Updates to the Greenhouse Gas and Energy Consumption Rates in MOVESZOlOa &EPA United States Environmental Protection Agency ------- Updates to the Greenhouse Gas and Energy Consumption Rates in MOVES2010a Assessment and Standards Division Office of Transportation and Air Quality U.S. Environmental Protection Agency NOTICE This technical report does not necessarily represent final EPA decisions or positions. It is intended to present technical analysis of issues using data that are currently available. The purpose in the release of such reports is to facilitate the exchange of technical information and to inform the public of technical developments. &EPA United States Environmental Protection Agency EPA-420-R-12-025 August 2012 ------- Contents 1 Updates to Energy Rates and Sourcebin Distribution for MOVES201 Oa 2 1.1 Introduction 2 1.2 Background: Energy Rates in the MOVES model 3 1.3 Structural Changes: 6 1.3.1 Updating the Database Sourcebinid Structure for Energy Rates 6 1.3.2 Converting MOVES2010 rates to the MOVES2010a structure 6 1.3.3 Changes to Engine Technologies 8 1.4 Updating Energy Rates 8 1.5 Inventory Impacts of Changes relative toMOVES2010 13 2 Methane and N2O in MOVES2010 16 Differences Between MOVES and "Sources and Sinks" 16 2.1 Nitrous Oxide Emission Rates: 18 2.2 Methane Emission Rates: 22 2.3 Alternative Fuels 26 3 Updates to the Methane Rates for MOVES 20 lOa 28 ------- 1 Updates to Energy Rates and Sourcebin Distribution for MOVES2010a 1.1 Introduction MOVES is the U.S. Environmental Protection Agency's (EPA) Motor Vehicle Emission Simulator. It helps to answer "what if questions, such as "How would particulate matter emissions decrease in my state on a typical weekday if truck travel was reduced during rush hour?" or "How does the total hydrocarbon emission rate change if my fleet switches to gasoline from diesel fuel?" The purpose of the tool is to provide an accurate estimate of emissions from mobile sources under a wide range of user-defined conditions. It is a state-of-the-art upgrade to EPA's modeling tools for estimating emissions from highway vehicles, based on analysis of millions of actual emission test results and considerable advances in the Agency's understanding of vehicle emissions. MOVES2010 was released in December of 2009. MOVES2010a was released in the summer of 2010 and updated MOVES2010. MOVES2010a incorporates new car and light truck greenhouse gas emissions standards affecting model years 2012 and later (published May 7, 2010) and updates to the Corporate Average Fuel Economy (CAFE) standards affecting model years 2008 through 2011.1 MOVES2010a includes reductions in greenhouse gas emission rates associated with those standards in future calendar years, and small reductions in refueling and sulfur-related emissions associated with the reductions in vehicle fuel consumption. This document details some of the updates for the MOVES2010a release. Specifically, the updates described in this document include: • Updates to the MOVES database to reflect new data and projections for 2008 and newer light duty energy rates o Model year 2008-2010 vehicle data o Model year 2011 Fuel Economy (FE) final rule projections o Model year 2012-2016 FE/GHG final rule projections o Corrections to model year 2000+ light duty diesel energy start rates • Modifications to the organization of energy rates in MOVES database (DB) o Improved consistency between energy rates and remainder of MOVES o Redefined energy rate structure o Removed unused engine technologies from the MOVES DB o Removed unused emission rates from MOVES DB This report also documents the methane and nitrous oxide rates, and includes discussion of the changes made in MOVES2010a in the way that methane emissions are determined for all vehicle types and model years. This report assumes that the user is familiar with the MOVES model and its database design. A detailed knowledge of the emission rate structure may prove helpful to the reader. 1 MOVES2010a, which only contains regulations that were final as of its release, does not reflect the impacts of Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles (finalized in 2011) or the Proposed Rulemaking to Establish 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and CAFE Standards (published in 2011). ------- Additional detail on MOVES is available on the MOVES technical background website (http://www.epa.gov/otaq/models/moves/movesback.htm). 1.2 Background: Energy Rates in the MOVES model The energy rates in MOVES2010 were originally developed for MOVES2004, and are documented in "MOVES2004 Energy and Emission Inputs Draft Report" (EPA420-P-05-003). As documented in that report, EPA created the MOVES 2004 energy rates by analyzing second by second (1 Hz) resolution data from 16 EPA test programs covering approximately 500 vehicles and 26 non-EPA test programs covering approximately 10,760 vehicles. "Holes" in the data were filled using either the Physical Emission Rate Estimator (PERE) 2 or interpolation. A partial timeline of the energy rates in MOVES is presented below. • MOVES2004 o Released with a full suite of energy rates to allow estimation of fuel consumption and GHG emissions. o Energy rates developed for fine detail of vehicle attribute and advanced technology, anticipating need for policy modeling (ex. "How does reducing vehicle weight affect energy consumption?") o Documentation: MOVES2004 Energy and Emission Rate Inputs (Report: EPA420-P-05-003, February 2005) • MOVES2010 o Relatively minor updates from MOVES2004 o Heavy Duty energy rates updated based on new scaled tractive power (STP) methodology o LD rates updated to include 2008-2011 model year 2011 Corporate Average Fuel Economy (CAFE) Standards for light trucks • MOVES2010a o Light Duty energy rates updated substantively to account for CAFE model year 2011, LD GHG model year 2012-2016 standards o All energy rates updated structurally to greatly simplify MOVES' energy approach with focus on inventory development, rather than policy modeling As seen above, between MOVES 2004 and MOVES2010a, MOVES shifted being from a technology modeling tool to primarily serving as an inventory model. This shift was partially driven by the emergence of the EPA OMEGA (Optimization Model for reducing Emissions of Greenhouse gases from Automobiles) model.3 OMEGA, which EPA used in recent mobile source greenhouse gas (GHG) rulemakings, 4 estimates the technology cost and emission impacts of vehicle GHG standards. Many light duty energy policy questions no longer are estimated by 2 Report: Fuel Consumption Modeling of Conventional and Advanced Technology Vehicles in the Physical Emission Rate Estimator (PERE) EPA420-P-05-001, February 2005 3 OMEGA web address: http://www.epa.gov/otaq/climate/models.htm OMEGA Version 1.3 documentation: EPA-420-B-10-042 4 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards; Final Rule: EPA-HQ-OAR-2009-0472-11424 ------- EPA with the MOVES model, but rather with the more narrowly focused OMEGA model. At the same time, the MOVES model has become the official EPA model for estimating mobile source emissions in State Implementation Plans and conformity modeling.5 Due to this change in scope, EPA reevaluated the structure of the energy rates for MOVES2010a. In MOVES, emission rates6 are defined by vehicle emission category (sourcebin) discriminators which describe combinations of vehicle attributes. MOVES allows different emission rates to be defined by different sourcebin discriminators; a given combination of pollutant and process can require any combination of the discriminators listed in Table 1-1. Table 1-1 - Sourcebin Discriminators Sourