delivery method is trucked cryogenic liquid
hydrogen, which is stored in much larger quantities at the station.
• Pipeline - There are over 300 miles of hydrogen pipeline in Texas, Louisiana and
California serving industrial demand. The hydrogen is not fuel cell grade and is of
relatively low pressure (350 - 1500 psi typically). With minimal clean-up and added
storage, compression, and dispensing equipment, this option can be an economical source
for hydrogen infrastructure placement, where pipelines exist.
• Co-generation - High temperature fuel cells for stationary or ancillary grid electricity
production (hydrogen energy stations) can provide a fuel source for a hydrogen
infrastructure. A jointly funded DOE/CARB/South Coast Air Quality Management
District (SCAQMD) project at a waste water treatment plant near Los Angeles features a
molten carbonate fuel cell run on treated anaerobic digester gas. The fuel cell produces
electricity to run the plant, and tail gas from the anode will be further cleaned, compressed
and dispensed at the on-site hydrogen station for FCEVs.74
4.3.1.2 Federal Demonstration Programs
The map below shows locations of hydrogen stations (includes lift trucks and transit
bus stations) in the U.S.75 Since 2004 the U.S. DOE Hydrogen Program has worked with
multiple partners in several states including California, New York, Florida, Michigan and
Washington D.C. to demonstrate FCEVs and infrastructure. The program worked in
partnership with industry, academia, national laboratories, and Federal and international
agencies to help overcome technical barriers through research and development of hydrogen
production, delivery, and storage technologies, as well as to address safety concerns and
develop model codes and standard. NREL has reported that over 130,000 kg of hydrogen has
been produced or dispensed in 23 of the Nation's 56 stations.
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WA
ID
MT
WY
KV
UT
CA
CO
NM
ND
SO
NE
K5
MN
Wl
OK
TX
AK
MO
AR
LA
VT NH
Mi
,MA
Ml
PA
CT
IL IN
OH
WV
ICY
VA
NC
-— NJ
MD
DC
'
MS AL
SC
FL\
Legend
Hydrogen Stations
None
IB or less
11 - 20
HI
4.3.1.3 California Demonstration Programs
Although there is much FCEV activity ongoing throughout the U.S. many OEMs are
focusing their pre-commercial vehicle rollouts in California. The state's Zero Emission
Vehicle (ZEV) regulation requires large volume automakers to produce a certain number of
"pure" zero emission and "near zero" emission vehicles for sale in California as a percentage
their overall sales.76 To date, over 250 fuel cell vehicles have been deployed in the State
fueling at over 26 limited access, private and public access fueling stations.
The SCAQMD which includes the greater Los Angeles area has been operating its
"Five Cities" hydrogen stations for over five years now. Each fueling station supports OEM
FCEVs and a fleet of five gas/electric hybrid vehicles that have been converted to run on
hydrogen. The aim of the project is to stimulate demand for hydrogen fueling, accelerate the
expansion of the region's hydrogen fueling network, and educate the public on hydrogen
powered vehicles. City officials and staff have used the converted hybrids in everyday city
fleet driving and showcased them to community groups, neighborhood associations and
schools.
To support continued roll out of FCEVs in California, the state has committed to
partnering with infrastructure providers to develop a network of stations in the greater Los
Angeles area, Sacramento and in the San Francisco Bay Area. The following chart shows
infrastructure and co-funding amounts for stations supporting OEM FCEV rollouts. Cost
share in most cases varied between 50-70% of expected station costs.
Table 4.3-1 Public Access Stations Nearing Completion in California
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Chapter 4
Location & Station
Proposer
Emeryville
Oakland
San Francisco Airport
Burbank
Los Angeles - CSULA
Los Angeles - UCLA
Torrance
Harbor City
Fountain Valley
Newport Beach
State
Funds
(Millions)
$2.7
$4.1
$1.7
$300K/yr
$2.7
$1.7
$0
$1.7
$2.7
$1.7
Total Cost
Estimated
(Millions)
$5.56
$5.96
$2.41
Not Available
$4.4
$4.32
Not Available
$2.47
$8.19
$4.03
Capacity
KgH2/
day
60
180+
120
100
60
140
50
100
100
100
Technology
Electrolyzer
100 % renewable
Liquid Delivery
33 % Biogas credits
Liquid Delivery
Gas deliver and On-site Steam
Methane Reformation
Electrolyzer
100% renewable
On-site Steam Methane
Reformation
Pipe line supplied
High pressure delivered Hydrogen
High Temperature Fuel Cell; 100 %
renewable from digester gas
On-site Steam Methane
Reformation
4.3.1.4 Station and Hydrogen Costs
The following chart shows actual and estimated ranges of costs to build 350/700 bar
demonstration pre-commercial hydrogen stations in California. The figures include: site
preparation, permits, engineering, capital equipment, utility connections, construction,
renewables, and installation. It excludes operation and maintenance and real-estate. The third
column figures are predicted cost ranges determined from an Institute of Transportation
Studies (ITS) workshop held at the University of California, Davis. Appendix G shows
information regarding the cost of hydrogen in the U.S. through 2050.
Table 4.3-2 Actual and Estimated Station Costs by Technology
Technology
Tube trailer delivery
High pressure composite
delivery
Liquid delivery
Onsite electrolyzer(s)
Onsite SMR
Energy station/gasifier
Station capacity
kg/day
100
100
100+
60- 130
100-140
100+
CARB Cost
$M 2008-11
1
1.0-1.7
1.7-2.7
2.0-4.0
(renewable)
2.5-4.0
6.0-8.5
(renewable)
ITS Est Cost
$M 2012-1777
0.4-1.0
0.8-1.0
1.1-1.4
1.4-2.0
1.4-2.0
n/a
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4.3.2 Prospects for Cost and Technology Improvement
Over the past several years, the DOE Hydrogen Program has tracked, set targets,
researched and funded studies to better predict the costs to transition to different alternative
fuels. The DOE 2009 target infrastructure performance metrics for hydrogen were set at
$3/gasoline gallon equivalent (gge) with a target average hydrogen fueling rate of 1.0
kg/minute. NREL reported that average fueling rates have improved from 0.66 kg/min in
2006 to 0.77 kg/min in 2009, and early market hydrogen costs at an on-site natural gas
reformation station ranged from $7.70 - $10.30, and onsite electrolysis ranged from $10.00 -
$12.90 /gge.78 In this NREL study, the number of refuelings by all OEMs with both
Generation 1 and Generation 2 vehicles totaled 25,811.79 However, independent of this
project, industry panels concluded that at 500 replicate 1500 kg/day stations/year, distributed
natural gas reformation could produce $2.75 - $3.50/kg and distributed electrolysis at $4.90 -
$5.70/kg.80 With the increased efficiency of FCEV relative to conventional vehicles, this
makes hydrogen potentially competitive to conventional fuels such as gasoline.
4.3.3 Infrastructure Rollout Strategy
To help ensure that hydrogen infrastructure is in place to match planned vehicle
rollouts, CARB and the California Energy Commission (CEC) conducted a confidential
survey of OEMs. The following table shows the estimated number and timing of FCEV
releases through the year 2017. The survey, conducted in late 2009, included an additional
breakdown of regions and cities/clusters in both northern and southern California.
Table 4.3-3 California Hydrogen Fuel Cell Vehicle Rollout Estimates
Year/Period
Cumulative Number of
Vehicles
CARB/CEC 2009 Survey
2010
92
2011
30
2012
95
2013
69
2014
839
2015-2017
44,706
4.3.3.1 Station Location Strategy
Pre-commercial hydrogen infrastructure will roll out in phases consisting of "clusters."
A Hydrogen Cluster could be a city or group of cities, group of neighborhoods or
unincorporated areas that are or will be targeted as a unit in which OEMs plan to place
FCEVs. Clusters have already been developed in southern California. The Santa
Monica/West Los Angeles area, the Torrance/Redondo Beach areas, the Hollywood area, and
the Irvine/Newport Beach areas each have at least one station operating with more under
construction to ensure increased convenience, sufficient redundancy, and increased capacity
for future vehicle rollouts.81
Depending on availability and customer acceptance, as vehicle numbers increase,
station number and capacity will increase within the Clusters. Bridging stations connecting
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the clusters and regions as well as destination (vacation cities for example) will be added to
the infrastructure. Infrastructure will expand and "secondary Clusters" will develop as the
FCEV market expands and the vehicles become more main stream.
4.3.3.2 Station Specifications
Pre-commercial hydrogen stations have made the transition from being "behind the
fence," to a near full retail experience. Station performance specifications now include 3-5
minute back-to-back fills, both 350 and 700 bar dispensers, convenient 24/7 hours, with no
attendant required and easy pay pumps. Extensive Codes and Standards have been developed
to help ensure stations are designed and built to a consistently high standard, are safe and are
compatible with all OEM vehicles. Appendix G provides a list of Codes and Standards that
have been developed for hydrogen infrastructure.
4.3.4 Policies and Partnerships
Government policies and partnerships can assist in focusing work on the most
important tasks needed for implementation of hydrogen infrastructure. Foremost in any
alternative fuel vehicle rollout, timing and execution of alternative fuel infrastructure is
difficult to achieve without help. A classic chicken and egg dilemma exists, more so with
hydrogen than with most alternative fuels because of the newness of the fuel and the initial
investment needed.
4.3.4.1 Partnerships
Partnerships such as the California Fuel Cell Partnership, made up of OEMs, energy
companies, industrial suppliers, academia and government, have created important tools,
communication pathways and served to build relationships between OEMs and fuel suppliers
specific to hydrogen and fuel cell implementation efforts. Memoranda of Understanding
(MOUs) like "H2 Mobility" in Germany for example are also being explored as a useful way
to bridge the uncertainty regarding fueling needs and vehicle rollout plans. These MOUs
between partners such as auto manufacturers, energy companies and local governments can
formalize vehicle/infrastructure strategies and or goals surrounding vehicle volumes, timing,
location and necessary fueling capacity. MOUs in Germany and Japan between major energy
companies and OEMs will help define the business case for hydrogen stations and prepare for
vehicle introductions.
4.3.4.2 Government Funding
Federal, State and local co-funding for both vehicle incentives and infrastructure costs
will likely be necessary for some years as a way of sharing risk with early adopters of FCEVs.
For example, in California, Assembly Bill 118 (2008) added a vehicle registration fee to
motorists to generate a fund for alternative fuel investments to help reach energy, GHG and
air quality goals. An annual investment plan is developed and serves as a guidance document
for the allocation of funding. Funding from this program has been made available for many
alternative fuels, including hydrogen infrastructure. 2
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Table 4.3-4 Scenarios of Government Support for Hydrogen Fuel Cell Vehicles and
Infrastructure: Three Policy Cases*
Policy
Case
Case 1
Case 2
Case 3
Time
Period
2012-2017
2018-2021
2022 - 2025
2012-2017
2018-2021
2022 - 2025
2012-2017
2018-2021
2022 - 2025
Vehicle Policies
Fuel Cell
Vehicle
Cost Sharing
50% of
incremental
FCV costs
50% of
incremental
FCV costs
50% of
incremental
FCV costs
50% of total
FCV costs
None
None
Fuel Cell
Vehicle
Tax Credits
None
None
None
None
100% of
incremental cost
1 00% of
incremental cost
50% of total
FCV costs | None
None
None
1 00% of
incremental cost
plus
$2,000/vehicle
100% of
incremental cost
plus
$2,000/vehicle
Fueling Infrastructure Policies
Station Cost Sharing
(for Distributed
Hydrogen
Production)
$1.3
Million/Station
$0.7
Million/Station
$0.3
Million/Station
$1.3
Million/Station
$0.7
Million/Station
$0.3
Million/Station
$1.3
Million/Station
$0.7
Million/Station
$0.3
Million/Station
Hydrogen Fuel
Subsidy
(Production
Tax Credit)
$0.50/kg
Decreases linearly
From2018toS0.30/kg
in 2025
$0.30/kg
in 2025
$0.50/kg
Decreases linearly
From2018toS0.30/kg
in 2025
$0.30/kg
in 2025
$0.50/kg
Decreases linearly
From2018toS0.30/kg
in 2025
$0.30/kg
in 2025
* This table is for illustrative purposes only and does not necessarily reflect a recommendation that
specific policies should be adopted at this time.
4.3.4.3 Regulatory Incentives and Requirements
Short of the government support for development of new hydrogen stations to kick
start the market sufficiently so that station volumes grow on their own, other policies or
requirements may be necessary as shown in the three scenario table above.83 California is
exploring a variety of approaches including both regulatory incentives and possible
requirements for installation of stations to ensure that enough stations are available to market
FCEVs successfully.
California's Low Carbon Fuel Standard: Adopted in 2009, the Low Carbon Fuel
Standard (LCFS) requires producers and importers of gasoline to ensure that the mix of fuel
they sell into the California market meets, on average, a declining standard for GHG
emissions. The standard is measured on a lifecycle basis in order to include all emissions from
fuel consumption and production, including the "upstream" emissions that are major
contributors to the global warming impact of transportation fuels. Because hydrogen has a
very low well to wheel carbon content, some regulatory incentive exists for energy companies
to provide hydrogen as part of their compliance strategy.
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Clean Fuels Outlet: In the 1990s when it was thought that California's Low Emission
Vehicle regulation would need alternative fuel vehicles to meet the strict fleet average tailpipe
standards, CARB adopted the Clean Fuels Outlet regulation that would require the installation
of an alternative fuel pump if a specified number of alternative fuel vehicles needing that fuel
were marketed in California. This was California's approach to ensuring alternative fuel
would be available when vehicles came to market. The thresholds that would trigger this
program have not yet been reached. The program is currently being reviewed in the context
of how it might be used to ensure sufficient hydrogen fueling stations.
4.4 Conclusions
The combined understanding of home recharging, electric vehicle charging system
costs, and ongoing work to develop voluntary standards indicate that infrastructure to support
electric-drive vehicles will be adequate to support EV/PHEV rollout in the near term. For
areas where relative inexperience implies uncertainties—such as the need for and use of
public infrastructure, and vehicle battery secondary uses—DOE activities have been designed
and are underway to inform future decisions: Infrastructure deployment projects are
underway and over the next 3-4 years will establish regional public charging networks and
collect data on how and when consumers use them to clarify the future role of public charging
in the U.S. In addition to confronting these technology challenges, DOE will continue to
support a communication and information campaign at the local, national, and international
levels. At the local level, DOE will continue to share information and best practice examples
to ensure that cities and local planning organizations receive the best methods for facilitating
vehicle electrification and the infrastructure to support it. At the national and international
levels, DOE will continue to coordinate government activities to ensure that national and
international voluntary standards for electric vehicles and support infrastructure work for U.S.
auto manufacturers, utilities, and consumers.
Regarding hydrogen, the considerable learnings brought about by DOE and other
programs, and the leadership, partnerships and funding commitment of California have
enabled pre-commercial hydrogen infrastructure to be built today. OEMs are sharing FCEV
rollout strategies with government leaders so public resources can be paired with private
sector investment. A number of automobile manufacturers have stated publicly that initial,
early commercial production of FCEVs could begin as early as 2015 if infrastructure is ready.
A general understanding has been achieved regarding how to create hydrogen station
networks using clusters in specific first markets. Government policies including regulations
and incentives are being developed to support and help guide the progress and help ensure
success.
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Chapter 4 References
45 Woodard, Tracy, representing Nissan Motor Co., Ltd. (2010). Department of Energy Plug-In Vehicle and
Infrastructure Workshop, Washington, DC. July 22, 2010.
46 Morrow, Kevin, Donald Karner, James Francfort. Plug-in Hybrid Electric Vehicle Charging Infrastructure
Review (2008). Idaho National Laboratory report INL/EXT-08-15058. November 2008.
47 BMW (2009), Presentation by Dr. Thomas Becker given at United Nations Climate Change Conference,
Copenhagen Denmark, December 2009.
48 Rivkin, Carl (2010), National Electric Vehicle Charging Station Permit Template, NREL (Golden, CO).
49 Pacific Gas and Electric Company (1999), "Electric Vehicle Infrastructure Installation Guide",
, Accessed Aug
17, 2010.
50 Electric Power Research Institute. Plug-in Electric Vehicle Infrastructure Installation Guidelines. September
25, 2009.
51 National Research Council (2010). Transitions to Alternative Transportation Technologies~Plug-in Hybrid
Electric Vehicles. Committee on Assessment of Resource Needs for Fuel Cell and Hydrogen Technologies.
52 Lin, Zhenhong and David Greene. PHEV Market Projection with Detailed Market Segmentation. TRB Annual
Meeting CD-ROM, January 2010.
53 Woodard, Tracy, representing Nissan Motor Co., Ltd. (2010). Department of Energy Plug-In Vehicle and
Infrastructure Workshop, Washington, DC. July 22, 2010.
54 Characterizing Consumers' Interest in and Infrastructure Expectations for Electric Vehicles: Research Design
and Survey Results. EPRI, Palo Alto, CA and Southern California Edison, Rosemead, CA: 2010. 1021285.
55 BMW (2010). Presentation by Andreas Klugescheid given at the 18th Annual Meeting of the UN Planning
Commission on Sustainable Development, New York, NY. May 12, 2010.
56 Kurani, Kenneth S., Jonn Axsen, Nicolette Caperello, Jamie Davies, Tai Stillwater (2009) Learning from
Consumers: Plug-In Hybrid Electric Vehicle (PHEV) Demonstration and Consumer Education, Outreach, and
Market Research Program. Institute of Transportation Studies, University of California, Davis, Research Report
UCD-ITS-RR-09-21.
57 Morrow, et. al. (2008).
58 Alternative Fuels & Advanced Vehicle Data Center. Advanced Vehicle Testing Activity: Battery Chargers for
Electric Vehicles.
. Accessed
Aug 17, 2010.
59 Nissan (2010). "Nissan Leaf, General Answers." ,
Accessed Aug 17, 2010.
60 JB Straubel, Tesla Motors Inc. CTO (2009), "Vehicle Fleet Experience Overview", 2009 ARE ZEV
Technology Symposium, Sept 21-22, 2009,
, Accessed Aug 17, 2010.
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61 The U.S. Department of Energy (DOE) (2010). Electric Charging Station Locations.
. Accessed on Aug 07, 2010.
62Childers, Craig (2010). "Infrastructure Support: Experience and Installation." Presentation at Plug-In 2010,
San Jose, CA. July 28, 2010.
63 Axsen, Jonn and Kenneth S. Kurani (2010) Anticipating plug-in hybrid vehicle energy impacts in California:
Constructing consumer-informed recharge profiles. Transportation Research Part D 15 (2010)212-219.
64 Kurani, 2009.
65 Morrow, et. al. (2008).
66 May, James W. and Matt Mattila (2009). "Plugging In: A Stakeholder Investment Guide for Public Electric-
Vehicle Charging Infrastructure." Rocky Mountain Institute. July 2009.
67 Electric Transportation Engineering Corporation (ETEC), 2009. Electric Vehicle Charging Infrastructure
Deployment Guidelines British Columbia, July..
68 Electrification Coalition (2009). "Electrification Roadmap" accessible from
http://www.electrificationcoalition.org.
69 Technical and Economic Feasibility of Applying Used EV Batteries in Stationary Applications, Sandia
National Laboratories, Albuquerque, NM: 2002.
70 Kintner-Meyer, M; K. Schneider; R. Pratt (2007). Impacts Assesment of Plug-In Hybrid Vehicles on Electric
Utilities and Regional U.S. Power Grids. Part 1: Technical Analysis, Journal of EUEC, Volume 1, 2007. Electric
Utility Environmental Conference, Tucson, AZ. January 22-24, 2007; Electric Power Research Institute (2010).
18 Utility EV Charging Study.
71 Gerkensmeyer, C., MCW Kintner-Meyer, and JG DeSteese (2010). Technical Challenges of Plug-In Hybrid
Electric Vehicles and Impacts to the US Power System: Distribution System Analysis. PNNL-19165. Pacific
Northwest National Laboratory (Richland, WA).
72 Presidential Memorandum Regarding Fuel Efficiency Standards, May 21, 2010, Available
http://www.whitehouse.gov/the-press-office/presidential-memorandum-regarding-fuel-efficiency-standards
73Hydrogen Pathways: Cost, Well-to-Wheels Energy Use, and Emissions for the Current Technology Status of
Seven Hydrogen Production, Delivery, and Distribution Scenarios, NREL /TP-6A1-46612, September 2009.
74 "Validation of an Integrated Hydrogen Energy Station" DOE Hydrogen Program, FY 2009 Annual Progress
Report.
75 NREL, www.afdc.energy.gov/afdc/fuels/hydrogen_locations.html.
76 "Frequently Asked Questions - The California Zero Emission Regulation", California Environmental
Protection Agency, Air Resources Board April 2010.
77 Institute of Transportation Studies, University of California Davis, Workshop, Roadmap for Hydrogen and
Fuel Cell Vehicles in California: A Strategy through 2017, May 5, 2009.
78http://nrel.gov/hydrogen/proj_learning_demo.html.
79 "Controlled Hydrogen Fleet Infrastructure Demonstration and Validation Project", NREL, Composite Data
Project Spring 2010.
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80 "Current (2009) State of the Art Hydrogen Production Cost Estimate Using Water Electrolysis", NREL
September 2009. http://hvdrogen.energv.gov/pdfs/46676.pdf and Distributed Hydrogen Production From Natural
Gas: Independent Review, National Renewable Energy laboratory, October 2006.
www.hydrogen.energy.gov/pdfs/40382.pdf.
81 "Hydrogen Fuel cell Vehicle and Station Deployment Plan: A Strategy for Meeting the Challenge Ahead,"
California Fuel Cell Partnership February 2010.
82 "2010-2011 Investment Plan for the Alternative Renewable Fuel and Vehicle Technology Program,"
California Energy Commission, CEC-600-2010-001-CTD.
83 "Analysis of the Transition to Hydrogen Fuel Cells & the Potential Hydrogen Energy Infrastructure
Requirements" ORNL/TM-2008/30.
Additional References
FreedomCAR and Fuel Partnership Codes and Standards Technical Team. Codes and Standards RD&D
Roadmap - 2008.
http://wwwl.eere.energy.gov/vehiclesandfuels/pdfs/program/cstt_roadmap.pdf
MYPP (Multi-Year Research, Development, and Demonstration Plan) 2007. Hydrogen Codes and Standards.
Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.
http://wwwl.eere.energy.gov/hydrogenandfuelcells/mypp/pdfs/codes.pdf
NRC (National Research Council) 2010. Review of the Research Program of the FreedomCAR and Fuel
Partnership: Third Report. Washington, D.C.: The National Academies Press.
http://www.nap.edu/catalog.php?record_id=12939
NREL (National Renewable Energy Laboratory) 2010. Vehicle Codes and Standards: Overview and Gap
Analysis. Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.
www.nrel.gov/docs/fylOosti/47336.pdf.
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5 Incentives and Flexibilities
This Chapter includes three sections. Chapter 5.1 provides an overview of the
regulatory flexibilities and incentives contained in the MYs 2012-2016 final rule for the
National Program. Chapter 5.2 includes a discussion of the potential regulatory flexibilities
and incentives for MYs 2017 and later which the agencies received input on during our
meetings with stakeholders. Chapter 5.3 contains a summary of the non-regulatory incentives
which the agencies received input on during our meetings with stakeholders. We note that
some of the flexibilities discussed in this Chapter were used in our analysis of future scenarios
in Chapter 6, though not all. As a result, when EPA and NHTSA undertake analysis for the
upcoming federal rulemaking, we would not project additional per-vehicle cost reduction
potential attributable to the flexibilities that have already been used to the current analysis.
Chapter 6 contains a detailed discussion of the flexibilities we considered in the analytical
assessment.
5.1 Overview of Existing Incentives and Flexibilities in the MYs 2012-2016 Program
EPA's and NHTSA's programs for MYs 2012 - 2016 provide compliance flexibilities
to manufacturers, some indefinitely (such as those required by statute), and some that are
designed, pursuant to agency discretion, to ease the transition during the early years of the
National Program to increasingly stringent regulations. These flexibilities are intended to
help provide sufficient lead time for most manufacturers to make necessary technological
improvements and reduce the overall cost of the program, without compromising overall
environmental and fuel economy objectives.
Under the CAFE program, Congress required through EPCA and EISA that NHTSA
provide three specific types of compliance flexibilities - credits earned for over-compliance
with a given standard, credits available due to production of alternative fuel vehicles, and the
option of paying civil penalties in lieu of compliance. ^ For the CAFE program, 49 U.S.C.
32903 allows manufacturers to earn credits (denominated in tenths of a mpg) if their fleet
average fuel economy for either passenger cars or light trucks exceeds an applicable CAFE
standard. Credits may be applied to compliance with a standard in any of the 3 consecutive
model years immediately before the model year in which the credits were earned (referred to
as "carry-back"), or in any of the 5 model years immediately after the credits were earned
(referred to as "carry-forward"). Credits may also be transferred by a manufacturer from one
of their fleets to another, or traded (sold) to other manufacturers. Credits may not, however,
be used to comply with the domestic minimum passenger car standard, and transferred credits
are subject to a statutory cap, preventing manufacturers from increasing a fleet CAFE level by
more than 1-2 mpg with transferred credits, depending on the model year. For purposes of the
MYs 2012-2016 GHG standards, EPA adopted similar averaging, banking, and trading
KK We note that small volume manufacturers (i.e., those that produce less than 10,000 vehicles for sale
worldwide) may also petition NHTSA for an exemption from the generally-applicable CAFE standards and
potentially obtain their own individual fuel economy standards under 49 U.S.C. 32902(d), but NHTSA does not
consider this a generally-available compliance flexibility like the others listed above, given the production
volume limit.
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provisions allowing manufacturers to bank over-compliance credits, transfer the credits
between their passenger car and light truck fleets, and trade them to other manufacturers.
EPA, did not include the EISA cap on transfers - thus, for purposes of GHG compliance,
manufacturers may transfer credits infinitely between their passenger car and light truck
fleets.
EPCA has also long contained manufacturing incentives for alternative fuel
automobiles. "Dedicated" (i.e.., "pure") alternative fuel vehicles and "dual-fueled" (i.e..,
"flexible-fuel" or "flex-fuel") alternative fuel vehicles both receive special calculations to
boost their fuel economy levels for compliance purposes under 49 U.S.C. 32905 and 32906.
In EISA, Congress provided for a phase-out of the alt-fuel credit, so that while manufacturers
can raise their CAFE levels up to 1.2 mpg using the alt-fuel credit through model year 2014,
the amount of possible increase due to the credit decreases by 0.2 mpg each year until it
phases out entirely after MY 2019. For purposes of the MYs 2012-2016 GHG standards,
EPA will allow FFV credits in line with CAFE program limits, but only during the period
from MYs 2012 to 2015. In MY 2016 and later, EPA will allow manufacturers to incorporate
the emissions performance on alternative fuels by basing the FFV's compliance value on test
values for both gasoline and the alternative fuel, weighted according to data provided by
manufacturers demonstrating that the alternative fuel is actually being used by FFVs in-use.
The final compliance flexibility mandated by statute for the CAFE program, at 49
U.S.C. 32912, is the option of paying civil penalties in lieu of compliance with an applicable
CAFE standard in a given model year. Some manufacturers face unique compliance
challenges because they serve relatively small market segments that tend to value vehicle
performance and utility much more highly than fuel economy. For these manufacturers, fuel-
saving technologies (such as, e.g., turbochargers), even when applied, are often used to
increase performance or utility rather than to increase fuel economy. Some of these
manufacturers have relied on this flexibility in past and recent model years, and for CAFE
purposes, some manufacturers may continue to do so in the future. The CAA does not have a
similar civil penalty flexibility - manufacturers who do not comply with applicable standards
may not certify their vehicles for sale in the U.S.
For CAFE purposes, EPCA and EISA are fairly prescriptive with regard to what
compliance flexibilities may be offered, but for GHG purposes, the CAA gives EPA broader
authority to craft compliance flexibilities through regulation. The following paragraphs detail
the flexibilities developed by EPA for the MYs 2012-2016 GHG program, in addition to the
averaging, banking, and trading provisions and FFV credits noted above.
EPA Air Conditioning System Credits: Air conditioning (A/C) systems contribute to
GHG emissions in two ways. First, hydrofluorocarbon (HFC) refrigerants, which are
powerful GHGs, can leak from the A/C system (direct A/C emissions). Second, operation of
the A/C system also places an additional load on the engine, which results in additional CC>2
tailpipe emissions (indirect A/C related emissions). EPA allows manufacturers to generate
credits by reducing either or both types of GHG emissions related to A/C systems.
EPA Temporary Lead-time Allowance Alternative Standards (TLAAS): Manufacturers
with limited product lines may be especially challenged in the early years of the National
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Program, and need additional lead time. Manufacturers with narrow product offerings may
not be able to take full advantage of averaging or other program flexibilities due to the limited
scope of the types of vehicles they sell. For example, some smaller volume manufacturer
fleets consist entirely of vehicles with very high baseline CC>2 emissions. Their vehicles are
above the CO2 emissions target for that vehicle footprint, but do not have other types of
vehicles in their production mix with which to average. Often, these manufacturers pay fines
under the CAFE program rather than meet the applicable CAFE standard. EPA believes that
these technological circumstances call for more lead time in the form of a more gradual
phase-in of standards. For these reasons, EPA included a temporary lead-time allowance for
manufacturers that sell vehicles in the U.S. in MY 2009 and for which U.S. vehicle sales in
that model year are below 400,000 vehicles. This allowance will be available only during the
MY 2012-2015 phase-in years of the program. A manufacturer that satisfies the threshold
criteria will be able to treat a limited number of vehicles as a separate averaging fleet, which
will be subject to a less stringent GHG standard.LL Specifically, a standard of 25 percent
above the vehicle's otherwise applicable footprint target level will apply to up to 100,000
vehicles total, spread over the four year period of MY 2012 through 2015. In addition,
manufacturers with between 5,000 and 50,000 U.S. vehicle sales in MY 2009 will have an
increased allotment of vehicles, a total of 250,000, compared to 100,000 vehicles (for other
TLAAS-eligible manufacturers). In addition, the TLAAS program for these manufacturers
would be extended by one year, through MY 2016, for a total of five years of eligibility. For
the smallest volume manufacturers, those with below 5,000 U.S. vehicle sales, EPA did not
set standards but instead deferred standards until a future rulemaking.
EPA Early Credits: EPA established opportunities for early credits in MYs 2009-2011
through over-compliance with a baseline standard. The baseline standard is set to be
equivalent, on a national level, to the California standards. Credits can be generated by over-
compliance with this baseline in one of two ways - over-compliance by the fleet of vehicles
sold in California and the CAA section 177 states (i.e., those states adopting the California
program), or over-compliance with the fleet of vehicles sold in the 50 states. EPA is also
providing for early credits based on over-compliance with CAFE, but only for vehicles sold in
states outside of California and the CAA section 177 states. Under the early credit provisions,
no early FFV credits are allowed, except those achieved by over-compliance with the
California program based on California's provisions that manufacturers demonstrate actual
use of the alternative fuel. EPA's early credits provisions are designed to ensure that there
would be no double counting of early credits. Credits for over-compliance with CAFE
standards during MYs 2009-2011 will still be available to be carried forward for
manufacturers to use toward compliance with CAFE in future model years, just as before.
EPA Advanced Technology Incentive: EPA provides an additional temporary incentive
to encourage the commercialization of advanced GHG/fuel economy control technologies--
including electric vehicles (EVs), plug-in hybrid electric vehicles (PHEVs), and fuel cell
LL EPCA does not permit such an allowance. Consequently, manufacturers who may be able to take advantage
of a lead-time allowance under the GHG standards would be required to comply with the applicable CAFE
standard or be subject to penalties for non-compliance, unless they qualified for an exemption/alternative CAFE
standard under 49 U.S.C. 32902(d).
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vehicles (FCVs)--for model years 2012-2016. The advanced technology vehicle incentive
program includes a zero gram/mile emissions compliance value for EVs and FCVs, and the
electric portion of PHEVs, for up to the first 200,000 EV/PHEV/FCV vehicles produced by a
given manufacturer during MY 2012-2016 (for a manufacturer that produces less than 25,000
EVs, PHEVs, and FCVs in MY 2012), or for up to the first 300,000 EV/PHEV/FCV vehicles
produced during MY 2012-2016 (for a manufacturer that produces 25,000 or more EVs,
PHEVs, and FCVs in MY 2012). For any production of EV/PHEV/FCV vehicles greater than
this amount, the compliance value for the vehicle will be greater than zero gram/mile, set at a
level that reflects the vehicle's net increase in upstream GHG emissions in comparison to the
gasoline vehicle it replaces.MM The Final Rule notes: "EPA will reassess the issue of how to
address EVs, PHEVs, and FCVs in rulemakings for model year 2017 and beyond, based on
the status of advanced technology vehicle commercialization, the status of upstream GHG
QA
emissions control programs, and other relevant factors."
EPA Off-cycle Credits: EPA is also providing an option for manufacturers to generate
credits for employing new and innovative technologies that achieve GHG reductions that are
not reflected on current test procedures. Examples of such potential "off-cycle" technologies
might include solar panels on hybrids, adaptive cruise control, and active aerodynamics,
among other technologies. This optional credit opportunity is currently available through the
2016 model year. Credits must be based on real additional reductions of CO2 emissions and
must be quantifiable and verifiable with a repeatable methodology.
5.2 Potential Credit Programs, Incentives, and Other Flexibilities for 2017 and Later
During the agencies' outreach with stakeholders, manufacturers provided early input
that several of the flexibility provisions in place for MYs 2012-2016 should be retained for
MY 2017 and later. Environmental groups also provided early input, as discussed below. As
EPA and NHTSA develop the proposed rule for MY 2017 and beyond standards, the agencies
will continue to consider the potential need for incentives and flexibilities in the 2017 and
later program, including whether and how some of EPA's MYs 2012-2016 provisions could
be applied to the new program, as well as whether any additional provisions would be
appropriate to address lead-time issues. Changes to flexibilities provided under EPCA/EISA
would require new legislation; NHTSA intends to develop any proposed standards within the
context of its statutory framework.
Most manufacturers support EPA continuing 3-year credit carry-back to cover prior
debits, 5-year credit carry-forward for use in future years, credit transfers between car and
truck categories, and credit trading between manufacturers. One manufacturer noted support
for unlimited credit carry-forward. These provisions, collectively known as Averaging,
Banking, and Trading (ABT), have been an important part of many mobile source programs
under CAA Title II, both for fuels programs as well as for engine and vehicle programs. EPA
believes, and manufacturers have confirmed, that ABT is important because it can help to
address many issues of technological feasibility and lead-time, as well as considerations of
MM See 75 FR 25436-25437.
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EPA will strongly consider proposing to continue these provisions in the MY 2017
and later program, as these types of compliance flexibilities will remain important as
standards become more stringent. As discussed above in Section 5.1, these provisions are
required by EPCA and EISA for the CAFE program.
While not a flexibility in the same sense as other credit programs and incentives
discussed in this chapter, several manufacturers supported the continued use of attribute-based
standards using the vehicle's footprint for setting GHG standards, consistent with EISA's
requirement that CAFE standards be attribute-based. A number of manufacturers also
supported the use of separate passenger car and light-truck standards for the GHG standards,
consistent with EISA's requirement that CAFE standards for cars and trucks be separate,
though one manufacturer indicated a single combined passenger car and truck standard
(though still attribute-based) should be considered.
Several smaller volume manufacturers have expressed continued concerns regarding
lead-time, and support for additional flexibility to address the unique needs of small volume
manufacturers such as the TLAAS program described above. In the MYs 2012-2016 Final
Rule, EPA determined that smaller volume manufacturers needed additional lead time to meet
the standards because their CO2 baselines are significantly higher and their vehicle product
lines are limited, reducing their ability to average across their fleets compared to larger
manufacturers. The need for this type of flexibility is tied closely to the level of stringency of
the standards to be proposed, and will be analyzed in that context.
EPA deferred small volume manufacturers (SVMs) with annual U.S. sales less than
5,000 vehicles from the MYs 2012-2016 standards. EPA plans to consider establishing
standards for these very small volume manufacturers as part of the MYs 2017-2025
rulemaking. SVMs noted in discussions that SVMs only produce one or two vehicle types but
must compete directly with brands that are part of large manufacturer groups that have far
more resources available to them. There is often a time lag in the availability of technologies
from suppliers between when the technology is supplied to large manufacturers and when it is
available to small volume manufacturers. Also, incorporating new technologies into vehicle
designs costs the same or more for small volume manufacturers, yet the costs are spread over
significantly smaller volumes. Therefore, SVMs typically have longer model life cycles in
order to recover their investments. SVMs further noted that despite constraints facing them,
SVMs need to innovate in order to differentiate themselves in the market and often lead in
incorporating technological innovations, particularly lightweight materials. Under the CAFE
program, manufacturers who manufacture less than 10,000 passenger cars worldwide
annually may petition for an exemption from generally-applicable CAFE standards, in which
case NHTSA will determine what level of CAFE would be maximum feasible for that
o c
particular manufacturer if the agency determines that doing so is appropriate.
^ NHTSA notes that it is statutorily prohibited from considering availability of credits (including the fuel
economy credits for alternative fuel capability) in determining what levels of CAFE stringency would be
maximum feasible for a given model year. 49 U.S.C. 32902(h).
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Several manufacturers have also expressed support for the continuation of A/C system
credits. EPA is strongly considering A/C credits for MYs 2017-2025. EPA has included A/C
credits in the initial emissions modeling done to support this report, as described in Chapter 6
and Appendix D. EPA plans to further evaluate the methodology used to determine credits,
including A/C-related test procedures.
Some manufacturers have also expressed support for the continuation of EPA's off-
cycle credits program. The off-cycle credits for new and innovative technologies are
currently available only through MY 2016. Manufacturers have noted that as long as the
credits represent real-world off-cycle emissions reductions, the credits should be able to be
generated beyond MY 2016. One manufacturer noted that company innovations do not end
with MY 2016 and that technologies will always exist which do not show up on the test
cycles. Also, credits give additional incentives for company investments in R&D and
innovations. EPA understands this perspective and will evaluate the off-cycle credits
provisions in the context of the MYs 2017-2025 program, including the potential need to
update the technology eligibility criteria for determining whether a technology qualifies as
new and innovative.
Some manufacturers encouraged EPA to continue to offer FFV credits. EPA finalized
provisions in the MYs 2012-2016 Final Rule to treat MY 2016 and later FFVs similarly to
conventional fueled vehicles, in that FFV emissions would be based on actual CO2 results
from emissions testing on the fuels on which it operates. In calculating the emissions
performance of an FFV, manufacturers may base FFV emissions in part on vehicle emissions
test results on the alternative fuel, if they can demonstrate that the alternative fuel is actually
being used in the vehicles. Performance will otherwise be calculated assuming use only of
conventional fuel. The manufacturer must establish the ratio of operation that is on the
alternative fuel compared to the conventional fuel. The ratio will be used to weight the CO2
emissions performance over the 2-cycle test on the two fuels. EPA will consider whether it is
appropriate to retain this approach in the MYs 2017-2025 rulemaking. In addition, one
manufacturer raised the concept of providing credits for CNG vehicles and vehicles operating
on E-25 and other bio-fuels.
In the MYs 2012-2016 Final Rule, EPA established four pathways for manufacturers
to earn early credits prior to MY 2012, and established baselines against which manufacturers
can earn credits. For MY 2017 and later, we believe the credit carry-forward provisions are
sufficient to provide manufacturers with credits for achieving reductions beyond those
required by the MYs 2012-2016 standards. No additional baselines or other provisions would
be needed if the credit carry-forward provisions remain in place.
For advanced technology vehicles, manufacturers support an advanced technology
vehicle incentive in the form of a 0 g/mile compliance value for electric operation for MYs
2017 and later. Two manufacturers also expressed support for additional credits in the form
of "bonus" credits or multipliers for advanced technology vehicles. EPA proposed a credit
multiplier for MYs 2012-2016 advanced technology vehicles but did not finalize it for reasons
o/r
described in the Final Rule. Some environmental and public interest groups expressed
concern that the 0 g/mi value does not adequately capture upstream emissions from the
charging of electrified vehicles, and believe an upstream emissions factor should be included
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in the compliance calculation for electrified vehicles. For CAFE compliance purposes, the
fuel economy of such vehicle models is determined consistent with petroleum equivalency
factors (PEFs) issued by DOE.87 Current EVs do not receive infinite fuel economy ratings
that would be equivalent to a 0 g/mi CC>2 emission rate; for example, the MY 2008 Tesla
Roadster received a fuel economy ratings of 248 mpg (equivalent to about 36 g/mi CC>2 based
on gasoline). EPA understands that the treatment of upstream emissions for EVs, fuel cell
vehicles, and the electric portion of PHEVs is a critical issue for the upcoming rulemaking,
and this issue is further discussed in Chapter 7.
5.3 Input on Non-regulatory Incentives from Stakeholders
In addition to the regulatory incentives and flexibilities discussed in the previous
section, the agencies recognize that there are many non-regulatory approaches that can
promote the commercialization of low-GHG light-duty vehicle technologies. These
approaches are outside the regulatory authority for NHTSA and EPA, but were raised in
many of our stakeholder meetings (in particular the OEMs and the automotive supply firms)
as potentially important drivers in the development and commercialization of advanced
technology vehicles. This section will only identify and briefly discuss those non-regulatory
strategies which were raised by stakeholders in our recent meetings. This is by no means a
comprehensive list or discussion of the potential non-regulatory policies and incentives which
could encourage low GHG/high fuel economy vehicles.
Federal research and development
The federal government performs automotive research and development (R and D)
that is ultimately transferred to the private sector. Several of the OEMs identified this type of
R and D support as an important the development of advanced vehicle technologies. The
Department of Energy (DOE) is the federal lead on automotive R and D with extensive
programs carried out at its national laboratories. DOE's FY2010 budget for the Vehicles
Technologies Program is $311 million, with major technology focuses on hybrid electric
systems, advanced engines, lightweight materials, and fuels technologies. Other federal
agencies have smaller programs, such as EPA which has a FY2010 budget of about $16
million. One major focus of EPA's program has been hydraulic hybrids, which are currently
being commercialized in heavy-duty vehicles. The Federal Transit Administration (FTA) of
the Department of Transportation (DOT) has a number of ongoing research and development
activities focusing on leading edge propulsion systems for buses designed to reduce operating
costs and harmful emissions. These activities include studies and demonstrations on vehicles
using plug-in hybrid electric, fuel cell, battery-dominant, and hydraulic hybrid technology.88
Federal financial assistance for private sector R and D and capital investment
Several of the OEMs and the automotive supply companies suggested that federal
assistance for R and D programs, as well as for capital investment, can play an important role
for the introduction of advanced technology vehicles. Historically, the federal government
has periodically provided financial assistance for private sector R and D through favorable tax
policies. More recently, the federal government has taken a much more proactive role in
stimulating private sector investments in new technologies by providing grants and low-
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interest loans to automakers and suppliers for R and D and capital investment in breakthrough
technologies with the potential to reduce fuel consumption and GHG emissions. For example,
DOE has an Advanced Technology Vehicles Manufacturing Loan Program that has received
appropriations of $7.5 billion for grants and loans to support the development of advanced
OQ
technology vehicles and associated components in the United States. The FTA has provided
approximately $100 million and plans to award an additional $75 million in FY 2010 under
the Transit Investments for Greenhouse Gas and Energy Reduction (TIGGER) Program.90
Through this Program, public transit agencies partner and contract with private sector
organizations, manufactures, system designers and integrators in acquiring and deploying new
technologies and systems that reduce energy and greenhouse gases. Additionally, through the
National Fuel Cell Bus Program (NFCBP), the FTA is leading a $50 million Federal effort
with the support and leverage of an additional $50 million in local and private contributions
for the innovative design and demonstration of fuel cell powered vehicles that have zero or
near-zero emissions. The ultimate objective of the NFCBP is the commercialization of fuel
cell buses. An additional $13.5 million has been appropriated under the Program in FY 2010.
Economic incentives for low-GHG vehicles
Some automakers told the agencies that the federal and state tax credits and grants
played an important role in sparking the initial hybrid vehicle market, and could play an even
more important role in promoting PHEVs and EVs in the future. Advanced technology
vehicles often have higher up-front costs, due to more expensive components and/or lower
production volumes, and any strategy that can reduce or offset the higher up-front cost to
consumers can remove one of the most important barriers to greater consumer demand. The
Energy Policy Act of 2005 established temporary federal income tax credits for buyers of new
hybrid, diesel, dedicated alternative fuel, and fuel cell vehicles that meet certain requirements.
For example, while available, consumers who purchased new hybrid vehicles received federal
tax credits that ranged from a few hundred dollars to as much as approximately $3,000 for the
Toyota Prius, the hybrid vehicle with the highest fuel economy. The federal hybrid vehicle
tax credit has been phased out for many manufacturers who have exceeded the cumulative
60,000 production cap per manufacturer for hybrids and diesel vehicles. More recently, the
American Recovery and Reinvestment Act of 2009 extended the tax credits to PHEVs and
EVs, which are now eligible for a federal tax credit up to $7,500 per vehicle for the first
200,000 cumulative vehicle production per manufacturer.
Some states, such as California, have also adopted state grants for certain advanced
technology vehicles. To date, both federal and state tax credits and grants for new vehicle
purchases have been provided to consumers, but it is also possible for tax credits to be
directed to manufacturers who sell advanced technology and/or low-GHG vehicles.
Another direct approach for reducing the up-front cost of advanced technology or low-
GHG vehicles to consumers would be a state sales tax exemption for buyers of vehicles that
meet certain requirements. Of course, without limitations such as cumulative production
caps, federal tax credits and exemptions from state sales taxes could have important impacts
on government revenues.
Non-economic incentives for owners of low-GHG vehicles
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Some automakers have specifically indicated that high occupancy vehicle (HOV)
access has been an important incentive for hybrid-electric vehicle owners, and could
potentially be for EV and PHEV owners as well. By providing two important incentives—
reduced travel time and improved trip time reliability—HOV lane access can be a big
incentive in some urban areas. The Safe, Accountable, Flexible, Efficient Transportation
Equity Act (SAFETEA-LU) of 2005 allows an exemption from the HOV occupancy
requirement for vehicles certified as "low emission and energy-efficient." Some state and
local governments have allowed drivers of certain advanced technology vehicles to use HOV
lanes regardless of the number of vehicle occupants. Analyses have suggested that HOV
access has been an effective incentive in promoting hybrid vehicle sales in certain urban
areas.00
Economic incentives for electric vehicle recharging systems/installation
One way to promote grid electricity use in EVs and PHEVs would be financial support
for vehicle recharging infrastructure. The American Reinvestment and Recovery Act
provides for a 50% tax credit on the installation of home charging equipment, up to a
maximum cost of $2,000, and on installation of commercial equipment up to a maximum cost
of $50,000. This tax credit expires at the end of 2010. Current home recharging systems cost
on the order of $2000 or so. These costs are expected to drop as charging systems become
more widespread and in higher volumes, as discussed further in Chapter 4. Public high-
voltage quick charging systems cost much more. Federal grants and/or tax credits to reduce
this cost would address another barrier to consumer demand. Many automakers have also
raised the practical challenges involved in the permitting process for charging stations.
Federal coordination to establish streamlined standards and codes for permitting processes
could assist in EV and PHEV commercialization.pp Several of the OEMs and automotive
suppliers suggested that these types of financial incentives for electric vehicle recharging
systems can play an important role in encouraging the purchase of PHEVs and EVs.
Tax incentives or disincentives
There are a number of tax incentives and disincentives that could be considered as part
of an overall strategy to promote low-GHG light-duty vehicle technology, such as higher
gasoline taxes (which would improve the relative economics of other fuels), a gasoline price
floor (which would preclude the risk of extremely low gasoline prices undercutting other
vehicle fuels), and reduced or zero alternative fuel taxes (for example, electricity currently
pays no excise/road tax, and there is uncertainty about whether this would be maintained if
and when EVs and PHEVS gain greater market share). A few of the OEMs suggested that
higher fuel taxes could be used to encourage the purchase of high fuel economy/low GHG
vehicles.
00 See, for example, "Impact of High Occupancy Vehicle (HOV) Lane Incentives for Hybrid Vehicles in
Virginia," David Diamond, LMI Research Institute, in Journal of Public Transportation, Vol. 11, No. 4, 2008,
pages 39-58. Accessed at http://www.nctr.usf.edu/jpt/pdf/JPTll-4Diamond.pdf.
pp See discussion in Chapter 4.
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Vehicle Labeling
Several stakeholders have emphasized the need for the federal government to educate
consumers about the energy and environmental performance of vehicles in general and
advanced technology vehicles in particular. On August 30, 2010, EPA and NHTS A jointly
announced proposed changes to the current fuel economy label for MY 2012 and beyond that
will provide new information (such as tailpipe CC>2 emissions) that will help consumers make
more informed purchase decisions.91 Among other changes, the joint proposal includes
several potential new label designs for PHEVs and EVs.
Chapter 5 References
84 75 Fed. Reg. 25435, 25341 (May 7, 2010).
8549U.S.C. 32902(d).
86 75 Fed. Reg. 25434, (May 7, 2010).
87 65 Fed. Reg. 36986-36992 (June 12, 2000). See also 49 U.S.C. 32904(a).
88 See, e.g., http://www.fta.dot.gov/documents/HydrogenandFuelCellTransitBusEvaluations42781-l.pdf.
89 http://www.atvmloan.energy.gov/
90 See http://www.fta.dot.gov/planning/planning environment 11424.html for more information on FTA's
TIGGER Program.
91 Revisions and Additions to Motor Vehicle Fuel Economy Label, Proposed Rule,
http://www.epa.gov/fuelecono my/regulations.htm#sticker.
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6 Analysis of Scenario Costs and Impacts
6.1 Context
The President's May 21 memorandum indicates that today's technical assessment
should inform the rulemaking process, and that the subsequent (to the technical assessment)
Notice of Intent (NOT) to Issue a Proposed Rule should describe, among other things,
potential standards that could practicably be implemented for the 2017-2025 model years.
For today's technical assessment, the agencies conducted an initial fleet-level analysis
of improvements in overall average GHG emissions and fuel economy levels. We have
analyzed a range of potential stringencies for model years 2020 and 2025 (i.e., progressively
lower GHG targets). We have also analyzed more than one illustrative technological pathway
by which these GHG targets could be met. We considered these different technology
pathways in order to address the difficulties in forecasting a single pathway and a single cost
estimate for the penetration of different advanced technologies into the light-duty vehicle fleet
at this time. We also believe this approach reflects the diversity in strategies we heard from
the OEMs during the stakeholder outreach meetings, who at this time indicated they are each
pursuing a range of technologies which they may use in the 2017-2025 time frame. The
agencies believe that the analyses presented in this technical assessment permit a reasonable
initial and approximate evaluation of the relative potential costs and effects of the aggregate
stringency levels evaluated in this report.
This analyses began with methods and information developed and applied in support
of the recently-promulgated GHG standards for the 2012-2016 model years, and also reflect
updates to the forecast of the future light vehicle fleet, as well as updates to the range and
characteristics of anticipated GHG and fuel-saving technologies (as discussed in Chapter 3).
However, we note, as discussed further below, that several of the simplifications
employed here would not be used for purposes of a full Federal rulemaking analysis. This
includes the requirements for both EPA and NHTSA to promulgate standards which meet
each agency's statutory requirements. The agencies have therefore provided a number of
caveats to today's analysis, discussed at greater length below.
6.2 Analytic Approach
This report presents modeling results that provide the technical basis for the analysis
provided by EPA, NHTSA, and CARB in this chapter. The modeling was performed by EPA
using the OMEGA model, which EPA utilized in the MYs 2012-2016 light-duty vehicle
rulemaking. The key inputs for the analysis (e.g., the technology costs and effectiveness) are
a result of the joint technical assessment of EPA, CARB, and NHTSA, as described in
Chapter 3 of this report.
OMEGA is EPA's vehicle greenhouse gas cost and compliance model, and it can be
used to simulate how manufacturers might respond to a specified vehicle CO2 emission
standard. Broadly, the model starts with a description of the future vehicle fleet, including
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different vehicle platforms,QQ sales, base CO2 emissions, attributes such as vehicle mass and
the extent to which CO2 reducing/fuel saving technologies are already utilized.
For the purpose of this analysis, over 60 vehicle platforms were used to capture the
anticipated important differences in vehicle and powertrain design and utility between now
and model year 2025. The model is then provided with a list of technologies which are
applicable to various types of vehicles, along with their cost and effectiveness and the
percentage of vehicle sales which can receive each technology during the time frame of
interest. The model combines this information with economic parameters, such as fuel prices
and a discount rate, to project how technologies could be added to vehicles in order to meet
various levels of GHG control. The result is a description of which technologies could be
added to each vehicle platform, along with the resulting cost, in order to meet a specified
GHG performance level.RR We note that for purposes of this Technical Assessment Report,
NHTSA did not perform modeling using the CAFE model, also referred to as the Volpe
modelss, to help analyze potential fuel economy standards as NHTSA has in recent CAFE
rulemakings. The Volpe model simulates how manufacturers might respond to potential fuel
economy standards on a yearly basis and supports analysis of fuel economy improving
technologies, economic effects, environmental effects and safety effects. For today's
technical assessment, the agencies decided to use the OMEGA model. In upcoming joint
rulemaking, NHTSA and EPA plan to make use of the CAFE and OMEGA models,
respectively, for purposes of examining potential future CAFE standards and GHG emissions
standards.
As discussed above, for this technical assessment, the vehicle fleet was analyzed as
one single industry wide fleet, irrespective of individual manufacturer differences. The size
and composition of the fleet is otherwise equivalent to our projection of the entire fleet
Q9
through model year 2025. Treating the entire fleet as a single fleet assumes, for example,
averaging GHG performance across all vehicle platforms is possible irrespective of who the
individual manufacturer is for a particular vehicle platform. This can be thought of as
analyzing the fleet as if there was a single large manufacturer, instead of multiple individual
manufacturers. Alternatively, it is equivalent to an assessment that assumes there are no
statutory limits on the ability to transfer credits between passenger car and light truck fleets
(which is the case under the CAA, but not under EISA), there are no market limits on the
ability to trade them between manufacturers, and that all manufacturers fully utilize such
flexibilities and experience no transaction costs in doing so.
QQ Vehicle platforms represent aggregations of similar vehicle models built by a manufacturer - for example, the
Dodge Caliber, Jeep Compass and Jeep Patriot are built from a single platform, and include a mix of passenger
cars and light trucks.
1111A description of OMEGA's specific methodologies and algorithms, as well as a copy of the peer review
documentation, is on the EPA website at http://www.epa.gov/oms/climate/models.htm.
ss DOT's CAFE Compliance and Effects Modeling System (commonly referred to as "the Volpe model") is
available at http://www.nhtsa.gov/Laws+&+Regulations/CAFE+-
+Fuel+Economv/CAFE+Compliance+and+Effects+Modeling+Svstem:+The+Volpe+Model. which also
provides model documentation, source code, inputs and outputs fromNHTSA's MY 2012-2016 rulemaking
analysis, and links to prior versions and analyses.
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This approach allows evaluation of multiple scenarios in the context of a long-term
technology-driven assessment. It focuses the analysis on the technology itself, independent of
the individual manufacturer, and produces a result that indicates how the fleet could
hypothetically achieve greater GHG reductions and increased fuel economy in the most
efficient manner. This approach also allows the assessment for this report to be performed
without consideration of the particular shapes of the passenger car and light truck attribute-
based curves, which are required by statute for CAFE purposes and will define the future
federal standards. The unlimited averaging that is modeled may reach the same result
irrespective of any specific attribute curves, and as long as the curves are calibrated to the flat
standard that is modeled here (without prejudging the outcome of those curves, which will be
carefully evaluated as part of the federal rulemaking process), the same fleet average may be
required.
We note that while the single fleet analysis approach simplifies some aspects of the
analysis and does offer some advantages, there are also important limitations which will be
addressed during the formal rulemaking process. Some of these limitations are statutory - the
requirements for CAFE under EPCA and EISA are more prescriptive than for GHG standards
under the CAA. Some of these limitations are more informational in nature - for example, a
simplified analysis leaves the agencies unable to consider certain information about the
potential effects of standards that the public (and particularly, the regulated manufacturers)
are accustomed to seeing in NHTSA and EPA analyses. The agencies recognize and
emphasize again that today's analysis, while reasonable at this early stage in developing a
National Program for post-MY2016 standards, is a first step, and that much more work will
need to be completed for the upcoming NPRM, including full modeling by both EPA and
NHTSA that will address each of the limitations, as discussed further below. As with the
MYs 2012-2016 final rule, the agencies' analyses for the NPRM will examine attribute-based
standards under which each manufacturer is subject to its own individual passenger car and
light truck CAFE and CC>2 requirements, where the standard for each manufacturer is based
on the production-weighted average of its passenger car and light truck targets, with the
targets established in the attribute-based curves. In the upcoming rulemaking both EPA and
NHTSA will also consider more than the overall industry-wide perspective provided in this
Report, and intend to analyze potential future CAFE and GHG standards in a manner similar
to that done for the MYs 2012-2016 rulemaking. For further information on the kinds of
comprehensive analyses performed for the MYs 2012-2016 rulemaking, see 75 Fed. Reg.
25324 (May 7, 2010).
EPCA as amended by EISA requires separate attribute-based CAFE standards for
passenger cars and light trucks, for each model year, that are the maximum feasible standards
T"T
for that fleet of vehicles in that model year. Today's analysis combines the passenger car
and light truck fleets, considers flat standards, and considers only a single model year out of
the nine model years that will be covered by the rulemaking.
TT 49 U.S.C. 32902.
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EPCA as amended by EISA allows manufacturers to pay fines in lieu of compliance1111
and subject to certain limitations allows manufacturers to earn, trade, and transfer credits (and
also earn credits for production of alternative-fueled vehicles in addition to simple over-
compliance with applicable standards),vv but does not allow the availability of credits to be
considered in determining what standards would be maximum feasible.ww Today's analysis
combines the passenger cars and light trucks of all manufacturers into a single fleet, which is
equivalent to assuming fully efficient trading and transfer of credits but is not allowed under
EPCA, and does not include the additional credit that manufacturers would get under EPCA
and EISA for alternative-fueled vehicles.
In determining what passenger car and light truck standards would be maximum
feasible in each model year, EPCA as amended by EISA requires NHTSA to consider and
balance four statutory factors: technological feasibility, economic practicability, the effect of
other motor vehicle standards of the Government on fuel economy, and the need of the United
States to conserve energy. While the tables of information presented below concerning
technology cost, effectiveness, and lead-time, fuel savings and GHG emissions avoided, and
other things, would help to inform NHTSA's consideration of many of the statutory factors,
this information alone may not be sufficient for purposes of a full rulemaking analysis. Other
pieces of information have historically been used to decide what standards would be
maximum feasible for each fleet for each model year, as discussed below.
By modeling a single fleet rather than separate fleets for different manufacturers, we
show the most cost-effective hypothetical path for the industry, as a whole, to any specific
overall average fuel economy level or GHG emission level. Differential impacts on
individual manufacturers, based on the different standards applicable to them given the
production-weighted average of their specific passenger car and light truck targets (with the
targets established in attribute-based curves), are thus not reflected in the current analysis. In
addition, in representing the market as a single fleet produced by a single manufacturer,
today's analysis exhausts available technologies only when, given input assumptions
regarding technology applicability and phase-in potential, no further technology can be
applied to any vehicle model. In contrast, in past rulemakings when the fleet is represented in
terms of discrete manufacturers' separate passenger car and light truck fleets, some
manufacturers have been estimated to exhaust available technologies in some model years at
stringencies well below those that would cause the aggregated manufacturer of a combined
fleet to do so. This occurs because manufacturers produce different mixes of vehicles, with
different levels of baseline technology utilization.
This is information that has historically been relevant to NHTSA's determinations of
whether standards are economically practicable.^ Understanding and recognizing the
™ 49 U.S.C. 32912.
vv 49 U.S.C. 32903, 32905, 32906.
** 49 U.S.C. 32902(h).
** For example, in its recent analysis of its final MY 2016 CAFE standards, NHTSA estimated that required
CAFE levels for passenger cars would average 37.8 mpg, but would range from 34.2 mpg (for Jaguar) to 4 1 . 1
mpg (for Porsche). Additionally, that same analysis estimated that passenger car cost increases (relative to
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differential impact of standards on manufacturers is one of the issues with which NHTSA has
grappled in determining maximum feasible standards. While the agency should not key its
standards to the least capable manufacturer, the agency should be aware of the impacts in
making its decision, since economic practicability is determined in part by the effects of the
standards on vehicle manufacturers. The results presented in this report represent what the
three agencies expect a hypothetical comprehensive-line vehicle manufacturer could achieve,
given the assumptions made here regarding the composition of the fleet and the availability,
cost, and effectiveness of various technologies. Note that the results presented here assume
trading between auto firms, which has not occurred in the past and may not occur in the
future. Among actual full-line vehicle manufacturers, we expect that a manufacturer-specific
assessment based on footprint-attribute standard curves will result in costs which are higher
and lower for the actual full-line manufacturers than a fleet-wide average due to the
differences among their product offerings. With respect to smaller volume manufacturers and
very low volume manufacturers (many of whom only produce high-performance luxury
vehicles), the agencies would expect that, in general, the level of technology they would
require and the costs they would incur would be higher than presented today, all other things
being equal. Thus, in future analysis done for the joint federal rulemaking NHTSA and EPA
would expect individual companies' projected costs will be higher or lower than the costs
shown here, depending on their particular fleet mixes. The results of this more detailed
analysis which will look at individual manufacturers could potentially change NHTSA's
evaluation of what CAFE standards are maximum feasible.
In addition, today's analysis includes estimates of cost increases associated with the
application of additional fuel-saving technology, as well as estimates of the corresponding
reductions in fuel consumption and CC>2 emissions, but does not include estimates of the
corresponding social benefits. In the rulemaking the agencies will consider a much broader
ranges of impacts of the standards.w Estimates of social benefits both reflect and inform
NHTSA's consideration of the four statutory factors, and are often a subject of great interest
among commenters to CAFE and GHG rules.
Finally, today's analysis does not include an evaluation of potential safety effects of
new standards. NHTSA has historically considered safety effects along with the four
statutory factors in determining appropriate levels of CAFE stringency, a practice recognized
approvingly in case law over several decades. EPA also considered the potential safety
effects of the 2012-2016 GHG standards in that recent rulemaking. Although today's analysis
compliance with the MY 2011 standard) would average $907 in MY 2016, but would range from $126 for
Toyota to $1,884 for Ford. NHTSA also found that, without using credits, instances of technology exhaustion
among a number of manufacturers would increase rapidly as stringencies increase faster than 4% annually. The
aggregated approach of today's analysis would have shown almost no technology exhaustion among the
regulatory alternatives considered by NHTSA in the MY 2012-2016 final rule. See, e.g., 75 Fed. Reg. at 25600
(May 7, 2010).
YY For example, NHTSA's and EPA's analysis supporting the MYs 2012-2016 final rule include estimates of
social benefits associated with fuel costs (setting aside taxes), economic impacts of petroleum dependence, the
social cost of carbon dioxide emissions (and criteria pollutant emissions), social costs (e.g., additional highway
congestion) and benefits (the value of additional travel) of additional travel demand induced by fuel economy
increases, and other factors.
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considers significantly greater levels of mass reduction than considered for the MYs 2012-
2016 final rule, it does not yield estimates of the corresponding safety implications. As
discussed in Chapter 3, NHTSA, EPA, and DOE have undertaken a number of important, new
safety-focused analyses to inform the future joint Federal rulemaking. NHTSA and EPA will
include a detailed assessment of safety impacts at that time.
Section 202(a) of the Clean Air Act, in contrast, provides broad discretion regarding
how EPA can consider relevant factors in establishing GHG emissions standards for light-
duty vehicles. For example, in setting GHG standards, section 202(a) of the CAA allows for
the consideration of the availability of transferred or traded credits earned for over-
compliance, the availability of credits for the use of advanced technologies and for A/C, and
other credit-generation mechanisms. This broader discretion to reflect anticipated
manufacturer behavior in response to available compliance flexibilities could allow standards
established under the CAA to be more stringent than could be established under EPCA as
amended by EISA, because the CAA allowed analysis would be able to show that more
stringent standards could be feasible when those flexibilities are taken into account.
However, as noted in several other locations in this report, there is significant additional
information and analysis which EPA (and NHTSA) believe are necessary in order to support
the future federal rulemaking, and EPA intends to develop a detailed analysis similar to that
performed for the MY2012-2016 standard setting rulemaking, and to consider many of the
same kinds of factors as it did in that rulemaking.
We emphasize again, however, that the upcoming rulemaking to develop the next
phase of the National Program will be based on a full analysis that is consistent with both the
statutory framework that provided under EPCA as amended by EISA, and the flexibilities that
can be considered under the CAA, just as the detailed analysis for the MYs 2012-2016 was
conducted. With these explanations and caveats, NHTSA and EPA believe today's analysis
provides a useful means of comparing the scenarios discussed below.
6.3 Development of Technology Pathways
The analysis for this Technical Assessment Report considers two model years - 2020
and 2025; four "technology pathways" - "A," "B," "C" and "D;" and four potential rates of
increase in fleetwide average stringency - 3%/year, 4%/year, 5%/year, and 6%/year. This
section of Chapter 6 discusses each of these elements, 6.4 describes other key inputs
employed in the analysis, 6.5 presents the results of the analysis., and in 6.6 we present a
sensitivity assessment related to battery cost estimates.
6.3.1 Model Years Considered
The analysis for this Technical Assessment Report considered two model years, 2020
and 2025. Vehicles are typically redesigned every 5 years on average, and tend to receive a
more modest "refresh" between major redesigns. By assessing potential scenarios at a five-
year increment, we base our assessment on an assumption of the efficient use of capital
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77
investments, engineering, financing, and other resources. This approach predicts that
manufacturers therefore have the opportunity to redesign vehicles by 2020, and again by
2025.
6.3.2 Scenario Stringencies Assessed
For each model year and each technology pathway (described below) we analyzed
four potential GHG targets representing a 3, 4, 5 and 6% decrease in GHG levels - that is,
starting with a 250 gram/mile overall average requirement in MY 2016, the g/mile CC>2
scenario fleet-wide target was lowered at the rates of 3% per year, 4% per year, 5% per year,
and 6% per year.AAA The 3, 4, 5, and 6% annual stringency increases were chosen for
evaluation because they represent a reasonably broad range of targets for this initial
assessment and because the rates of increase are consistent with CARS's letter of
commitment in response to the President's memorandum. The assessment for each scenario
is characterized using four broad metrics: per-vehicle cost increase, vehicle technology mix,
net reduction in GHG emissions, and net reduction in fuel consumption. BBB
The scenario stringencies are shown below in terms of the specific grams/mile CO2
values analyzed for MY 2020 and 2025, and like the 250 g/mile standard, include the
potential usage of air conditioning emissions reductions (Table 6.3-1). Air conditioning
emissions reduction in the 2025 time frame was estimated at 15 grams compared to a 2008
baseline system for all four technology paths.ccc'93 The increase in estimated air conditioning
reductions relative to those projected in the MYs 2012-2016 timeframe is largely due to an
anticipated increase in the use of alternative refrigerants.DDD Note that EPA has not made any
determination at this time whether reductions due to improvements in air conditioning should
be treated as a credit or a requirement during the 2017-2025 timeframe.
zz The MYs 2012-2016 final rule discusses the 5-year vehicle redesign practice in much more detail; see 75 FR
at 25445 and 25573.
AAA For this assessment these future targets were modeled as a flat, or universal, standard, rather than as
attribute-based standards. Since the difference between attribute-based and flat standards is that flat standards
apply the same requirement to every manufacturer in the fleet, while attribute-based standards allow different
requirements depending on the vehicles that each manufacturer produces for sale, modeling the entire new
vehicle fleet as if it were a single automotive firm causes flat standards and attribute-based standards to produce
the same average required stringencies. For the upcoming joint federal rulemaking, NHTSA and EPA will
propose attribute-based standards.
BBB Additional impacts from fuel economy/CO2 standards such as co-pollutants, the social cost of carbon, or
energy security premiums could be quantified. While this text does not discuss these topics, as discussed above,
they are extensively discussed in the recent 2012-2016 final rule and will be discussed in the upcoming joint
federal rulemaking.
ccc While the air conditioning reductions were modeled in this analysis, their relative cost-effectiveness suggests
that manufacturers will use them to meet any standard. As the MYs 2012-2016 final rule allowed for a similar
crediting program, all costs and benefits from the A/C system control are present in the reference case (MY
2016) as well. A more complete discussion of the potential reductions in leakage from air conditioning systems
is presented in Appendix D to the Technical Assessment Report.
DDD In this analysis, EPA anticipates that prior to the MY 2020 timeframe, low GWP refrigerants will be
approved under the Significant New Alternatives Policy Final Rule (1994). The use of low GWP refrigerants in
this analysis does not indicate a decision on behalf of EPA.
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Table 6.3-1: Modeled GHG Targets
Scenario Title
3% per year
4% per year
5% per year
6% per year
CO2 Target (g/mile)
in MY 2020 (MPG)
221 (40)
212 (42)
204 (44)
195 (46)
CO2 Target (g/mile)
in MY 2025 (MPG)
190 (47)
173(51)
158(56)
143 (62)
Note: The targets evaluated were CO2 targets which could be meet through reductions in CO2 as well as
through air conditioning system hydroflurocarbon reductions converted to a CO2 equivalent value. MPGe is the
equivalent MPG value if all of the CO2 reductions came from fuel economy improvement technologies. Real-
world CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent lower. Thus, the
3% to 6% range evaluated in this assessment for MY 2025 would span a range of real world fuel economy
values of approximately 37 to 50 mpg, which correspond to the regulatory test procedure values of 47 and 62
mpg, respectively.
The reference case GHG emissions scenario assumes no further improvements in CO2
emissions from the 2016 final rule standards, which are projected to produce a fleet wide
average of approximately 250 grams CC>2 per mile. This projected fleet wide average is
assumed to remain in place indefinitely. We also assume that the fleet mix, including market
segmentation, is unchanged between scenarios, though it does change over time from 2016 to
2025 as discussed in Appendix A. Additionally, we did not explicitly model any crediting
schemes in this analysis, other than the air conditioning emission reductions which are a
fundamental component of EPA's MYs 2012-2016 program, and the allowance of unlimited
car-truck credit transfer and inter-manufacturer trading which result from combining
individual manufacturers into a single industry-wide fleet.
6.3.3 Technology Pathways Considered
As discussed in the introduction to this Chapter, the use of distinct "technology
pathways" illustrate that there are multiple mixes of advanced technologies which can achieve
the range of GHG targets we analyzed. The approach of considering four technology
pathways for this assessment was chosen for several reasons. First, in our stakeholder
meetings with the auto manufactures, the companies described a range of technical strategies
they were pursuing for potential implementation in the 2017-2025 time frame. For example,
some firms are pursuing an HEV focused strategy and others a mass reduction and next
generation gasoline/diesel engine focused strategy. Using multiple technology pathways
allows the agencies to evaluate how different technical approaches could be used to meet
progressively more stringent scenarios.
Second, this approach helps to generally capture the uncertainties we see with
forecasting the potential penetration of and costs of different advanced technologies into the
light-duty vehicle fleet ten to fifteen years into the future at this time. As discussed in
Chapter 3, there is significant on-going technology development work occurring at the auto
companies and in the broader automotive supply base on a large range of advanced
technologies. The three agencies also have on-going technology cost, safety, and
effectiveness work which has not been completed. Therefore we believed it is appropriate for
this initial technology assessment to consider more than one technology pathway.
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What are the four technology pathways?
• Pathway A is intended to portray a technology path focused on HEVs, with less
reliance on advanced gasoline vehicles and mass reduction, relative to Pathways B and
C.
• Pathway C represents an approach where the industry focuses most on advanced
gasoline vehicles and mass reduction, and to a lesser extent on HEVs.
• Pathway B represents an approach where advanced gasoline vehicles and mass
reduction are utilized at a more moderate level, higher than in Pathway A but less than
Pathway C.
• Pathway D represents an approach focused on the use of PHEV, EV and HEV
technology, and less reliance on advanced gasoline vehicles, mass reduction.
For MY 2025, as will be seen in the following section which presents the results of the
assessment, as the CO2 stringency scenario increases progressively from 3% per year to 6%
per year, the extent of electrification of the fleet (the combined penetration of HEVs, PHEVs,
and EVs) increases for each of the three pathways. However, the degree of electrification is
highest for Pathways A and D, and the least for Pathway C. This occurs because under
pathway C, there is a higher degree of mass reduction and a higher penetration of advanced
gasoline, which means that the penetration of HEV/PHEV/EVs needed to achieve the CO2
stringency is lower, as compared to Pathways A, B and D. This impact is seen clearly for the
4%, 5%, and 6% per year stringency scenarios. However, for the 3% per year scenario the
distinction between Pathways B and C are very small, because the level of stringency is low
enough that it requires only a modest level of mass reduction and advanced gasoline vehicle
technology and the degree of electrification needed to meet the CO2 target (190 g/mile CO2
in MY 2025) for Pathways B and C is minimal. Pathway D has the highest level of EVs, and
also high levels of HEVs, in particular when compared to Pathways B and C.
For MY 2020, in contrast, there is little distinction between the technology projected
for the technology pathways A, B, and C for the 3%, 4%, and 5% per year scenarios, because
the overall level of stringency for each of these scenarios in MY 2020 is modest, and the
overall difference between the MY2020 emission target for 3%, 4%, and 5% per year is small
compared to in MY 2025. For example, the 3% and 4% per year targets in MY 2025 are 17
g/mile CO2 apart, but in MY 2020, the 4% per year target is only 9 g/mile more stringent than
the 3% per year scenario (See Table 6.3-1 above). The combination of the less stringent
targets in MY 2020 and the smaller delta between the emission targets results in only small
differences between Pathways A, B, and C for the 3%, 4%, and 5% per year targets for
MY2020. Only with the most stringent scenario analyzed for MY 2020, the 6% per year
scenario, is there a significant difference in the technology penetrations between Pathways A,
B and C for MY 2020. Note that due to time constraints we were not able to assess MY2020
for Pathway D.
All four of these pathways include significant amounts of mass reduction, relative to
2008 model year vehicles, ranging from 15 to 30% in 2025. The ability of the industry to
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reduce mass at the higher end of this range is an open technical issue which the agencies are
carefully evaluating and will continue to as we move forward. In addition, as discussed in the
joint 2012-2016 NHTSA and EPA final rule, the effects of vehicle mass reduction on safety
should be analyzed from a societal fatality perspective, which could affect the maximum
levels used for the future joint federal rulemaking. Although those effects have not been
included in this Report, the two agencies will consider them for the future joint federal
rulemaking. As discussed in Chapter 3, NHTSA, EPA, and DOE have a number of on-going
projects in this area which will inform the future joint federal rulemaking.
The agencies note that these pathways, of course, are meant to represent ways that
manufacturers could respond to eventual standards, and do not represent ways that they must
respond to those standards. EPA's GHG standards and NHTSA's CAFE standards are
performance-based and not technology mandating - manufacturers have wide discretion to
apply the technologies that they choose in meeting the standards.
How are the different technology pathways implemented in the analysis?
In order to analyze four distinct technology pathways, we developed maximum
technology penetration rates which we could implement within the OMEGA model. These
maximum technology penetration rates are discussed in Chapter 3. These penetration rates
were informed by the range of technology approaches we heard from different auto
companies, and represent the three agencies' initial assessment of potential technology
feasibility and lead time considerations for model year 2025.
A large number of technologies were considered by the agencies and are used in this
analysis (see Chapter 3 for a detailed discussion of all the technologies considered). For the
purposes of evaluating the four technical pathways, we assessed the impact of approaches
which placed a different emphasis on broad technology classes. The broad technology classes
evaluated for purposes of this analysis are defined below. For a more detailed discussion of
any individual technology, please see Chapter 3 of this report:
• Conventional Spark Ignition (SI) - This technology category includes all technologies
that are not contained in other categories such as gasoline direct injection engines,
cylinder deactivation, six and eight speed automatic and dual clutch transmissions, and
start-stop micro-hybrid technology.
• Advanced SI - This technology includes gasoline spark ignition engines which are
currently under development by OEMs and suppliers and are not anticipated to be
widely used in the 2012- 2016 time frame. For purposes of this analysis, based on the
agencies expert judgment to define these advanced SI engines, we modeled a direct
injection gasoline engine with cooled exhaust gas recirculation, and with a larger
degree of engine downsizing and higher level of turbocharging as compared to the
turbo-downsized engines included in our analysis for the MYs 2012-2016 final rule.
This technology is discussed in detail in chapter 3, and is similar to the technologies
that many OEMs indicated were underdevelopment and which they anticipate will be
introduced into the market in the 2017-2025 time frame.
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• Hybrid - While the agencies recognize there are many types of full-hybrids either in
production or under development, for the purposes of this analysis we have
specifically modeled two types of hybrids, P-2 and 2-Mode type hybrids.
• Plug-in Hybrid (PHEV) - This technology includes PHEV's with a range of 20 and 40
miles and is discussed in Chapter 3. As discussed in Appendix B, we project that
PHEV technology is not available to some vehicle types, such as large pickup. While
it is possible to electrify such vehicles, there are tradeoffs in terms of cost, electric
range, and utility that would reduce the appeal of the vehicle to a narrower market.
• Electric Vehicle (EV) - This technology includes vehicles with actual on-road ranges
of 75, 100, and 150 miles. The actual on-road range was calculated using a projected
30% gap between two-cycle and on-road range. These vehicles are powered solely by
electricity and are not powered by any liquid fuels. As with PHEVs, and as discussed
in Appendix B, we assumes that EV technology is not available to some vehicle types,
such as large pickup. While it is possible to electrify such vehicles, there are tradeoffs
in terms of cost, range, and utility that would reduce the appeal of the vehicle to a
narrower market. These trade-offs are expected to reduce the market for other vehicle
types as well, and for this analysis we have considered this in the development of the
maximum technology penetration rates we use for the three pathways as discussed in
Chapter 3. Note that for this assessment, we modeled EVs and did not consider fuel
cell vehicles (FCVs). An assessment could be done considering FCVs in addition to
EVs. However, such an assessment would need to carefully consider the availability
of the necessary infrastructure to support FCV penetration.
• Mass Reduction - This technology includes material substitution, smart design, and
mass reduction compounding. The actual amount of reduction from the 2008 baseline
was determined based on CBI provided by vehicle manufacturers, assessments
provided by material suppliers, and existing studies in the literature, including the
2010 report from Lotus Engineering. As discussed above as well as in Chapter 1 and
Chapter 3, NHTSA and EPA intend to conduct a thorough assessment of the levels of
mass reduction that could be achieved which is both technologically feasible and
which can be implemented in a safe manner for the joint federal NPRM.
Chapter 6.4 discusses additional key inputs used in our technical assessment, and Chapter
6.5 presents the results of the assessment.
6.4 Other Key Inputs to the Analysis
In addition to the technology effectiveness and cost estimates detailed in Chapter 3,
and the development of the four technology pathways discussed above, key inputs to today's
analysis are summarized below, and are discussed in more detail in Appendix E.
Vehicle Sales - The vehicle sales projection is based upon output from the National Energy
Modeling System (NEMS) which is maintained by the Department of Energy's Energy
Information Administration. As in the MYs 2012-2016 Final Rule, the car and truck split was
drawn from NEMS, while market segmentation was drawn from CSM Worldwide's
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forecasting tool. Total market size is estimated in 2025 at 17.0 million vehicles (58% cars).
Cars, in the context of NEMS, are defined using the pre-MY 2011 CAFE definition. For this
analysis the DOT Volpe Center produced a custom run of NEMS. This run generated the
same overall vehicle sales as the Reference Case for the Energy Information Administration's
Annual Energy Outlook (AEO) 2010,94 but a different sales split between cars and light
trucks. A detailed discussion on this topic is presented in Appendix A.
On-road Fuel Economy Shortfall - The "on-road gap" is the difference between the fuel
economy experienced and the CO2 emissions emitted in actual driving, as opposed to the
higher fuel economy and lower emission level experienced on the specified emissions tests
(the FTP and the HFET). The gap includes the real-world effects of wind, road grade, air
conditioning usage, and a variety of other factors. As in the MYs 2012-2016 final rule, we
assume a 20% gap from certification results, similar to today's vehicles for internal
combustion engines, as determined in EPA's 2006 fuel economy labeling rulemaking.95
Based on engineering judgment, the 2006 labeling rule analysis, and Confidential Business
Information, we estimated a larger, 30% gap from test results for power consumed by electric
motors in PHEVs and EVs in-use compared to the emissions test procedure.
Fuel Prices - The gasoline and electricity prices used in today's analysis are drawn from the
Reference Case Scenario AEO 2010.96 The gasoline fuel prices were $3.49 in 2025 including
all taxes.EEE Electricity prices are projected at approximately $0.11 in 2025 and gradually
increase beyond that point. Beyond 2035, fuel prices were extrapolated, and the details are
discussed in Appendix E.
Vehicle Miles Traveled Assumptions, Survival rates- VMT schedules and survival rates
are available in Appendix E. Expected lifetime VMT is approximately 207,000 miles for cars
in the 2025 time frame and approximately 246,000 miles for trucks in the 2025 time frame.
While long term trends for VMT growth are uncertain, these schedules reflect the same
projection methodology used in the MYs 2012-2016 final rule.97 As in the 2012-2016 final
rule, these values derive from assumptions made in AEO 2010.
VMT Rebound - Chapter Four of the Joint Technical Support Document to the recent MYs
2012-2016 final rule surveys previous studies, summarizes recent work on the rebound effect,
and explains the basis for the 10 percent rebound effect EPA and NHTSA are using in the
current technical analysis.98 The use of a 10 percent rebound effect in this analysis reflects an
assumption that the rebound effect applicable to the MYs 2012-2016 vehicles will remain
applicable throughout future time periods.FFF The agencies plan to conduct new analysis of
the expected rebound effect in this time frame in a future rulemaking.
Upstream Emissions - The upstream emission factors for gasoline is the same as that used in
the MYs 2012-2016 final rule (2,478 g CO2eq / gallon). 99 For the present report, we rely
EEE Note fuel taxes are included when models select technology options and when conducting payback analysis.
However fuel taxes are not used for calculating social benefits.
FFF It should be noted, however, that CARB, when adopting its initial GHG standards for MYs 2009-2016, relied
on a study that found that a rebound effect on the order of 3 percent was appropriate.
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upon the electricity emission factors produced by the EPA Office of Atmospheric Programs
for an analysis of the American Clean Energy and Security Act of 2009 (H.R. 2454). °° This
scenario assumes no new power sector regulations, but does assume construction of new
plants to replace older retired plants. In 2025, it is assumed that electricity generation at the
plant is equivalent to 558 g CC>2 eq/kwh. This value should be adjusted upwards for feedstock
gathering, transmission losses, and losses while charging the vehicle. After adjustment, the
2025 electricity emission factor is approximately 703 g CC>2 eq for each kW-hour consumed
from the battery pack.
Global Warming Potentials -The global warming potentials (GWP) used in this analysis are
consistent with the MYs 2012-2016 final rule and with the 2007 Intergovernmental Panel on
Climate Change (IPCC) Fourth Assessment Report (AR4). These GWP values are 1430 for
HFC, 298 for NO2, and 25 for CH4. 101 At this time, the 1996 IPCC Second Assessment
Report (SAR) global warming potential values have been agreed upon as the official U.S.
framework for addressing climate change and are used in the official U.S. greenhouse gas
inventory submission to the United Nations climate change framework, which is consistent
with the use of the SAR global warming potential values in current international agreements.
There are slight differences between SAR and AR4 values, most notably a 10% increase in
the value used for HFC.
6.5 Results of Analysis
This section presents the results from our modeling assessment of future stringency
scenarios using the four technology pathways described in Chapter 6.3. The inputs are
discussed in Chapter 3 of this technical report, and a detailed description of the analytic
methodology is provided in Appendix F. In addition, all of the modeling input and output
files used for the assessment are available on the web.000
This section presents the assessment results for model year 2020 and 2025. First, we
present results at a "fleet-wide" level, that is at an aggregated level for the new model year
fleet in 2025, for the four technology pathways we analyzed. The four technology pathways
are discussed in detail in Chapter 6.3. Second, we present results at a car-fleet and truck-fleet
level, in order to show the range of costs and impacts at a more detailed level. This is
followed by the fleet-wide level results for the MY2020 assessment.
The following tables show summaries of per-vehicle increases in costs, as well as fleet
wide reductions in fuel consumption and GHG emission reductions. The costs, fuel savings,
and GHG emission reductions are calculated against the reference fleet of MY 2025 vehicles
complying with the MY 2016 standards. The listed reductions in GHG emissions and fuel
consumption are cumulative over the lifetime of the selected model years, and are the delta
between the GHG emissions and fuel consumption under the MY 2016 reference case and the
selected emission control/fuel economy scenario.
GGG The input files, modeling tool, and output files used for this Technical Assessment Report are available at
http://www.epa.gov/oms/climate/models.htm
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In the assessment of potential future ranges of stringency presented in this report, we
based our compliance analysis on the tailpipe emissions from all vehicles - thus EVs were
evaluated at a 0 gram/mile CO2 level and PHEVs were evaluated as 0 gram/mile for the
electric drive portion of the vehicles operation. For the purposes of the GHG impacts, we
have included the resultant increase in upstream CO2 from the use of PHEVs and EVs in our
overall calculation of the net CC>2 reductions for each of the scenarios evaluated. As a result,
a single stringency scenario may have a range of CO26 impacts depending on the
electrification of the fleet.
Based on our initial assessment in this report, we see that the conventional vehicle
technologies are typically more cost effective than any of the other technology options,
followed by advanced spark-ignition (SI) engines, hybrids, electric vehicles, and PHEVs (see
Table 6.5-2 for example).HHH Mass reduction, which is generally highly cost effective, is
often among the first technologies chosen. In our modeling assessment, vehicle technologies
are applied in a ranked manner that values cost-effective reductions in fuel consumption and
CC>2 emissions.
The cost of the MY 2025 scenarios for the entire new vehicle fleet ranges from $773
(3%, Path C) to $3,455 (6%, Path A) per vehicle, as shown in Table 6.5-1. Technology
pathway C, which relies upon advanced gasoline technology and greater mass reduction as
compared to Pathway A and B, demonstrates the lowest costs. Pathway A and B show a
greater electrification of the fleet and somewhat higher costs.
The GHG reduction over the lifetime of the MY 2025 vehicles ranges from 343
million metric tons (MMT) CC^e avoided in the 3% scenario to between 531MMT and 593
MMT CO26 in the 6% scenario. The range in CC>2 emission reduction is due to differing
degrees of fleet electrification under the technology pathways. MY 2025 vehicles, over the
course of their lifetimes, will reduce between 0.7 billion barrels of gasoline consumption
under the 3% scenario to 1.3 billion barrels under the 6% scenario. For reference, the
NHTSA & EPA National Program in MY 2016 is projected to reduce 0.6 billion barrels of
fuel and 325 MMT CO2e over the lifetime of MY 2016 vehicles.
Table 6.5-1: Assessment Projections for Model Year 2025 Vehicles by Technology Path
Scenario
3%/year
4%/year
5%/year
6%/year
New Fleet Target
CO2
190
173
158
143
MPGe*
46.8
51.4
56.2
62.1
Path A
$930
$1,700
$2,500
$3,500
Per- Vehicle Cost increase
($)
PathB
$850
$1,500
$2,300
$3,200
PathC
$770
$1,400
$2,100
$2,800
PathD
$1,050
$1,900
$2,600
$3,400
HHHWe did not assign an explicit monetary value to driving range, and as a consequence, the model typically
chose shorter range electric vehicles (EV75) over longer range electric vehicles (EV150), as each produced the
same statutory CO2 reduction. The agencies will consider this issue in the context of a future rulemaking.
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Scenario
3%/year
4%/year
5%/year
6%/year
Lifetime
CO2e Reduction (MMT)
Path A
340
440
520
530
PathB
340
440
520
550
PathC
340
440
530
590
PathD
340
405
440
470
Lifetime
Gasoline Reduction (Billion Barrels)
Path A
0.7
0.9
1.1
1.3
PathB
0.7
0.9
1.1
1.3
PathC
0.7
0.9
1.1
1.3
PathD
0.7
0.9
1.1
1.3
Note - these costs, CO2 reductions, and fuel savings are relative to the 2016 EPA GHG standards. Per-vehicle
cost represented the estimated cost to the consumer, including the direct manufacturing costs for the new
technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto
manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of
indirect costs.
* MPGe is the MPG equivalent to the CO2 target if all CO2 reductions occur from fuel economy improvement
technologies. Real-world CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent
lower. Thus, the 3% to 6% range evaluated in this assessment would span a range of real world fuel economy
values of approximately 37 to 50 mpg, which correspond to the regulatory test procedure values of 47 and 62
mpg, respectively. For the technical assessment, we have estimated a reduction of 15 g/mile CO2 equivalent
from air conditioning system improvements, which would not actually translate into MPG improvements.
The penetration of HEVs, EVs, and PHEV in MY 2025 varies considerably depending
on the technology pathway and scenario, as can be seen in Table 6.5-2. As discussed in
Chapter 6.3, Technology Pathway A places greater focus on HEV technology and less
emphasis on mass reduction and advanced gasoline engine technology. Thus, in the 3%/year
scenario, Path A results in 11% HEV penetration, and the most stringent 6% scenario
increases HEV penetration to 68% for Path A, all with approximately a 15% reduction in
mass for the new vehicle fleet.
Pathway C places greater emphasis on mass reduction and advanced gasoline vehicle
technology, and therefore the penetration of HEVs ranges from 3% up to 44% of the new
vehicle fleet. The penetration of gasoline and diesel vehicles for each of the stringency
scenarios is highest for Pathway C, and the degree of mass reduction is also the highest
among the four pathways, ranging from 18% to 26%.
Pathway B shows a technology approach in between Paths A and C, with advanced
gasoline technology and mass reductions higher than for Path A but lower than Path C, and
HEV penetrations lower than Path A but higher than Path C. This trend is not as strong for
the 3% per year stringency scenario because the level of stringency does not require enough
advanced technology to show much of a difference between Pathways B and C.
Pathway D places a greater emphasis on PHEV and EVs than the other three
technology paths. As a consequence, there are lower penetrations of advanced gasoline
engines and of mass reduction, but more electric vehicles than in the other three pathways.
Table 6.5-2: Assessment Projections for Model Year 2025 Vehicles
New Fleet Technology Penetration Estimates
Scenario | Technology
New Vehicle Fleet Technology Penetration
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3%/year
4%/year
5%/year
6%/year
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
Path A
PathB
PathC
PathD
Gasoline & diesel
vehicles
89%
97%
97%
75%
65%
82%
97%
55%
35%
56%
74%
41%
23%
44%
53%
29%
HEV
11%
3%
3%
25%
34%
18%
3%
41%
65%
43%
25%
49%
68%
47%
44%
55%
PHEV
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
2%
2%
0%
2%
BEV
0%
0%
0%
0%
0%
0%
0%
4%
1%
1%
0%
10%
7%
7%
4%
14%
Net Mass
Reduction111
15%
18%
18%
15%
15%
20%
25%
15%
15%
20%
25%
15%
14%
19%
26%
14%
Table 6.5-3 present estimates of payback period and net lifetime savings. Payback
period is the number of years it takes for the higher initial cost of the vehicle to be off-set by
the vehicle's fuel savings. As discussed in Chapter 6.4, we used AEO 2010 reference case for
fuel prices, including fuel taxes, and we discounted the fuel savings using a 3 percent discount
rate. The net lifetime savings is the total lifetime fuel savings for the vehicle discounted at 3
percent minus the initial vehicle cost increase. As can be seen in Table 6.5-3, all MY 2025
scenarios, regardless of technology pathway, have a positive net lifetime fuel savings between
approximately $4,900 and $7,400, and for MY 2025 all of the scenarios and technology
pathways pay back in 4.2 years or less.
m Please note that we show net mass reduction relative to model year 2008 vehicles. In the case of PHEVs and
EVs, the batteries increase the weight of the vehicle. This battery weight increase is combined with the mass
reduction technology to calculate net mass reduction for those vehicles.
6-16
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2017-2025 Technical Assessment
Table 6.5-3: Estimated Consumer Payback and Lifetime Savings
For Model Year 2025 Vehicles (3% Discount Rate)
Scenario
3%/year
4%/year
5%/year
6%/year
Payback (years)
Path A
1.6
2.5
3.1
4.1
PathB
1.5
2.2
2.8
3.7
PathC
1.4
1.9
2.5
3.1
PathD
1.9
2.9
3.6
4.2
Net Lifetime Savings ($s)
Path A
$5,032
$5,862
$6,450
$6,162
PathB
$5,084
$6,041
$6,705
$6,564
PathC
$5,174
$6,198
$6,959
$7,379
PathD
$4,882
$5,329
$5,532
$5,705
Note - these estimates are relative to vehicle which comply with the 2016 EPA GHG
standards
The following discussion presents information regarding the assessment projections of
technology application and per-vehicle cost increases at the car-fleet and truck-fleet level for
MY 2025. We categorized passenger cars and light trucks using the same category definitions
as contained in the 2012-2016 National Program final rule. The results are presented
sequentially by technology pathway (i.e., Pathway A, Pathway B, Pathway C, and Pathway
D). The costs and CO2 emission levels discussed in this section reflect the same parameters
as the previous fleet level summaries (Section 6.5.1.1). The cost increases are relative to the
same vehicles under the MY 2016 standard, and the CO26 and MPGe levels include
improvements to the vehicle air conditioning system, but exclude outlet electricity.
Car and Truck Fleet Information for Technology Path A for MY 2025
Table 6.5-4 presents vehicle segment level results for Technology Pathway A showing
the CO2e target level by segment, the MPG-equivalent level by segment, and the average per-
vehicle cost increase by segment for the four scenario stringency levels. Table 6.5-5 presents
the corresponding vehicle segment level technology penetration rates and mass reductions for
model year 2025 under the Technology Pathway A. The results show that as would be
expected, the smaller size vehicles (e.g., the subcompact/compact segment and the midsize
car segment), which start off at a lower average CO2 level, also generally have the lowest
CO2 levels under the four stringency scenarios.
As can be seen in Table 6.5-5, mass reduction is very cost effective across all vehicle
categories, and under all stringency scenarios is at or near the maximum 15% we allowed
under Pathway A. The penetration of HEV technology is significantly higher in the truck-
fleet for the 3% and 4% per year scenarios, and more evenly distributed between the car and
truck fleets for the 5% and 6% per year scenarios. EVs first penetrate the new vehicle fleet in
the 5% per year stringency scenario at a low level, and for the 6% per year scenario EVs
represent 10% of all passenger cars, and only 2% of all light-duty trucks. PHEV technology
is generally selected last in our assessment, and does not enter the new fleet until the
assessment of the 6% per year category.
6-17
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Chapter 6
Table 6.5-4: Technology Path A, Assessment Projections for Model Year 2025:
CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets
Scenario
3%/year
4%/year
5%/year
6%/year
Vehicle Segment
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
CO2e Level
(g/mile)*
174
225
190
162
197
173
141
192
158
117
198
143
MPGe Level*
51.2
39.5
46.7
54.9
45.0
51.3
62.9
46.4
56.4
75.9
45.0
62.0
Per-Vehicle
Cost Increase ($)
$659
$1,485
$927
$1,184
$2,792
$1,705
$2,231
$3,106
$2,515
$3,629
$3,095
$3,455
*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning
related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2
reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and
real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost
to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for
the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and
indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs.
Table 6.5-5: Technology Path A, Assessment Projections
New Fleet Technology Penetration for Car and
for Model Year 2025:
Truck Fleets
Scenario
3%/year
4%/year
5%/year
6%/year
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
Net Mass
Reduction
(%)
15%
15%
15%
15%
15%
15%
15%
15%
15%
14%
15%
14%
Net Mass
Reduction
(Ibs)
491
673
550
491
673
550
491
673
550
467
665
529
HEV
(%)
6%
24%
11%
20%
65%
34%
60%
74%
65%
71%
61%
68%
PHEV
(%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
3%
1%
2%
EV
(%)
0%
0%
0%
0%
0%
0%
1%
0%
1%
10%
2%
7%
Adv. SI
(%)
23%
49%
31%
46%
18%
37%
27%
14%
23%
15%
35%
22%
6-18
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2017-2025 Technical Assessment
Car and Truck Fleet Information for Technology Path B for MY 2025
Table 6.5-6 presents vehicle segment level results for Technology Pathway B showing
the CO2e target level by car-truck fleet, the MPG-equivalent level by car-truck fleet, and the
average per-vehicle cost increase by car-truck fleet for the four scenario stringency levels.
Table 6.5-7 presents the corresponding car-truck fleet technology penetration rates and mass
reductions for model year 2025 under the Technology Pathway B.
As can be seen in Table 6.5-7, mass reduction is very cost effective across all vehicle
categories, and under all stringency scenarios is at or near the maximum 20% we modeled
under Pathway B. The penetration of HEV technology is generally more focused in the truck-
fleet, and increases overall as the level of stringency increases. In general, when compared to
Pathway A, the penetration of HEVs in Pathway B is lower.
EVs first penetrate the new vehicle fleet in the 5% per year stringency scenario,
though at a low rate of 1% for the fleet. This increases to approximately 7% of the fleet under
the 6% per year scenario, with most of these concentrated in the passenger car vehicles.
PHEV vehicles are only seen in the 6% per year scenario, and represent 2% of the vehicle
fleet for Pathway B.
6-19
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Chapter 6
Table 6.5-6: Technology Path B Assessment Projections for Model Year 2025:
CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets
Scenario
3%
4%
5%
6%
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
CO2e Level
(g/mile)
170
233
190
160
202
173
146
183
158
130
171
143
MPGe Level
52.4
38.2
46.7
55.7
44.1
51.3
61.0
48.6
56.3
68.5
52.0
62.1
Per-Vehicle
Cost Increase ($)
$753
$1,047
$849
$1,070
$2,465
$1,522
$1,748
$3,335
$2,263
$2,698
$4,327
$3,227
*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning
related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2
reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and
real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost
to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for
the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and
indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs.
Table 6.5-7: Technology Path B, Assessment Projections for Model Year 2025:
New Fleet Technology Penetration for Car and Truck Fleets
Scenario
3%/year
4%/year
5%/year
6%/year
Vehicle
Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
Net Mass
Reduction
(%)
17%
19%
18%
20%
20%
20%
20%
20%
20%
19%
20%
19%
Net Mass
Reduction
(Ibs)
572
848
658
655
897
733
654
897
733
630
887
712
HEV (%)
4%
2%
3%
5%
45%
18%
30%
72%
43%
27%
88%
47%
PHEV (%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
2%
1%
2%
EV (%)
0%
0%
0%
0%
0%
0%
1%
0%
1%
9%
2%
7%
Adv. SI
(%)
46%
66%
52%
72%
45%
63%
62%
21%
49%
60%
9%
44%
6-20
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2017-2025 Technical Assessment
Car and Truck Fleet Information for Technology Path C for MY 2025
Table 6.5-8 presents car-fleet and truck-fleet level results for Technology Pathway C,
specifically the CO2e target levels, the MPG-equivalent target levels, and the average per-
vehicle cost increase for the four scenario stringency levels. Table 6.5-9 presents the
corresponding car-fleet and truck-fleet technology penetration rates and mass reductions for
model year 2025 under the Technology Pathway C. The results show that as with Pathways A
and B, the car fleet, which start off at a lower average CO2 level, also has a lower CO2 levels
under the four stringency scenarios as compared to the truck fleet. The per-vehicle cost
increase difference between the car-fleet and truck-fleet is on the order of $300 to $350 for
the 3% and 4% per year scenarios, but increases to approximately $2,000 for the 5% per year
scenario and $1,600 for the 6% per year scenario.
As can be seen in Table 6.5-9, mass reduction is very cost effective across both the car
and truck fleets, and is on the order of 18% for the 3% per year scenario, and between 25 and
27% for the high stringency scenarios. The penetration of HEV technology is similar between
the car and truck fleets for the 3% and 4% scenarios, but in the 5% and 6% per year scenarios
is more weighted towards the truck-fleet. Technology Path C has the overall highest use of
the advanced gasoline technologies, and as can be seen the mix between the car fleet and the
truck fleet is very dependent upon the level of stringency, with higher levels under the 3% ,
5% and 6% per year scenario in the car-fleet, but similar levels between cars and trucks in the
4% per year scenario.
EVs penetrate the new vehicle fleet only in the 6% per year stringency scenario for
Pathway C, and overall are concentrated in the passenger cars fleet, representing 5% of all
passenger cars, and only 1% of all light-duty trucks. PHEV technology is not required in this
assessment under Technology Pathway C.
6-21
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Chapter 6
Table 6.5-8: Technology Path C Assessment Projections for Model Year 2025:
CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets
Scenario
3%
4%
5%
6%
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
CO2e Level
(g/mile)
169
233
190
154
213
173
148
178
158
130
170
143
MPGe Level
52.6
38.1
46.8
57.9
41.8
51.4
60.1
49.9
56.3
68.3
52.4
62.2
Per-Vehicle
Cost Increase ($)
$674
$980
$773
$1,255
$1,604
$1,368
$1,420
$3,412
$2,066
$2,316
$3,909
$2,833
*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning
related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2
reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and
real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost
to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for
the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and
indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs.
Table 6.5-9: Technology Path C Assessment Projections for Model Year 2025:
New Fleet Technology Penetration for Car and Truck Fleets
Scenario
3%/year
4%/year
5%/year
6%/year
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
Net Mass
Reduction
(%)
17%
19%
18%
25%
25%
25%
25%
25%
25%
27%
26%
26%
Net Mass
Reduction
(Ibs)
569
839
653
809
1,122
909
818
1,143
922
868
1,180
970
HEV
(%)
4%
2%
3%
4%
2%
3%
8%
60%
25%
31%
71%
44%
PHEV
(%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
EV
(%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
5%
1%
4%
Adv. SI
(%)
32%
76%
46%
96%
98%
97%
91%
39%
74%
65%
28%
53%
6-22
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2017-2025 Technical Assessment
Car and Truck Fleet Information for Technology Path D for MY 2025
Table 6.5-10 presents car-fleet and truck-fleet level results for Technology Pathway D,
specifically the CO2e target levels, the MPG-equivalent target levels, and the average per-
vehicle cost increase for the four scenario stringency levels. Table 6.5-10 presents the
corresponding car-fleet and truck-fleet technology penetration rates and mass reductions for
model year 2025 under the Technology Pathway D. The results show that as with the three
other pathways, the car fleet, which starts off at a lower average CO2 level, also has a lower
CO2 levels under the four stringency scenarios as compared to the truck fleet. The per-
vehicle cost increase difference between the car-fleet and truck-fleet is on the order of $500 to
$1,000 depending on the stringency of the scenario, with the exception of the 3% per year
scenario, where there is little cost difference between the car fleet and truck fleet.
As can be seen in Table 6.5-10, mass reduction is very cost effective across both the
car and truck fleets, though the level of mass reduction is no higher than the 15% we
considered for this Pathway. The penetration of HEV technology is similar between the car
and truck fleets in the 6% scenario, but in the 3%, 4%, and 5% scenarios are weighted more
heavily towards the car fleet. Advanced gasoline engines were not allowed in this scenario,
as we were trying to assess a hypothetical industry approach in which no advancements in
gasoline powertrain systems are pursued beyond MY2016, and all of the industry resources
are concentrated on HEV, PHEV, and EV technology.
Relative to the other Technology Pathways, Technology Pathway D features a higher
penetration of EVs and HEVs. The relatively high penetration of HEVs in the 3% scenario is
due to the complete lack of advanced gasoline engines (that is, no improvement in gasoline
engines and transmissions beyond what will be used in MY 2015). More stringent scenarios
require relatively higher penetrations of EVs and HEVs. The penetration of PHEV
technology remains relatively low, appearing only in the 6% scenario.
6-23
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Chapter 6
Table 6.5-10: Technology Path D Assessment Projections for Model Year 2025:
CO2, MPG, and Per-Vehicle Costs for Car and Truck Fleets
Scenario
3%
4%
5%
6%
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
CO2e Level
(g/mile)
166
238
190
143
235
173
127
222
158
115
201
143
MPGe Level
53.4
37.4
46.9
62.2
37.8
51.4
69.8
40.0
56.2
77.4
44.2
62.3
Per-Vehicle
Cost Increase ($)
$1,026
$1,096
$1,049
$2,215
$1,203
$1,887
$2,940
$1,917
$2,608
$3,555
$3,061
$3,395
*note, the CO2e value includes 15 grams/mile of CO2-equivalent reduction from air conditioning
related GHGs (CO2 and HFC reductions), and the MPGe level is equivalent MPG value if all CO2
reductions come from fuel economy improvements. Real-world CO2 is typically 25 percent higher and
real-world fuel economy is typically 20 percent lower. Per-vehicle cost represented the estimated cost
to the consumer, including the direct manufacturing costs for the new technologies, indirect costs for
the auto manufacturer (e.g., product development, warranty) as well as auto manufacturer profit, and
indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of indirect costs.
Table 6.5-11: Technology Path D Assessment Projections for Model Year 2025:
New Fleet Technology Penetration for Car and Truck Fleets
Scenario
3%/year
4%/year
5%/year
6%/year
Vehicle Type
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
All Cars
All Trucks
Fleet
Net Mass
Reduction
(%)
15%
15%
15%
15%
15%
15%
15%
15%
15%
14%
15%
14%
Net Mass
Reduction
(Ibs)
491
673
550
489
673
549
482
669
542
467
657
528
HEV
(%)
30%
14%
25%
54%
13%
41%
59%
29%
49%
55%
57%
55%
PHEV
(%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
2%
2%
2%
EV
(%)
1%
0%
0%
6%
1%
4%
13%
3%
10%
19%
4%
14%
Adv. SI
(%)
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
6-24
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2017-2025 Technical Assessment
MY 2020 Results
We present here the fleet-wide results for our MY2020 assessment. The cost of the
MY 2020 scenarios for the entire new vehicle fleet ranges from $289 (3%) to $1,057 (6%,
Path A) per vehicle, as shown in Table 6.5-12. Technology pathway C, which relies upon
advanced gasoline technology and greater mass reduction as compared to Pathway A and B,
demonstrates the lowest costs. Pathways A and B show greater penetration of HEVs and
somewhat higher costs.
The GHG reduction over the lifetime of the MY 2020 vehicles ranges from 172
million metric tons (MMT) CC^e avoided in the 3% scenario to between 306 MMT CC^e in
the 6% scenario. MY 2020 vehicles, over the course of their lifetimes, will reduce between
0.4 billion barrels of gasoline consumption under the 3% scenario to 0.6 billion barrels under
the 6% scenario. For reference, the NHTSA & EPA National Program in MY 2016 is
projected to reduce 0.6 billion barrels of fuel and 325 MMT CO2e over the lifetime of MY
2016 vehicles.
Table 6.5-12: Assessment Projections for Model Year 2020 Vehicles by Technology Path
Scenario
3%/year
4%/year
5%/year
6%/year
New Fleet Target
CO2
221
212
204
195
MPGe*
40.2
41.9
43.6
45.5
Per- Vehicle Cost increase
($)
Path A
$289
$399
$577
$1,057
PathB
$289
$399
$583
$1,035
PathC
$289
$399
$565
$865
Lifetime
CO2e Reduction
(MMT)
Path A
172
215
262
306
Path
B
172
215
262
306
Path
C
172
215
262
306
Lifetime
Gasoline Reduction
(Billion Barrels)
Path A
0.4
0.5
0.5
0.6
Path
B
0.4
0.5
0.5
0.6
Path
C
0.4
0.5
0.5
0.6
Note - these costs, CO2 reductions, and fuel savings are relative to the 2016 EPA GHG standards. Per-vehicle
cost represented the estimated cost to the consumer, including the direct manufacturing costs for the new
technologies, indirect costs for the auto manufacturer (e.g., product development, warranty) as well as auto
manufacturer profit, and indirect costs at the dealership - see Chapter 3.2.5 for detail on our estimation of
indirect costs.
* MPGe is the MPG equivalent to the CO2 target if all CO2 reductions occur from fuel economy improvement
technologies. Real-world CO2 is typically 25 percent higher and real-world fuel economy is typically 20 percent
lower. Thus, the 3% to 6% range evaluated in this assessment would span a range of real world fuel economy
values of approximately 32 to 36 mpg, which correspond to the regulatory test procedure values of 40.2 and 45.5
mpg, respectively. For the technical assessment, we have estimated a reduction of 15 g/mile CO2 equivalent
from air conditioning system improvements, which would not actually translate into MPG improvements
The penetration of HEVs, EVs, and PHEV in MY 2020 varies little depending on the
technology pathway and scenario, as can be seen in Table 6.5-13.
Pathway C places greater emphasis on mass reduction and advanced gasoline vehicle
technology. Therefore, the degree of mass reduction is also the highest among the four
pathways, ranging from 11% to 18%.
Pathway B shows a technology approach in between Paths A and C, with advanced
gasoline technology and mass reductions higher than for Path A but lower than Path C, and
HEV penetrations lower than Path A but higher than Path C. This trend is not as strong in the
6-25
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Chapter 6
MY 2020 results because the level of stringency does not require enough advanced
technology to show much of a difference between Pathways B and C under most stringencies.
6-26
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2017-2025 Technical Assessment
Table 6.5-13: Assessment Projections for Model Year 2020 Vehicles
New Fleet Technology Penetration Estimates
Scenario
3%/year
4%/year
5%/year
6%/year
Technology
Path
Path A
PathB
PathC
Path A
PathB
PathC
Path A
PathB
PathC
Path A
PathB
PathC
New Vehicle Fleet Technology Penetration
Gasoline & diesel
vehicles
97%
97%
97%
97%
97%
97%
97%
97%
97%
85%
87%
97%
HEV
3%
3%
3%
3%
3%
3%
3%
3%
3%
15%
13%
3%
PHEV
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
BEV
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
Net Mass
Reduction"1
11%
11%
11%
14%
14%
14%
15%
15%
15%
15%
15%
18%
Table 6.5-14 present estimates of payback period and net lifetime savings for MY
2020 vehicles. Payback period is the number of years it takes the cost increase of the vehicle
to be off-set by the vehicle's fuel savings. As discussed in Chapter 6.4, we used AEO 2010
reference case for fuel prices, including fuel taxes, and we discounted the fuel savings using a
3 percent discount rate. The net lifetime savings is the total lifetime fuel savings for the
vehicle discounted at 3 percent minus the initial vehicle cost increase. As can be seen in
Table 6.5-14, all MY 2020 scenarios, regardless of technology pathway, have a positive net
lifetime fuel savings between approximately $2,600 and $4,300, and for MY 2020 all of the
scenarios and technology pathways pay back in 2.2 years or less.
Table 6.5-14: Estimated Consumer Payback and Lifetime Savings
For Model Year 2020 Vehicles (3% Discount Rate)
Scenario
3%/year
4%/year
5%/year
6%/year
Payback (years)
Path A
1.0
1.1
1.4
2.2
PathB
1.0
1.1
1.4
2.2
PathC
1.0
1.1
1.3
1.8
Net Lifetime Savings ($s)
Path A
$2,632
$3,249
$3,854
$4,082
PathB
$2,632
$3,249
$3,792
$4,105
PathC
$2,632
$3,249
$3,823
$4,281
Note - these estimates are relative to vehicles which comply with the 2016 EPA GHG
standards
111 Please note that we show net mass reduction relative to model year 2008 vehicles. In the case of PHEVs and
EVs, the batteries increase the weight of the vehicle. This battery weight increase is combined with the mass
reduction technology to calculate net mass reduction for those vehicles.
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6.6 PHEV and EV Battery Cost Sensitivity Assessment
The agencies judged that there is uncertainty in the cost for EV and PHEV large-
format lithium-ion batteries in the 2025 time frame. As discussed in Chapter 3, the
development of these batteries for automotive applications is occurring at a very rapid rate
and the market is far from mature, thus our ability to accurately predict the costs for these
technologies for the 2025 time frame is difficult. The cost of the battery pack is the single
largest incremental cost difference between a gasoline vehicle and either a PHEV or an EV.
Depending upon the vehicle range (and thus the size of the battery) and the time frame (e.g.,
today or the 2025 time frame), the battery pack cost can represent on the order of 60 to 80%
or more of the incremental cost of a PHEV/EV. Given the uncertainty in the costs of lithium-
ion batteries in the 2025 time frame, and the significant portion of the PHEV and EV
incremental costs the battery represents, the agencies believe it is appropriate to include a
sensitivity analysis on battery pack costs.
As discussed in Chapter 3, the agencies used a battery costing model developed by
Argonne National Laboratory (ANL) which provides unique battery pack cost estimates for
EV and PHEVs based on various variables such as production volume, battery cell chemistry
material, battery capacity and power, useable fraction of the state-of-charge range, etc. There
are also many economic projections used in the ANL model, such as cost of capital
equipment, plant area, labor cost, etc. Based on 500,000 units per year production volume,
and using an assumption there will be incremental improvements in battery cycle life such
that the battery performance is maintained for the useful life of the vehicle, EPA derived a
battery pack cost projection for 2025 EVs of approximately $160/kW-h for EV75, $150/kW-h
for EV100, $140/kW-h for EV150, and of 2025 PHEVs of $180/kW-h for 40-mile PHEVs
and $250/kW-h for 20-mile PHEVs assuming the use of LiMn2O4-spinel/graphite cell
chemistry. We note that this cost is lower than the cost estimates projections obtained from
our meetings with the OEMs, where the majority of the estimates were in the $300 to
$400/kW-h range for 2020 and $250 to $300/kW-h range for 2025.
Because of uncertainty in future battery costs, the agencies conducted a sensitivity
assessment on the battery costs for 2025 by increasing all of the PHEV and EV battery-pack
costs by $100/kW-hr. We also examined the potential impact of lower battery costs by
reducing all of the PHEV and EV battery-pack costs by $50/kW-hr. The $100/kW-hr higher
cost is comparable to commodity pricing for high-volume LiCoO2 cells for consumer
applications. The $50/kW-hr lower cost assumes a breakthrough in battery design that would
approximately triple cell energy density.
We selected the 5% per year and 6% per year targets under technology Pathway B for
2025 as the scenario on which to assess the potential impact of these changes in Li-ion battery
costs. The results show that for the higher battery cost estimates, the projected 2025 Pathway
B costs for the 5% per year targets would increase by $36 per vehicle and for the 6% per year
targets would increase by $397 per vehicle. For the lower battery cost estimates, the projected
2025 Pathway B costs for the 5% per year targets would decrease by $18 per vehicle and for
the 6% per year targets would decrease by $199 per vehicle. This impact on the fleet-wide
average cost assessment is relatively modest because PHEVs and EVs represent on the order
of 1% of the new vehicles under the Pathway B 5% per year scenario, and 9% under the
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2017-2025 Technical Assessment
Pathway B 6% per year scenario. However, the impact on actual PHEVs and EVs can be
large. For example, for a midsize EV passenger car with a real-world range of 100 miles (an
EV100), the sensitivity analysis done by adding $100/kW-hr to the battery pack costs
increased the cost of the midsize car EV100 on the order of $5,700, and the impact of
lowering the EV100 battery pack costs by $50/kW-hr reduced the costs of the midsize car
EV100 by $2,800.
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Chapter 6
Chapter 6 References
92
93
94
Documented in Appendix A to this report.
See Appendix D to this report.
Energy Information Administration, Annual Energy Outlook 2010, Reference Case (May 2010 2009), Table
12. Available at http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html
95
EPA. 2006, Final Technical Support Document. Fuel Economy Labeling of Motor Vehicle Revisions to
Improve Calculation of Fuel Economy Estimates. EPA-HQ-OAR-2009-0472-0281
96
Energy Information Administration, Annual Energy Outlook 2010, Reference Case (May 2010 2009), Table
12. Available at http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html
97 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate
Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901
http://www.epa.gov/otaq/climate/regulations/420rl0901.pdf. Additional details on the projections used here can
be found in Appendix E of this report.
98 Sorrell, S. and J. Dimitropoulos, 2007. "UKERC Review of Evidence for the Rebound Effect, Technical
Report 2: Econometric Studies", UKERC/WP/TPA/2007/010, UK Energy Research Centre, London, October
and Greening, L.A., D.L. Greene and C. Difiglio, 2000. "Energy Efficiency and Consumption - The Rebound
Effect - A Survey", Energy Policy, vol. 28, pp. 389-401.
99 EPA. Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy
Standards; Final Rule Regulatory Impact Analysis Chapter 5.
100 EPA. Analysis of H.R. 2454 in the 111th Congress.
http://www.epa.gov/climatechange/economics/economicanalyses.html
101 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate
Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901.
http://www.epa.gov/otaq/climate/regulations/420rl0901.pdf. Original data found in Intergovernmental Panel on
Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007.
http://www.ipcc.ch/pdf/assessmentreport/ar4/wgl/ar4-wgl-chapter2.pdf. Docket ID: EPA-HQ-OAR-2009-0472-
0117
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7 Other Key Factors
7.1 Potential Impacts on the Economy and Employment
The primary impacts of the use of advanced vehicle technologies on the economy are
the net benefits that they produce. Positive net benefits result in improvements in economic
welfare in the aggregate. Measures of net benefits, though, are not necessarily correlated with
the effects of technologies on employment or on the auto manufacturing base in the U.S. This
report does not provide a quantitative assessment of these effects. Instead, this section
discusses the potential impacts of advanced technologies on the auto industry in general and
employment in the auto sector.
7.1.1 Impacts on Auto Manufacturers, Suppliers, and Auto Industry Employment
The automotive market is becoming increasingly global. The U.S. auto companies
produce and sell automobiles around the world, and foreign auto companies produce and sell
in the U.S. As a result, the industry has become increasingly competitive. Staying at the
cutting edge of automotive technology while maintaining profitability and consumer
acceptance has become increasingly important for the sustainability of auto companies.
Trends in the world automotive market suggest that investments in improved fuel
economy and advanced technology vehicles are a necessary component for maintaining
competitiveness in coming years. For instance, most companies are expanding hybrid-electric
vehicle production to stay competitive while meeting more stringent fuel economy and
emissions regulations. Fuel economy requirements in other developed countries are generally
higher, and greenhouse gas (GHG) emissions standards tighter, than in the U.S. As
automakers seek greater commonality across the vehicles they produce for the domestic and
foreign markets, improving fuel economy and reducing GHGs in U.S. vehicles should have
spillovers to foreign production, and vice versa, thus yielding the ability to amortize
investment in research and production over a broader product and geographic spectrum.
Auto companies are already conducting major research and investment activities in
advanced technologies and improvements to conventional technologies to improve fuel
economy and reduce GHG emissions. In addition, as discussed in Chapter 2, in recent
meetings with auto firms, all expressed plans to increase significantly their offerings and sales
of advanced technology vehicles in coming years. Successful research and investment
activities can contribute to long-term gains in many directions. Companies that develop new
technologies not only get the advantages of using them, but also the opportunity to license
those technologies to other companies. Those technologies may have spinoffs into other
sectors. For instance, research into new battery technologies may lead to improvements in
other battery-intensive uses, such as storage of wind or solar energy when the quantity of
electricity demanded is lower than the amount produced.
The effects of the use of advanced technologies on U.S. auto sector employment
depend on how the standards affect several factors: the number of vehicles produced
(discussed below), the labor intensity of vehicle production, and any changes in market shares
between domestically produced and imported vehicles and auto parts.
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Chapter 7
Productivity in the auto industry has been increasing over time, as automakers have
improved process efficiency and enhanced vehicle quality. °2 Improved productivity has the
great benefit of providing better vehicles at lower prices to consumers; it also means fewer
worker-hours needed per dollar of vehicle value. Higher productivity leads to more efficient
vehicle manufacturing, which could result in less expensive and/or improved quality vehicles.
Either outcome would likely give consumers greater purchasing power, and thus lead to
higher vehicle sales. Even though higher productivity implies that worker-hours per vehicle
may go down, increased vehicle sales may lead overall employment in the auto industry to
increase, as it did in the 1990s (a time of both high productivity increases and employment
increases). At this time it is not possible to predict the effect of production involving
advanced vehicle technologies on labor needs. It is possible that the smaller-volume
production likely in the early years for advanced technology vehicles may be more labor-
intensive than mass production, if scale economies of production are not exhausted.
Another variable affecting auto sector employment is where production takes place.
The location of production will depend on how domestic production costs, especially for
advanced technologies, compare to foreign production costs, and on the cost of transporting
vehicles and parts between the U.S. and other countries. Investments in advanced technology
production facilities, such as battery manufacturing and vehicle electrification projects,
supported by the Recovery Act (for example) reduce the need for importing these parts from
overseas.103 These investments by the Department of Energy have created immediate jobs in
building this capacity, and they also help ensure that these components can be produced in the
U.S. Tax breaks and other manufacturing incentives provided by a number of local and state
governments for advanced vehicle technologies, such as in Michigan, have also contributed
incentives for domestic production.
7.1.2 Impacts on Vehicle Sales
The effect of advanced technologies on vehicle sales depends on the attractiveness to
consumers of the new technologies and improved fuel economy relative to the increased
vehicle price. In the light-duty greenhouse gas/fuel economy rule covering 2012-2016, the
very large fuel savings were estimated to recover the up-front technology costs in under three
years. If consumers considered at least three years' worth of fuel savings when purchasing a
vehicle, then that rule was predicted to increase vehicle sales.104 The use of advanced
technologies can be expected, as in that rule, to improve fuel economy and increase vehicle
costs. Chapter 6 of this report shows that more stringent standards will provide fuel savings
that exceed vehicle cost increases in four years or less. The weights that consumers put on
these two factors will affect total vehicle sales.105
7.1.3 Summary
With increased globalization of auto markets, increased competitiveness in the
industry, and higher fuel economy/lower GHG standards becoming the norm around the
world, auto companies have already begun to invest in new technologies that will meet future
standards. These new technologies will increase the purchase prices of new vehicles, at the
same time that they reduce their fuel costs; the net effect on auto sales depends on how
consumers trade off those attributes. The net effect on employment will be affected not only
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2017-2025 Technical Assessment
by the effects of the proposed standards on auto sales, but also on the effects on productivity
and location of production. These investments will help the U.S. auto sector to stay on the
cutting edge of auto technology.
For the forthcoming notice of proposed rulemaking for 2017-2025 GHG and CAFE
standards, EPA and NHTSA will further investigate the impacts of the proposed standards on
the auto industry, and employment. Further analysis requires information on the effects of the
proposed standards on vehicle sales, on expected expenditures in the auto sector, and on any
predictions of changes in location of manufacturing due to the specific standards in the
forthcoming proposal.
7.2 Upstream GHG Emissions
In the assessment of potential future ranges of stringency presented in Chapter 6 of
this report, we based our analysis on the tailpipe emissions from all vehicles - thus EVs were
evaluated at a 0 gram/mile CO2 level and PHEVs were evaluated as 0 gram/mile for the
electric drive portion of the vehicles operation. For the purposes of the GHG impacts
presented in Chapter 6, we have included the resultant increase in upstream CO2 from the use
of PHEVs and EVs in our overall calculation of the net CO2 reductions for each of the
scenarios evaluated. As discussed in Chapter 6, the upstream CO2 emission factors from
powerplants is based on a future business as usual case,
The issue of upstream emissions will be considered in the MY 2017-2025 light-duty
vehicle joint federal rulemaking. EPA has not considered upstream fuel-related emissions
issues in the past with respect to the non-GHG emissions standards for motor vehicles.
As discussed in Chapter 2, many stakeholders have expressed opinions on this topic,
with most automakers supporting the tailpipe only or zero grams per mile approach and
environmental groups typically supporting a net upstream GHG emissions accounting.
EPA will be fully evaluating this issue for the MY 2017-2025 light-duty vehicle GHG
emissions proposal based on the status of commercialization of EVs, PHEVs, and FCVs, the
potential of these technologies to provide long-term GHG emissions savings, the status of and
outlook for upstream GHG control programs, and other relevant factors.
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Chapter 7 References
102 Baily, Martin N., et al., "Increasing Global Competition and Labor Productivity: Lessons from the US
Automotive Industry," McKinsey Global Institute, November 2005,
http://www.mckinsey.com/mgi/publications/us_autoindustry/index.asp, accessed 8/17/10.
103 "Recovery Act Awards for Electric Drive Vehicle Battery and Component Manufacturing Initiative" and
"Recovery Act Awards for Transportation Electrification,"
http://wwwl.eere.energy.gov/recovery/pdfs/battery_awardee_list.pdf
104 This result led to questions why private market interactions between auto producers and consumers had not
led to incorporation of these technologies into vehicles in the absence of the rule. This issue was discussed in the
Preamble for that rule, Federal Register 75(88) (Friday, May 7, 2010), in Section III.H. 1, pp. 25510-25513, and
IV.G.6, pp. 25651-25657.
105 Though a number of studies have included examination of the role of fuel economy in consumers' purchases,
the results appear to be highly varied. See Greene, David L., "How Consumers Value Fuel Economy: A
Literature Review," Report EPA-420-R-10-008, Office of Transportation and Air Quality, U.S. Environmental
Protection Agency, March 2010. EPA-HQ-OAR-2009-0472-11465.
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Al Appendix A: The Baseline and Reference Vehicle Fleet
The passenger cars and light trucks sold currently in the United States, and those
which are anticipated to be sold in the MYs 2017-2025 time frame, are highly varied and
satisfy a wide range of consumer needs. From two-seater miniature cars to 11-seater
passenger vans to large extended cab pickup trucks, American consumers have a great
number of vehicle options to accommodate their utility needs and preferences. Recent
volatility in oil prices and the state of the economy have demonstrated that consumer demand
and choice of vehicles within this wide range can be sensitive to these factors. Although it is
impossible for anyone or any organization to precisely predict the future, a characterization
and quantification of the future fleet are required to assess the impacts of rules which would
affect that future fleet. In order to do this, the various leading publicly-available sources are
examined, and a series of models are relied upon that help us to project the composition of a
reference fleet. This appendix gives a high level over view of the process to accomplish this
and a simple analysis of the fleet's characteristics, drawing extensively from the joint final
TSD for the MYs 2012-2016 final rule.
Al.l Why do the agencies establish a baseline and reference vehicle fleet?
In order to calculate the impacts of potential future EPA and NHTSA standards, it is
necessary to estimate the composition of the future vehicle fleet absent those CAFE/GHG
standards in order to conduct comparisons. EPA in consultation with NHTSA has developed
a comparison fleet in two parts. The first step was to develop a baseline fleet based on model
year 2008 data. EPA and NHTSA create a baseline fleet in order to track the volumes and
types of fuel economy-improving and CCVreducing technologies which are already present in
today's fleet. Creating a baseline fleet helps to keep, to some extent, the agencies' models
from adding technologies to vehicles that already have these technologies, which would result
in "double counting" of technologies' costs and benefits. The second step was to project the
baseline fleet sales into MYs 2017-2025. This is called the reference fleet, and it represents
the fleet that would exist in MYs 2017-2025 absent any change from current regulations. The
third step was to add technologies to that MY 2008 fleet such that each manufacturer's
average car and truck CC>2 levels are in compliance with their MY 2016 CAFE standards.
This final "reference fleet" is the light duty fleet estimated to exist in MYs 2017-2025 without
new CAFE/GHG standards. All of the agencies' estimates of emission reductions/fuel
economy improvements, costs, and societal impacts for purposes of this Technical
Assessment Report are developed in relation to this reference fleet for MY 2016. This
Appendix describes the first two steps of the development of the baseline and reference fleets.
The third step of technology addition is developed separately by each agency as the outputs of
the OMEGA and Volpe models; for purposes of this Technical Assessment Report, as
discussed above, only the OMEGA model was employed for the main analysis, although both
models will be run for the forthcoming federal rulemaking. The overall process for
developing baseline and reference fleets for the agencies' modeling is described in the MYs
2012-2016 final rule in section II of the preamble and in each agency's respective RIA.
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Appendix A
A1.2 The 2008 baseline vehicle fleet
Al.2.1 Why did the agencies choose 2008 as the baseline model year?
A baseline vehicle fleet was developed by EPA in consultation with NHTSA for the
2012-2016 final rule. The baseline for the 2012-2016 final rule is comprised of model year
2008 individual vehicle attribute data volumes along with projected volumes out to 2016.
Model year 2008 vehicle data was again chosen to be the basis of the baseline fleet, but for
different reasons than the final rule. Model year 2008 is now the most recent model year for
which the industry had normal sales. Model year 2009 data was available, but the agencies
believe that the model year was disrupted by the economic downturn and the bankruptcies of
both General Motors and Chrysler. There was a significant reduction in the number of
vehicles sold by both companies and the industry as a whole. These abnormalities made the
agencies conclude that 2009 data was unsuitable for projecting the future fleet. Therefore, the
agencies chose to use model year 2008 as the baseline since it was the latest representative
transparent data set available.
Al .2.1.1 On what data is the baseline vehicle fleet based?
As part of the CAFE program, EPA measures vehicle CC>2 emissions and converts
them to mpg and generates and maintains the federal fuel economy database. Most of the
information about the 2008 vehicle fleet was gathered from EPA's emission certification and
fuel economy database, most of which is available to the public. The data obtained from this
source included vehicle production volume, fuel economy, carbon dioxide emissions, fuel
type, number of engine cylinders, displacement, valves per cylinder, engine cycle,
transmission type, drive, hybrid type, and aspiration. However, EPA's certification database
does not include a detailed description of the types of fuel economy-improving/CCVreducing
technologies considered in this final rule, because this level of information is not necessary
for emission certification or fuel economy testing. Thus, EPA augmented this description
with publicly-available data which includes more complete technology descriptions from
Ward's Automotive Group.1;A In a few instances when required vehicle information was not
available from these two sources (such as vehicle footprint), this information was obtained
from publicly-accessible internet sites such as Motortrend.com, Edmunds.com and other
sources to a lesser extent (such as articles about specific vehicles revealed from internet
search engine research.2'6
For details on how the 2008 baseline fleet was constructed for the 2012-2016 final
rule, please see the Chapter 1 of the Joint Technical Support Document for that rule.
A Note that WardsAuto.com is a fee-based service, but all information is public to subscribers.
B Motortrend.com and Edmunds.com are free, no-fee internet sites.
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A1.3 The MY 2017-2025 Reference Fleet
The reference fleet aims to reflect the current market conditions and expectations
about conditions of the vehicle fleet during the model years to which the agencies' rules
apply. Fundamentally, constructing this fleet involved projecting the MY 2008 baseline fleet
into the 2017-2025 model years. It also included the assumption that none of the models had
changes during this period, in terms of both the technology present in the vehicles themselves,
and the vehicles present in the fleet. Projecting what the fleet will look like in the future is a
process that is inherently uncertain. NHTSA and EPA therefore relied on many sources of
reputable information to make these projections.
Al .3.1 On what data is the reference vehicle fleet based?
EPA and NHTSA have based the projection of total car and light truck sales on recent
projections made by the Energy Information Administration (EIA). EIA publishes a
projection of national energy use annually called the Annual Energy Outlook (AEO).3 EIA
published its Annual Energy Outlook for 2010 in May 2010. Similar to the analyses
supporting the MYs 2012-2016 rulemaking, the agencies have used the Energy Information
Administration's (EIA's) National Energy Modeling System (NEMS) to estimate the future
relative market shares of passenger cars and light trucks. However, the version of NEMS
supporting EIA's Annual Energy Outlook 2010 (AEO2010) contains a "dummy variable" that
forces the passenger car market share to increase after 2007, to facilitate projected compliance
with EISA's requirement that the overall fleet achieve 35 mpg by 2020 (the car and truck
volumes based on this analysis are shown in Table Al.3-1. Because we use our market
projection as a baseline relative to which we measure the effects of new standards, and we
attempt to estimate the industry's ability to comply with new standards without changing
product mix, the AEO2010 projected shift in passenger car market share as a result of
legislatively required fuel economy improvements creates a circular logic. Therefore, for the
current analysis, a new projection of passenger car and light truck sales shares was developed
by running scenarios from the AEO2010 reference case that first deactivate the above-
mentioned dummy variable and holds post-2017 CAFE standards constant at MY 2016 levels.
Incorporating these changes reduced the projected passenger car share of the light vehicle
market by an average of about 5% during 2017-2025. This case is referred to as the Unforced
Reference Case, and the values are shown below in Table Al.3-2.
Table Al.3-1 AEO Original Reference Case Values
Model Year
2017
2018
2019
2020
2021
2022
2023
2024
Cars
9,329,656
9,375,428
9,640,245
10,105,479
10,156,471
10,178,345
10,293,661
10,516,662
Trucks
6,855,287
6,595,148
6,482,139
6,436,088
6,303,343
6,166,611
6,118,791
6,166,036
Total Vehicles
16,184,943
15,970,576
16,122,384
16,541,566
16,459,813
16,344,956
16,412,452
16,682,698
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Appendix A
2025
10,761,857 6,204,297 16,966,155
Table Al.3-2 AEO Unforced Reference Case Values
Model Year
2017
2018
2019
2020
2021
2022
2023
2024
2025
Cars
8,783,816
8,728,990
8,899,836
9,230,279
9,265,881
9,282,884
9,382,100
9,588,366
9,817,211
Trucks
7,401,127
7,241,586
7,222,548
7,311,287
7,193,932
7,062,072
7,030,352
7,094,332
7,148,944
Total Vehicles
16,184,943
15,970,576
16,122,384
16,541,566
16,459,813
16,344,956
16,412,452
16,682,698
16,966,155
Using the unforced reference case, EIA projects that total light-duty vehicle sales
gradually recover from their currently depressed levels by roughly 2013. In 2017, car and
light truck sales are projected to be 8.8 and 7.4 million units, respectively. While the total
level of sales of 16.1 million units is similar to pre-2008 levels, the fraction of car sales is
projected to be higher than that existing in the 2000-2007 timeframe. Note that EIA's
definition of cars and trucks follows that used by NHTSA prior to the MY 2011 CAFE final
rule. The MY 2011 CAFE final rule reclassified a number of 2-wheel drive sport utility
vehicles from the truck fleet to the car fleet. EIA's sales projections of cars and trucks for the
2017-2025 model years under both the old NHTSA truck definition are shown above in Table
Al.3-1 and Table Al.3-2.
In addition to a shift towards more car sales, sales of segments within both the car and
truck markets have also been changing and are expected to continue to change in the future.
Manufacturers are continuing to introduce more crossover models which offer much of the
utility of SUVs but use more car-like designs and unibody structures. In order to reflect these
changes in fleet makeup, EPA and NHTSA used a custom long range forecast purchased from
CSM Worldwide (CSM). CSM Worldwide (CSM) 4 is a well-known industry analyst, that
provided the forecast used for the 2012-2016 final rule. NHTSA and EPA decided to use the
forecast from CSM for several reasons. One, CSM agreed to allow us to publish their high
level data, on which the forecast is based, in the public domain. Two, it covered all the
timeframe of greatest relevance to this analysis (2017-2025 model years). Three, it provided
projections of vehicle sales both by manufacturer and by market segment. Four, it utilized
market segments similar to those used in the EPA emission certification program and fuel
economy guide. As discussed further below, the CSM forecast is combined with other data
obtained by NHTSA and EPA.
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2017-2025 Technical Assessment
Al.3.2 How do the agencies develop the reference vehicle fleet?
The process of producing the 2017-2025 reference fleet involved combining the
baseline fleet with the projection data described above. This was a complex multistep
procedure, which is described in detail in the Joint Technical Support Document from the
2012-2016 final rule with an abbreviated discussion in this section.
Al .3.2.1 How was the 2008 baseline data merged with the CSM data?
Merging the 2008 baseline data with the 2017-2025 CSM data required a thorough
mapping of certification vehicles to CSM vehicles by individual make and model. One
challenge the agencies faced when determining a reference case fleet was that the sales data
projected by CSM had different market segmentation than the data contained in EPA's
internal database. In order to create a common segmentation between the two databases, side-
by-side comparison of the specific vehicle models in both datasets was performed, and an
additional "CSM segment" modifier in the spreadsheet was created, thus mapping the two
datasets. The reference fleet sales based on the "CSM segmentation" was then projected.
In the combined EPA certification and CSM database, all of the 2008 vehicle models
were assumed to continue out to 2025, though their volumes changed in proportion to CSM
projections. Also, any new models expected to be introduced within the 2011-2025
timeframe are not included in the data. These volumes are reassigned to the existing models.
All MY 2017-2025 vehicles are mapped to the existing vehicles by a process of mapping to
manufacturer market share and overall segment distribution.
Al .3.2.2 How were the CSM forecasts normalized to the AEO forecasts?
The projected CSM forecasts for relative sales of cars and trucks by manufacturer and
by market segment were normalized (set equal) to the total sales estimates of the AEO 2010
reference case. NHTSA and EPA used projected car and truck volumes for this period from
AEO 2010. However, the AEO projects sales only at the car and truck level, not at the
manufacturer and model-specific level, which are needed for the analysis. The CSM data
provided year-by-year percentages of cars and trucks sold by each manufacturer as well as the
percentages of each vehicle segment. Using these percentages normalized to the AEO-
projected volumes then provided the manufacturer-specific market share and model-specific
sales for model years 2017-2025 (it is worth clarifying that the agencies are not using the
model-specific sales volumes from CSM, only the volumes by manufacturer and segment).
This process is described in greater detail in Chapter 1 of the Joint Technical Support
Document for the 2012-2016 final rule.
Al.3.3 What are the sales volumes and characteristics of the reference fleet?
Table Al.3-3 and Table Al.3-6 below contain the sales volumes that result from the
process above for MY 2008 and 2017-2020. Table Al.3-4 and Table Al.3-5 below contain
the sales volumes that result from the process above for MY 2021-2025.
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Appendix A
Table Al.3-3 Vehicle Segment Volumes"
Reference Class
Segment
LargeAuto
MidSizeAuto
CompactAuto
SubCmpctAuto
All Cars
LargePickup
SmallPickup
LargeSUV
MidSizeSUV
Small SUV
MiniVan
Cargo Van
All Trucks
Actual and Projected Sales Volume
2008
557,693
3,097,859
1,976,424
1,364,434
6,971,256
1,581,880
177,497
2,783,949
1,263,360
285,355
642,055
110,858
6,870,108
2017
381,148
3,472,360
2,452,469
2,530,789
8,783,816
1,521,906
156,992
3,210,047
1,365,334
148,962
758,207
186,730
7,401,127
2018
361,437
3,456,168
2,432,700
2,529,308
8,728,990
1,452,047
158,850
3,168,335
1,316,762
150,791
743,808
200,370
7,241,586
2019
361,164
3,501,241
2,500,944
2,588,403
8,899,836
1,404,242
163,210
3,226,391
1,286,724
157,027
727,994
205,042
7,222,548
2020
406,604
3,603,571
2,598,610
2,674,638
9,230,279
1,413,451
148,911
3,266,435
1,311,146
165,874
728,384
223,940
7,311,287
a Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks.
Table Al.3-4 Vehicle Segment Volumes"
Reference Class
Segment
LargeAuto
MidSizeAuto
CompactAuto
SubCmpctAuto
All Cars
LargePickup
SmallPickup
LargeSUV
MidSizeSUV
Small SUV
MiniVan
Cargo Van
All Trucks
Actual and Projected Sales Volume
2021
384,191
3,604,960
2,629,933
2,704,376
9,265,881
1,352,502
148,400
3,274,899
1,266,485
165,290
720,675
208,102
7,193,932
2022
353,301
3,635,168
2,645,629
2,708,913
9,282,884
1,302,512
142,033
3,245,920
1,238,672
163,744
713,307
195,757
7,062,072
2023
352,705
3,732,222
2,651,598
2,708,098
9,382,100
1,251,253
145,507
3,281,687
1,219,552
163,691
712,312
193,828
7,030,352
2024
345,006
3,781,545
2,756,463
2,770,523
9,588,366
1,226,935
149,188
3,353,515
1,247,145
167,086
695,336
189,957
7,094,332
2025
356,435
3,835,289
2,847,781
2,843,941
11,461,493
1,215,296
149,308
3,395,154
1,258,695
169,425
700,287
194,544
5,504,662
a Volumes in this table are based on the pre-2011 NHTSA definition of Cars and Trucks.
Table Al.3-5 2011+ NHTSA Car and Truck Definition Based Volumes
Vehicle Type
Trucks
Actual and Projected Sales Volume
2008
5,620,847
2017
5,846,663
2018
5,703,588
2019
5,667,948
2020
5,714,586
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2017-2025 Technical Assessment
Cars
Cars and Trucks
8,220,517
13,841,364
10,338,280
16,184,943
10,266,989
15,970,576
10,454,435
16,122,384
10,826,981
16,541,566
Table Al.3-6 2011+ NHTSA Car and Truck Definition Based Volumes
Vehicle Type
Trucks
Cars
Cars and Trucks
Actual and Projected Sales Volume
2021
5,618,286
10,841,528
16,459,813
2022
5,505,720
10,839,236
16,344,956
2023
5,468,789
10,943,663
16,412,452
2024
5,475,941
11,206,758
16,682,698
2025
5,504,662
11,461,493
16,966,155
Table Al.3-7 also shows how the change in fleet make-up may affect the footprint
distributions over time. The resulting data indicate that footprint will not change significantly
between 2008 and 2025. There will be an increase in the number of cars sold (as compared to
trucks), which will cause the average footprints for cars and trucks combined to be slightly
smaller (about 2%). This is the result of AEO projecting an increased number of cars, and
CSM predicting that most of that increase will be in the subcompact segment.
Table Al.3-7 Production Foot Print Mean
Model Year
2008
2017
2018
2019
2020
2021
2022
2023
2024
2025
Foot Print Mean
Cars
45.45
44.94
44.93
44.92
44.95
44.93
44.91
44.93
44.92
44.92
Foot Print Mean for
Trucks
54.12
53.93
53.85
53.76
53.89
53.81
53.78
53.66
53.51
53.47
Foot Print Mean for Cars & Trucks
Combined
48.97
48.19
48.12
48.03
48.04
47.96
47.90
47.84
47.74
47.69
Table Al.3-8 and Table Al.3-9 below show the changes in engine cylinders over the
model years. The current assumptions show that engines will be downsized over the model
years to which these rules apply. The biggest projected shift occurs between MY 2008 and
2013. This shift is a projected consequence of the expected changes in class and segment mix
as predicted by AEO and CSM, and does not represent engine downsizing attributable to the
rules.
A-7
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Appendix A
Table Al.3-8 Truck Percentages of 4, 6, 8 Cylinder Engines by Model Year
Model Year
2008
2017
2018
2019
2020
2021
2022
2023
2024
2025
Percentage of 4
Cylinders
10.33%
10.94%
10.65%
10.42%
10.29%
10.28%
10.26%
10.26%
10.47%
10.52%
Percentage of 6
Cylinders
56.40%
63.67%
64.51%
65.47%
65.57%
66.33%
66.74%
67.73%
68.09%
68.22%
Percentage of 8
Cylinders
33.27%
25.39%
24.84%
24.12%
24.14%
23.39%
23.00%
22.01%
21.44%
21.26%
Table Al.3-9 Car Percentages of 4, 6, 8 Cylinder Engines by Model Year
Model Year
2008
2017
2018
2019
2020
2021
2022
2023
2024
2025
Percentage of 4
Cylinders
56.99%
60.63%
60.70%
60.72%
60.39%
60.75%
61.19%
61.05%
61.12%
61.20%
Percentage of 6
Cylinders
37.80%
34.55%
34.47%
34.43%
34.74%
34.47%
34.16%
34.32%
34.19%
34.11%
Percentage of 8
Cylinders
5.20%
4.82%
4.83%
4.85%
4.87%
4.78%
4.65%
4.63%
4.68%
4.69%
Al.3.4 How does manufacturer product plan data factor into the baseline?
In the spring and fall of 2009, many manufacturers submitted product plans in
response to NHTSA's request. NHTSA and EPA both have access to these plans, and both
agencies have reviewed them in detail. A small amount of product plan data was used in the
development of the baseline. The specific pieces of data are:
• Wheelbase
• Track Width Front
• Track Width Rear
• Curb Weight
• GVWR (Gross Vehicle Weight Rating)
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2017-2025 Technical Assessment
The track widths, wheelbase, curb weight, and GVWR for vehicles could have been
looked up on the internet (159 were), but were taken from the product plans when available
for convenience. To ensure accuracy, a sample from each product plan was used as a check
against the numbers available from Motortrend.com. These numbers will be published in the
baseline file since they can be easily looked up on the internet.
A-9
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Appendix A
Appendix A References
All references can be found in Docket EPA-HQ-OAR-2009-0472.
1 WardsAuto.com: Used as a source for engine specifications.
2 Motortrend.com and Edmunds.com: Used as a source for foot print and vehicle weight data.
3 Energy Information Administration's 2009 Annual Energy Outlook.
4 CSM World Wide, CSM World Wide is a paid service provider.
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2017-2025 Technical Assessment
Appendix B: Package Cost and Effectiveness
Bl Explanation of Technology Packages
As discussed briefly at the end of Chapter 3, EPA believes that manufacturers are
likely to bundle technologies into -packages" to capture synergistic aspects and reflect
progressively larger CO2 reductions with additions or changes to any given package. In
addition, manufacturers typically apply new technologies in packages during model
redesigns—which occur once roughly every five years—rather than adding new technologies
one at a time on an annual or biennial basis. This way, manufacturers can more efficiently
make use of their redesign resources and more effectively plan for changes necessary to meet
future standards.
Therefore, the approach taken by EPA for purposes of this Technical Assessment
Report is to group technologies into packages of increasing cost and effectiveness. While
developing its analysis for the 2012-2016 rulemaking, EPA employed 19 different vehicle
types for modeling the entire fleet. For the current assessment, we have used the same 19
vehicle types, with the exception that vehicle type 15 was replaced with a different baseline
engine to provide us with a more appropriate set of technologies and packages for large cars
with baseline V8 overhead valve engines. Each of these 19 vehicle types is mapped into one
of six classes of vehicles: Subcompact, Small car, Large car, Minivan, Small truck, and Large
truck. Note that, for the current assessment, EPA has created a new vehicle class called
-Subcompact" which allows for greater differentiation of costs for this growing class of
vehicles (such as the Honda Fit, the Toyota Yaris, and the new Ford Fiesta). Note also that
these 19 vehicle types span the range of vehicle footprints—smaller footprints for smaller
vehicles and larger footprints for larger vehicles—which served as the basis for the 2012-2016
GHG standards. The resultant 19 vehicle types, their baseline engines and their descriptions
are shown in Table Bl-1.
Table Bl-1: List of 19 Vehicle Types used to Model the Light-duty Fleet
Vehicle
Type#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Base Engine
1.5L4VDOHCI4
2.4L 4V DOHC 14
2.4L 4V DOHC 14
3.0L4VDOHCV6
3.3L4VDOHCV6
4.5L4VDOHCV8
2.6L 4V DOHC 14 (15)
3.7L2VSOHCV6
4.0L 2V SOHC V6
4.7L 2V SOHC V8
4.2L 2V SOHC V6
3.8L2VOHVV6
5.7L2VOHVV8
5.4L3VSOHCV8
5.7L2VOHVV8
3.5L4VDOHCV6
4.6L 4V DOHC V8
Base
Trans
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
Vehicle Class
Subcompact
Small car
Small car
Minivan
Large car
Large car
Minivan
Small truck
Minivan
Minivan
Large truck
Large truck
Large truck
Large truck
Large car
Minivan
Minivan
Description
Subcompact car 14
Compact car 14
Midsize car/Small MPV 14
Compact car/Small MPV V6
Midsize/Large car V6
Midsize car/Large car V8
Midsize MPV/Small truck 14
Midsize MPV/Small truck V6
Large MPV V6
Large MPV V8
Large truck/van V6
Large truck/MPV V6
Large truck/van V8
Large truck/van V8
Large car V8
Large MPV V6
Large MPV V8
B-l
-------
Appendix B
18
19
4.0L 4V DOHC V6
5.6L4VDOHCV8
4spAT
4spAT
Large truck
Large truck
Large truck/van V6
Large truck/van V8
To prepare inputs for the OMEGA model, EPA builds a -master-set" of technology
packages. The master-set of packages for each vehicle type are meant to reflect the most
likely technology packages manufacturers would consider when determining their plans for
complying with future standards (as well as technology pathways described in Chapter 3 and
6). In other words, they are meant to reflect the most cost effective groups of technologies—
those that provide the best trade-off of costs versus fuel consumption improvements. This is
done by grouping reasonable technologies in all possible permutations and ranking those
groupings based on the Technology Application Ranking Factor (TARF).A Grouping
reasonable technologies" simply means grouping those technologies that are complementary
(e.g., turbocharging plus downsizing) and not grouping technologies that are not
complementary (e.g., dual cam phasing and coupled cam phasing).
To generate the master-set of packages for each of the vehicle types, EPA has built
packages in a step-wise fashion looking first at conventional gasoline technologies, then
advanced gasoline technologies and then hybrid and other electrified vehicle technologies.
This was done by presuming that auto makers would first concentrate efforts on conventional
gasoline engine and transmission technologies paired with varying levels of mass reduction to
improve fuel consumption. This is essentially the impact that the 2012-2016 rule will have as
that rule did not rely heavily on advanced gasoline technologies or
hybridization/electrification of the fleet. The initial levels of mass reduction considered were
up to 15%.B Different pathways matched more intensive mass reductions with more
advanced technologies.
Once the conventional gasoline engine and transmission technologies have been fully
considered, we expect that auto makers would apply more complex (and costly) technologies
such as advanced gasoline engines (turbocharged and cooled EGR technology for example)
and further mass reduction (beyond 15%) in both the conventional and advanced gasoline
packages.
From there, auto makers would most likely move to hybridization using one of two
types of hybridization -P2 or 2-mode—depending on the vehicle type.c These hybrids could
A The Technology Application Ranking Factor (TARF) is the factor used by the OMEGA model to rank
packages and determine which are the most cost effective to apply. The TARF is calculated as the net
incremental cost (or savings) of a package per kilogram of CO2 reduced by the package relative to the previous
package. The net incremental cost is calculated as the incremental cost of the technology package less the
incremental discounted fuel savings of the package over 5 years. The incremental CO2 reduction is calculated as
the incremental CO2/mile emission level of the package relative to the prior package multiplied by the lifetime
miles travelled. More detail on the TARF can be found in the OMEGA model supporting documentation (see
EPA-420-B-09-035).
B Importantly, the mass reduction associated for each of the 19 vehicle types was based on the vehicle-type sales
weighted average curb weight.
c For the current assessment, we have considered P2 hybrids and 2-mode hybrids and have not considered
power-split or other hybrid technologies. The 2-mode hybrid has been considered because it provides for
hybridization of a vehicle while also maintaining acceptable towing capability. The P2 hybrid has been chosen
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2017-2025 Technical Assessment
employ either conventional or advanced gasoline engines and would be paired with varying
levels of mass reduction ranging from 15% up to 30%.
Lastly, for some vehicle types, we anticipate that auto makers would move to more
advanced electrification in the form of both range extended electric vehicles (REEV)D and full
electric vehicles (EV). These also would be paired with varying levels of mass reduction
from 15% up to 30%. In general the packages are generated in order of increasing complexity
or cost.
Focusing first on the conventional gasoline packages, the first step in creating these
packages was to consider the 8 primary categories of conventional gasoline engine
technologies. These are:
Our -anytime technologies" (ATT) which consist of low friction lubes, engine
friction reduction, aggressive shift logic (automatic transmission only), early
torque converter lock-up (automatic transmission only), and low rolling resistance
tires.
- Variable valve timing (VVT) consisting of coupled cam phasing (CCP, for OHV
and SOHC engines) and dual cam phasing (DCP, for DOHC engines)
Variable valve lift (VVL) consisting of discrete variable valve lift (DVVL, for
DOHC engines)
- Cylinder deactivation (Deac, considered for OHV and SOHC V8 engines)
- Gasoline direct injection (GDI)
Turbocharging and downsizing (TDS, which always includes a conversion to GDI)
Stop-start
- Mass reduction consisting, in this step, of 3%, 5%, 10% and 15%.
In this first step, we also considered the 3 primary transmission technologies. These
are:
6 speed automatic transmission (6sp AT)
- 6 speed dual clutch transmission with wet clutch (6sp wet-DCT)
- 6 speed dual clutch transmission with dry clutch (6sp dry-DCT)
In considering the transmissions, we had to first determine how each transmission
could reasonably be applied. DCTs, especially dry-DCTs, cannot be applied to every vehicle
type due to low end torque demands at launch. In addition, wet-DCTs are more efficient than
6sp ATs, and dry-DCTs are more efficient still. Further, each transmission has lower costs,
respectively. Therefore, moving from 6sp AT to wet-DCT to dry-DCT as quickly as possible
is preferable. Throughout this assessment, each of these transmissions were allowed on each
because we believe that, in the timeframe of the current assessment, the P2 hybrid will provide the most cost
effective approach to improving fuel consumption in vehicles that have no and/or comparatively low towing
demands.
D We are using the term REEV synonymously with PHEV (plug-in hybrid electric vehicle) for the purposes of
this analysis.
B-3
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Appendix B
vehicle type giving consideration to the expected towing demands and curb weights as shown
in Table Bl-2 For example, vehicle type 5 is equipped with a 4 speed automatic transmission
in the baseline. In a package consisting of a 3% to 20% mass reduction, we believe this
vehicle type could convert to a wet-DCT because the lighter weight results in reduced low end
torque demands thus making the wet-DCT feasible. Upon reaching 25% mass reduction, the
vehicle type could employ a dry-DCT because the even lighter weight results in further
reduction in low end torque demands. We note that we have estimated that all vehicle types
will employ DCTs rather than 6 speed automatic transmissions, because we believe that the
wet-DCT is capable of meeting the towing demands of the light-duty fleet while providing
better efficiency and lower costs than the 6 speed automatic transmission, and it is thus
reasonable to assume that all manufacturers will choose to employ wet-DCTs rather than 6
speed automatics.
Table Bl-2: Application of Transmission Technologies in Building Packages
Vehicle
Type#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Vehicle
Class
Subcompact
Small car
Small car
Minivan
Large car
Large car
Minivan
Small truck
Minivan
Minivan
Large truck
Large truck
Large truck
Large truck
Large car
Minivan
Minivan
Large truck
Large truck
Base
Engine
14
14
14
V6
V6
V8
14
V6
V6
V8
V6
V6
V8
V8
V8
V6
V8
V6
V8
Mass Reduction
0%
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
4spAT
3% 5% 10% 15% 20% :
6sp dry-DCT
>5% 30%
6sp dry-DCT
6sp dry-DCT
6sp wet-DCT 6sp dry-DCT
6sp wet-DCT
6sp wet-DCT
6sp dry-
DCT
6sp dry-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
6sp wet-DCT
We start by first building a -preliminary-set" of conventional gasoline packages for
each vehicle type consisting of combinations of each of these 8 primary engine technologies.
The initial packages represent what we expect a manufacturer will most likely implement on
all vehicles, including low rolling resistance tires, changes to accommodate low friction
lubricants, engine friction reduction, aggressive shift logic, early torque converter lock-up and
improved electrical accessories. Subsequent packages include more sophisticated gasoline
engine and transmission technologies such as turbo/downsizing, GDI, increasing mass
reduction and dual-clutch transmissions. This preliminary-set of conventional gasoline
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2017-2025 Technical Assessment
packages was ranked by its TARF for each vehicle type. The TARF ranking process
eliminated some packages in favor of more cost effective packages. The packages that
remained after the TARF ranking process were then included in the master-set of packages for
each vehicle type.
Once the preliminary-set of conventional gasoline packages had been pared down and
moved into the master-set of packages, the most effective (i.e., not the most cost effective, but
simply the most effective) of the conventional gasoline packages was paired with increasing
levels of mass reduction up to 30%. Also, the advanced gasoline packages come in—note that
all advanced gasoline packages are turbo/downsized GDI engines equipped with cooled EGR,
dual cam phasing and discrete variable valve lift. We have built one advanced gasoline
package without stop-start technology and one with. Each of these is then paired with
increasing levels of mass reduction up to 30%. Even though these advanced technologies are
paired with increased mass reduction, the model is able to isolate the effect of these
individually in order to examine the separate technology pathways described in Chapter 3 and
6 of the TAR. The master-set of packages now consists of the most cost effective
conventional gasoline packages with mass reductions ranging from 0% to 15%, the most
effective conventional gasoline package with increasing levels of mass reduction up to 30%,
and advanced gasoline packages (both with stop-start and without) with mass reduction levels
ranging from 15% to 30%.
The next packages after the conventional and advanced gasoline packages are the
FIEVs. As noted, we have considered P2 and 2-mode FIEVs for this assessment as discussed
in section B4E. The agencies assumed that, for some of the vehicles types ranging in size up
to and including -targe Car", -Minivan" and -Small Truck", towing capacity could be
reduced to approximately 1,500 poundsF on HEV models and that these vehicles would use a
P2 FIEV configuration. As described in Chapter 3, in some cases this reflects a loss in towing
utility as compared to the baseline vehicle. For such vehicle types, consumers requiring
greater towing capacity would select a non-HEV powertrain. The agencies assumed that the
HEV versions of most of the larger vehicle types would require the same towing capacity as
the baseline vehicle and a 2-mode FIEV powertrain was selected for these vehicle types. The
breakdown of HEV application is shown in Table Bl-3.
Table Bl-3: Types of Hybridization Considered in this Assessment
Vehicle
Type#
1
2
O
4
Vehicle
Class
Subcompact
Small car
Small car
Minivan
Base Engine
14
14
14
V6
HEV Type
P2
P2
P2
P2
' P2 hybrids are defined and described in Chapter 3 (sction 3.2.3)
B-5
-------
Appendix B
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Large car
Large car
Minivan
Small truck
Minivan
Minivan
Large truck
Large truck
Large truck
Large truck
Large car
Minivan
Minivan
Large truck
Large truck
V6
V8
14
V6
V6
V8
V6
V6
V8
V8
V8
V6
V8
V6
V8
P2
P2
P2
P2
2-mode
2-mode
2-mode
P2
2-mode
2-mode
P2
P2
2-mode
P2
2-mode
As done with conventional gasoline packages, we began with a preliminary-set of
HEV packages that paired the HEV powertrain with increasing levels of engine technologies.
For example, the preliminary-set of HEV packages would pair the HEV powertrain first with
a very basic gasoline engine (e.g., anytime technologies (ATT) and variable valve timing
(VVT), such as dual cam phasing (DCP)), then a slightly more sophisticated gasoline engine
(e.g., ATT, DCP, GDI), then a more sophisticated gasoline engine (e.g., ATT, DCP, GDI,
turbo/downsize), then an advanced gasoline engine (e.g., ATT, DCP, variable valve lift, GDI,
turbo/downsize, cooled EGR), etc. We then ranked the preliminary-set of HEV packages
according to TARF to generate the most cost effective set of HEV packages for each vehicle
type that would then be included in the master-set of packages.
In general, the result of the TARF ranking of the preliminary-set of packages resulted
in a master-set of packages that included three versions of HEV for each vehicle type. The
first version employs a simple conventional gasoline engine such as one equipped with
anytime technologies and valve timing control. The second employs a
downsized/turbocharged gasoline engine and gasoline direct injection. The third employs an
advanced gasoline engine with turbo/downsizing, direct injection and cooled EGR. Each of
these versions of HEV was then paired with mass reduction levels ranging from 15% to 30%.
The last step was to build the REEVs and EVs for vehicle types 1 through 8 and 15.
The other vehicle types were not considered for electrification beyond HEVs for purposes of
the current analysis, either because of their expected towing demands or because of their high
vehicle weight which would make the electrification of the vehicle prohibitively expensive.
We have developed 2 primary types of REEV packages and 3 primary types of EV packages
all of which are included in the master-set of packages. The REEVs consist of packages with
battery packs capable of 20 miles of all electric operation (REEV20) and packages with
battery packs capable of 40 miles of all electric operation (REEV40). For EVs, we have built
packages capable of 75, 100 and 150 miles of all electric operation, EV75, EV100 and
EV150, respectively. These ranges were selected to represent an increasing selection of
ranges (and costs) that consumers will require and that we believe will be available in the
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2017-2025 Technical Assessment
2020 timeframe. For each of these packages, we have estimated specific battery-pack costs
for systems placed in vehicles with 15% and 20% mass reduction to the -glider" (i.e., the
vehicle less any powertrain elements). We have then paired each REEV with 15%, 20%, 25%
and 30% mass reduction and each EV with 15% and 20% mass reduction. Note that the
REEVs with 25% and 30% mass reduction are not assumed to be constructed with the smaller
battery packs and electric motors that would be possible with the 30%-lighter vehicle. This
may make our estimates of cost effectiveness for REEVs with these higher mass reductions
conservative since, while the higher mass reduction means lower fuel consumption and CC>2
emissions, those benefits are balanced against the higher costs of further mass reduction
without accounting for the lower cost of a smaller battery pack and motor. The end result is a
master-set of over 40 packages for those vehicle types with REEVs and EVs and as many as
30 packages for those vehicle types without REEVs and EVs. Because of the large number of
total packages, Table Bl-4 shows only the resultant master-set of packages for vehicle type 5,
a large car with a V6 DOHC engine in the baseline. Note that a complete master-set of
packages for each vehicle type along with their costs and effectiveness estimates is contained
in a memorandum to the docket for this report.1 Importantly, for each level of mass reduction,
there is some level of expected engine downsizing made possible due to the lower vehicle
weight. The analysis does not account for any cost credit for downsizing that consists only of
minor displacement changes (i.e., less than 20%)—only because we have not yet developed
estimated costs or savings of doing so—even though the engine itself would contain
somewhat less material. However, when a downsize occurs that consists of cylinders being
removed (in the case of V8 to V6 and V6 to 14 downsizing) or a large displacement change
(in the case of an 14 to smaller 14), we do consider the cost implications of the downsizing
because we have tear-down data upon which to base our cost estimates.
Table Bl-4: Technology Packages used in OMEGA for Vehicle Type 5, Large Car V6
Tech
Pkg#
500
501
502
503
504
505
506
507
508
509
510
511
512
513
514
515
516
517
518
519
Mass
Rdxn
0%
3%
5%
15%
15%
15%
15%
15%
20%
25%
30%
20%
25%
30%
20%
25%
30%
15%
20%
25%
Package Technologies
3.3L4VDOHCV6
4V DOHC I4+ATT+DCP+GDI+TDS
4V DOHC I4+ATT+DCP+GDI+TDS
4V DOHC I4+ATT+DCP+GDI+TDS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+SS+EGR
4V DOHC I4+ATT+DCP+DS+HEV
4V DOHC I4+ATT+DCP+DS+HEV
4V DOHC I4+ATT+DCP+DS+HEV
Transmission
4spAT
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
6sp DCT-dry
6sp DCT-wet
6sp DCT-dry
6sp DCT-dry
6sp DCT-wet
6sp DCT-dry
6sp DCT-dry
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
Description
Baseline Package
ATT= Anytime techs
DCP=dual cam phasing
GDI=gasoline direct
injection,
TDS=turbo/downsize
DVVL=discrete variable
valve lift
SS=stop- start
EGR=cooled EGR
HEV=P2 for this vehicle
type
B-7
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Appendix B
520
521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
538
539
540
30%
15%
20%
25%
30%
15%
20%
25%
30%
15%
20%
30%
15%
20%
30%
15%
20%
15%
20%
15%
20%
4V DOHC I4+ATT+DCP+DS+HEV
4V DOHC I4+ATT+DCP+GDI+TDS+HEV
4V DOHC I4+ATT+DCP+GDI+TDS+HEV
4V DOHC I4+ATT+DCP+GDI+TDS+HEV
4V DOHC I4+ATT+DCP+GDI+TDS+HEV
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV
4V DOHC I4+ATT+DCP+DVVL+GDI+TDS+EGR+HEV
4V DOHC I4+ATT+GDI+DS+REEV20
4V DOHC I4+ATT+GDI+DS+REEV20
4V DOHC I4+ATT+GDI+DS+REEV20
4V DOHC I4+ATT+GDI+DS+REEV40
4V DOHC I4+ATT+GDI+DS+REEV40
4V DOHC I4+ATT+GDI+DS+REEV40
EV75 (27kWh, 75 miles onroad @ 3 14 Wh/mi)
EV75 (27kWh, 75 miles onroad @ 304 Wh/mi)
EV100 (39kWh, 100 miles onroad @ 323 Wh/mi)
EV100 (39kWh, 100 miles onroad @ 314 Wh/mi)
EV150 (63kWh, 150 miles onroad @ 346 Wh/mi)
EV150 (63kWh, 150 miles onroad @ 337 Wh/mi)
6sp DCT-dry
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
6sp DCT-dry
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
6sp DCT-dry
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
6sp DCT-wet
6sp DCT-wet
6sp DCT-dry
N/A
N/A
N/A
N/A
N/A
N/A
To reiterate, some preliminary packages considered during the package creation
process were determined to not be cost-effective when ranked with other packages for the
given vehicle type. For example, the packages shown in Table B1-4 move immediately from
the baseline package to a rather complex turbo/downsized package in package number 501.
This does not mean that we did not consider packages consisting only of, for example, DCP
or DCP+GDI when generating our preliminary-set of packages. Rather, it means that those
packages simply were not as cost effective in this analysis, based on their Technology
Application Ranking Factor (TARF), as was the package shown as #501. For that reason, the
intermediate packages that were part of the preliminary-set of packages have simply been
eliminated from consideration and have not been included in the master-set of packages since
OMEGA will never pick them given the levels of potential standards considered in this
Technical Assessment Report.
Once the master-set of packages is complete, they are all ranked once again based on
TARF to generate the tanked-set" of packages for each of the technology paths discussed in
Section 3.3 of the main report. While the master-set of packages is considered unchanging (at
least in the context of this current analysis), the ranked-set of packages is different for each
technology pathway because each pathway has different levels of, for example, mass
reduction caps. For a technology pathway with a mass reduction cap of 15%, those packages
with mass reductions greater than 15% would be eliminated from consideration and would not
be included in the ranked-set of packages. Likewise, those packages having mass reductions
greater than 20% would be eliminated in a technology pathway having a mass reduction cap
of 20%. The package ranking also changes for each given year since technology costs and,
hence, package costs change year-to-year. As a result, a ranked-set of packages in 2020 may
or may not include the same packages as a ranked-set of packages in 2025 even if using the
same mass reduction cap, and they may or may not be ranked in the same order.
B-8
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2017-2025 Technical Assessment
B2 Engine Technologies
B2.1 Updated Tear-down Costs from FEV
As noted in Chapter 3, the agencies have reconsidered many of the costs used in the
2012-2016 joint final rule where those costs were based on tear-down studies conducted by
FEV under contract to EPA. We have reconsidered these costs because, in the 2012-2016
light-duty final rule, the agencies relied on the FEV tear-down study findings in part for
estimating the cost of several technologies. However, for some of the technologies, NHTSA
and EPA modified FEV's actual estimated costs. This was done because FEV based their
costs on the assumption that these technologies would be mature when produced in large
volumes (450,000 units or more). The agencies believed that there was some uncertainty
regarding each manufacturer's near-term ability to employ the technology at the volumes
assumed in the FEV analysis with fully learned costs. There was also the potential for near
term (earlier than 2016) supplier-level costs to be higher than those considered in the FEV
analysis because existing equipment and facilities need to be converted to the production of
new technologies and may lead to stranded capital if done too rapidly.0 However, the
agencies consider the FEV results to be valid for the 2017-2025 timeframe because the
limitations considered in the 2012-2016 light-duty rule should no longer exist and sales
volumes of 450,000 units are likely by then due to, at least in part, the new GHG and fuel
economy requirements.
We reiterate that the agencies believe that the best method to derive technology cost
estimates is to conduct studies involving tear-down and analysis of actual vehicle
components. A tear-down analysis involves breaking down a technology into its fundamental
parts and manufacturing processes by completely disassembling vehicles and vehicle
subsystems and precisely determining what would be required for its production. More
details about tear-down studies can be found in the studies supporting the 2012-2016 light-
duty final rule as well as the FEV and Munro Associates report for EPA.2 This tear-down
method of costing technologies is often used by manufacturers to benchmark their products
against competitive products. Historically, vehicle and vehicle component tear-down has not
been done in large scale by researchers and regulators due to the expense required for such
studies.
To date, such tear-down studies have been completed on the five technologies listed
below. These completed tear-down studies provide a thorough evaluation of the component
or system cost relative to their baseline (or replaced) technologies. A more detailed
description of these technologies can be found in the Technical Support Document prepared
for the 2012-2016 light-duty final rule.3 For these technologies, the agencies have relied on
the tear-down data available and scaling methodologies used in EPA's ongoing study with
FEV.
G Stranded Capital is defined as manufacturing equipment and facilities that cannot be used in the production of
a new technology.
B-9
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Appendix B
4.
5.
Stoichiometric gasoline direct injection and turbocharging with engine downsizing
(TDS) for a large DOHC (dual overhead cam) 4 cylinder engine to a smaller
DOHC 4 cylinder engine.
Stoichiometric gasoline direct injection and turbo charging with engine
downsizing for a SOHC (single overhead cam) 3 valve/cylinder V8 engine to a
SOHC V6 engine.
Stoichiometric gasoline direct injection and turbo charging with engine
downsizing for a DOHC V6 engine to a DOHC 4 cylinder engine.
6-speed automatic transmission replacing a 5-speed automatic transmission.
6-speed wet dual clutch transmission (DCT) replacing a 6-speed automatic
transmission.
FEV's costing methodology for these studies has been published and has been peer
reviewed.4 Using this tear down costing methodology, FEV has developed costs for each of
the above technologies. In addition, using the studies listed above, FEV and EPA were able
to extrapolate the engine downsizing costs for the following scenarios to estimate costs
presented in the 2012-2016 rule:
1. Downsizing a SOHC 2 valve/cylinder V8 engine to a DOHC V6.
2. Downsizing a DOHC V8 to a DOHC V6.
3. Downsizing a SOHC V6 engine to a DOHC 4 cylinder engine.
4. Downsizing a DOHC 4 cylinder engine to a DOHC 3 cylinder engine.
The costs used in the 2012-2016 rule and the updated costs used in this assessment are
shown in Table B2.1-1.
Table B2.1-1: Comparison of Stoichiometric Gasoline Direct Injection,
Turbo/Downsizing and Transmission Costs, Inclusive of Markups, used in the 2012-2016
Rulemaking versus this Assessment
Stoichiometric GDI (I3/I4)a
Stoichiometric GDI (V6) a
Stoichiometric GDI (V8) a
Turbo/Downsize 14 DOHC
to 13 DOHCb
Turbo/Downsize 14 DOHC
to smaller 14 DOHCb
Turbo/Downsize V6
DOHC to 14 DOHCb
Turbo/Downsize V6 SOHC
to 14 DOHCb
Turbo/Downsize V6 OHV
to 14 DOHCb
Turbo/Downsize V8
DOHC to V6 DOHCb
Turbo/Downsize V8 SOHC
2012-2016
rulemaking;
applicable to the
2012MY
(2007 dollars)
$236
$341
$390
$395
$441
$168
$365
$872
$669
$923
2012-2016
rulemaking;
applicable to the
2016MY
(2007 dollars)
$209
$301
$346
$349
$391
$149
$323
$771
$592
$816
Assessment
Report;
applicable to the
2017MY
(2008 dollars)
$213
$370
$446
$287
$365
-$27
$110
$754
$491
$649
Assessment
Report;
applicable to the
2025MY
(2008 dollars)
$181
$299
$360
$245
$311
-$3
$107
$628
$428
$555
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2017-2025 Technical Assessment
2V/cyltoV6DOHC
Turbo/Downsize V8 SOHC
3 V/cyl to V6 DOHCb
Turbo/Downsize V8 OHV
to V6 DOHCb
6 speed automatic
transmission (from a 4
speed automatic
transmission) a
6 speed dual wet-clutch
transmission (from a 4
speed automatic
transmission) a
6 speed dual dry-clutch
transmission (from a 4
speed automatic
transmission) a
$832
$1,242
$112
$104
$53
$736
$1,099
$99
$92
$47
$590
$1,101
-$13
-$134
-$190
$507
$920
-$10
-$108
-$153
a Low complexity ICMs applied: 2012MY=1.11; 2016MY=1.11; 2017MY=1.17;2025MY=1.13. The2012MYand
2016MY ICMs differ from the 2017MYICM—all considered near term—due to factors described in Section 3.2.5 of the
main report. The 2025MY ICM is a long term ICM.
b Medium complexity ICMs applied: 2012MY=1.25; 2016MY=1.25; 2017MY=1.31; 2025MY=1.19. The 2012MY and
2016MY ICMs differ from the 2017MY ICM—all considered near term—due to factors described in Section 3.2.5 of the
main report. The 2025MY ICM is a long term ICM.
B2.2 Advanced Gasoline Cost and Effectiveness
B2.2.1 Turbocharged/downsized Engines with Gasoline Direct Injection
In the 2012-2016 final rule, the agencies estimated the combined effectiveness of
turbocharging, engine downsizing and GDI in reducing GHG emission to be 7%. Recent data
supports GHG effectiveness in the range of 12 to 30% depending on the extent of engine
downsizing for a given engine torque requirement.5'6'7 Taking into consideration the
availability of more recent published data and confidential business information, the Agencies
estimate the effectiveness of a Turbocharged GDI with single-stage turbocharging, dual cam-
phasing and with downsizing consistent with a BMEP level of approximately 22-24 bar to be
15%.
B2.2.2 Cooled EGR
A new technology considered for this assessment was cooled EGR with
turbocharging. This technology was described briefly in the 2012-2016 GHG and CAFE final
rule but the technology was not used in the cost and effectiveness analysis. Cooled EGR can
prevent combustion knock and thus allows for an increase in engine compression ratio and/or
more aggressive engine downsizing when combined with turbocharging and gasoline direct
injection while maintaining torque output and vehicle performance. Cooled EGR with
aggressive engine downsizing (approximately 24-bar BMEP), single-stage turbocharging,
dual cam phasing and discrete variable valve lift has been estimated by Ricardo to reduce
o
CO2 emissions over both the UDDS and highway fuel economy test by 23%. The
incremental effectiveness of cooled EGR relative to a downsized, turbocharged GDI engines
B-ll
-------
Appendix B
without EGR has been estimated to reduce BSFC by various sources to be approximately 5 to
13%.5'9'10'u Based on the cited publically available data and confidential business
information, the Agencies estimate the incremental effectiveness of cooled EGR with single-
stage variable geometry turbocharging and with downsizing consistent with approximately
24-bar BMEP to be 6% relative to turbocharging, downsizing and GDI without cooled EGR
as described in section B2.2.1; and 20% relative to a baseline 2008 PFI engine. We expect to
update the effectiveness values of this technology for the NPRM based on vehicle simulation
modeling currently being conducted under an EPA contract with Ricardo.
The costs for the technology here build upon the costs presented in the 2012-2016 rule
which showed costs of $75 for an EGR cooler, $20 for an EGR valve and $20 for associated
piping for a total direct manufacturing cost of $115 (2007 dollars). We have updated each of
those costs to 2008 dollars with the results being $77, $20 and $20, for a total of $117. To
provide sufficient transient engine control, we have assumed that a dual-loop EGR system
will be used with both high and low pressure EGR loops. We have doubled EGR component
costs to $235 to reflect components in both EGR loops and have added a $5 venturi to provide
for EGR flow from the low pressure exhaust system to the high pressure intake system, thus
giving a total of $240 for the cooled EGR portion of the system. Because the system is
expected to employ higher levels of boost over a broader range of flow conditions than the
conventional gasoline turbocharged system, we have also included a 1.5x factor to the
turbocharger costs to cover the incremental cost increase of a variable geometry turbocharger.
In other words, the turbocharger system cost is 1.5x greater on engines with cooled EGR than
on downsized, turbocharged engines without cooled EGR. This was estimated based on
engineering judgment with input from suppliers. Therefore, to the $240 value, we have added
$620 for I-configuration engines (1.5x the single turbocharger cost of $413 equals $620) and
$1,043 (1.5x the twin turbocharger cost of $695 equals $1,043) for V-configuration engines
(one turbocharger per cylinder bank, which is conservative as it is possible that not all V-
configuration engines will use twin turbochargers). The results being $859 ($240+$620) for
I-configuration engines and $1,283 ($240+$ 1,043) for V-configuration engines (direct
manufacturing costs, 2008 dollars, 2012MY). All of the costs stated thus far represent direct
manufacturing costs in 2008 dollars and are applicable to the 2012 model year. We consider
time based learning to be applicable to this advanced gasoline technology. The resultant
direct manufacturing cost and marked up costs are shown in Table B2.2-1 Importantly, these
costs shown here do not represent package costs since they do not include the anytime
technologies,11 DCP, DVVL, GDI, or downsizing related costs or other technologies that
might be included in an advanced gasoline package (such as stop-start or hybridization).
Table B2.2-1: Cooled EGR System Costs (2008 dollars)
Year
I-configuration engines
V-configuration engines
Direct Mfg Costs
2012
$859
$1,283
2020
$701
$1,048
2025
$634
$947
Costs with ICM
2012
$1,125
$1,681
2020
$878
$1,304
2025
$754
$1,127
H Anytime technologies are simpler technologies that can be added outside the normal redesign cycle, thus they
can be implemented anytime. An example is low rolling resistance tires.
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2017-2025 Technical Assessment
| ICM applied | | | | 1.31 | 1.31 | 1.19 |
B3 Transmission Technologies
B3.1 6, 7, and 8 speed Automatic Transmissions
As discussed in the 2012-2016 rule, manufacturers can choose to replace 4- and 5-
speed transmission with 6-, 7-, or 8-speed automatic transmissions. Additional ratios allow
for further optimization of engine operation over a wider range of conditions, but this is
subject to diminishing returns as the number of speeds increases. As additional planetary gear
sets are added (which may be necessary in some cases to achieve the higher number of ratios),
additional weight and friction are introduced. Also, the additional shifting of such a
transmission can be perceived as bothersome to some consumers, so manufacturers need to
develop strategies for smooth shifts. Some manufacturers are replacing 4- and 5-speed
automatics with 6-speed automatics, and 7- and 8-speed automatics have also entered
production, albeit in lower-volume applications in luxury and performance oriented cars.
As discussed in the 2012-2016 rule, confidential manufacturer data projected that 6-
speed transmissions could incrementally reduce fuel consumption by 0 to 5 percent from a
baseline 4-speed automatic transmission, while an 8-speed transmission could incrementally
reduce fuel consumption by up to 6 percent from a baseline 4-speed automatic transmission.
GM has publicly claimed a fuel economy improvement of up to 4 percent for its new 6-speed
automatic transmissions.12 The 2008 EPA Staff Technical Report found a 4.5 to 6.5 percent
fuel consumption improvement for a 6-speed over a 4-speed automatic transmission.13 Based
on this information, the agencies estimated that the conversion to a 6-,7- and 8-speed
transmission from a 4 or 5-speed automatic transmission with IATC would have an
incremental fuel consumption benefit of 1.4 percent to 3.4 percent, for all vehicle classes.
From a baseline 4 or 5 speed transmission without IATC, the incremental fuel consumption
benefit would be approximately 3 to 6 percent, which is consistent with the EPA Staff Report
estimate.
The agencies reviewed these effectiveness estimates and concluded that they remain
accurate. The GHG model estimates the packaged effectiveness of 4.5 to 6.5 percent.
The cost associated with 6 speed automatic transmissions has been updated for this
assessment relative to the estimates presented in the 2012-2016 rule. These updated costs are
presented above in Table B2.1-1 Dual Clutch Transmissions / Automated Manual
Transmissions.
An Automated Manual Transmission (AMT) is mechanically similar to a conventional
manual transmission, but shifting and launch functions are automatically controlled by the
electronics. There are two basic types of AMTs, single-clutch and dual-clutch (DCT). A
single-clutch AMT is essentially a manual transmission with automated clutch and shifting.
Because of shift quality issues with single-clutch designs, DCTs will likely be far more
common in the U.S. and are the basis of the estimates that follow. A DCT uses separate
clutches (and separate gear shafts) for the even-numbered gears and odd-numbered gears. In
this way, the next expected gear is pre-selected, which allows for faster and smoother shifting.
B-13
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Appendix B
For example, if the vehicle is accelerating in third gear, the shaft with gears one, three and
five has gear three engaged and is transmitting power. The shaft with gears two, four, and six
is idle, but has gear four engaged. When a shift is required, the controller disengages the odd-
gear clutch while simultaneously engaging the even-gear clutch, thus making a smooth shift.
If, on the other hand, the driver slows down instead of continuing to accelerate, the
transmission will have to change to second gear on the idling shaft to anticipate a downshift.
This shift can be made quickly on the idling shaft since there is no torque being transferred on
it.
In addition to single-clutch and dual-clutch AMTs, there are also wet clutch and dry
clutch designs which are used for different types of vehicle applications. Wet clutch AMTs
offer a higher torque capacity that comes from the use of a hydraulic system that cools the
clutches. Wet clutch systems are less efficient than the dry clutch systems due to the losses
associated with hydraulic pumping. Additionally, wet AMTs have a higher cost due to the
additional hydraulic hardware required.
Overall, DCTs likely offer the greatest potential for effectiveness improvements
among the various transmission options presented in this report because they offer the
inherently lower losses of a manual transmission with the efficiency and shift quality
advantages of electronic controls. The lower losses stem from the elimination of the
conventional lock-up torque converter, and a greatly reduced need for high pressure hydraulic
circuits to hold clutches or bands to maintain gear ratios in automatic transmissions.
However, the lack of a torque converter will affect how the vehicle launches from rest, so a
DCT will most likely be paired with an engine that offers sufficient torque at low engine
speeds to allow for adequate launch performance.
Referring to the 2012-2016 rule, these transmissions offer an effectiveness of 9.5 to
14.5 percent over a 4-speed automatic transmission. The agencies conclude that 8 to 13
percent effectiveness is still appropriate for this rule. The costs associated with 6 speed dual
clutch transmissions have been updated for this assessment relative to the estimates presented
in the 2012-2016 rule. These updated costs are presented above in Table B2.1-1. EPA had
hoped to include in this assessment FEV-generated tear-down cost estimates for an 8 speed
dual clutch transmission. Unfortunately, that work was not complete in time, but it is
expected to be used in the upcoming federal NPRM.
B4 Vehicle Technologies
B4.1 Aerodynamic Improvement Cost and Effectiveness
This can be achieved via two approaches, either reducing the drag coefficients or
reducing vehicle frontal area. To reduce drag coefficients, skirts, air dams, underbody covers,
and more aerodynamic side view mirrors can be applied, or the vehicle ride height can be
lowered. In addition to the standard aerodynamic treatments, the agencies have included a
second level of aerodynamic technologies (Aero 2) which could include active grille shutters,
rear visors, and larger under body panels. The GHG and fuel economy effectiveness of 2% is
unchanged from estimates used for 2016 model year vehicles in the 2012-2016 final rule, and
is based on a 10% assumed reduction in aerodynamic drag coefficient. This second level of
B-14
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2017-2025 Technical Assessment
aerodynamic technologies was not considered in the 2012-2016 light-duty rule and, as such,
the estimated costs are new and are presented in Table B4.1-1 along with the first level (Aero
1) as used in the 2012-2016 rule. Effectiveness for Aero 2 is based on an additional 10%
reduction in aerodynamic drag coefficient from the 2008 baseline and provides another 2%
reduction in GHG. Note that we apply time based learning to aerodynamic improvements.
Table B4.1-1: Costs Associated with Aerodynamic Improvements (2008 dollars)
Direct Manufacturing Costs (applicable to the 2015MY)
Technology
Aero 1 (incremental to base vehicle)
Air dam
Tire spats
Under body panels
Total (Average=$40)
Aero 2 (incremental to base vehicle)
Under body panels
Active grill shutters
Rear visors - hood, liftgate, tailgate
Low profile roof rack - stowable cross bows
Total (Average=$ 120)
Quantity
1
4
1
3,4
1
1
1
$/unit
$15-20
$2.50
$15-20
$10-20
$25-40
$15-20
$30
$/vehicle
Low
$15
$15
$30
$30
$25
$15
$70
$/vehicle
High
$20
$10
$20
$50
$80
$40
$20
$30
$170
Marked up costs
Technology
Aero 1 (ICM: Nearterm=1.17; Longterm=1.13)
Aero 2 (ICM: Near term=1.3 1; Long term=l. 19)
Year^
2015
$47
$157
2020
$40
$128
2025
$36
$115
B4.2 Electrified Vehicles Costing - HEV, PHEV, and EV Vehicles
While the overall methodology for costing electrified vehicles has not changed from
the 2012-2016 rule the scaling and cost basis for both batteries and electric motors has been
modified. Specifically, cost information developed by Oak Ridge National Laboratory
(ORNL) on electric motors has been applied, as well as battery costing information from
Argonne National Laboratory (ANL). Refer to the Technical Support Document (TSD)14 for
the 2012-2016 rule for a full description of the electrified vehicle costing methodology.
B4.2.1 Changes to the 2017-2025 Electrified Vehicle Costing
Unless otherwise noted, the cost basis and scaling for electrified vehicles in the 2017-
2025 analysis is identical to that used in the 2012-2016 rule. There are, however, several
changes to the cost basis due to various factors. The first was agreement within the agencies
that the mass of electrified vehicles would continue to be reduced while energy densities of
batteries are expected to increase. These trends made the current battery and motor sizing
strategies inappropriate for this analysis. In addition, recent data from ANL, which has been
corroborated with battery manufacturer data, indicates that battery costs will be dependent on
not only the annual production volume, but also the ratio of the power to energy. The
agencies, once again, determined that the application of a fixed $/kW-hr value was not
appropriate going forward. One of the caveats in applying the ANL cost model was that it
B-15
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Appendix B
was highly dependent of production volumes, volumes at which batteries will on be produced
until approximately MY 2025. As such, the electrified vehicle costing model was to apply
time based learning to the non-battery costs, as those are based on the 2012-2016 rule, and
treat the ANL battery costs as 2025 values. With regard to motor costs, the agencies
leveraged a cost study performed by ORNL on the Toyota Prius15 motor costs and applied the
ORNL results directly. Further detail for each of these considerations is provided below.
B4.2.1.1 P2 Hybrid Electric Vehicles
A P2 hybrid is a vehicle with an electric drive motor coupled to the engine crankshaft
via a clutch. The engine and the drive motor are mechanically independent of each other,
allowing the engine or motor to power the vehicle separately or combined. This is similar to
the Honda HEV architecture with the exception of the added clutch between the flywheel or
flexplate and the electric motor, additional battery capacity, and increased electric motor
power. Examples P2 hybrids include the 2011 Hyundai Sonata Hybrid, 2010 Hyundai Elantra
LPI HEV (Korean market only), the 2011 Infinity G35 Hybrid and the 2011 Volkswagen
Touareg Hybrid. The agencies believe that the P2 is an example of a -strong" hybrid
technology that is typical of what we will see in the timeframe of this rule. The agencies
could have equally chosen the power-split architecture as the representative HEV architecture.
These two HEV's have comparable average GHG effectiveness values (combined city and
highway fuel economy), though the P2 systems may have lower cost due to reduced number
of parts and complexity.
The Agencies estimated the effectiveness of the P2 hybrid system to be 30% within
our analysis. The effectiveness when combined with a DCT transmission is approximately
37%. The effectiveness used for vehicle packages with the P2 hybrid configuration within this
analysis reflects a conservative estimate of system performance. Vehicle simulation modeling
of technology packages using the P-2 hybrid configuration is currently underway under
contract with Ricardo Engineering. The agencies plan to update the effectiveness of hybrid
electric vehicle packages using the new Ricardo vehicle simulation modeling runs prior to the
NPRM.
Hybrid effectiveness was also applied differently across vehicle classes within this
analysis when compared to the 2012-2016 rule. Previously, the Agencies assumed less engine
downsizing and reduced effectiveness with increasing vehicle size to preserve some light-
towing capability for large cars, CUVs, minivans and small light trucks. For this analysis, P2
hybrid packages were only applied to vehicles with reduced towing capability (SAE Class I or
less) and the relative effectiveness due to engine downsizing with the P2 hybrid package was
applied equally across all vehicle categories capable of receiving the P2 hybrid package in the
Omega model.
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2017-2025 Technical Assessment
Engine Electric Motor Transmission/
Clutch / Transaxle
oooq
Figure B4.2-1: Functional schematic of P2 hybrid electric vehicle powertrain
configuration (not to scale).
B4.2.1.2 Battery and Motor Sizing
Baseline vehicle effective power-to-weight ratio1 was used to approximate equivalent
performance for EVs, PHEVs and P2 hybrids. Electric motors were sized based on
maintaining this ratio for EV, PHEV and hybridJ vehicles. In addition, some level of mass
reduction is expected to be realized for these types of vehicles, so the motor sizing was
dependent on the final, mass reduced, vehicle. Motor size for PHEVs assumed full vehicle
performance could be achieved on electric motor drive only. The Agencies scaled P2 hybrid
motors to represent 20% of the vehicle's (combined) effective power, as supported by
manufacturer's confidential information.
The battery packs were sized to provide 75, 100 or 150 mile on-roadK ranges in the
case of EVs and 20 or 40 mile on-road ranges in the case of PHEVs. Battery sizing for EVs
and PHEVs was based on a vehicle energy demand estimate (derived from EPA's lumped
parameter model) used to determine each vehicle's electric energy consumption, in Wh/mile,
for future EV, PHEV and hybrid packages (which considers road load and weight reductions).
1 To compare with conventional ICE-powered vehicles, we use -effective" vehicle power -defined here as the
peak combined power of the vehicle's engine and electric motor. In the case of P2 hybrids it is assumed that the
peak rated power values are additive, although this is not necessarily true for other architectures (such as power-
split hybrids, where the engine and motor power peaks do not occur at the same operating speed)
1 Vehicle weight reduction when applied to EVs and PHEVs was applied to the glider only (curb-weight less
electric drive components). Weight reduction was applied to the entire vehicle in the case of HEVs.
K EVs and PHEVs are assumed to experience an onroad range shortfall of 30%, whereas HEVs are assumed to
see a shortfall of 25%. In terms of energy consumption (and thus battery size), this represents an increase of
43% and 33% for EVs/PHEVs and HEVs, respectively.
B-17
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Appendix B
Additionally, battery usable state-of-charge (SOC) windowsL were assumed at 80% for future
EVs, 70% for future PHEVs and 50% for future HEVs.
B4.2.1.3 Battery Cost
Battery costs were determined using a model developed by Argonne National
Laboratory (ANL) which provides unique battery pack cost estimates for each of the three
major types of electrified vehicles. Within the model, battery pack costs are estimated based
on a bill of materials determined by battery pack design criteria. The costs include materials,
manufacturing processes, cost of capital equipment, plant area and labor for each
manufacturing step. A basic description of the ANL Li-ion battery cost model and initial
modeling results for PHEV applications were published within a peer-reviewed technical
paper presented at EVS-2416. ANL has extended modeling inputs and pack design criteria
within the cost model to include analysis of manufacturing costs for EV and HEV battery
packs in addition to the original work on PHEV battery costs.17 A thorough peer-review of
the ANL Li-ion battery cost model and its inputs and results is pending. The agencies expect
to continue to work with DOE and ANL (as well as manufacturers) to obtain the most up to
date information for the upcoming NPRM.
Within the ANL battery cost model, a bill of materials for a battery pack is determined
based on specific design criteria. The design criteria include a vehicle application's power
and energy storage capacity requirements, the battery's cathode and anode chemistry, and the
number of cells per module and modules per battery pack. The model assumes use of a
laminated multi-layer prismatic cell and battery modules consisting of double-seamed rigid
containers (Figure B4.2-2). The model also assumes that the battery modules are air-cooled.
The model takes into consideration the cost of capital equipment, plant area and labor for each
step in the manufacturing process for battery packs and places relevant limits on electrode
coating thicknesses and other processes limited by existing and near-term manufacturing
processes. Figure B4.2-3 shows a basic schematic of the plant layout and production steps
assumed within the model The ANL model also takes into consideration annual pack
production volume and economies of scale for high-volume production.
L On-road range is defined as the percentage of a battery pack's useful operating range. For durability and safety
reasons, electric vehicle batteries are not discharged completely, nor are they typically operated at fully charged
levels. Because of this limitation,. Thus the nominal battery size required always larger than that which is used,
and is calculated as the actual required capacity divided by the SOC window.
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2017-2025 Technical Assessment
Heat Transfer Surfaces
on Top and Bottom of
Container in Contact
with Cell Edge Seals
Cell with Stiff, Multi-
Layer Container
Cell Cross-Section
Battery Module
Figure B4.2-2: Prismatic Cell and Module Design for High Power-to Energy HEV
Battery Packs (provided courtesy of Argonne National Laboratory).
B-19
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Appendix B
Receiving
Shipping
<=
/;
1 1
1 1
;!
Cell and
Scrap
Recycling
Electrode Materials
Preparation
i — ^j> Positive • *
Negative
Battery Pack
Assembly and
Testing
= <=
Control
Laboratory
Module
11 Assembly
i
Charge-
Retention
Testing
<=
Final
Cell
Sealing
— ^
Electrode
Coating
^Positive ,
Negative
Solvent ~rrj
Evaporation
=^> Positive ,_
Negative
=> —
Formation
Cycling
— i
Materi.
Handli
<=
s
--> Solvent
Recovery
=>
Calendering
^>
Air
Locks
ils
ng
Electrc
= i> i=
>de
Assembly Route Dry Room
Outdoor dry-room air
processing equipment
The areas in this diagram for each processing step are approximately proportional to
the estimated plant areas in the baseline plant.
Figure B4.2-3: Lithium-ion Battery Pack Manufacturing Plant Schematic Diagram
(provided courtesy of Argonne National Laboratory).
The cost outputs from the ANL model used by the Agencies to determine 2025 HEV,
PHEV and EV battery costs assume 500,000 pack/year production volume. We also assumed
the use of a common cathode and anode chemistry, LiMn2O4-spinel for the cathode and
graphite for the anode. While it is expected that other Li-ion battery chemistries will likely be
available in the 2017-2025 timeframe, the specific chemistry used for the cost analysis was
chosen to be consistent with publicly available information on current and near term HEV,
PHEV and EV product offerings from Hyundai, GM and Nissan.18'19'20'21 The battery designs
used in the model also assumed full power delivery at 80% of the open circuit voltage. For
EVs, battery power was assumed to be sufficient to provide peak motor power for an
application with 15% added to account for HVAC and other non-motor electric loads. For
HEVs and PHEVs, battery power was assumed to be sufficient to provide peak motor power
for an application. The ANL battery cost model results for is compared to the costs used in
the 2012-2016 final rule and to cost estimates compiled by EPA from OEM battery suppliers
and auto OEMs in Figure B4.2-4.
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2017-2025 Technical Assessment
Estimated Battery Pack Costs
$800
^,
v>
tt
3
1 Total Range of OEM Supplier Estimates (>5sources) collected by EPA from 2008 -2010
T Range from the majority of OEM stakeholder meetings in June-August 2010
D2012-2016 EPACost Estimate
ODOE/ANL(PHEV20) O DOE/ANL(PHEV40)
ADOE/ANL(EV150) D DOE/ANL(EV100)
T
[1 1 I
2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030
Calendar Year
Figure B4.2-4: Comparison of direct manufacturing costs per unit of energy storage
($/kW-hr) between the estimates used by EPA in the 2012-2016 GHG final rule, the
ANL battery cost model results for PHEV20, PHEV40, EV100 and EV150 packages and
OEM battery suppliers (2008 dollars, markups not included). Multiple points shown
for the ANL cost model results for PHEV 20, PHEV40, EV100 and EV150 reflect the
range of energy-specific costs for EPA's subcompact through large-car package
categories (see Table B4.2-1 for details). A range of OEM estimated battery costs is also
shown for comparison (red bars) which may or may not reflect additional cost markups.
A PHEV and EV battery cost sensitivity analysis is included in Chapter 6, section 6.5
of the Technical Assessment. The analysis includes PHEV and EV battery pack costs
approximately $100/kW-hr higher and $50/kW-hr lower than the costs estimates from the
ANL battery cost model. The $100/kW-hr higher cost is comparable to commodity pricing
for high-volume LiCoO2 cells for consumer applications. The $50/kW-hr lower cost assumes
a breakthrough in battery design that would approximately triple cell energy density.
B4.2.1.4 Motor Costing
The agencies agreed that based on a review of the technical literature the cost-vs-
power relationship should not be a constant $15/kW across motor sizes. A linear relationship
was chosen based on 2007 Camry/Prius motor and generator costs (based on ORNL/EEA-
estimated costs) and treated as near-term (2012-2016) results. The motor sizing, determined
as described above was then applied to the linear cost model developed by ORNL:
• y (motor cost in USD) = 8.28 * (motor size in kW) +181.43
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Appendix B
The final value is then learned down from 2012 to 2025 by applying time based
learning.
B4.2.1.5 Learning Applied to Battery and Non-Battery Costs
As described above, the battery costs developed using the ANL model were
considered the 2025 model year costs expressed in 2008 dollars. In contrast, the remaining
parts of the hybrid or electrified vehicle system, termed the non-battery costs, were considered
the 2012 model year costs expressed in 2008 dollars. While the non-battery systems are
considered rather mature technologies for which time based learning is appropriate, the Li-ion
battery system is a new technology for which volume based learning is more appropriate. In
fact, the agencies believe it is likely that battery technology will undergo several levels of
volume based learning between 2012 and 2025 given the newness of the technology and the
rapid pace of development. For this reason, we have generated a unique learning curve for
the battery system technology that attempts to estimate costs back in time from the 2025
estimates discussed above. This allows us to estimate costs in the 2020 timeframe for
OMEGA as well as estimate those costs in each year between today and 2025. The learning
curve we have generated is shown in Figure B4.2-5. This learning curve consists of 5 full
volume based learning steps each of which results in costs being reduced 20% relative to the
prior step. These learning steps are shown occurring every two years beginning in 2012 until
2020 at which time a 5 year gap is imposed until 2025 when the ANL costs are reached and
the learning curve factor equals 1. Beyond 2025, time based learning is applied at 3% cost
reductions per year. The smooth line shows a logarithmic curve fit applied to the learning
curve as EPA's cost model would apply learning.
4.00
3.50
3.00
2.50
2.00
1.50
1.00
0.50
0.00
Battery Pack Learning Curve
2012 2016 2020 2024 2028
Learning curve Log. (Learning curve)
Figure B4.2-5: Battery Pack Learning Curve
Using this learning curve, we can estimate the battery pack direct manufacturing costs
for each year and for each type of battery pack. These details are shown in Table B4.2-1
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2017-2025 Technical Assessment
which shows, in the upper portion of the table, the estimated direct manufacturing costs for
each type of battery pack considered (for a large car in this example) and in the lower portion
the $/kWh estimated in each year based on the learning curve shown in Figure B4.2-5.
Table B4.2-1: Direct Manufacturing Costs for Battery Packs and Associated $/kWh for
Each, Costs for a Large Car (2008 dollars, markups not included)
Cost Element
2012
2015
2018
2019
2020
2021
2022
2023
2024
2025
Battery Pack Costs
P2 battery pack
REEV20
battery pack
REEV40
battery pack
EV75 battery
pack
EV1 00 battery
pack
EV1 50 battery
pack
$1,956
$7,120
$10,461
$14,276
$18,170
$26,869
$1,565
$5,696
$8,368
$11,421
$14,536
$21,495
$1,002
$3,645
$5,356
$7,309
$9,303
$13,757
$1,002
$3,645
$5,356
$7,309
$9,303
$13,757
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$801
$2,916
$4,285
$5,847
$7,443
$11,005
$641
$2,333
$3,428
$4,678
$5,954
$8,804
Cost per Kilowatt-hour
$/kWh (P2)
$/kWh
(REEV20)
$/kWh
(REEV40)
$/kWh (EV75)
$/kWh
(EV100)
$/kWh
(EV150)
$2,964
$809
$581
$501
$464
$426
$2,371
$647
$465
$401
$371
$341
$1,518
$414
$298
$256
$237
$218
$1,518
$414
$298
$256
$237
$218
$1,214
$331
$238
$205
$190
$174
$1,214
$331
$238
$205
$190
$174
$1,214
$331
$238
$205
$190
$174
$1,214
$331
$238
$205
$190
$174
$1,214
$331
$238
$205
$190
$174
$971
$265
$190
$164
$152
$140
B4.2.1.6 In-home Charger Costs
We have also estimated cost associated with in-home chargers and installation of in-
home chargers. Charger costs are covered in more detail in Section 4.2.3 of the main report.
Here we summarize the actual costs used for developing EV and REEV package costs. We
have estimated the cost of a level 1 charge cord at $30 (2008 dollars) based on typical costs of
similar electrical equipment sold to consumers today and that for a level 2 charger at $200
(2008 dollars). Labor associated with installing either of these chargers is estimated at $1,000
(2008 dollars). Further, we have estimated that all REEV20 vehicles (REEVs with a 20 mile
range) would be charged via a level 1 charger and that all EVs, regardless of range, would be
charged via a level 2 charger. For the REEV40 vehicles (REEVs with a 40 mile range), we
have estimated that: 25% of subcompacts would be charged with a level 1 charger with the
remainder charged via a level 2 charger; 10% of small cars would be charged with a level 1
charger with the remainder charged via a level 2 charger; and all remaining REEV 40 vehicles
would be charged via a level 2 charger. All costs presented here are considered valid for the
2025 model year. We have applied the learning curve presented above in Section B4.2.1.5 to
the charger costs. We have also applied our High 2 ICMs to these costs (1.70 through the
2021MY and 1.45 thereafter). Installation costs, being labor costs, have no learning impacts
B-23
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Appendix B
or ICM applied. The resultant costs for 2017, 2020 and 2025 are shown in Table B4.2-2.
These costs are included in our package costs for all REEV and EV packages.
Table B4.2-2: In-home Charger Related Costs for REEVs and EVs (2008 dollars)
Technology
REEV20-Charger
REEV40-Charger
EV-Charger
Labor
Vehicle Class
Subcompact
Small car
Large car
Minivan
Small truck
Subcompact
Small car
Large car
Minivan
Small truck
Subcompact
Small car
Large car
Minivan
Small truck
Subcompact
Small car
Large car
Minivan
Small truck
2017
$100
$523
$608
$664
$664
$1,000
2020
$64
$335
$389
$425
$425
$1,000
2025
$44
$228
$265
$290
$290
$1,000
B4.3 Mass Reduction Cost Model
Application of mass reduction technologies for 2017-2025 vehicles has been discussed
at length in meetings with vehicle manufacturers in preparation for this Technical Assessment
Report. One of the challenges the manufacturers identified with respect to mass reduction
was the feasibility of substituting some lower density materials for higher density materials.
These issues included material availability, forming, joining, painting, corrosion, reparability,
and impact performance. The agencies agree that these issues need further study in order to
determine the feasibility of certain types of mass reduction and the appropriateness of
assuming their applicability in the MYs 2017-2025 timeframe for purposes of the upcoming
federal rulemaking.
To begin to address these issues, the collaborative NHTSA, EPA, and DOE team
described in Chapter 3 has focused on several tasks including a peer review of the Lotus
Engineering report22 regarding holistic vehicle mass reduction opportunities, a 2nd phase of
analysis by Lotus Engineering to assess the functional performance and safety of phase 1
designs and to modify designs as appropriate through computer aided engineering (CAE), and
two projects being conducted by DOE regarding, one regarding mass reduction feasibility and
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2017-2025 Technical Assessment
the other consisting of an actual vehicle build (Multi Material Vehicle - MMVM). NHTSA
and EPA may also consider jointly funding a study to evaluate potentially feasible amounts of
mass reduction and their accompanying cost for MY 2017-2025 separately from the study
contracted to Lotus engineering by CARB. Computer Aided Engineering (CAE) tools would
be used to analyze the structure of the vehicle. The proposed design should meet at least the
same functional objectives as the baseline vehicle. If funded, this study would be designed to
be finished in time for incorporation in the final rule analysis.
For the 2012-2016 final rule, NHTSA and EPA relied on a 2015 cost of $1.32 (2007$)
per pound of mass reduction, and the limit of mass reduction (penetration cap) was set to 10%
based on our feasibility analysis.23 This cost was estimated by calculating an average of the
costs estimated in three studies: 2002 NAS report (normalized estimated cost $1.50/lb)24,
Sierra Research (normalized estimated cost $1.01/lb for 10% mass reduction with
9S
compounding) , and MIT (normalized estimated cost $1.36/lb for 14% mass reduction
without mass compounding).26 The $1.32 per pound cost would be $1.35 per pound in 2008
dollars. With a year of time-based learning at 3% per year the cost would be $1.31 (2008$)
per pound in 2016 and with 4 years of time-based learning at 2% per year would be $1.20
(2008$) per pound in 2020.
However, in the 2017-2025 timeframe, many of the OEMs indicated in meetings with
the agencies over the summer that they will be capable of higher levels of mass reduction than
10 percent per vehicle. The OEMs also generally stated that there is some initial amount of
mass reduction which can be accomplished with zero or very little cost (much lower than that
estimated in the 2012-2016 rule of $1.32/lb), but emphasized that higher percentages of mass
reduction may result in higher costs and that these costs are likely to increase non-linearly
with increasing mass reduction levels. In response to this stakeholder feedback and based on
our own preliminary analysis of the potential for vehicle mass reduction in the 2020 and 2025
timeframe, the agencies have begun updating our mass reduction cost model to reflect this
progressively increasing level of cost. A simple non-linear cost model is introduced below
that has been employed for purposes of this Technical Assessment Report, but EPA and
NHTSA intend to rely on additional studies for the upcoming federal rulemaking that are
expected to be complete before the NPRM and final rule. The collaborative team has taken
several actions to inform the cost model, including meeting with vehicle manufacturers,
DOE's update of their 2007 study on feasibility and cost, and EPA funding a 3rd party cost
assessment of the Lotus Report.
The agencies developed the non-linear cost model for mass reduction for purposes of
this Technical Assessment Report by averaging the 2012-2016 linear cost for mass reduction
in 2025 with the cost estimate for the High Development Case in the Lotus Engineering study,
and then drawing a parabolic curve between $0 for 0 percent mass reduction and that average
dollar value at 32 percent mass reduction. While the agencies recognize that there have been
a number of vehicle mass reductions studies conducted in the literature in the past 10 years27
M DOE Notice of Intent to Issue Funding Opportunity Announcement N.:DE-FOA-000239.
http://www.netl.doe.gov/business/solicitations/NOTICE%20OF%20INTENT.pdf
B-25
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Appendix B
9R 9Q ^0 ^ 1
, a complete literature review is beyond the scope of the report, and thus the agencies
believe that the mass reduction feasibility and cost study conducted by Lotus Engineering in
2010 is the most comprehensive vehicle mass reduction study conducted to date.
Lotus Engineering purchased a 2009 Toyota Venza (a crossover SUV, or CUV) and
tore the vehicle down, analyzing every subsystem of the vehicle. The study split the mass
reduction into two phases: "low" and -high" development, to represent different potential
levels of mass reduction. For the low development case, the majority of the body in white
(BIW) weight reduction was accomplished by converting mild steel to high strength steel. In
addition, all vehicle components and subsystems were compared to the best-in-class vehicle
mass leaders and substituted (and scaled) to the Venza, which allowed significantly more
weight reduction and the use of mass decompounding. This approach provided an extremely
cost effective manner of reducing weight and cost compared to other studies in the literature
that attempted to evaluate reducing similar amounts of mass. In the high development case,
Lotus considered much more material substitution in the BIW, from steel to aluminum,
magnesium, plastic and other materials, and relied extensively on completely novel (and
smart) design of all possible components to reduce mass in all vehicle systems. Table B4.3-1
summarizes the cost results from this study:
Table B4.3-1: Costs for Mass Reduction Based on the Lotus Engineering Study*
Cost per
vehicle
Cost per pound
Lower
bound
Upper
bound
Lower
bound
Upper
bound
Low Development
(19% mass reduction)
-$400
-$0.55
-$1600
$800
-$2.20
$1.10
High Development
(32% mass reduction)
$600
$0.50
-$600
$1800
-$0.50
$1.49
* Estimates assume a total variable (or piece) cost of the Toyota Venza to be $20,000
The agencies note that some limitations exist for the Lotus study. First, Lotus
analyzed these considerable levels of mass reduction based on a single vehicle. The agencies
acknowledge that most of the improvements described in the report can be applied across all
vehicles to varying degrees, but due to the expense and time of the study, it is impractical for
our current purposes to conduct similar studies across many different vehicles. Second,
Lotus' cost estimates were based on manufacturer (OEM) piece costs due to the initial scope
of the study, and only partially included the manufacturer tooling and assembly plant costs.
As mentioned earlier, follow-up studies are being planned to improve these cost estimates.
Third, the designs created by Lotus for the low and high development cases have not been
shown to meet FMVSS safety regulations and voluntary NCAP and IMS guidelines, or to
achieve vehicle functional performance similar to the baseline vehicle. Each of these issues is
being addressed in the Phase 2 Lotus study, but was not addressed in time for this Technical
Assessment Report.
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2017-2025 Technical Assessment
The Lotus study also shows that it is possible to take up to 19% of the mass out of the
vehicle at no cost (cost savings in fact) by using less costly piece costs for many components
based on their benchmarking analysis. The agencies agree that it may be possible to remove
mass at a cost savings on many vehicles - there are a number of other studies that have
similar conclusions. However, the agencies are concerned about assigning a negative cost
value at the higher ranges of what some of the manufacturers shared was the maximum
feasible (approximately 20% mass reduction) within the 2017-2025 timeframe. Therefore, the
agencies are pursuing further cost studies to confirm all of the costs (including manufacturing
and tooling) before using the Lotus results directly. The agencies do acknowledge that the
Lotus study included a high degree of uncertainty in the cost estimates, and that some degree
of mass reduction may be possible at a cost savings.
The agencies note that most manufacturers stated in stakeholder meetings over the
summer that they anticipate that future safety and emission regulatory requirements will
require increases in vehicle mass and, in addition, they intend to implement voluntary safety
improvements that will increase vehicle mass. Net mass reduction for the 2017-2025
timeframe will thus actually be the mass reduction achieved through methods similar to those
identified in studies discussed above, but offset by mass increases for safety and emission
regulations and voluntary safety improvements. Manufacturers also frequently stated that
they already have incorporated varying levels of mass reduction in current production
vehicles. The agencies have not considered these baseline factors explicitly in estimating the
cost for mass reduction that is being used for this assessment.
Thus, to model how mass reduction costs could increase at a non-linear rate for
purposes of this Technical Assessment Report, the agencies have relied on a parabolic shape
for the cost curve - where the cost per pound increases as the square of the percentage mass
reduction. To determine the magnitude of the curvature, the parabola was calibrated to go
through a designated -high value" at 32% mass reduction. To determine this high value, the
agencies averaged the $1.20/lb (2008$ in the 2020MY) value developed using the 2012-2016
rule methodology, with the Lotus high development cost figure of $0.50/lb at 32% mass
reduction (as described above). This averaging represents two factors. First, that the agencies
believe that the cost used in the 2012-2016 rule appropriately captures the longer timeframe
and improved design optimization methods that are likely to lower costs in the 2017-2025
timeframe; but on the other hand, that the agencies believe that a constant value, independent
of the complexities involved with greater levels of mass reduction, is not realistic. And
second, as described above, the agencies believe that the Lotus costs on their own are too low,
due to the missing manufacturing and tooling costs. The averaging of the two costs offsets
the missing Lotus costs. A variety of non-linear curves could have been employed, however,
the 2n order polynomial defines the simplest model, which seemed reasonable for the current
analysis. The curve has the shape shown in Figure B4.3-1.
B-27
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Appendix B
$1.50
$1.00
$0.50
u
,0 $- •
•-• 0% 5% 10% 15% ;
8 $(0.50) i
-o
c
3
| $(i.oo)
01
Q.
$(1.50)
• Lotus Results
$(2.00) 2012-2016 CostModel
2017-2025 CostModel
1
0% 25% 30%
!
'
I
35% 40%
$(2.50)
%Mass Reduction
Figure B4.3-1: Mass Reduction Cost Model in Dollars per Pound in Model Year 2020
Compared to the Lotus Results and 2012-2016 Final Rule Cost.
Accounting for the indirect cost markup (ICM) on the mass reduction cost model, the
agencies believe that it is appropriate to assign higher markups for the higher levels of mass
reduction due to their increased complexity and lead time required. Descriptions of these
different levels of ICM are in Chapter 3. Table B4.3-2 shows this increasing ICM with mass
reduction levels.
Table B4.3-2: Indirect Cost Markup Factors for Increasing Levels of Mass Reduction
Mass
Reduction
3%
5%
10%
15%
20%
25%
30%
Complexity
Low
Low
Low
Low
Medium
Medium
High 1
ICM
Near
Term
1.17
1.17
1.17
1.17
1.31
1.31
1.51
ICM
Long
Term
1.13
1.13
1.13
1.13
1.19
1.19
1.32
Accounting for the ICMs, the model with and without markups is shown in Figure B4.3-2.
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2017-2025 Technical Assessment
Figure B4.3-2: Mass Reduction Cost Model in 2008 Dollars per Pound in Model Year
2020 With and Without Indirect Cost Markups
Direct Mfr Cost
Marked up Cost
0% 5% 10% 15% 20% 25% 30%
I Mass Reduction Percentage
As mentioned earlier, the agencies continue to explore avenues of increasing the
fidelity of the mass reduction cost model, and believe that there are studies that are currently
or anticipated being conducted which will improve the fidelity of the points used to calibrate
this model and which may be employed for the upcoming federal rulemaking.
B5 Fuel Cell Vehicle Technology Cost, Effectiveness and Lead-
time Assessment
B5.1 Technology Summary
The state of fuel cell vehicle (FCV) technology has seen significant progress towards
the U.S. Department of Energy (DOE) 2015 performance targets over the last few years. Fuel
cell stack durability has more than doubled since 2006 and high volume production system
cost has been reduced by over 80% since 2002 (additional details are provided below).
Progress is still required in the areas of fuel cell costs, durability, and on-board hydrogen
storage. However, the technology has matured sufficiently for commercialization, and
production launch is feasible in the 2015-2017 time-frame. First generation vehicles will
likely require financial incentives to initiate the market (as is currently planned for battery
technologies).
B5.2 Fuel Cell Costs
Based on the most recent fuel cell system cost analysis by Directed Technologies, Inc
(DTI32), contracted by DOE, today's fuel cell technology when produced at high volumes
would have a cost of $51/kW (system net power). Additionally, projected 2015 technology at
high volume production would cost $39/kW. For a lOOkW system in a large car (vehicle type
5), this would equate to $3,945 (not including hydrogen storage). The analysis for this report
B-29
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Appendix B
bundled the fuel cell system costs with the electric drive component costs consistent with how
the EV and PHEV technology packages were developed. For FCVs, this analysis assumed a
system sized for the large car platform (vehicle type 5), and included the HEV battery pack
and hydrogen storage costs in addition to the system noted above.
The system costs noted above are the fully-learned, high volume production costs
from DTI. However, these production volumes are not assumed to be achieved by 2025 for
this analysis. FCV production levels of-85,000 per year in the U.S. were assumed,
representing approximately 0.5% of the U.S. LDV market in 2025. This is discussed further
in Section B4.3.4. At these lower production levels, the incremental fuel cell system direct
manufacturing cost is closer to +$4,800.
As part of this analysis, fuel cell vehicle production costs were developed by relying
on the 2015 technology costs from DTI along with the non-fuel cell electric drive component
costs from the EPA OMEGA model. Figure B5.2-1 below shows the simulated production
costs for a lOOkW fuel cell system (average system size for larger vehicle platforms in this
analysis). Note this is not the full FCV production cost which would include the full electric
drive bill of material. Also not shown is the retail price markup (ICM); FCVs are assumed to
have the same ICM as the EV and PHEV vehicle types, using the high complexity ICM
values noted earlier in Appendix B.
100,000 200,000 300,000
Annual Production Volume
400,000
500,000
Figure B5.2-1: FC Production Cost Curve for a lOOkW system (not including H2
storage)
(Sources: DTI (cost curve), extrapolation to lOOkW)
Figure B5.2-2 shows the summary breakdown of vehicle costs at the high volume
production level. The fuel cell system cost at this level is based on the DTI $39/kW high
volume data point. Compared to the 2010 DTI system estimate, this 2015 production cost
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2017-2025 Technical Assessment
assumes system improvements, including the elimination of external humidification
components, elimination of an air expander, and slightly higher membrane operating
temperatures that allow the reductions in the radiator and cooling loop size. For fuel cell
stack costs, DTI assumes platinum loadings of 0.15 mg/cm2. In addition to the fuel cell
system, the battery pack modeled was the lithium-ion battery assumed for HEVs in Table
B4.2-1. Balance of EV drive components include drive motors, controllers, DC/DC
converters, electric AC and heating, and a few other components. Finally, as noted above, the
hydrogen storage system cost was assumed to be $10/kWh, notably higher than the DOE 2015
target given the lower production volumes.
Controller &
OCIloUl o
$512
Fuel Loop
$100
Water &
Trpermal Mngt
$500
Air Loop
$700
FC Stack
$2,133
Figure B5.2-2: Detailed fuel cell system costs at high volume production
(Source: DTI, CARS)
Table B5.2-1 shows the resulting direct manufacturing costs for the 2020 and 2025
model years, highlighting the higher costs compared to the fully learned production levels at
the far right of Figure B5.2-1.
Table B5.2-1: Fuel cell direct manufacturing costs at assumed production volumes
U.S. FCV Sales
Fuel cell system cost
(lOOkW)
Hydrogen storage cost
(4kg@$10/kWh)
2020MY
20,000
$ 5,900
$1,320
2025MY
85,000
$ 4,800
$1,320
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Appendix B
Finally, as a reference, DOE's analysis of various hydrogen storage systems was
reviewed. The production costs for various on-board hydrogen storage technology
alternatives were analyzed by TIAX under contract to DOE 3. This analysis assumed high
pressure gaseous storage remained the technology choice in 2025, although the cryo-
compressed alternative is receiving increased attention by major OEMs. The current DOE
2010 target is $4/kWh and the 2015 target is $2/kWh, although DOE is planning to revise
these targets soon. For the 2025 FCV simulated in this analysis, a storage cost of $10/kWh
was assumed given production levels will not reach the fully mature point.
B5.3 Performance Status
Automakers are nearing DOE 2015 performance targets and continue to push the
technology toward commercial readiness, as documented in the DOE 2009 Report to
Congress34. A few of the key accomplishments are listed below and further information can
be found at DOE's Hydrogen Program Accomplishments webpage
35
• Significantly reduced the cost of automotive fuel cells (from $275/kW in 2002 to
$51/kW in 2010 (DTI), based on projections of high-volume manufacturing costs)
• Doubled the durability of fuel cell systems in vehicles operating under real-world
conditions (data in 2006 showed 950-hour durability—today, this number is 2500
hours, equivalent to approximately 75,000 miles of driving)
• Reduced the cost of producing hydrogen from both renewable resources and natural
gas (hydrogen can now be produced by distributed reforming of natural gas at a
projected high-volume cost of $3.00/gallon gasoline equivalent; this does not take into
account FCV efficiency gains over an ICE which would improve these operating costs
further)
• Independently validated a real-world driving range of 450 miles for an FCV from one
of the major OEMs.
The table below summarizes the cost, durability, and efficiency targets along with the
status of today's technology as assessed by DOE's Technology Validation Program.36
Table B5.3-1: Current Status and U.S. DOE Targets for Automotive Fuel Cells
System Efficiency
System Cost
Fuel Cell System
Durability
Vehicle Range
H2 Storage Costs
2009
(Current
Status)
53-59%
$61 /kW
2,500 hours
(-75,000 mi)
254 miles 3*
2010
(Cost
Update)
$51/kW3/
$20 /kWh 3y
2010
Target
60%
$45 /kW
2,000 hours
(-60,000 mi)
250 miles
$4 /kWh
2015
Target
60%
$30 /kW
5,000 hours
(-150,000 mi)
300 miles
$2 /kWh
Fuel cell system volume and weight have been largely reduced and are expected to
achieve the targets, allowing for marketable vehicle integration. For example, the Honda FCX
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2017-2025 Technical Assessment
Clarity's fuel cell stack is 1/5 the weight and 1/4 the volume compared to the previous FCV
model40. The weight and volume progress are a result of improvements in fuel cell materials
(stamped metal flow plates, aromatic membrane structure, reductions in catalyst loading) and
fuel cell simplification (part-count reduction, improved manufacturing). A detailed summary
of the performance of the Generation 2 FCVs being evaluated in the DOE Technology
Validation Program can be found in the NREL presentation to the 2010 DOE Merit Review41.
FCVs have achieved the DOE 2015 efficiency targets already, which translates into
large energy and greenhouse gas reductions compared to conventional vehicles. Although the
full well-to-wheel (WTW) GHG reductions depend on the fuel source, hydrogen produced
from natural gas and used in an FCV results in WTW GHG reductions of 50% compared to a
projected internal combustion engine vehicle, and 20% compared to a projected hybrid
vehicle42. Given that the vehicle powertrain is a zero emission technology, all emissions are
generated from the fuel production and delivery stages.
B5.4 Hydrogen Storage
As noted above, the majority of FCV technology requirements necessary for a
marketable vehicle have been addressed through continued R&D and demonstration. This
includes rapid start-up, cold-start operation, stack power density, balance-of-plant (BOP)
operation, and efficiency. On-board hydrogen storage is one of the remaining challenges that
will require further development. This will not prevent the commercial launch of FCVs,
however, as adequate storage systems are available for use in early commercial vehicles. The
storage technology chosen by the majority of OEMs for existing FCVs is high pressure (700
bar or 10,000 psi) gaseous storage. Although volumetric density, cost, and station dispensing
complexity (a need for pre-cooling) are not ideal, the technology is ready today.
Technologies under consideration by OEMs and energy companies for next generation
vehicles include intermediate pressure gaseous storage (between 350 and 700 bar where pre-
cooling won't be required) and cryo-compressed hydrogen storage. The latter has the promise
of higher volumetric density, lower cost, and substantially reduced fuel boil-off (in engine-off
mode) compared to liquid storage43.
Additional FCV and hydrogen storage information can be found from the following
DOE resources.
• 2010 U.S. DOE Merit Review Proceedings, June 2010.
http: //www. hydrogen. energy. gov/annual_revi ew 10_proceedings. html
• 2009 U.S. DOE Hydrogen Program Annual Progress Report, November 2009.
http://www.hydrogen.energy.gov/annual_progress09.html
B5.5 Commercialization Status
Production announcements have been made by at least three major OEMs for a 2015
launch. Production volumes will depend in part on the hydrogen infrastructure rollout in
strategic locations where early customers are expected. In the U.S., this is likely to be in
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Appendix B
Southern California and New York where infrastructure is emerging. Based on two
independent confidential surveys of OEMs and their FCV plans (conducted by the CaFCP44
and CARB/CEC), up to 50,000 FCVs could be deployed in California by 2018 (cumulative
on-road).
Hydrogen infrastructure continues to be a large challenge for FCVs in preparation for
vehicle commercialization in 2015. Addressing this challenge requires stakeholder
coordination and sustained commitments from both the public and private sectors. However,
this activity is progressing in California, with actions coordinated by the CaFCP, CARB and
CEC. The state is providing large cost-share incentives for hydrogen stations (led by CEC),
and strategic planning is relying on concepts outlined in the CaFCP's 2009 Action Plan45 and
2010 Progress and Next Steps, as well as the UC Davis Roadmap.46
For the purposes of identifying production costs in this analysis, annual production
volumes were estimated. Broadly based on California's Zero Emission Vehicle Regulation as
well as hydrogen infrastructure advancements in California and a few other states, it was
assumed FCVs would comprise 0.5% of the U.S. LDV market in 2025. With a total assumed
LDV market of 16.5 million vehicles, this equates to annual sales volumes of 85,000
nationally. Although these levels are lower than previous FCV scenarios by the DOE
(ORNL47) and the National Academies (NAS48), they represent full commercial scale
production volumes and should result in the needed FCV cost reductions such that market
share could grow significantly beyond 2025.
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Appendix B References
1 Memorandum to Docket EPA-HQ-OAR-2010-0799 from Todd Sherwood dated September 16, 2010.
2 U.S. Environmental Protection Agency, —Ight-Duty Technology Cost Analysis Pilot Study," Contract No. EP-
C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-
11282; peer review report dated November 6, 2009, is at EPA-HQ-OAR-2009-0472-11285; -iight-duty
Technology Cost Analysis - Report on Additional Case Studies," EPA-HQ-O AR-2009-0472-11604
3EPA-420-R-10-901
4 U.S. Environmental Protection Agency, —Ight-Duty Technology Cost Analysis Pilot Study," Contract No. EP-
C-07-069, Work Assignment 1-3, December 2009, EPA-420-R-09-020, Docket EPA-HQ-OAR-2009-0472-
11282; peer review report dated November 6, 2009, is at EPA-HQ-O AR-2009-0472-11285; -iight-duty
Technology Cost Analysis - Report on Additional Case Studies," EPA-HQ-O AR-2009-0472-11604.
5 Turner, J.W.G., Pearson, R.J., Curtis, R. Holland, B. -Sabre: a cost effective engine technology combination
for high efficiency, high performance and low CO2 emissions," Low Carbon Vehicles 2009: Institution of
Mechanical Engineers conference proceedings, May 2009.
6 Lumsden, G. OudeNijeweme, D., Fraser, N., Blaxill, H. development of a Turbocharged Direct Injection
Downsizing Demonstrator Engine," SAE Technical Paper Series, No. 2009-01-1503.
7 Yi., I, Wooldridge, S., Coulson, G., Hilditch, I, Iyer, C., Moilanen, P., Papaioannou, G., Reiche, D., Shelby,
M. VanDerWege, B., Wearver, C., Xu, Z., Davis, D., Hinds, B., Schamel, A. development and Optimization of
the Ford 3.5L V6 EcoBoost Combustion System," SAE Technical Paper Series, No. 2009-01-1494.
8 Cruff, L., Kaiser, M., Krause, S., Harris, R., Krueger, U., Williams, M. -EBDI - Application of a Fully Flexible
HighBMEP Downsized Spark Ignited Engine," SAE Technical Paper Series, No. 2010-01-0587.
9 Taylor, I, Fraser, N., Wieske, P. -Water Cooled Exhaust Manifold and Full Load EGR Technology Applied to
a Downsized Direct Injection Spark Ignition Engine," SAE Technical Paper Series, No. 2010-01-0356.
10 Kaiser, M., Krueger, U., Harris, R., Cruff, L. -Boing More with Less - The Fuel Economy Benefits of Cooled
EGR on a Direct Injected Spark Ignited Boosted Engine," SAE Technical Paper Series, No. 2010-01-0589.
11 Kapus, P.E., Fraidl, O.K., Prevedel, K., Fuerhapter, A. —GDTurbo - The Next Steps," JSAE Technical Paper
No.20075355,2007.
12 General Motors, news release, -From Hybrids to Six-Speeds, Direct Injection And More, GM's 2008 Global
Powertrain Lineup Provides More Miles with Less Fuel" (released Mar. 6, 2007). Available at
http://www.gm.com/experience/fuel_economy/news/2007/adv_engines/2008-powertrain-lineup-082707.jsp (last
accessed Sept. 18, 2008).
13 -EPA Staff Technical Report: Cost and Effectiveness Estimates of Technologies Used to Reduce Light-duty
Vehicle Carbon Dioxide Emissions" Environmental Protection Agency, EPA420-R-08-008, March 2008, at page
17, Docket EPA-HQ-OAR-2009-0472-0132.
14 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE
Rule. EPA-420-R-10-901, April, 2010.
15 Olszewski, M., 2008. Evaluation of the 2007 Toyota Camry Hybrid Synergy Drive System. Oak Ridge
National Laboratory. ORNL/TM-2007/190. Oak Ridge, Tenesssee. April.
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Appendix B
16 Nelson, P. A., Santinit, D.J., Barnes, J. -Factors Determining the Manufacturing Costs of Lithium-Ion Batteries
for PHEVs," 24th World Battery, Hybrid and Fuel Cell Electric Vehicle Symposium and Exposition EVS-24,
Stavenger, Norway, May 13-16, 2009 (www.evs24.org).
17 Santini, D.J., Gallagher, K.G., and Nelson, P.A. -Modeling of Manufacturing Costs of Lithium-Ion Batteries
for HEVs, PHEVs, and EVs," Paper to be presented at the 25th World Battery, Hybrid and Fuel Cell Electric
Vehicle Symposium and Exposition, EVS-25, Shenzhen, China, November 5-9, 2010 (www.evs25.org).
Advance draft provided by DJ. Santini, Argonne National Laboratory, August 24, 2010.
18 -Hyundai ups tech ante with Sonata Hybrid," Automotive News, August 2, 2010.
19 -Chevrolet Stands Behind Volt With Standard Eight-Year, 100,000-Mile Battery Warranty," GM Press release
(http://media.gm. co m/content/media/us/en/news/news_detail.brand_gm.html/content/Pages/news/us/en/2010/Jul
y/0714_volt_battery)
20 -Nissan's new 2012 hybrid system aims for 1.8-L efficiency with a 3.5-L V6," SAE Automotive Engineering
Online, February 15, 2010.
21 —Ilhium-ion Battery," Nissan Technological Development Activities (http://www.nissan-
global.com/EN/TECHNOLOGY/INTRODUCTION/DETAILS/LI-ION-EV/). 2009.
22 Lotus Engineering, Inc. —A Assessment of Mass Reduction Opportunities for a 2017 - 2020 Model Year
Vehicle Program," Published by the The International Council on Clean Transportation and available on the
Internet at http://www.theicct.org/2010/03/lightweight-future/. March 30, 2010.
23 Joint Technical Support Document: Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standardsfor EPA and NHTSA 2012-2016 GHG and CAFE
Rule. EPA-420-R-10-901, April, 2010.
24 Effectiveness and Impact of Corporate Fuel Economy Standards, NAS, 2002.
25 Basic Analysis of the Cost and Long-Term Impact of the Energy Independence and Security Act Fuel
Economy Standard, Sierra Research, 2008.
26 The Impact of Mass Decompounding on Assessing the Value of Vehicle Lightweighting, MIT 2008.
27 Assessment of Fuel Economy Technologies for Light Duty Vehicles, NAS, 2010.
28 Analysis of Light Duty Vehicle Weight Reduction Potential, Energy and Environmental Analysis Inc,
prepared for DOE, July, 2007.
29 Cost-Effectiveness Of a 25% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit,
prepared for DOE, 2008/
30 Cost-Effectiveness Of a 40% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit,
prepared for DOE, 2009.
31 Cost-Effectiveness Of a 50% Body and Chassis Weight-Reduction Goal In Light-Duty Vehicles, Das, Sujit,
prepared for DOE, 2010.
32 Directed Technologies Inc (DTI), -Mass-Production Cost Estimation for Automotive Fuel Cell Systems,"
2010 U.S. DOE Merit Review, FC018, June 7-11, 2010.
http://www.hvdrogen.energy.gov/pdfs/reviewlO/fc018 iames 2010 o web.pdf
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33 TIAX LLC, — Aidysis of Hydrogen Storage Materials and On-Board Systems," 2010 U.S. DOE Merit
Review, ST002, June 7-11, 2010.
http://www.hydrogen.energv.gov/pdfs/reviewlO/st002 lasher 2010 o web.pdf
34 -Hydrogen and Fuel Cell Activities, Progress, and Plans," U.S. DOE Report to Congress, January 2009.
http://www.hvdrogen.energv.gov/program records.html
35
http://wwwl.eere.energy.gov/hydrogenandfuelcells/accomplishments.html
36 Refer to Table 3.1 in the U.S. DOE 2009 Report to Congress and a year-end summary by Dr. Sunita Satyapal,
http://wwwl.eere.energy.gov/hydrogenandfuelcells/pdfs/cng_h2_workshop_l_satyapal.pdf
37 DTI. Projected 2015 system cost = $39/kW. System cost does not include H2 storage assembly or electric
drive components
38 Corresponds to vehicle fuel economy observations of 43-58 mi/kg-H2 as noted by the National Renewable
Energy Laboratory (NREL) in -Controlled Hydrogen Fleet and Infrastructure Analysis," 2010 U.S. DOE Merit
Review, TV001, June 10, 2010. www.hvdrogen.energv.gov/pdfs/reviewlO/tv001 wipke 2010 o web.pdf
39 TIAX LLC, — Aulysis of Hydrogen Storage Materials and On-Board Systems," 2010 U.S. DOE Merit
Review, ST002, June 7-11, 2010.
http://www.hydrogen.energy. gov/pdfs/review 10/st002 lasher 2010 o web.pdf. (Based on 700 bar gaseous
pressure system at 5.6 kg H2 storage)
40 Knight, Ben. Honda Motor Company. —Fd Cell Vehicle Technology Performance and Steps Ahead
Presentation". CARB ZEV Symposium, September 21, 2009.
http://www.arb.ca.gov/msprog/zevprog/2009svmposium/2009program.htm
41 NREL, — Cntrolled Hydrogen Fleet and Infrastructure Analysis," 2010 US DOE Merit Review, TV001, June
10, 2010
42 -Well-to-Wheels Greenhouse Gas Emissions and Petroleum Use," U.S. DOE Hydrogen Program Record #
9002, March 25, 2009.
43 Argonne National Laboratory, -System Level Analysis of Hydrogen Storage Options," 2010 U.S. DOE Merit
Review, ST001, June 7-11, 2010.
44 California Fuel Cell Partnership (CaFCP), -Hydrogen Fuel Cell Vehicle and Station Deployment Plan: A
Strategy for Meeting the Challenge Ahead (Progress and Next Steps)," April 2010.
http://www.fuelcellpartnership.org/resources/print-materials
45 CaFCP, —Hdrogen Fuel Cell Vehicle and Station Deployment Plan: A Strategy for Meeting the Challenge
Ahead (Action Plan)," February 2009. http://www.fuelcellpartnership.org/resources/print-materials
46 University of California, Davis, —Radmap for Hydrogen and Fuel Cell Vehicles in California: A Transition
Strategy Through 2017," a public-private collaborative report following a series of workshops, December 2009.
47 Oak Ridge National Laboratory, -Transition to Hydrogen Fuel Cell Vehicles & the Potential Hydrogen Energy
Infrastructure Requirement," ORNL/TM-2008/30, March 2008.
48 National Academies of Science, -Transitions to Alternative Transportation Technologies: A Focus on
Hydrogen," Committee on Assessment of Resource Needs for Fuel Cell and Hydrogen Technologies, 2009.
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Appendix C - Reserved
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Dl Appendix D: Air Conditioning
Dl.l Overview
Over 95% of the new cars and light trucks in the United States are equipped with
mobile air conditioning (MAC or A/C) systems. In the 1970s and 1980s, A/C systems were
an optional (luxury) feature, but these systems are now standard on almost all new vehicle
models. The A/C system is a unique and distinct technology on the automobile. It is different
from the other technologies described in Chapter 3 of the joint Technical Support Document
(TSD) to the recent MY 2012-2016 Final Rule in several ways. First, most of the
technologies described in the joint TSD directly affect the efficiency of the engine,
transmission, and vehicle systems. As such, these systems are almost always active while the
vehicle is moving down the road or being tested on a dynamometer for the fuel economy and
emissions test drive cycles. A/C on the other hand, is a parasitic load on the engine that only
burdens the engine when the vehicle occupants demand it. Since it is not tested as a normal
part of the fuel economy and emissions test drive cycles for compliance purposes, it is
referred to as an "off-cycle" effect. There are many other off-cycle loads that can be switched
on by the occupant that affect the engine; these include lights, wipers, stereo systems,
electrical defroster/defogger, heated seats, power windows, etc. However, these electrical
loads individually amount to a very small effect on the engine (although together they can be
significant). The A/C system (by itself) adds a significantly higher load on the engine as
described later in this chapter. Secondly, present A/C systems are capable of leaking a
powerful greenhouse gas (GHG) directly into the air - even when the vehicle is not in
operation. No other vehicle system has associated GHG leakage. Because of these factors, a
distinct approach to control of MAC systems is justified, and a separate technical discussion is
also warranted.
D1.2 Leakage
D 1.2.1 Overview
This section describes a preliminary analysis of leakage emission reductions in the
2025 timeframe. It is expected that this analysis will be reevaluated during the rulemaking
process. The technological basis for the expected leakage reductions is discussed in detail in
the EPA's model year (MY) 2012-2016 Light Duty Greenhouse Gas Final Rule (2016 FRM)
RIA Chapter 2, and is summarized here.
Mobile air conditioner (MAC) systems leak a powerful greenhouse gas directly into
the air - even when the vehicle is not in operation. Because MAC emissions are not measured
during certification testing for the GHG program, the 2016 final rule offered a compliance
credit to encourage manufacturers to reduce the leakage from MAC systems. The analysis
discussed herein serves as an update to that analysis. As in the 2016 FRM, a 2008 vehicle is
considered an unimproved system, and is the basis of the discussion shown here.
The hydrofluorocarbon (HFC) refrigerant compound used in most model year 2008
vehicles is R134a (also known as 1,1,1,2-Tetrafluoroethane, or HFC-134a). Based on the
D-l
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Appendix D
higher global wanning potential (GWP) of HFC-134a, a small leakage of this refrigerant has a
greater global warming impact than a similar amount of emissions of some other mobile
source GHGs. R134a has a global warming potential of 1430,A which means that 1 gram of
R134a has a warming potential equivalent to 1,430 grams of CC>2 (which has a GWP of I).1
The high pressure of an MAC system increases its propensity for leaks. In order for
the A/C system to take advantage of the refrigerant's thermodynamic properties and to
exchange heat properly, the system must be kept at high pressures even when not in operation.
Typical static pressures can range from 50-80 psi depending on the temperature, and during
operation, these pressures can get to several hundred psi. At these pressures leakage can
occur through a variety of mechanisms. The refrigerant can leak slowly through seals,
gaskets, and even small failures in the containment of the refrigerant. The rate of leakage
may also increase over the course of normal wear and tear on the system. Leakage may also
increase more quickly through rapid component deterioration such as during vehicle
accidents, maintenance or end-of-life vehicle scrappage (especially when refrigerant capture
and recycling programs are less efficient). Small amounts of leakage can also occur
continuously even in extremely "leak-tight" systems by permeating through hose membranes.
This last mechanism is not dissimilar to fuel permeation through porous fuel lines.
Manufacturers may be able to reduce these leakage emissions through the implementation of
technologies such as leak-tight, non-porous, durable components. The global warming impact
of leakage emissions also can be addressed by using alternative refrigerants with lower global
warming potential.
As MACs leak even when not being driven, it is most appropriate to determine their
leakage based on a g/year or g/lifetime. However, for purposes of an estimation of
reductions, it is possible to divide lifetime leakage losses by lifetime vehicle miles traveled
(VMT) in order to determine the appropriate average g/mile leakage rate.
D 1.2.2 Description of Vintaging Model Inputs and Data Sources
New data concerning HFC leakage has become available since the 2016 final rule
analysis was completed. Most significantly, based on new data from the EPA Office of
Atmospheric Programs (OAP), EPA has decreased the average charge size and leakage
assumed in its analysis as compared to the 2016 final rule analysis. The inputs used to derive
the HFC reductions are drawn from the OAP Vintaging model and are shown below in Table
Dl.2-1. These values are discussed in the following paragraphs, and are drawn from internal
EPA documentation of the Vintaging model.
Table Dl.2-1: Inputs for HFC Potential Reduction Calculation from Vintaging Model
A The global warming potentials (GWP) used in this analysis are consistent with Intergovernmental Panel on
Climate Change (IPCC) Fourth Assessment Report (AR4). At this time, the IPCC Second Assessment Report
(SAR) global warming potential values have been agreed upon as the official U.S. framework for addressing
climate change. The IPCC SAR GWP values are used in the official U.S. greenhouse gas inventory submission
to the United Nations climate change framework.
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2017-2025 Technical Assessment
2008 MY Vehicle MAC Charge (g HFC)
Lifetime of a MAC system (years)
Fraction of Vehicles w/AC
Recurring Annual Loss Rate (Service+Leaks)
End of Life Loss
Car
550
12
99%
18%
43%
Truck
780
12
99%
18%
43%
Dl.2.2.1
Charge Size
The Vintaging model contains weighted average refrigerant charge sizes based on
motor vehicle sales data and charge size data, by make, model, and year. 2008 Sales data is
from Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years. Charge size data
is from the Mobile Air Conditioning Society (MACS) Worldwide's A/C & Cooling System
Specifications: 1996-2007.,3 No assumptions are made regarding continued reductions in
charge size beyond 2008.
Dl.2.2.2
AC System Lifetime
The Vintaging Model assumes that all light duty passenger vehicle AC systems (in the
U.S.) last exactly 12 years. This is in agreement with the IPCC report IPCC/TEAP 2005
Safeguarding the Ozone Layer and the Global Climate System - Issues Related to
Hydrofluorocarbons andPerfluorocarbons, which indicates lifetimes (worldwide) of 9 to 12
years.
Dl.2.2.3
Fraction of Vehicles with AC
Not all vehicles are sold with AC; Ward's vehicle sales data are adjusted based on the
percentage of vehicles with AC, which increases over time before reaching a maximum of
99% in 2002 (light trucks) and 2003 (cars). The Vintaging Model assumes that 1% of
vehicles continue to be sold without air conditioning beyond 2003.
Dl.2.2.4
Emission Rates
The Vintaging Model assumes that losses occur from three events: leak, service, and
disposal. Although vehicle ACs are serviced during discrete events and not usually every
year, emissions from those events are averaged over the lifetime of the AC system. Leak and
service emissions are considered "annual losses" and are applied every year; disposal is
considered an "end of life loss" and is applied only once for each vintage of vehicles.
Emission rates in the Vintaging model do improve over time, with the 2008 vehicle emission
rates attributable to vehicles manufactured from 1998 to present.
Of note, the Vintaging model assumes that charge loss is replaced every year; ie, a
vehicle with a charge of 100 grams would lose a constant rate of 18 grams/year. While other
emissions, such as fugitive emissions at a production facility, leaks from cylinders in storage,
etc., are not explicitly modeled, such emissions are accounted for within the annual loss rate.
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Appendix D
Dl.2.3 Calculation of the Lifetime HFC loss per vehicle
Several modifications were made to the Vintaging model outputs for the analysis of
the potential HFC reductions. Most importantly, the charge size of the average car was
increased as a result of the reclassification of a number of two wheel drive SUVs below 6,000
pounds as cars starting in MY 2011, as discussed in Appendix A. It was assumed that 20% of
the new cars were classic trucks. As a result, the charge sizes were weighted together, with a
weighting of 80% car and 20% truck in order to calculate the car charge under the revised MY
2011 and later definition. The charge size of trucks was not adjusted. We also assume that
only vehicles which have AC systems are eligible for the AC credit, increasing the 99% value
to 100%
Using this data, the total average lifetime losses from an AC system can be calculated
using Equation D1.2-1:
Total Lifetime HFC Emissions = (Average Charge Size) * (Average Annual Loss) * (Average Lifetime)
+ (End of Life Loss)
Equation Dl.2-1: Calculation of Total Lifetime HFC Loss
Applying this equation results in an average per-vehicle HFC loss of approximately
2.59 charges (18% loss of initial charge * 12 years + 43% loss at end of life.). This results in
total lifetime losses of 1,543 g for cars and 2,020 grams for trucks.
Dl.2.4 Calculation of the HFC Credit Maximum
The maximum HFC credit is set so that the reduction in HFC emissions can be
replaced by an equivalent amount of tailpipe CO2 emissions. As CO2 emissions are regulated
on a gram/mile basis, the HFC emissions must be converted into an equivalent metric using
Equation Dl.2-2. Based on the MY 2012-2016 final rule, the total lifetime VMT of cars and
trucks is estimated at 195,264 and 225,865 respectively. These values are consistent with the
MY 2012-2016 final rule, consistent with the early years of the time frame, and are slightly
lower than the MY 2025 VMT estimated in this technical report.
CO2eq g / mile = (Total lifetime HFC emissions) / (Total Lifetime VMT) * (GWP)
Equation Dl.2-2: Conversion of Lifetime HFC Emissions into CO2eq emissions
Finally, because a known 20% shortfall (the "on-road" gap) exists between
certification test CO2 emissions and actual on-road emissions, the CO2 equivalent emissions
calculated above were multiplied by 0.8 in order to appropriately offset the reduction in real
emissions.
The maximum possible credit, calculated through this methodology, is shown below.
Assuming that alternative refrigerant with a GWP of zero is used, the maximum potential
credit would be based on removing the full lifetime emissions. As discussed in the 2016 final
rule, if conventional HFC 134a were used in an AC system, the maximum potential leakage
reduction is 50% of the annual emission leakage. No improvements would be expected to end
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2017-2025 Technical Assessment
of life emissions, so the total possible credit is approximately 45% of the maximum credit
with alternative refrigerant.
Table D 1.2-2: Maximum Credit (g/mile CO2 eq)
Maximum Credit (Alternative Refrigerant w/ 0
GWP)
Maximum Credit (HFC 134a)
Car
9.2
3.8
Truck
10.4
4.3
Fleet
(MY 2025)
9.6
3.9
As the charges for the cars and light trucks differ, the mix of cars and trucks is significant to this analysis.
MY 2025 is projected to have 67.5% cars and 2 wheel drive SUVs below 6,000 Ibs.
Dl.2.5 System Leakage Standards
In the timeframe considered in this Technical Assessment Report, EPA is considering
a number of options to reduce A/C leakage emissions, including the setting of a refrigerant
leakage standard for mobile A/C systems. The purpose of a leakage standard, as opposed to
credits, is to assure that high-quality, low-leakage components are used in each air
conditioning system design. EPA is considering a percent leakage per year standard curve,
which is scaled to the refrigerant capacity of the system (i.e. small-capacity systems would
have a larger allowable leakage standard than those with larger capacity). Since refrigerant
leakage past the compressor shaft seal is the dominant source of leakage in belt-driven air
conditioning systems, a single "percent refrigerant leakage per year" standard may not fairly
addresses the range of system refrigerant capacities likely to be used in passenger cars, light
duty trucks, and other vehicles. Since systems with less refrigerant may have a larger
percentage of their annual leakage from the compressor shaft seal than systems with more
refrigerant capacity, their relative percent refrigerant leakage per year could be higher, and a
more extensive application of leakage reducing technologies could be needed to meet a
standard.
Manufacturers can choose to reduce A/C leakage emissions in two ways. First, they
can utilize leak-tight components. Second, manufacturers can largely eliminate the global
warming impact of leakage emissions by adopting systems that use an alternative, low-GWP
refrigerant. EPA believes that reducing A/C system leakage is both highly cost-effective and
technologically feasible. The availability of low leakage components is being driven by the
air conditioning program in the light duty GHG rule which apply to 2012 model year and later
vehicles. The cooperative industry and government Improved Mobile Air Conditioning
(EVIAC) program has demonstrated that new-vehicle leakage emissions can be reduced by
50% by reducing the number and improving the quality of the components, fittings, seals, and
hoses of the A/C system. All of these technologies are already in commercial use and exist
on some of today's systems.
In the MY 2012-2016 rule, EPA required that manufacturers demonstrate
improvements in their A/C system designs and components through a design-based method.
Thismethod for calculating A/C Leakage is based closely on an industry-consensus leakage
scoring method, described below. This leakage scoring method is correlated to
experimentally-measured leakage rates from a number of vehicles using the different
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Appendix D
available A/C components. Under this approach, manufacturers would choose from a menu of
A/C equipment and components used in their vehicles in order to establish leakage scores,
which would characterize their A/C system leakage performance and calculate the percent
leakage per year as this score divided by the system refrigerant capacity.
Consistent with the Light Duty Vehicle Greenhouse Gas Emissions rulemaking, EPA
is considering that a manufacturer would compare the components of its A/C system with a
set of leakage-reduction technologies and actions that is based closely on that being developed
through EVIAC and the Society of Automotive Engineers (as S AE Surface Vehicle Standard
J2727, August 2008 version). See generally 75 FR at 25426. The J2727 approach was
developed from laboratory testing of a variety of A/C related components, and EPA believes
that the J2727 leakage scoring system generally represents a reasonable correlation with
average real-world leakage in new vehicles. Like the EVIAC approach, our proposed approach
would associate each component with a specific leakage rate in grams per year identical to the
values in J2727 and then sum together the component leakage values to develop the total A/C
system leakage. However, in this "percent system leakage per year" approach, the total A/C
leakage score and is then divided the value by the total refrigerant system capacity to develop
a percent leakage per year.
EPA believes that the design-based approach would result in estimates of likely
leakage emissions reductions that would be comparable to those that would eventually result
from performance-based testing (e.g. SAE J2763), and may consider allowing performance
test results in lieu of design-based results, if a manufacturer can demonstrate that 100% of
their vehicles systems are leak tested before they leave the assembly plant. At the same time,
comments are encouraged on all developments that may lead to a robust, practical,
performance-based test for measuring A/C refrigerant leakage emissions.
D1.3 Air conditioning Efficiency
D 1.3.1 Overview
EPA estimates that the CC>2 emissions from A/C related load on the engine of a
vehicle with an unimproved air conditioning system accounts for about 3.9% of total
greenhouse gas emissions from passenger vehicles in the United States. This is equivalent to
CC>2 emissions of approximately 14.3 g/mi per vehicle. A complete discussion of this
estimate is available in Chapter 2 of the EPA RIA to the MY 2012-2016 final rule.
In brief, most of the excess load on the engine comes from the compressor, which
pumps the refrigerant around the system loop. Significant additional load on the engine may
also come from electrical or hydraulic fan units used for heat exchange across the condenser
and radiator. EPA believes that the controls which manufacturers would use to achieve
improved A/C efficiency would focus primarily, but not exclusively, on the compressor,
electric motor controls, and system controls which reduce load on the A/C system (e.g.
reduced ,,ieheat' of the cooled air and increased use of recirculated cabin air).
The program EPA finalized in the MY 2012-2016 final rule encourages the reduction
of A/C CO2 emissions from cars and trucks by up to 40% from 2008 baseline levels through a
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2017-2025 Technical Assessment
credit system. A 40% reduction would be equivalent to a reduction of 5.7 grams of CC>2
emissions per mile.
Dl.3.2 A/C Efficiency Credits
Similar to the 2012-to-2016 Light-Duty GHG Rule, a design-based approach to credits
is being considered, although the number and type of items listed in the technology "menu" -
as well as the amount of credit assigned to each item - may change as new methods of testing
them in the vehicle develop. The design-based approach used in the GHG Rule was used
because it was not possible to accurately assess their effectiveness of these technologies using
the A/C Idle Test.
Dl.3.3 A/C Efficiency Test
A new test to measure the impact of the A/C system operation on emissions is being
evaluated with input from USCAR, CARB, and the European Union. The primary goal in
developing this new test is to create a test cycle and test conditions which reflect
environmental and driving experience found in typical customer usage (rather than the
extreme, high ambient temperature condition of the SC03 or the idle-only condition of the
A/C Idle Test). A secondary goal of this new test is to create a cycle which captures the
effectiveness of advanced A/C technologies, and can demonstrate a fuel savings compared to
a baseline technology. This new test may include a solar soak condition (to measure the
effectiveness of solar load reducing technologies such as solar glass and cabin ventilation), a
transient drive cycle (to measure the dynamic performance of the system during cabin cool-
down), and steady-state cycles (to measure the effectiveness of the system under stabilized
cabin temperature conditions).
If this new test cycle is able to accurately assess the efficiency of the A/C system and
its components, it could be used to determine the level of credits available. But if the
effectiveness of certain technologies cannot be measured on the new test, a design menu
approach may be utilized.
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Appendix D
Appendix D References
1IPCC. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007.
2 Ward's Automotive. Ward's US Light Vehicle Sales: 2005 through 2008 Calendar Years.
3 Mobile Air Conditioning Society (MACS) Worldwide. A/C & Cooling System Specifications: 1996-2007.
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El Appendix E: Key Inputs to the Analysis
This section discusses the key inputs to the analysis which were jointly developed by
the agencies for today's Technical Assessment Report. These economic inputs incorporate a
range of forecast information, economic estimates, and input parameters. This section
describes the sources that the agencies relied upon for this information, the rationale
underlying each assumption, and the agencies' estimates of specific parameter values. These
common values were then used as inputs to the analyses presented in this Technical
Assessment Report.
Please note that there are additional economic and environmental impacts which were
not considered in this assessment. A partial list includes: co-pollutant impacts, health
impacts, the social cost of carbon emissions, and energy security. The exclusion of these
impacts from this Technical Assessment Report does not suggest that these impacts should be
disregarded. As in the MY 2012-2016 final rule, NHTSA and EPA will carefully consider
other impacts of emission and fuel economy standards during the development of the
upcoming Notice of Proposed Rulemaking (NPRM).
Many of the inputs used in this technical assessment are carried forward from the
analyses conducted for the MY 2012-2016 final rule. As part of developing the upcoming
NPRM, EPA and NHTSA will consider updating these inputs.
El.l Vehicle Sales
As discussed in Chapter 6, the vehicle sales projection is based upon output from the
National Energy Modeling System (NEMS) which is maintained by the Energy Information
Administration (EIA). As in the MY 2012-2016 final rule, the car and truck split was drawn
from NEMS, while market segmentation was drawn from CSM's forecasting tool. Total
market size is estimated in 2020 at 16.5 million vehicles (55.8 % cars) and in 2025 at 17.0
million vehicles (57.9% cars). Cars, in the context of NEMS, are defined using the pre-MY
2011 CAFE definition, as discussed above in Appendix A.
For this analysis the DOT Volpe center produced a custom run of NEMS. This run
generated the same overall vehicle sales as the reference case for AEOEIA Annual Energy
Outlook 2010, but a different sales split between cars and light trucks. A detailed discussion
on this topic is presented in Appendix A.
E1.2 On-road Fuel Economy Shortfall
Fuel economy levels achieved by vehicles in on-road driving fall significantly short of
their levels measured by EPA under the laboratory test conditions used under the CAFE
program to establish its published fuel economy ratings. In analyzing the impacts from
passenger car and light truck GHG and fuel efficiency standards, the agencies adjust the test
fuel economy performance of each passenger car and light truck model downward from its
rated value to reflect the expected size of this on-road fuel economy differential.
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Appendix E
The agencies note that in December 2006, EPA adopted changes to its regulations on
fuel economy labeling, which were intended to bring vehicles' rated fuel economy levels
closer to their actual on-road fuel economy levels.l Comparisons of on-road and CAFE fuel
economy levels developed by EPA as part of that final rule indicate that actual on-road fuel
economy for light-duty vehicles averages approximately 20 percent lower than published fuel
economy levels.2 While there is great heterogeneity among the population of drivers, as
discussed in the referenced material, 20 percent represents the average for modeling a fleet.
For example, if the overall EPA fuel economy rating of a light truck is 20 mpg, the on-road
fuel economy actually achieved by a typical driver of that vehicle is expected to be 16 mpg
(20*.80). EPA and NHTSA both applied this 20% differential in calculating the fuel savings
of the MY 2012 - 2016 joint final rule.
In this technical assessment report, the agencies assume that the overall energy
shortfall for the electric drivetrain is 30%. Specifically, this refers to a larger shortfall relative
to laboratory conditions while operating on electricity rather than liquid fuel. The 30% value
is derived from engineering judgment based on several data points. Foremost among these,
during the stakeholder meetings conducted prior to this technical assessment, confidential
business information (CBI) was supplied by several manufacturers which indicated that
electrically powered vehicles had greater variability in their on-road energy consumption than
vehicles powered by internal combustion engines. Further, data from the 2006 analysis of the
"five cycle" label potentially supported a larger on-road shortfall for vehicles with hybrid-
electric drivetrains.3 Finally, heavy accessory load, extreme temperatures, and aggressive
driving have deleterious impacts of unknown magnitudes on battery performance. As a
counterpoint, CBI provided by several other manufacturers suggested that the on-
road/laboratory differential attributable to electric operation should approach that of liquid
fuel operation in the future. Consequently, 30% was judged a reasonable estimate for the
current analysis.
El.3 Fuel Prices
Federal government agencies generally use EIA's projections in their assessments of
future energy-related policies. The retail fuel price forecasts presented in AEO 2010 span the
period from 2007 through 2035. Measured in constant 2008 dollars, the AEO 2010 Reference
Case forecast of retail gasoline prices during calendar year 2020 is $3.34 per gallon, rising
gradually to $3.91 by the year 2035 (these values include federal, state and local taxes).
However, valuing fuel savings over the maximum lifetimes of passenger cars and light trucks
used in this analysis requires fuel price forecasts that extend through 2060, approximately the
last year during which a significant number of MY 2025 vehicles will remain in service. To
obtain fuel price forecasts for the years 2036 through 2060, the agency assumes that retail fuel
prices will continue to increase after 2035 at the average annual rate (0.7%) projected for
2008-2035 in the AEO 2010 Reference Case. This assumption results in a projected retail
price of gasoline that reaches $4.34 in 2050.
A The agency defines the maximum lifetime of vehicles as the highest age at which more than 2 percent of those
originally produced during a model year remain in service. In the case of light-duty trucks, for example, this age
has typically been 36 years for recent model years.
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The value of fuel savings resulting from improved fuel economy and GHG emissions
to buyers of light-duty vehicles is determined by the retail price of fuel, which includes
federal, state, and any local taxes imposed on fuel sales. Total taxes on gasoline, including
federal, state, and local levies averaged $0.42 per gallon during 2008, while those levied on
diesel averaged $0.50. Because fuel taxes represent transfers of resources from fuel buyers to
government agencies, however, rather than real resources that are consumed in the process of
supplying or using fuel, their value must be deducted from retail fuel prices to determine the
value of fuel savings resulting from more stringent fuel efficiency and GHG standards to the
U.S. economy as a whole.4 When calculating the costs to any individual driver, the taxes are
included as part of the realized fuel savings.6
E1.4 Vehicle Lifetimes and Survival Rates
The agencies' analysis of fuel savings and related benefits for this Technical
Assessment Report begins by estimating the resulting changes in fuel use over the entire
lifetimes of cars and light trucks. The change in total fuel consumption by vehicles produced
during each of these model years is calculated as the difference in their lifetime fuel use under
the reference and alternative assumptions.
The first step in estimating lifetime fuel consumption by vehicles produced during a
model year is to calculate the number of those vehicles expected to remain in service during
each future calendar year after they are produced and sold.0 This number is calculated by
multiplying the number of vehicles originally produced during a model year by the proportion
expected to remain in service at the age they will have reached during each subsequent
calendar year, often referred to as a "survival rate."
The agencies used survival rate estimates from a NHTSA study5 in calculating fuel
savings and other impacts from the analyzed scenarios. The proportions of passenger cars and
light trucks expected to remain in service at each age up to their maximum lifetimes are
shown in Table El.4-1.D Note that that these survival rates were calculated against the pre-
MY 2011 definitions of cars and light trucks, because the NHTSA study has not been updated
B For society, the fuel taxes represent a transfer payment. By contrast, an individual realizes savings from not
paying the additional money.
c Vehicles are defined to be of age 1 during the calendar year corresponding to the model year in which they are
produced; thus for example, model year 2000 vehicles are considered to be of age 1 during calendar year 2000,
age 1 during calendar year 2001, and to reach their maximum age of 26 years during calendar year 2025.
NHTSA considers the maximum lifetime of vehicles to be the age after which less than 2 percent of the vehicles
originally produced during a model year remain in service. Applying these conventions to vehicle registration
data indicates that passenger cars have a maximum age of 26 years, while light trucks have a maximum lifetime
of 36 years. See Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, "Vehicle Survivability and
Travel Mileage Schedules," DOT HS 809 952, 8-11 (January 2006). Available at http://www-
nrd.nhtsa.dot.gov/Pubs/809952.pdf (last accessed August 25, 2010).
D The maximum age of cars and light trucks was defined as the age when the number remaining in service has
declined to approximately two percent of those originally produced. Based on an examination of recent
registration data for previous model years, typical maximum ages appear to be 26 years for passenger cars and
36 years for light trucks.
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Appendix E
since 2006. Because the agencies are unaware of a better data source, these values were used
unchanged. No improvements in survival rates were explicitly projected into the future.
The survival and annual mileage estimates reported in this section's tables reflect the
convention that vehicles are defined to be of age 1 during the calendar year that coincides
with their model year Thus for example, model year 2012 vehicles will be considered to be
of age 1 during calendar year 2012. This convention is used in order to account for the fact
that vehicles produced during a model year typically are first offered for sale in June through
September of the preceding calendar year (for example, sales of a model year typically begin
in June through September of the previous calendar year, depending on manufacturer). Thus
virtually all of the vehicles produced during a model year will be in use for some or all of the
calendar year coinciding with their model year, and they are considered to be of age 1 during
that year.E
E As an illustration, virtually the entire production of model year 2012 cars and light trucks will have been sold
by the end of calendar year 2012, so those vehicles are defined to be of age 1 during calendar year 2012. Model
year 2012 vehicles are subsequently defined to be of age 2 during calendar year 2013, age 3 during calendar year
2014, and so on. One complication arises because registration data are typically collected for July 1 of each
calendar year, so not all vehicles produced during a model year will appear in registration data until the calendar
year when they have reached age 2 (and sometimes age 3) under this convention.
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2017-2025 Technical Assessment
Table El.4-1 Survival Rates
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
ESTIMATED
SURVIVAL
FRACTION
CARS
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
0
0
0
0
0
0
0
0
0
ESTIMATED
SURVIVAL
FRACTION
LIGHT TRUCKS
0.9950
0.9741
0.9603
0.9420
0.9190
0.8913
0.8590
0.8226
0.7827
0.7401
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
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Appendix E
E1.5 VMT
A critical element in estimating lifetime fuel use by the cars or light trucks produced
during a future model year is to calculate the total number of miles that they will be driven
during each year of their expected lifetimes. To estimate total miles driven, the number of
cars and light trucks projected to remain in use during each future calendar year is multiplied
by the average number of miles a surviving car or light truck is expected to be driven at each
age. Estimates of average annual miles driven by MY 2001 cars and light trucks at each age
were developed by NHTSA from the Federal Highway Administration's 2001 National
Household Transportation Survey (Table El.5-1). These estimates represent the typical
number of miles driven by a surviving light duty vehicle. To determine the miles driven by
the average vehicle of a given vintage at a given age, one would multiply the mileage
accumulation by the corresponding survival rate.
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Table El.5-1 MY 2001 Mileage Schedules based on NHTS 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
ESTIMATED
VEHICLE MILES
TRAVELED
CARS
14,231
13,961
13,669
13,357
13,028
12,683
12,325
11,956
11,578
11,193
10,804
10,413
10,022
9,633
9,249
8,871
8,502
8,144
7,799
7,469
7,157
6,866
6,596
6,350
6,131
5,940
0
0
0
0
0
0
0
0
0
0
ESTIMATED
VEHICLE MILES
TRAVELED
LIGHT TRUCKS
16,085
15,782
15,442
15,069
14,667
14,239
13,790
13,323
12,844
12,356
11,863
11,369
10,879
10,396
9,924
9,468
9,032
8,619
8,234
7,881
7,565
7,288
7,055
6,871
6,739
6,663
6,648
6,648
6,648
6,648
6,648
6,648
6,648
6,648
6,648
6,648
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Appendix E
El.5.1 Adjusting vehicle use for future fuel prices
The estimates of average annual miles driven by passenger cars and light trucks
reported in Table El.5-1 reflect the historically low gasoline prices that prevailed at the time
the 2001 NHTS was conducted. Under the assumption that people tend to drive more as the
cost of driving decreases, the higher fuel prices in more recent projections leads to lower
mileage schedules. For this report, the agencies updated the analysis with the forecasts of
future gasoline prices reported in the AEO 2010 reference case. This adjustment accounts for
the difference between the average retail price per gallon of fuel forecast during each calendar
year over the expected lifetimes of future model year passenger cars and light trucks, and the
average price that prevailed when the NHTS was conducted in 2001. The elasticity of annual
vehicle use with respect to fuel cost per mile corresponding to the 10 percent fuel economy
rebound effect used in this analysis (i.e., an elasticity of -0.10) was used in conjunction with
the difference between each future year's fuel prices and those prevailing in 2001 to adjust the
estimates of vehicle use derived from the NHTS to reflect the effect of higher future fuel
prices. This procedure was applied to the NHTS derived mileage figures to adjust annual
mileage by age during each calendar year of the expected lifetimes of future model year cars
and light trucks.
El.5.2 Ensuring consistency with growth in total vehicle use
The estimates of annual miles driven by passenger cars and light trucks at each age
were also adjusted to reflect projected future growth in average vehicle use. Increases in the
average number of miles cars and trucks are driven each year have been an important source
of historical growth in total car and light truck use, and are expected to represent an important
source of future growth in total light-duty vehicle travel as well. As an illustration of the
importance of growth in average vehicle use, the total number of miles driven by passenger
cars increased 35 percent from 1985 through 2005, equivalent to a compound annual growth
rate of 1.5 percent.6 During that time, however, the total number of passenger cars registered
for in the U.S. grew by only about 0.3 percent annually.F Thus growth in the average number
of miles automobiles are driven each year accounted for the remaining 1.2 percent (= 1.5
percent - 0.3 percent) annual growth in total automobile use.G Further, the AEO 2010
Reference Case forecasts of total car and light truck use and of the number of cars and light
trucks in use suggest that their average annual use will continue to increase gradually from
2010 through 203 5.
In order to develop reasonable estimates of future growth in average car and light
truck use, the agencies calculated the rate of growth in the mileage schedules necessary for
F A slight increase in the fraction of new passenger cars remaining in service beyond age 10 has accounted for a
small share of growth in the U.S. automobile fleet. The fraction of new automobiles remaining in service to
various ages was computed from R.L. Polk vehicle registration data for 1977 through 2005 by the agency's
Center for Statistical Analysis.
G See supra note k below.
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total car and light truck travel to increase at the rate forecast in the AEO 2010 Reference
Case. The growth rate in average annual car and light truck use produced by this calculation
is approximately 1.15 percent per year.H This rate was applied to the mileage figures reported
in Table El.5-1 to estimate annual mileage by age during each calendar year of the expected
lifetimes of cars and light trucks during all model years.
Separate adjustments for projected fuel prices and growth in vehicle use were made
for each calendar year. Because the effects of both fuel prices and cumulative growth in
average vehicle use vary by year, these adjustments result in different VMT schedules for
each future year. While the adjustment for future fuel prices generally reduces average
mileage at each age from the 2001 values, the adjustment for expected future growth in
average vehicle use increases it. The net impact is growth over time.
El.5.3 Final VMT equation
Below, we show the equations used to determine the VMT schedules used in this
analysis. This particular form of the equation uses a negative form of the rebound rate.
Where:
V = CY 2001 VMT from NHTSA analysis of NHTS data
SGR = Secular Growth Rate
YS = Years since 2001
RR= Rebound rate
FCPM = Fuel Cost per mile
Where:
EC= Electrical consumption per mile
EP = Electricity Price
GC = Gasoline Consumption per mile
GP = Gasoline Price
H It was not possible to estimate separate growth rates in average annual use for cars and light trucks, because of
the significant reclassification of light truck models as passenger cars discussed previously.
E-9
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Appendix E
Table El.5-2 MY 2020 and 2025 Reference Mileage Schedules1
VEHICLE
AGE
1
2
o
6
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
MY 2020
ESTIMATED
VMT
CARS
16,882
16,334
16,235
16,143
16,048
15,750
15,356
15,040
14,044
13,707
13,243
12,824
12,439
11,991
11,518
11,054
10,607
10,169
9,743
9,337
8,949
8,588
8,252
7,943
7,671
7,436
0
0
0
0
0
0
0
0
0
0
ESTIMATED
VMT LIGHT
TRUCKS
19,017
18,398
18,281
18,160
18,024
17,643
17,145
16,728
15,538
15,092
14,504
13,968
13,472
12,912
12,333
11,773
11,245
10,741
10,266
9,833
9,438
9,098
8,809
8,576
8,415
8,324
8,307
8,313
8,317
8,315
8,318
8,323
8,324
8,328
8,335
8,335
MY 2025
ESTIMATED
VMT
CARS
17,749
17,152
17,071
16,976
16,879
16,586
16,175
15,846
14,774
14,427
13,921
13,492
13,101
12,634
12,142
11,664
11,193
10,731
10,281
9,854
9,444
9,064
8,709
8,382
8,096
7,847
0
0
0
0
0
0
0
0
0
0
ESTIMATED
VMT LIGHT
TRUCKS
19,991
19,315
19,219
19,094
18,954
18,578
18,056
17,623
16,342
15,883
15,244
14,693
14,188
13,603
12,999
12,422
11,866
11,334
10,833
10,376
9,960
9,601
9,296
9,050
8,880
8,784
8,766
8,773
8,777
8,775
8,779
8,784
8,785
8,789
8,797
8,797
1 VMT schedules differing by approximately 0.2% over the course of a vehicle lifetime were used in the
estimation of costs and impacts. The VMT schedules used in cost estimation are shown here.
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2017-2025 Technical Assessment
El.5.4 Comparison to the VMT schedules in the MY 2012-2016 Final Rulemaking
The VMT schedules used in the MY 2012-2016 final rulemaking and this assessment
report are compared below.
Table El.5-3 Summary of Reference Expected Lifetime VMT
Car
Trucks
2001 NHTS in
NHTSA Report
152,137
179,954
MY 2012-2016
Final Rule
195,264
225,865
MY 2020
197,578
231,856
MY 2025
207,922
244,026
E1.6 VMT Rebound
The VMT rebound effect refers to the fraction of fuel savings expected to result from
an increase in vehicle fuel economy that is offset by additional vehicle use. The increase in
vehicle use that stems from improved fuel economy occurs because vehicle owners respond to
the resulting reduction in vehicle fuel consumption and operating costs by driving more.
The magnitude of the rebound effect is one of the determinants of the actual fuel
savings that are likely to result from adopting stricter fuel economy or emissions standards,
and thus is an important parameter affecting the evaluation of potential standards for future
model years. It can be measured directly by estimating the elasticity of vehicle use with
respect to fuel economy itself, or indirectly by the elasticity of vehicle use with respect to fuel
cost per mile driven.1 When expressed as a positive percentage, either of these parameters
gives the fraction of fuel savings that would otherwise result from adopting stricter standards,
but is offset by the increase in fuel consumption that results when vehicles with increased fuel
economy are driven more.
The fuel economy rebound effect for light-duty vehicles has been the subject of a large
number of studies since the early 1980s. Although they have reported a wide range of
estimates of its exact magnitude, these studies generally conclude that a significant rebound
effect occurs when vehicle fuel efficiency improves.15 The most common approach to
1 FuelFuel cost per mile is equal to the price of fuel in dollars per unit divided by fuel economy in miles per
unitunit, so this figure declines when a vehicle's fuel economy increases.
K Some studies estimate that the long-run rebound effect is significantly larger than the immediate response to
increased fuel efficiency. Although their estimates of the adjustment period required for the rebound effect to
E-ll
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Appendix E
estimating its magnitude has been to analyze household survey data on vehicle use, fuel
consumption, fuel prices (often obtained from external sources), and other determinants of
household travel demand to isolate the response of vehicle use to higher fuel economy. Other
studies have relied on econometric analysis of annual U.S. data on vehicle use, fuel economy,
fuel prices, and other variables to identify the response of total or average vehicle use to
changes in fleet-wide average fuel economy and its effect of fuel cost per mile driven. Two
recent studies analyzed yearly variation in vehicle ownership and use, fuel prices, and fuel
economy among individual states over an extended time period in order to measure the
response of vehicle use to changing fuel economy.L
Chapter Four of the Joint Technical Support Document to the recent MYs 2012-2016
final rule surveys these previous studies, summarizes recent work on the rebound effect, and
explains the basis for the 10 percent rebound effect EPA and NHTSA are using in the current
technical analysis.7 The use of a 10 percent rebound effect in this analysis reflects an
assumption that the rebound effect applicable to the MYs 2012-2016 vehicles will remain
applicable throughout future time periods. The agencies plan to conduct new analysis of the
expected rebound effect in this time frame in a future rulemaking.
E1.7 Estimating Emissions and Fuel Savings
A vehicle emission standard would reduce GHG emissions emitted directly from vehicles
due to reduced fuel use and decreased leakage from air conditioning systems. In addition to these
"downstream" emissions, reducing CC>2 emissions translates directly to reductions in the
emissions associated with the processes involved in getting petroleum to the pump, including the
extraction and transportation of crude oil, and the production and distribution of finished gasoline
(termed "upstream" emissions). The agencies quantified these impacts using the inputs
discussed in this section.
Table El.7-1 Processes Considered
PROCESS
Crude Oil Extraction
Crude Oil Transport
Oil Refining
Fuel Transport and Distribution
Fuel Tailpipe Emissions
Air Conditioning System Leakage
UPSTREAM / DOWNSTREAM
Upstream
Upstream
Upstream
Upstream
Downstream
Downstream
reach its long-ran magnitude vary, this long-ran effect is most appropriate for evaluating the fuel savings and
emissions reductions resulting from stricter standards that would apply to future model years.
L In effect, these studies treat U.S. states as a data "panel" by applying appropriate estimation procedures to data
consisting of each year's average values of these variables for the separate states.
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2017-2025 Technical Assessment
1.7.1 Estimating reductions in GHG emissions from vehicle use (downstream)
For the analysis documented in today's Technical Assessment, the agencies used the
OMEGA model to directly calculate CC>2 emissions based on g/mile rates. These CC>2
emissions were converted to gallons of fuel under the assumption that approximately the
entire carbon content of liquid fuel is converted to CO2 emissions during the combustion
process. The weighted average CO2 content of gasoline is estimated to be 8,887 grams per
gallon, while that of diesel fuel is estimated to be approximately 10,200 grams per gallon. For
details, please see EPA's RIA and NHTSA's RIA from the recent MY 2012-2016 Final Rule.
EPA estimated the increases in emissions of methane (CFLj) and nitrous oxide (N2O)
due to increased vehicle use ("rebound driving") by multiplying the increase in total miles
driven by cars and light trucks of each model year and age by emission rates per vehicle-mile
for these GHGs. These emission rates, which differ between cars and light trucks as well as
between gasoline and diesel vehicles, were estimated by EPA using its Motor Vehicle
Emission Simulator (MOVES 2010) model. The MOVES model assumes that the per-mile
rates at which cars and light trucks emit these GHGs are determined by the efficiency of fuel
combustion during engine operation and chemical reactions that occur during catalytic after-
treatment of engine exhaust, and are thus independent of vehicles' fuel consumption rates.
Thus MOVES emission factors for these GHGs are assumed to be unaffected by changes in
energy consumption. TheCH4 and N2O emission factors are the same as those used in the MY
2012-2016 Final Rule. The full derivation of these factors is available in Chapter 4 of the
related Joint Technical Support Document.
The emission factors used for HFC leakage emissions are discussed in Appendix D to
this report.
E1.8 Upstream Emissions
In this analysis, we calculated upstream emission impacts for the greenhouse gases
CH/i, N2O, and CO2 from both gasoline and electricity production. The upstream gasoline
emission factor, expressed in the form of gram/gallon produced, is taken directly from the
analysis supporting the MYs 2012-2016 final rule. EPA derived the upstream gasoline
emission factor from the Department of Energy's GREET model, which provides separate
estimates of air pollutant emissions that occur in four phases of fuel production and
distribution: crude oil extraction, crude oil transportation and storage, fuel refining, and fuel
distribution and storage. EPA modified the GREET model to change certain assumptions
about emissions during crude petroleum extraction and transportation, as well as to update its
emission rates to reflect adopted and pending EPA emission standards. The agency converted
these emission rates from the mass per fuel energy content basis on which GREET reports
them to mass per gallon of fuel supplied using the estimates of fuel energy content reported
by GREET. Full details of this analysis are described in the MYs 2012-2016 rulemaking
docket memo "Calculation of Upstream Emissions for the GHG Vehicle Rule." The upstream
gasoline emission factor does not change over time.
E-13
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Appendix E
Table El.8-1 Gasoline Upstream Emission Factors
POLLUTANT
CO2
CH4
N2O
CO2eq
GASOLINE (g/gallon)
2,161
12.25
0.03
2477
In the MY 2012-2016 Final Rule analysis, we noted that there are many issues
involved with projecting the electricity upstream GHG emissions. Relevant issues associated
with future EV and PHEV use include, but are not limited to, average versus marginal power
generation, daytime versus nighttime vehicle charging, geographical differences, and changes
in future electricity feedstocks.
For the present report, we rely upon the reference case projections produced by the
EPA Office of Atmospheric Programs for an analysis of the American Clean Energy and
o
Security Act of 2009 (H.R. 2454). This scenario assumes no new power sector regulations,
but does assume construction of new plants to replace older retired plants. This results in a
slight decrease (-10% compared to 2005) in the emission rate per kWh electricity produced,
as newer plants tend to emit less than the plants which they have replaced. The H.R 2454
base case analysis indicates that 4,395 MWh of net generation will be produced in 2025, with
2462 million metric tons of CO2 emissions resulting. This results in an emission factor of 555
grams CO2 per kWh. Based on eGrid20059, we estimate that approximately 0.01 grams of
CFLj and 0.01 grams of N2O are emitted per kilowatt hour. We assume that electricity
emission factors do not change after 2025.
The upstream emission factor for electricity was adjusted upwards by six percent in
order to properly capture the feedstock gathering that occurs upstream of the powerplant.M
Feedstock gathering includes the gathering, transporting, and preparing fuel for electricity
generation. This adjustment factor is consistent with those discussed in the MY 2012-2016
Final Rule.10
It is important to carefully outline the frame of reference for electricity emission
factors. For calculations of GHG emissions from electricity generation, the total energy
consumed from the battery is divided by 0.9 to account for charging losses, and by 0.93 to
account for losses during transmission. The upstream emission factor is applied to total
electricity production, rather than simply power consumed at the wheel. NO
M The factor of 1.06 to account for GHG emissions associated with feedstock extraction, transportation, and
processing is based on Argonne National Laboratory's The Greenhouse Gases, Regulated Emissions, and Energy
Use in Transportation (GREET) Model, Version l.Sc.O, available at
http://www.transportation.anl.gov/modeling_simulation/GREET/). EPA Docket EPA-HQ-OAR-2009-0472.
N By contrast, consumer electricity costs would not include the power lost during transmission. While
consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric
meter.
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2017-2025 Technical Assessment
POLLUTANT
C02
CH4
N2O
C02eq
CO2eq adjusted for
feedstock gathering
CY 2025
ELECTRICITY (g/kWh)
555
0.01
0.01
558
591
E1.9 Global Warming Potentials
Increases in emissions of non-CO2 GHGs are converted to equivalent increases in CO2
emissions using estimates of the Global Warming Potential (GWP) of hydrofluorocarbon
134a (HFC134a), methane and nitrous oxide. These GWPs are one way of accounting for the
higher radiative forcing capacity and differing lifetimes of methane and nitrous oxide when
they are released into the earth's atmosphere, measured relative to that of CO2. Because these
gases differ in atmospheric lifetimes, their relative damages are not constant over time.
Impacts other than temperature change also vary across gases in ways that are not captured by
GWP. For instance, CO2 emissions, unlike methane and other greenhouse gases, contribute to
ocean acidification. Methane contributes to health and ecosystem effects arising from
increases in tropospheric ozone, while damages from methane emissions are not offset by the
positive effect of CO2 fertilization. Noting these caveats, the CO2 equivalents of increases in
emissions of these gases are then added to the increases in emissions of CO2 to summarize the
effect of the total increase in CO2-equivalent GHG emissions from vehicle use.
As in the final rule, the GWP values from the Intergovernmental Panel on Climate
Change Annual Report 4 are used. These are 1430 for HFC134a, 298 for N2O, and 25 for
CH4.
Tl,P
0 By contrast, consumer electricity costs would not include the power lost during transmission. While
consumers indirectly pay for this lost power through higher rates, this power does not appear on their electric
meter.
p The global warming potentials (GWP) used in this rule are consistent with Intergovernmental Panel on Climate
Change (IPCC) Fourth Assessment Report (AR4). Due to international agreement, the IPCC Second
Assessment Report (SAR) GWP values are used in the official U.S. greenhouse gas inventory submission to the
climate change framework.
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Appendix E
Appendix E References
1 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy
Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,
http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Dav-27/a9749.pdf.
2 EPA, Final Technical Support Document: Fuel Economy Labeling of Motor Vehicle Revisions to Improve
Calculation of Fuel Economy Estimates, Office of Transportation and Air Quality EPA420-R-06-017 December
2006, Chapter II, http://www.epa.gov/fueleconomv/420r06017.pdf.
3 EPA, Fuel Economy Labeling of Motor Vehicles: Revisions To Improve Calculation of Fuel Economy
Estimates; Final Rule, 40 CFR Parts 86 and 600, Federal Register, December 27, 2006, pp. 77872-77969,
http://www.epa.gov/fedrgstr/EPA-AIR/2006/December/Dav-27/a9749.pdf.
4 OMB Circular A-4, September 17, 2003. http://www.whitehouse.gov/omb/assets/omb/circulars/a004/a-4.pdf
5 Lu, S., NHTSA, Regulatory Analysis and Evaluation Division, "Vehicle Survivability and Travel Mileage
Schedules," DOT HS 809 952, 8-11 (January 2006). Available at http://www-nrd.nhtsa.dot.gov/pdf/nrd-
30/NCSA/Rpts/2006/809952.pdf (last accessed Feb. 15,2010).
6 FHWA, Highway Statistics, Summary to 1995, Table vm201at
http://www.fhwa.dot.gov/ohim/summarv95/vm20la.xlw . and annual editions 1996-2005, Table VM-1 at
http://www.fhwa.dot.gov/policv/ohpi/hss/hsspubs.htm (last accessed Feb. 15,2010).
7 Sorrell, S. and J. Dimitropoulos, 2007. "UKERC Review of Evidence for the Rebound Effect, Technical
Report 2: Econometric Studies", UKERC/WP/TPA/2007/010, UK Energy Research Centre, London, October
and Greening, L.A., D.L. Greene and C. Difiglio, 2000. "Energy Efficiency and Consumption - The Rebound
Effect - A Survey", Energy Policy, vol. 28, pp. 389-401.
8 EPA Office of Atmostpheric Programs. Analysis of HR2454.
http://www.epa.gov/climatechange/economics/economicanalyses.html
9 U.S. EPA. 2009. eGrid2007 dataset. http://www.epa.gov/cleanenergy/energyresources/
egrid/index.html. Accessed February 3, 2010. The Emissions & Generation Resource Integrated Database
(eGRID) is a comprehensive inventory of environmental attributes of electric power systems. The preeminent
source of air emissions data for the electric power sector, eGRID is based on available plant-specific data for all
U.S. electricity generating plants that provide power to the electric grid and report data to the U.S. government.
10 MY 2012-2016 Final Rule, Section III.2.C
11 EPA. Final Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate
Average Fuel Economy Standards. Joint Technical Support Document. Chapter 4. EPA-420-R-10-901
http://www.epa.gov/otaq/climate/regulations/420rl0901.pdf. Original data found in Intergovernmental Panel on
Climate Change. Chapter 2. Changes in Atmospheric Constituents and in Radiative Forcing. September 2007.
http://www.ipcc.ch/pdf/assessmentreport/ar4/wgl/ar4-wg 1 -chapter2.pdf. Docket ID: EPA-HQ-OAR-2009-0472-
0117
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2017-2025 Technical Assessment
Fl Appendix F: EPA Documentation of OMEGA model
Analysis
Fl.l Overview of OMEGA
This Appendix provides the methodology underlying the technical assessment of the
future vehicle scenarios presented in Chapter 6. As in the analysis of the MY 2012-2016
rulemaking, evaluating the feasibility of these scenarios included identifying potentially available
technologies and assessing their effectiveness, cost, and impact on relevant aspects of vehicle
performance and utility. The wide number of technologies which are available and likely to be
used in combination required a method to account for their combined cost and effectiveness. As
described in Chapter 6, this included developing three distinct technology pathways which
emphasized one or the other of the more advanced technologies, such as hybrids, advanced
gasoline engine, plug-ins and battery EVs.
Applying these technologies efficiently to the wide range of vehicles produced by various
manufacturers is a challenging task. In order to assist in this task, EPA has developed a
computerized model called the Optimization Model for reducing Emissions of Greenhouse gases
from Automobiles (OMEGA). Broadly, the model starts with a description of the future vehicle
fleet, including manufacturer, sales, base CO2 emissions, footprint and the extent to which
emission control technologies are already employed. For the purpose of this Technical
Assessment Report analysis, 63 generic vehicle platforms—were used to capture important
differences in engine design, vehicle design and vehicle utility. The model is then provided with a
list of technologies which are applicable to various types of vehicles, along with their cost and
effectiveness and the maximum percentage of vehicle sales which can receive each technology.
This list varies slightly depending on whether model year 2020 or 2025 standards are being
evaluated and on the specific technology pathway being evaluated. The model combines this
information with economic parameters, such as fuel prices and a discount rate, to project how
manufacturers could apply available technology in order to meet specified levels of emission
control. For this Technical Assessment Report, as all vehicle sales have been combined into a
single manufacturer, the model indicates how the industry when complying as a single
manufacturer might use technology to reduce GHG emissions. The resulting output is a
description of which technologies are added to each vehicle platform, along with the
accompanying cost.
OMEGA includes several components, including a number of pre-processors that assist
users in preparing a baseline vehicle forecast,1 creating and ranking technology packages,2 and
calculating the degree to which technology is present on baseline vehicles. The OMEGA core
model assembles this information and produces estimates of increases in vehicle cost and CO2
reduction. Based on the OMEGA core model output, the technology penetration of the new
vehicle mix and the scenario impacts (fuel savings, emission impacts, and other monetized
benefits) are calculated by post-processors. The pre- and post- processors are Microsoft Excel
spreadsheets and visual basic programs, while the OMEGA core model is an executable program
written in the C# language. The files used in this analysis, as well as the current version of
OMEGA, are available in the TAR docket.
F-l
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Appendix F
Pro-Processors
Figure Fl.1-1: Information Flow in the OMEGA Model
Existing Technology
Calculation
Reference File
Scenario File
Fuels File
Core Model
v
OMEGA
Post-Processors
Technology Penetration
Impacts
A detailed description of the OMEGA model, as well as the general modeling
methodology is provided in the MY 2012-2016 rule preamble Section HID. Consequently,
the interested reader may find additional depth there,3 or in the OMEGA user guide on the
EPA website.4 The remainder of this appendix assumes a basic knowledge of OMEGA's
operation, and focuses on the particular data sources and methodologies used in the scenario
analysis described in Chapter 6.
F1.2 Summary of Inputs
The inputs underlying the OMEGA analysis have significant impacts on the results,
and are described in detail elsewhere in this Assessment Report, as follows. The fleet
projection used for this analysis is described in Appendix A. The vehicle technology
packages are described in Chapter 3 and Appendix B. The inputs relating to air conditioning
controls are outlined in Appendix D. The other economic and environmental outputs are
described in Appendix E. The detailed description of analytic scenarios, including the
standards modeled and the reasoning behind a single fleet analysis, is available in Chapter 6.
Generally, the table of contents to this technical assessment is a useful guide to additional
detail.
F1.3 Configuration of the Scenario File
The scenario file in OMEGA contains a directory of data input files, a group of
economic parameters, and a set of CO2 g/mile targets. For the Technical Assessment Report
analysis, OMEGA was configured so that each technical pathway/model year combination
was a single scenario file containing six runs. Four runs corresponding to each of the four
emission control scenarios (i.e.., 3% per year, 4% per year, etc.) were included. Also included
were a diagnostic run requiring maximum application of technology, as well the reference
case scenario of MY 2016 GHG standards from the recent MY 2012-2016 final rule. As a
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2017-2025 Technical Assessment
result, six scenario files were created (2 MYs x 3 technical pathways), and each scenario file
contained parameters for six OMEGA runs.
The emission control scenarios were each configured with a flat standard
corresponding to the appropriate stringency. No limits were placed on credit transfers
between the car and truck fleets. As in the MY 2012-2016 final rule analysis, EPA accounted
for the emission reductions and technology costs due to air conditioning controls outside of
the OMEGA model. In the MY 2025 timeframe, air conditioning remains a highly cost-
effective technology to control GHG emissions, and consequently, EPA projects that the
entire market will convert to low leakage, high efficiency systems. In the time frame of MY
2020 and later, these emission reductions were assigned a statutory value of 20.6 grams in the
reference scenario5 and 15.3 grams in the control scenarios.6 An example of the adjustments
is shown in Table Fl.3-1. The MY 2016 footprint curves and the flat standards were each
adjusted by the maximum potential AC credits to produce the credit adjusted targets. The
agencies note, as discussed in Chapter 6 above, that the upcoming federal rulemaking analysis
will consider fuel economy and emission control scenarios defined in terms of attribute-based
standards, but we believe the scenarios considered here are meaningful for purposes of this
assessment.
Table Fl.3-1: Adjustment of Standards for Air Conditioning Credits
Scenario
Reference
3%
4%
5%
6%
Sales-Weighted
MY 2025 Target
248.1
190.1
173.1
157.6
143.2
Projected AC
Credits1
20.6
15.3
15.3
15.3
15.3
Sales-Weighted MY
2025 Credit Adjusted
Target
268.7
205.4
188.4
173.9
158.5
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Appendix F
A further adjustment was made with respect to the credit adjusted targets listed above.
The scenarios described in this document are defined by a sales weighted average of car and
truck CO2 emissions. When credit transfer is allowed between cars and trucks, OMEGA
weights the CO2 average by both sales and vehicle miles traveled (VMT).A Light trucks
generally are driven more than cars, so the sales and VMT weighted CO2 emission average
tends to be slightly lower than the sales-weighted average. To account for this difference, the
diagnostic run was used to produce VMT and sales weighted targets that corresponded to the
sales weighted targets listed above. These calibrated targets can be seen in the scenario files
available in the TAR docket.
We also updated the VMT ratios used in car/truck credit transfer to the appropriate
MY lifetime values discussed in Appendix E.
F1.4 Configuration of the Technology File
The technology input file defines the technology packages which the model can add to
the vehicle fleet. A separate technology file was developed for each of the six technology
pathway/model year combinations considered in this Technical Assessment Report. While
the individual technology costs were the same between technology pathways, they differed
between MY 2020 and MY 2025 due to the learning effects discussed in the Appendix 3 and
the MY 2012-2016 Final Rule Section HE. Due to the different limits on maximum
penetrations of several key technologies (discussed in Chapter 6), each of the technology
pathways also required a separate technology file and model run. The change in those
maximum penetration rates also slightly affected the set of most cost effective technology
packages selected for inclusion in the OMEGA model runs. The processes to build and rank
technology packages for the technology file are described in the Chapter 3 and Appendix B of
this report. This section describes the configuration of the OMEGA Technology input file
which occurs after the ranked packages are developed.
F 1.4.1 Multiple Fuel Tracking
OMEGA 1.0.2, which was used during the MY 2012-2016 rule analysis, tracked CO2
emissions at the vehicle platform level. For the present analysis, an upgrade was made to the
OMEGA model to track CO2 emissions by fuel within each vehicle platform. As a result, a
vehicle platform can be composed of sub-vehicles, each with its own fuel, CO2 emission rate
and electricity consumption rate. To facilitate this tracking, every technology is encoded
with its operating fuel, as well as the fuel of the vehicles to which it applies. In combination
with technology specific caps,B this allows a vehicle platform to be split so that subsequent
technologies can be applied to the specific subsets of the vehicle (Table Fl.4-1). Thus, for
example, a certain fraction of a vehicle's sales can be equipped with a diesel engine.
Subsequent diesel-based technologies can then be applied more simply and directly to this
A This practice is consistent with EPA's MY 2012-2016 regulations allowing VMT weighted credit transfer
between car and truck fleets.
B -Gap" is a shorthand term for the maximum penetration rates for certain technologies which define the various
technology paths.
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2017-2025 Technical Assessment
subset of sales. The model keeps track of the sales and CO2 emission rates of both the
gasoline and diesel versions of the vehicle.
In the example below, Technology Package 3 is applied to the gasoline fuel vehicle
created by the application of Technology Package 1. Technology Package 4 is applied to the
diesel fuel vehicle created by the application of Technology Package 2.
Table Fl.4-1: Example of Multiple Fuel Technology File
Tech
Package
1
2
3
4
Name
GDI Gasoline Engine
Diesel Engine
Gasoline Hybrid
Improved Diesel
Cap1
100%
15%
100%
100%
Fuel of the
Technology
Gasoline
Diesel
Gasoline
Diesel
Fuel to which the
Technology Applies
Gasoline
Gasoline
Gasoline
Diesel
IPlease note that OMEGA technology caps are relative to the population on that fuel, so a 100% cap on
technology package four indicates that it applies to 100% of the 15% of vehicles which were converted to diesel
in step
In the current TAR analysis, this model feature simplified the ability to apply several
types of electric vehicle and plug-in electric vehicle technology packages to the same baseline
vehicle. In addition, we found it useful when applying certain advanced gasoline technology
packages which had caps of less than 100%. For example, most of the technology paths limit
the use of advanced (e.g., EGR-boosted) gasoline engine technologies to less than 100%. In
most cases, further technology packages can be applied to both the vehicles which received
this advanced gasoline technology and those that did not. By effectively treating -advanced
gasoline engines" as including a change in fuels, we were able to simplify the addition of
subsequent technologies to both the subset of vehicle sales with this technology and that
without it. This could have been accomplished without taking advantage of the OMEGA
model's new fuel tracking capability, but the estimation of the cost and effectiveness of the
subsequent technology packages would have had to consider the fact that they were being
applied to a subset of the vehicle's sales which did not have the average attributes of that
vehicle at that stage of technology addition.
For example, if EGR boost technology is added to 50% of the sales of those vehicles
operating on gasoline, it may be possible to hybridize both the vehicles with and without the
EGR boost technology, with differing costs and effectiveness. It is possible to determine the
overall impact of hybridizing the non-EGR vehicles first and then the EGR-boosted vehicles
and developing the appropriate OMEGA model inputs which accomplish both of these steps
of technology addition. However, since we were not using all of the fuel types currently
tracked in the OMEGA model (e.g. E10), it was easier to separate the EGR-boosted vehicles
from those without this technology by changing the former vehicles' fuel to -E10". We
simply made the fuel properties of E10 exactly the same as those for gasoline. Then for
example, the incremental effect of hybridizing the non-EGR boosted vehicles could be used
directly in the model without the need to sales weight this impact by including the fact that the
emissions of the non-EGR vehicles were not changing.
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Appendix F
To further illustrate this issue, consider the case of Vehicle A, a gasoline vehicle with
CC>2 emissions of 300 g/mile. In this example scenario, diesel packages are limited to 50% of
the fleet because of concerns relative to production capacity.0 In this case, two sequential
diesel packages should be applied to the same 50% subset of the vehicle (Table F 1.4-2). As
can be seen in this table, OMEGA 1.3 now more accurately attributes the reductions to the
appropriate subset within the vehicle platform.
Table Fl.4-2: Tracking CO2
Step
1
2
Package
Fuel
Diesel
Diesel
Maximum
Penetration
Limit
50%
50%/100%
Reduction
10%
10%
OMEGA 1.0.2
Applied to average
vehicle.
CO2 Avg
300
285
270.75
OMEGA 1.3
Applied to a specific fuel
within a platform.
CO2
Avg
300
285
271.5
CO2
Gas
300
300
300
CO2
Diesel
N/A
270
243
lrThe maximum penetration limit in the second step applies to 50% of the total vehicles (OMEGA 1.0.2) or 100%
of the diesel vehicles (OMEGA 1.3)
In the analysis presented in this report, we encode limited technologies to different
fuels so that the appropriate reductions are taken. As an example, plug-in hybrids are coded
to diesel fuel. The fuels input file was modified so that the appropriate gasoline fuel
properties are attributed to -diesel" fuel.
Fl.4.2 Tracking of Electricity
OMEGA 1.3 also tracks electrical consumption in kWh per mile. Each technology
package is now associated with an -electricity conversion percentage" which refers to the
increase in the energy consumed by the electric drivetrain relative to reduction in the
consumption of energy from liquid fuel. Electricity is a highly refined form of energy which
can be used quite efficiently to create kinetic energy. Thus, electric motors are much more
efficient than liquid fuel engines. Consequently, the electric consumption percentage input in
in the Technology File for plug-in vehicles is generally well below than 100%. It may be
possible that this percentage could exceed 100% under certain circumstances, for example
when one type of plug-in vehicle is being converted into another plug-in vehicle and
electricity consumption per mile is increasing due to larger and heavier batteries, etc.
However, that was not the case for any of the technologies evaluated in this analysis.
c Please note, this is just an example, and has no implications relative to actual maximum penetration rates for
diesel vehicles.
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F1.5 Configuration of the Market File
F 1.5.1 Creating the Generic Vehicles
As discussed in Section F1.4 above, vehicle manufacturers typically develop many
different models by basing them on a smaller number of vehicle platforms. The platform
typically consists of a common set of vehicle architecture and structural components. This
allows for efficient use of design and manufacturing resources. In the MY 2012-2016 Final
Rule, EPA created over 200 vehicle platforms which were used to capture the important
differences in vehicle and engine design and utility of future vehicle sales of roughly 16
million units in the 2016 timeframe. For the current analysis, we are not differentiating
between manufacturers, and consequently require fewer vehicle platforms for the analysis.
The approximately sixty vehicle platforms are a result of mapping the 1130 vehicle fleet into
the 19 engine based vehicle types (Table Fl.5-1) and the 10 body size and structure based
utility classes (Table F 1.5-2). As not all vehicle types match to all utility types, the number of
generic vehicles is less than the multiplicative maximum of the two tables.
Table Fl.5-1 : Vehicle Types in the TAR Analysis
Vehicle Type #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Name
Subcompact Car
Compact Car 14
Midsize Car/Small MPV (unibody)
Compact Car/Small MPV (unibody)
Midsize/Large Car
Midsize Car/Large Car
Mid-sized MPV (unibody )/Small Truck
Midsize MPV (unibody)/Small Truck
Large MPV (unibody)
Large MPV (unibody)
Large Truck (+ Van)
Large Truck + Large MPV
Large Truck (+ Van)
Large Truck (+Van)
Large Car
Large MPV (unibody)
Large MPV (unibody)
Large Truck (+ Van)
Large Truck (+ Van)
Cam
DOHC
DOHC
DOHC
DOHC
DOHC
DOHC
DOHC
SOHC
SOHC
SOHC
SOHC
OHV
OHV
SOHC3V
OHV
DOHC
DOHC
DOHC
DOHC
Engine
14
14
14
V6
V6
V8
14
V6
V8
V8
V6
V6
V8
V8
V8
V6
V8
V6
V8
Table Fl.5-2 : Vehicle Types in the Technical Assessment Analysis
Utility
Class #
1
2
3
Utility Class
Subcompact Auto
Compact Auto
Mid Size Auto
Vehicle Use l
Car
Car
Car
Footprint Criteria
Footprint <43
43<=Footprint<46
46<=Footprint<53
Structure Criteria
—
—
—
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Appendix F
4
5
6
7
8
9
10
Large Auto
Small SUV
Large SUV
Small Pickup
Large Pickup
Cargo Van
Minivan
Car
SUV
SUV
Pickup
Pickup
Van
Van
56<=Footprint
43<=Footprint<46
46<=Footprint
Footprint < 50
50<=Footprint
—
—
—
—
—
—
—
Ladder Frame
Unibody
1. Vehicle use type is based upon analysis of EPA certification data.
Fl.5.2 Accounting for Technology already on the Vehicles
The market data input file utilized by OMEGA, which characterizes the vehicle fleet,
is designed to account for the fact that the 2008 model year vehicles which comprise our
baseline fleet may already be equipped with one or more of the technologies available in
general to reduce CO2 emissions. As described in Appendix B, EPA decided to apply
technologies in packages, as opposed to one at a time. However, 2008 vehicles were
equipped with a wide range of technology combinations, many of which cut across the
packages. Thus, EPA developed a method to account for the presence of the combinations of
applied technologies in terms of their proportion of the EPA packages described in Chapter 3.
This analysis can be broken down into four steps
The first step in the updated process is to breakdown the available GHG control
technologies into five groups: 1) engine-related, 2) transmission-related, 3) hybridization, 4)
weight reduction and 5) other. Within each group we gave each individual technology a
ranking which generally followed the degree of complexity, cost and effectiveness of the
technologies within each group. More specifically, the ranking is based on the premise that a
technology on a 2008 baseline vehicle with a lower ranking would be replaced by one with a
higher ranking which was contained in one of the technology packages which we included in
our OMEGA modeling. The corollary of this premise is that a technology on a 2008 baseline
vehicle with a higher ranking would be not be replaced by one with an equal or lower ranking
which was contained in one of the technology packages which we chose to include in our
OMEGA modeling. This ranking scheme can be seen in the TEB/CEB calculation macro,
available in the docket.
In the second step of the process, we used these rankings to estimate the complete list
of technologies which would be present on each baseline vehicle after the application of each
technology package. We then used the EPA lumped parameter model to estimate the total
percentage CO2 emission reduction associated with the technology present on the baseline
vehicle (termed package 0), as well as the total percentage reduction after application of each
package. This process was repeated to determine the total cost of all of the technology
present on the baseline vehicle and after the application of each applicable technology
package.
The third step in this process is to determine the degree of each technology package's
incremental effectiveness and incremental cost is affected by the technology already present
on the baseline vehicle. The degree to which a technology package's incremental
effectiveness is reduced by technology already present on the baseline vehicle is termed the
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technology effectiveness basis, or TEB, in the OMEGA model. The value of each vehicle's
TEB for each applicable technology package is determined as follows:
( TotalEffec f } ( 1- TotalEffec t
pl
1 - TotalEffec tvj ) I- TotalEffec tpj_
pj_,
1-
I- TotalEffec tpl
l-TotalEffect^
Where
TotalEffectv.i = Total effectiveness of all of the technologies present on the baseline vehicle after
application of technology package i
TotalEffectv!_! = Total effectiveness of all of the technologies present on the baseline vehicle after
application of technology package i-1
TotalEffectp! = Total effectiveness of all of the technologies included in technology package i
TotalEffectp!_! = Total effectiveness of all of the technologies included in technology package i-1
Equation 1.5-1 - TEB calculation
The degree to which a technology package's incremental cost is reduced by
technology already present on the baseline vehicle is termed the cost effectiveness basis, or
CEB, in the OMEGA model. The value of each vehicle's CEB for each applicable
technology package is determined as follows:
CEB; = 1 - (TotalCostV;i - TotalCostV;i_i) / (TotalCostp;i - TotalCostp;i_i)
Where
TotalCostv = total cost of all of the technology present on the vehicle after addition
of package i or i-1 to baseline vehicle v
TotalCostp = total cost of all of the technology included in package i or i-1
i = the technology package being evaluated
i-1 = the previous technology package
Equation 1.5-2 - CEB calculation
The values of CEB and TEB are capped at 1.0 or less, since a vehicle cannot have
more than the entire package already present on it. In other words, the addition of a
technology package cannot increase emissions nor reduce costs. (A value of 1.0 causes the
OMEGA model to not change either the cost or CO2 emissions of a vehicle when that
technology package is added.) The value of a specific TEB or CEB can be negative, however.
This implies that the incremental effectiveness or the incremental cost of adding a package
can be greater than that when adding the packages in sequence to a vehicle with no baseline
technology.
An example of this is a baseline vehicle with a 6 speed manual transmission. All of
our technology package effectiveness and cost estimates are estimated for specified baseline
vehicles, all of which have 4 speed automatic transmissions. Our technology packages
improve this transmission, sometimes to a 6 speed automatic transmission and then a dual
clutch transmission and sometimes directly to a dual clutch transmission. Subsequent
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Appendix F
packages may then strongly hybridize the vehicle. If a baseline vehicle has a 6 speed manual
transmission, this transmission is unaffected by the technology packages which include either
a 6 speed automatic transmission or a dual clutch transmission, since the manual transmission
is both cheaper and/or more efficient than these other transmissions. However, when the
vehicle is hybridized, this manual transmission is replaced. The incremental cost of changing
this vehicle to a power-split hybrid design, for example, is greater than that for a vehicle with
a dual clutch transmission, since the credit for removing the manual transmission is less than
that for the dual clutch transmission. The negative CEB causes the OMEGA model to apply a
cost for this power-split package which is slightly higher than that for the typical baseline
vehicle.
The fourth step is to combine the fractions of the cost and effectiveness of each
technology package already present on the individual 2008 vehicles models for each vehicle
type. For cost, percentages of each package already present are combined using a simple
sales-weighting procedure, since the cost of each package is the same for each vehicle in a
vehicle type. For effectiveness, the individual percentages are combined by weighting them
by both sales and base CO2 emission level. This appropriately weights vehicle models with
either higher sales or CC>2 emissions within a vehicle type. Once again, this process prevents
the model from adding technology which is already present on vehicles, and thus ensures that
the model does not double count technology effectiveness and cost associated with complying
with the reference standards or the CO2 control scenarios.
For this analysis, we automated the process through a visual basic macro that both
operates the lumped parameter model and calculates the TEBs and CEBs. This macro-
enabled excel file is available in the docket.
F1.6 Post-processing OMEGA
F 1.6.1 A/C Credits
As noted above, A/C credits were simply subtracted off the OMEGA results for both
the reference and control cases. A/C system costs were added into both cases. As a result, the
delta between reference and control cases, both in terms of costs and environmental impact,
did not change.
Fl.6.2 Calculating Technology Penetrations
Technology penetrations were calculated using the new -techpacksales" output file of the
OMEGA model. This output provides, for each of the approximately 60 vehicle platforms,
the distribution of sales among the tech packs. In a post-processing step, this distribution is
applied back to the 1130 individual vehicles of the disaggregate baseline fleet projection so
that we have the tech pack distribution of each vehicle. As discussed in the description of
TEB/CEB calculations, we have already produced a file which contains the specific
technologies on each vehicles with every possible technology package. By applying the
technology pack distributions from the 60 vehicle platforms back against the 1130 vehicles in
dissagregated fleet, we are able to determine the specific technologies on each vehicle in each
scenario and tech pathway. As an example, this file would show what technologies are
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actually on a Ford F150 with technology package 1, 2, 3 etc. This file is combined with
OMEGA's technology pack distribution output to determine the penetration of each tracked
technology.
Fl.6.3 Impacts Calculations
Liquid fuel consumption, electricity consumption and emission impacts were
calculated in a modified version of the post-processor spreadsheet that was used in the MY
2012-2016 final rule. This spreadsheet, available in the downloadable material accompanying
this technical assessment report, is the repository for the inputs discussed in Appendix E. The
impacts calculations sequentially calculate light duty vehicle stock, VMT, and impacts for
each MY and CY from 2010 through 2050. Outputs are available on either calendar year or
model year basis. For this Technical Assessment Report, the VMT algorithm was integrated
into the benefits calculations, electricity calculations were added, and the inputs and outputs
were restructured. Provided the same inputs, the current benefits spreadsheet would still
provide the same outputs as the version used in the MY 2012-2016 Final Rule.
A detailed discussion of the benefits calculations algorithms is available in the MY
2012-2016 Final Rule RIA chapter 5 and in the OMEGA users guide.
We note that the current analysis did not rely upon many of the outputs of the
OMEGA benefits post-processor. These outputs, such as co-pollutant impacts, monetized
emission impacts, the benefits of additional travel time, and damages due to noise, accidents,
and congestion, may not produce accurate results in the context of the numerous input
changes, and should not be used.
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Appendix F
Appendix F References
1 Appendix A
2 Appendix B
3 http://www.epa.gov/oms/climate/regulations.htm
4 http://www.epa.gov/oms/climate/models.htm
5 EPA. LD GHG MY 2012-2016 Rule, RIA Chapter 2 and 5.
6 Appendix D to this report.
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Gl Appendix G: Infrastructure
Appendix G contains a compilation of additional information to support Chapter 4,
Infrastructure Assessment. Appendix G contains additional information covering the
following topic areas:
• DOE-funded grants for electric drive demonstration and evaluation programs
• Estimates of costs of charging equipment
• Battery end of life value
• Voluntary standards
• Hydrogen Infrastructure
Gl.l American Recovery and Reinvestment Act: Transportation Electrification
Initiative
Through the American Recovery and Reinvestment Act of 2009 (ARRA), DOE has
awarded cost-shared grants to companies under the Transportation Electrification Initiative to
establish development, demonstration, evaluation, and education projects to accelerate the
market introduction and penetration of advanced electric drive vehicles. The component
projects of the Transportation Electrification Initiative and other DOE electric-drive vehicle
infrastructure activities are discussed below.
ECOtality North America
ECOtality North America has been awarded a cost-shared grant of nearly $115 million
to support -The EV Project," to deploy electric-drive vehicles and charging infrastructure in
sixteen major U.S. cities beginning in 2010. Upon full deployment of vehicles and
infrastructure under this project in 2011, approximately 8,500 electric drive vehicles and
14,850 Level 2 charging stations will be in service, providing a rich set of data regarding the
operational and charging behavior of electric drive vehicle owners in a variety of markets.
The ECOtality project will install grid-connected vehicle infrastructure in Phoenix,
AZ; Tucson, AZ; San Diego, CA; Los Angeles, CA; Portland, OR; Eugene, OR; Salem, OR;
Corvallis, OR; Seattle, WA; Dallas, TX; Fort Worth, TX; Houston, TX; Nashville, TN;
Knoxville, TN; Chattanooga, TN; and Washington, DC. Residential Level 2 charging stations
will be provided at no cost to purchasers of the Nissan LEAF EV and the Chevrolet Volt
Extended Range Electric Vehicle (EREV) who subscribe to the program. Additionally, Level
3 DC —efet" chargers will be installed along routes connecting neighboring cities - such as
Nashville/Knoxville/Chattanooga, Phoenix/Tucson, and Seattle/Portland/Eugene -
establishing a network of electric vehicle corridors between electric transportation hubs.
More information about The EV Project is available at http://www.theevproject.com.
Coulomb Technologies
G-l
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Appendix G
Coulomb Technologies has been awarded a cost-shared grant of $15 million to support
its -ChargePoint America" project, to deploy electric-drive vehicles and charging
infrastructure in nine major metropolitan areas beginning in 2010. The project will result in
the deployment of approximately 5,000 Level 2 charging stations at residential and
commercial locations in Bellevue/Redmond, WA; Sacramento, CA; San Jose/San Francisco
Bay, CA; Los Angeles, CA; Austin, TX; Detroit, MI; New York, NY; Washington, DC; and
Orlando, FL. Residential chargers will be provided to purchasers of the Chevrolet Volt
EREV - in some cases, at no cost - and will also be deployed in conjunction with electric
drive vehicles from Ford and Smart USA. More information about ChargePoint America is
available at http://www.chargepointamerica.com.
Navistar
Navistar was awarded a cost-shared grant of over $39 million to develop and
demonstrate a fleet of all-electric medium-duty delivery trucks, which the company has
named the eStar. These vehicles will be manufactured in Wakarusa, IN, and deployed
through various fleet partners nationwide. In total, 950 Class 2c-3 electric trucks will be
deployed in conjunction with 950 Level 2 charging stations, at locations specified by the
respective fleet owners. Data collected from these vehicles and charging stations will provide
valuable information regarding the performance and suitability of medium-duty electric
vehicles and the infrastructure required to support them. More information about eStar trucks
is available at http://www.estar-ev.com.
General Motors
General Motors was awarded a cost-shared grant of over $30 million to develop and
deploy a fleet of Chevrolet Volt EREVs, and to gather data on vehicle performance and
infrastructure requirements. A fleet of 125 Chevy Volts will be deployed in combination with
over 650 Level 2 charging stations, through electric utility partners in several diverse
geographic locations throughout the U.S. The project will include the installation,
demonstration, and testing of charging infrastructure in residential, commercial, and public
locations. Additionally, a comprehensive set of data will be collected from the vehicles and
charging stations from December 2010 through 2012, and will contribute to a more complete
understanding of typical vehicle usage and operational needs, supporting the next generation
of vehicle designs and infrastructure planning. The project will also include an analysis of
fast charging requirements and the development and demonstration of smart charging
capabilities using General Motors' OnStar telematics service.
Smith Electric Vehicles
Smith Electric Vehicles has been awarded a $32 million cost-shared grant to develop
and demonstrate a fleet of all-electric medium-duty trucks. Approximately 500 vehicles will
be built in Kansas City, MO, and deployed with 500 Level 2 charging stations through fleet
partners representing a range of commercial and public-sector markets in diverse geographic
and climatic areas by the end of 2011. In addition, the project will include the collection of
real-world performance data using an automatic GPS-based telemetry system. The Smith
Electric Vehicles project, combined with the Navistar project, will provide valuable insight
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into the applicability of electric-drive powertrains in medium-duty trucks in a variety of
vocations. More information about Smith Electric Vehicles is available at
http://www.smithelectric.com.
South Coast Air Quality Management District
SCAQMD was awarded a cost-shared grant of over $45 million to develop,
demonstrate, and evaluate a fleet of medium-duty plug-in hybrid electric trucks and shuttle
buses. A total of 378 vehicles will be demonstrated nationwide, in combination with 378
Level 2 charging stations. The majority of the vehicles will be bucket trucks based on the
Ford F-550 chassis, deployed through electric utility partners, while the shuttle buses, based
on the Ford E-450, will be deployed via shuttle bus fleet operators. Data collected from the
fleet will be analyzed in order to quantify the attributes of PHEV technologies for Class 4/5
vehicles in terms of emissions, greenhouse gas reductions, and fossil fuel displacement. An
additional goal of the project is to develop production ready smart charging capability for
commercial applications. More information about the current status of this program is
available at http://www.aqmd.gov/hb/2010/july/100710a.htm.
Chrysler Group LLC
Chrysler has been awarded a $48 million cost-shared grant to develop and demonstrate
153 plug-in hybrid electric Dodge Ram pickup trucks combined with Level 2 charging
infrastructure. The trucks and charging stations will be deployed through partner fleets in
diverse geographies and climates, spanning from North Dakota to Arizona, and from Hawaii
to Massachusetts. Full deployment of the vehicles will be achieved in early 2011, followed
by data collection and vehicle monitoring activities through 2013 in order to prove real-world
product viability and to quantify the benefits to consumers and to the nation. As part of this
project Chrysler, with support from its project partners, will develop and demonstrate bi-
directional charging capability.
Education Grants
Through the Transportation Electrification Initiative, ten grants totaling nearly $40
million were awarded to educational institutions to establish programs to train engineers,
technicians, and emergency first responders, as well as to inform the general public, in
preparation for the transition to vehicles with advanced electric drive technologies. At the
university level, graduate and undergraduate engineering degree programs will be created to
educate students in technologies related to electric drive vehicles and charging infrastructure.
Several community colleges received grants to establish technical training courses and
certificate programs to train service personnel and automotive technicians to properly service
and maintain vehicles with electric drive powertrains. Similarly, electric vehicle safety
training programs will be created to train emergency personnel in proper safety protocols
related to electric vehicles and infrastructure, which will differ from current vehicles and
infrastructure with which first responders are already familiar. Furthermore, consumer
outreach and K-12 educational materials will be created to familiarize the general public with
electric-drive vehicle capabilities and infrastructure utilization. All of these activities will
take place through projects supported by Transportation Electrification grants awarded to the
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Appendix G
University of Michigan, J. Sargeant Reynolds Community College, West Virginia
University/National Alternative Fuels Training Consortium, Michigan Technological
University, Missouri University of Science and Technology, Wayne State University,
Colorado State University, Purdue University, City College of San Francisco, and the
National Fire Protection Association.
G1.2 Charger Cost Estimates
The following list of charger cost estimates details the sources and the respective
estimates pulled from each that were used in constructing the charger cost estimate Table 4.2-
2, -Estimated Costs for Charging Stations". Here, the estimates are listed by source along
with assumptions and context that are relevant to the cost estimate.
Level 1
1. Residential (Morrow, Karner and Francfort, 2008)1
a. Charge cord + circuit installation, 20A $878
2. Public networked (May and Mattila, 2009)2
a. 12A stations (Coulomb Technologies) $2500 each + $1000 for —gteway" station
3. Public (May and Mattila, 2009)3
a. 20 amp/4 vehicle (Shorepower Technologies/SynkroMotive) $2500-$2900
4. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)4
a. 5 charge cords $1250
b. 5 20 amp circuits $2221
c. Installed $4165
Level 2, Residential or Fleet Depot
1. Residential, no service panel upgrade (ETEC, 2009)5
a. 40 amp EVSE $780
b. Installed $2272
2. Residential (Morrow, Karner and Francfort, 2008)6
a. EVSE 32 amp $650
b. Charge cord $200
c. 40 amp circuit $1080
d. Installed $2146
3. Residential, no upgrade (May and Mattila, 2009)7
a. 9-25 amp EVSE, output 3.3 kW (Brusa/Metric Mind) $3870 - $6353
4. Residential (Electrification Coalition, 2009)8
a. No upgrade $500-$1500
b. With upgrade, -&p to $2500")
5. Commercial Fleet (10 stations) (ETEC, 2009)9
a. Distribution panel $650
b. EVSE 40 amp $780 * 10
c. EVSE Pedestal $450 * 10
d. Installed $31,375
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e. $3138/station
6. Apartment complex, not networked (5 stations) (Morrow, Karner and Francfort, 2008)10
a. 5 EVSEs $3250
b. 5 charge cords $1000
c. 5 circuits $2611 including labor costs for circuits and EVSEs
d. Installed $7597 for 5 stations
e. $1520/station
Level 2, Public
7. Public (2 chargers) (ETEC, 2009)11
a. Distribution sub-panel $250
b. EVSE40amp $780*2
c. EVSE Pedestal $450 * 2
d. Installed $12,875
e. $6438/station
8. Public networked (May and Mattila, 2009)12
a. 32 amp stations (Coulomb Technologies) $3500 each + $1000 for —geway" station
b. 120 amp stations, charges 4 vehicles (EV-Charge America) $1200-$1500
c. 16.8 kW smart station (GoSmart Technologies) $2200-$3800
d. Above apparently are hardware only
9. Public stations (May and Mattila, 2009)13
a. Pre-assembled unit, $1400-$1800/single 24-30 amp, $2800/60 amp double (eTec)
10. Public (Electrification Coalition, 2009)14: up to $5,000
Level 3, Public Quick Charge
1. Public Level 3 (2 stations) (ETEC, 2009)15
a. Distribution sub-panel $650
b. Fast charger (30 kW) $25,000 * 2
c. Point of sale system $2500
d. Installed $64,158
2. Unspecified (Electrification Coalition, 2009)16 $25,000-$50,000
3. Nissan 50 kW Quick EV Charger, CHAdeMO standard, manufacturer's suggested retail price,
not including installation $17,500 - 20,600A'17
4. Confidential submission, EVSE in high volume, direct manufacturing cost, not including
installation $8,000B
The range in the costs for quick-charge EVSEs reflects a difference between current,
relatively low volume public quick-charge EVSEs and a future EVSE incorporating multiple
A Lower cost is base unit, higher cost reflects options for hot or cold climate operation.
B Confidential information provided to EPA, ARB and NHTSA, August 2010. Manufacturing cost and general
description of architecture cleared for release by the original source on September 10, 2010.
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Appendix G
chargers of the same type used for on-vehicle charging in order to share economies of scale
between EVSEs and components sourced in much higher volume for automobile production.
This would be expected to provide a significant cost reduction for some of the most expensive
components within public quick-charge EVSEs.
G1.3 Battery End-of-Life Value Potential
Chapter 4.2.4 discusses issues surrounding the assessment of a secondary use value for
EV/PHEV batteries. Work is underway to study this issue, including the extent of the market
for secondary use batteries and the potential value to the original vehicle purchaser. This
section summarizes one such study supported by DOE.
Accelerated development and market penetration of PHEVs and EVs is presently
restricted by the high cost of lithium-ion (Li-Ion) batteries. In fact, it has been estimated that a
-50% reduction in battery costs is necessary to equalize the current economics of owning
PHEVs and conventionally fueled vehicles.18
One way to address this problem is to recover a fraction of the battery cost via reuse in
other applications after it is retired from service within the vehicle, where it may still have
sufficient performance to meet the requirements of other energy storage applications. By
extracting additional services and revenue from the battery in a post-vehicle application, the
total lifetime value of the battery is increased.
There are several current and emerging applications where the secondary use of PHEV
and EV batteries may be beneficial. For example, the use of renewable solar and wind
technologies to produce electricity is growing, and their increased market penetration requires
energy storage to mitigate the intermittency of wind and solar energy. New trends in utility
peak load reduction, energy efficiency, and load management also need energy storage. Smart
grid, grid stabilization, low-energy buildings, and utility reliability require energy storage as
well. It is reasonable to suggest that some utility applications are capable of supporting
1 Q 90 91
2010's new battery prices. Assuming that battery prices fall faster than the value of
these utility applications (not improbable, given the anticipated decline in battery prices and
that the increased presence of renewable generation should drive utility application values
higher), the same will be true in the 2017-2025 time frame.
Thus, substantial markets for used automotive batteries may exist, and given that the
allowable battery costs for these applications will exceed new battery prices, battery salvage
values must be determined relative to competing products rather than application values.
Assuming that a primary competitor is new automotive Li-Ion batteries, salvage values can be
computed based upon anticipated future Li-Ion prices. Additionally, the salvage value must be
greater than the -competing" application of leaving the battery in the aging vehicle and
accepting its reduced range capability or selling it to someone with reduced range
requirements. Under these assumptions, it is reasonable to assume that the future salvage
value of a used PHEV/EV battery will be proportional to the cost of an equally capable new
battery, taking into consideration the health of the used battery, the cost of collecting,
refurbishing, and certifying the used battery, and a jised' product discount factor. Given
efforts to ramp up automotive battery production between 2010 and 2015, it is reasonable to
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assume that such batteries will be a relatively mature product and that the majority of the
benefits owed to economies of scale will be achieved by 2017, leading to the following:
Battery life will be improved such that 10 years of in-vehicle life is common and
significant health remains in the battery post automotive retirement
fairly low
Battery price reduction across the battery life will be relatively small
Batteries will be treated as a commodity, thus used product discounts will be
Recognizing the value of secondary use and leveraging advances in battery
health monitoring, automotive batteries will be designed to minimize reconditioning costs
Based on the preceding conditions, one study estimates that net present salvage values
for EV/PHEV batteries sold in the 2017-2025 time frame are approximately 20% of their
initial purchase price.22
G1.4 List of Voluntary Standards
This list of voluntary standards illustrates the complexity and interrelationships due to
the addition of communication to the interface between the vehicle and each major element of
the consumer-vehicle-grid system. These efforts are to enhance long-term success; however,
they are not a prerequisite for a successful near-term market launch. It is worth noting that
the SAE J1772 standard is complete, which is a significant development; many others are still
under development.
SAE - The following existing standards were identified in the Phase 1 NIST
Framework and Roadmap for Smart Grid Interoperability Standards as standards that can be
used now to support Smart Grid development:
• SAE J1772 Electrical Connector between PEVD/EV and EVSE
o SAE J1772™ Electric Vehicle and Plug in Hybrid Electric Vehicle
Conductive Charge Coupler
• SAE J2293 Communications between PEVs and EVSE for DC Energy [Part 1,
Part 2]
o SAE J2293/1 Energy Transfer System for Electric Vehicles:
Functional Requirements and System Architectures
c Available at http://www.nist.gov/public affairs/releases/upload/smartgrid interoperability final.pdf (last
accessed August 26, 2010).
D -PEV" (p_lug-in electric vehicle) is SAE's language of choice for what is called a PHEV elsewhere in this
document.
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Appendix G
o SAE J2293/1 Energy Transfer System for Electric Vehicles:
Communication Requirements and Network Architecture
• SAE J2836/1-3 Use Cases for PEV Interactions (in development) [Part 1, Part 2,
Part3]
o J2836/1 Use Cases for Communication between Plug-in Vehicles
and the Utility Grid
o J2836/2 Use Cases for Communication between Plug-in Vehicles
and the Supply Equipment (EVSE)
o J2836/3 Use Cases for Communication between Plug-in Vehicles
and the Utility Grid for Reverse Power Flow
o J2836/4 Use Cases for Diagnostic Communication for Plug-in
Vehicles
o J2836/5 Use Cases for Communication between Plug-in Vehicles
and their customers.
• SAE J2847/1-3 Communications for PEV Interactions (in development) [Part 1,
Part 2, Part3]
o J2847/1 Communication between Plug-in Vehicles and the Utility
Grid
o J2847/2 Communication between Plug-in Vehicles and the Supply
Equipment (EVSE)
o J2847/3 Communication between Plug-in Vehicles and the Utility
Grid for Reverse Power Flow
o J2847/4 Diagnostic Communication for Plug-in Vehicles
o J2847/5 Communication between Plug-in Vehicles and their
customers
• J2894 Power Quality Requirements for Plug-in Vehicle Chargers - Part 1:
Requirements
• J2894/2 Power Quality Requirements for Plug-in Vehicle Chargers - Part 2: Test
Methods
• J2931/1 Power Line Carrier Communications for Plug-in Electric Vehicles
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IEEE - Standards Coordinating Committee 21 (SCC21) sponsors the development of
1547 interconnection standards and the P2030 smart grid interoperability standards project.
• IEEE 1547 Standard for Interconnecting Distributed Resources with Electric
Power Systems
• IEEE P2030 Guide for Smart Grid Interoperability of Energy Technology and
Information Technology and Information Technology Operation with the Electric
Power System (EPS) and End-Use Applications and Loads
UL - Underwriters Laboratories plays a critical role in the certification of hardware to
be used in charging. UL offers certification for the many aspects of the EVSE, including the
charge equipment (Levels 1-3), plugs, receptacles, cord sets and personal protection
equipment. Of particular interest are specifications with respect to grounding/isolation.
NFPA - NEC, part 625, specifically addresses the installation of charging equipment.
It is updated every 3 years; currently NEC-2008 applies and inputs/petitions for the next
version (NEC-2011) are closed. The draft national template project relies heavily on the NEC
as it is the primary reference for permitting and installation in local municipalities.
International - SAE and JARI agree on Level 2 charging standards (both countries
use single-phase current); though, high-power Level 3 DC coupler standards for public
charging differ substantially from those proposed in the U.S. (and Europe so far). The JARI
Level 3 standards are promoted by CHAdeMO, an association formed in Japan to promote
global adoption of JARI EV infrastructure standards, and are used on the TEPCO charge
equipment that will be deployed by the ARRA-funded vehicle demonstration program (along
with the Nissan Leaf EV); a U.S. Level 3 standard has yet to be developed. Though proposed
charge coupler standards are constantly being refined, the following chart was recently
developed to explain the differences at this time.
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Appendix G
Argonne™
Plugging in Internationally
[Standard/proposed charge couplers]
Residential Charging
Overnight
Public Opportunity Charging
~1 mile/minuteofcharge
Public Fast Charging
~3-10 miles/minuteofchargB
(Re-oonfigured) IEC 62196-2 Type 2
SAEJ1772™ charging configurations and max ratings (ref: Kissel, June 2010]
AC LI: 120V AC lt|>, 12-16A/1.44-1.92kW AC L2: 240V AC lt|>, 80A/19.2kW
ACL2:240VACl((>,80A/19.2kW DC LI: 200-450V DC, 80A/19.2kW
DC L2: 200-450V DC, 200A/90kW
ACL3:240VAC1((>, 400A (TBD I((>or3(t>?)
DC L3: (TBD) 200-600V DC, < 400A/S 240kW
Figure Gl.4-1: International Charge Couple Comparison
G1.5 Hydrogen Infrastructure
Section 4.3 in Chapter 4, Infrastructure Assessment, contains an overview of hydrogen
refueling technology and availability. This section provides additional details about hydrogen
infrastructure including costs, standards, and codes for hydrogen infrastructure installation.
Gl. 5.1 Cost of Hydrogen
This section summarizes slides taken from a presentation by Professor Joan Ogden of
the Institute of Transportation Studies University of California, Davis. 23
The slides indicate projected cost of hydrogen in various U.S. cities from 2014 to
2030, U.S. average delivered hydrogen cost through 2050 and hydrogen transition timing and
costs.
' Level 2 is up to 80 amp, but typically 16-32 amp
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3.2'
Lostogete Da irons
Klatil rlorH3
Figure 1.5-1: Cost of Hydrogen in Selected US Cities (UCD SSCHISM Model)
J. Ogden and C. Yang, "Build-up of a hydrogen infrastructure in the US," Chapter 15,
in The Hydrogen Economy: Opportunities and Challenges, edited by Dr Michael Ball and Dr
Martin Wietschel, Cambridge University Press, 2009, pp.454-482.
In certain regions, such as Los Angeles, hydrogen cost for infrastructure is projected to
decrease rapidly between 2015 and 2018 as FCEVs are rolled out.
($/gallon gasoline equivalent)
2000 2010
2020 2030
Year
2040 2050
Figure 1.5-2: US Average Delivered Hydrogen Cost (NRC 2008), Electricity and
Gasoline Price (EIA 2008)
G-ll
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Appendix G
National Research Council, National Academies of Engineering, Transitions to
Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version
available from National Academies website
http://www.nap. edu/catalog.php?record_id= 12222
Studies by UC Davis indicate that hydrogen costs can be competitive with gasoline in
2020. Note that 1 kg of hydrogen has approximately the same energy content (lower heating
value) as 1 gallon of gasoline (1kg hydrogen = 1 gallon gasoline equivalent (gge)
H2 Transition Timing and Costs (NRG 2008)
Breakeven Year
(Annual Cash flow = 0)
Cumulative cash flow difference
(H2 FCV -Gasoline refCar) to
breakeven year
Cumulative vehicle first cost
difference (H2 FCVs-Gasoline
Car) to breakeven year
# H2 FCVs cars at breakeven
year (millions)
H2 cost at breakeven year
H2 demand # H2 stations at
breakeven year
Total cost to build infrastructure
for demand at breakeven year
S22 Billion
5.6
(1.9% of fleet)
S3.3/kg
4200 t/d
3600 stations
£8 Billion
National Research Council, National Academies of Engineering, Transitions to
Alternative Transportation Technologies: A Focus on Hydrogen, Pre-publication version
available from National Academies website
http://www.nap.edu/catalog.php?record_id= 12222
In 2008, the NRC's Committee on Assessment of Resource Needs for Fuel Cell and
Hydrogen Technologies released the report, -Transitions to Alternative Transportation
Technologies—A Focus on Hydrogen," which was required by the Energy Policy Act (2005)
section 1825. One of the committee's conclusions was that to accelerate the penetration of
FCEVs, strong government policies will be required. The NRC estimated that the
government cost to support a transition to FCEVs for the period from 2008 to 2023 would
be approximately $55 billion (this amounts to slightly more than $3.5 billion/year or about
$10,000 per FCEV—the committee compared this value to ethanol subsidies, which were
$2.6 billion in 2006 and are expected to grow to $15 billion/year by 2015). The table shows
details on government costs required for infrastructure.
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Gl.5.2 Codes and Standards to Support Hydrogen and Fuel Cell Infrastructure
The United States and most countries in the world have established laws and
regulations that require commercial products to meet all applicable codes and standards to
demonstrate that they are safe, perform as designed and are compatible in the systems in
which they are used. Hydrogen has an established history of industrial use as a chemical
feedstock, but not as an energy carrier on a large-scale commercial basis. The development
and promulgation of codes and standards are essential to establish a market-receptive
environment for commercial, hydrogen-based products and systems for energy use.
The key U.S. and international standards development organizations (SDOs)
developing and publishing the majority of hydrogen codes and standards are shown in the
table below. These organizations typically work with the public and private sectors to
develop codes and standards.
The U.S. Department of Energy (DOE) conducts underlying safety R&D and works
with domestic and international SDOs to facilitate the development of applicable codes and
standards. These standards are then referenced by building and other codes to expedite
regulatory approval of hydrogen technologies. This approach ensures that U.S. consumers can
purchase products that are safe and reliable, regardless of their country of origin, and that U.S.
companies can compete internationally.24
Organizations Involved in Codes and Standards Development and Publication
Organization
Responsibility
Domestic Codes and Standards
American Society for Testing and Materials
(ASTM)
American National Standards Institute (ANSI)
American Petroleum Institute (API)
American Society of Heating, Refrigeration
and Air Conditioning Engineers (ASHRAE)
American Society of Mechanical Engineers
(ASME)
Compressed Gas Association (CGA)
CSA America (CSA)
Materials testing standards and protocols
Certifies consensus methodology of and serves as
clearinghouse for codes and standards development
Equipment standards
Equipment design and performance standards
Equipment design and performance standards
Equipment design and performance standards
Equipment standards
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Appendix G
U.S. Department of Transportation
International Association of Plumbing and
Mechanical Officials (IAPMO)
Institute of Electrical and Electronic Engineers
(IEEE)
National Fire Protection Association (NFPA)
Natural Gas Institute (NGI)
Society of Automotive Engineers (S AE)
Underwriters Laboratories (UL)
International Electrotechnical Commission (IEC)
International Organization for Standardization
(ISO)
Vehicle standards and regulations
Mechanical building code
Electrical standards
Model building codes, standards
Natural gas vehicle standards
Vehicle system and subsystem design and
performance standards
Equipment and performance testing standards
International Performance Standards
International Performance Standards
In February 2010, the National Renewable Energy Laboratory (NREL) published the
Vehicle Codes and Standards: Overview and Gap Analysis. The gap analysis includes a list
of applicable codes and standards for alternative fuels including hydrogen infrastructure. The
list of applicable codes and standards is below:
25
ANNUAL INSPECTIONS
CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas
Association 2005)
CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004)
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
BALANCE OF PLANT
Piping & Tubing
ASME B31.12, Hydrogen Piping and Pipelines
CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas
Association 2005)
IFC (International Code Council 2006)
International Fuel Gas Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006)
Pressure Relief
CGA S-1.3, PRD Standards Part 3 - Stationary Storage Containers for Compressed Gases
(Compressed Gas Association 2005)
IFC (International Code Council 2006)
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International Fuel Gas Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Valving and Fittings
ASME B31.3, Process Piping (American Society of Mechanical Engineers 2006)
CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas
Association 2005)
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Venting and Other Equipment
CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004)
IFC (International Code Council 2006)
International Fuel Gas Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
CANOPY TOPS
International Building Code (International Code Council 2009)
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
COMPRESSED HYDROGEN GAS STORAGE
Equipment Location
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
General Safety Requirements
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Storage Containers
CGA PS-20, Direct Burial of Gaseous Hydrogen Storage Tanks (Compressed Gas Association
2006)
CGA PS-21, Adjacent Storage of Compressed Hydrogen and Other Flammable Gases
(Compressed Gas Association 2005)
IFC (International Code Council 2006)
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Appendix G
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
COMPRESSION SYSTEMS AND EQUIPMENT
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
DESIGN
Barrier Walls
IFC (International Code Council 2006)
Equipment
International Fire Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Fuel Stations
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
Equipment
International Fire Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Fuel Stations
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Weather Protection
IFC (International Code Council 2006)
DISPENSING
Electrical Equipment
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection
Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Fuel Lines
CGA G-5.4, Standard for Hydrogen Piping Systems at Consumer Locations (Compressed Gas
Association 2005)
IFC (International Code Council 2006)
International Fuel Gas Code (International Code Council 2006)
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NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Gaseous Dispensers
IFC (International Code Council 2006)
Facilities
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Hoses and Connectors
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Liquid Dispensers
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Vehicle Connectors
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
SAE J2600, Compressed Hydrogen Surface Vehicle Refueling Connection Devices (Society of
Automotive Engineers 2002)
DISPENSING, OPERATIONS, AND MAINTENANCE SAFETY
Gaseous Hydrogen
CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004)
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Liquid Hydrogen
CGA G-5.5, Hydrogen Vent Systems (Compressed Gas Association 2004)
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
FIRE SAFETY
Construction
IFC (International Code Council 2006)
International Fuel Gas Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Equipment
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
G-17
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Appendix G
Signage
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
LIQUID HYDROGEN STORAGE
Equipment Location
IFC (International Code Council 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
General Safety Requirements
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Storage Containers
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
CGA H-3 Cryogenic Hydrogen Storage (Compressed Gas Association 2006)
ON-SITE HYDROGEN PRODUCTION
IFC (International Code Council 2006)
International Fuel Gas Code (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
OPERATION APPROVALS
Dispensing
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
Fire And Emergency Planning
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
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Fuel Delivery
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Ignition Control
IFC (International Code Council 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Personnel Issues and Training
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Signage
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Vehicle Access
IFC (International Code Council 2006)
NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages (National Fire
Protection Association 2003)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
SETBACKS AND FOOTPRINTS
Liquid Systems
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic
Fluids in Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection
Association 2005)
Outdoor Gaseous Systems
IFC (International Code Council 2006)
G-19
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Appendix G
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
TRANSPORTATION
Compressed Hydrogen Gas
CGA P-l, Safe Handling of Compressed Gases in Containers (Compressed Gas Association 2006)
IFC (International Code Council 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Liquid Hydrogen
CGA P-12, Safe Handling of Cryogenic Liquids (Compressed Gas Association 2005)
IFC (International Code Council 2006)
NFPA 52, Vehicular Fuel Systems Code (National Fire Protection Association 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
Natural Gas
ASME B31.8, Gas Transmission and Distribution Systems (American Society of Mechanical
Engineers 2003)
VAPORIZERS
IFC (International Code Council 2006)
IFC (International Code Council 2006)
NFPA 55, Standard for Storage, Use and Handling of Compressed Gases and Cryogenic Fluids in
Portable and Stationary Containers, Cylinders and Tanks (National Fire Protection Association
2005)
The table below provides a summary of the identified Code and Standards Gaps for the
expanded use of hydrogen as an alternative fuel. Also, the table presents the impacted document
and proposed means to address the gap. It also illustrates the various areas of hydrogen codes and
standards that require additional work in order to create a complete and standardized control
strategy.
One key area that may require additional work is operations and maintenance
requirements for fuel dispensing systems. This area is of particular concern because relatively
little data for the use of vehicular hydrogen dispensing systems exists. As data is accrued, it may
become apparent that additional safety measures are needed to address operations and
maintenance. A second area of concern is potential releases of hydrogen in confined spaces such
as indoor fueling operations, tunnels, and parking garages. The release characteristics and
prevention and mitigation measures vary for these different locations, but many of the same
analytical tools can be used to characterize the hazards of these releases. A third area of concern is
the potential energy contained in high-pressure storage and dispensing systems. The following
table lists several other important gaps that require further work.
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Codes and Standards Gaps for Hydrogen
25
Codes or Standard Gap
Documents Impacted
Gap Resolution
No final fuel quality
standard
ISO Fuel Quality Draft
International Standard,
ASTM analysis standards,
SAE Technical Information
Report (TTR)J2719
Provide data to ensure that
draft standards become final
standards
Potentially incomplete
requirements for indoor
hydrogen vehicle dispensing
NFPA 52, IFC
Evaluate indoor release
characteristics and accident
scenarios for potential
application to code
development
Off road vehicle storage
tank standards are
incomplete
CSA America Heavy Goods
Vehicle (HGV) 4.3, SAE
J2601
Support standards
development work with
direct committee
involvement and data
support
Bulk liquefied hydrogen
storage requirements lack
technical basis
documentation
NFPA 55, NFPA 2, IFC
Evaluate liquid release
impacts and frequencies and
provide this information to
relevant technical
committees to validate or
revise bulk liquefied
hydrogen storage
requirements
Requirements for tunnels,
parking garages, and repair
garages need review to
determine whether
additional requirements for
hydrogen are needed
[meeting with New York
Port Authority January
2009]
NFPA 505, IFC, NFPA 88B,
NFPA 30A, IBC,
International Mechanical
Code (IMC)
Evaluate safety concerns in
these environments and
work with the technical
committees to provide data
required to address codes
and standards requirements
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Appendix G
Operations and maintenance
procedures lack supporting
operational history data
[conversation with Larry
Fluer]
NFPA 52, NFPA 30A, IFC
Evaluate existing procedures
to determine where they
might be incomplete.
Evaluate operations and
maintenance history for
similar fuels to determine
whether useful information
can be retrieved and applied
to hydrogen
Steam Methane Reformation
(SMR) plants do not have a
safety standard
[conversation with Roger
Smith]
No current code specifically
addresses SMR plants
Develop a code or standard
that addresses SMR plants
New storage systems, such
as metal hydrides, are
minimally addressed in
codes and standards
NFPA 55, CGA H-l and H-
2, IFC
Determine whether new
chemical storage systems are
adequately addressed in
codes and standards
Limited familiarity with
relevant hydrogen codes and
standards among project
developers and code
officials [conversation with
Larry Fluer]
All hydrogen codes and
standards
Regional codes and
standards workshops as well
as web training and
background information can
help address this issue
Incomplete requirements for
sensing technologies [Rivkin
analysis of NFPA 52]
NFPA 52, NFPA 55
Support the use of sensing
technologies that replace
odorants through evaluating
sensing technologies and
supporting code and
standards development work
in sensing technologies
High-pressure storage,
handling, and use of
hydrogen [David Farese
DOE Safety Panel meeting]
NFPA 52, NFPA 55, CGA
H series of documents
Evaluate codes and
standards that address high-
pressure storage to
determine if requirements
are adequate and if
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2017-2025 Technical Assessment
additional work is required
Global Technical
Regulations (GTR)
Coordination with SAE and
DOT regulations
Continue to represent the
United States in GTR
development meetings and
evaluate impacts of GTR in
domestic regulations, codes,
and standards
Coordination of
international (primarily ISO)
standards and domestic
codes and standards
Multiple documents: SAE,
CSA, UL, NFPA
Evaluate component
standards to ensure that
there are not unnecessary
conflicts
The DOT guidance
documents for incidents
involving flammable gases
are too general and
prescriptive
DOT Emergency Response
Guide
Add additional material to
the DOT guide for hydrogen
incidents
G-23
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Appendix G
Appendix G References
1 Morrow, Karner, Francfort (2008). -Plug-in Hybrid Electric Vehicle Charging Infrastructure Review", Battelle
Energy Alliance, U.S. Department of Energy Idaho National Laboratory. Nov 2008.
2 May, James W. and Matt Mattila (2009). -Plugging In: A Stakeholder Investment Guide for Public Electric-
Vehicle Charging Infrastructure." Rocky Mountain Institute. July 2009.
3 May and Mattila, 2009.
4 Morrow, Karner, Francfort, 2008.
5 Electric Transportation Engineering Corporation (ETEC), 2009. Electric Vehicle Charging Infrastructure
Deployment Guidelines British Columbia, July.
Also, Electric Transportation Engineering Corporation (2010), Electric Vehicle Charging Infrastructure
Deployment Guidelines for the Central Puget Sound Area, May.
6 Morrow, Karner, Francfort, 2008.
7 May and Mattila, 2009..
8 Electrification Coalition (2009). -Electrification Roadmap", Electrification Coalition. Nov 2009.
9 ETEC, 2009.
10 Morrow, Karner, Francfort, 2008.
11 ETEC, 2009.
12 May and Mattila, 2009.
13 May and Mattila, 2009.
14 Electrification Coalition, 2009.
15 ETEC, 2009.
16 Electrification Coalition, 2009.
17 Press release from Nissan, May 2010, accessed on the Internet at: http://www.nissan-
global.com/EN/NEWS/2010/_STORY/100521-01-e.html.
18 Brooker, et al (2010), -Technology Improvement Pathways to Cost-Effective Vehicle Electrification," to be
presented at the SAE 2010 World Congress, Detroit, MI, April 2010.
19 Energy Storage for the Electricity Grid: Benefits and Market Potential Assessment Guide, Sandia National
Laboratories, Albuquerque, NM: 2010.
20 Kamath (2010), -Lithium Ion Batteries in Utility Applications", Proceedings of the 27th International Battery
Seminar and Exhibit, Ft. Lauderdale, FL, March 2010.
21 Market Feasibility for Nickel Metal Hydride and Other Advanced Electric Vehicle Batteries in Selected
Stationary Applications, EPRI, Palo Alto, CA, and SMUD, Sacramento, CA: 2000.
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2017-2025 Technical Assessment
22 Neubauer, Jeremy and Ahmad Pesaran (2010), Preliminary EV/PHEV Battery Secondary Use Analysis in
Support of EPA 2017-2025 Technical Assessment.
23 Slides from a Presentation by Prof Joan Ogden. -What is needed to initiate new fuel/vehicle pathways?
Comparing Transition Costs for H2 FCVs, PHEVs and Biofuels." Prof. Joan Ogden, Institute of Transportation
Studies, University of California, Davis, June 14, 2010.
24 MYPP (Multi-Year Research, Development, and Demonstration Plan) 2007. Hydrogen Codes and Standards.
Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.
http://wwwl.eere.energv.gov/hvdrogenandfuelcells/mvpp/pdfs/codes.pdf
25 NREL (National Renewable Energy Laboratory) 2010. Vehicle Codes and Standards: Overview and Gap
Analysis. Washington, D.C.: U.S. Department of Energy, Energy Efficiency and Renewable Energy.
www.nrel.gov/docs/fylOosti/47336.pdf
G-25
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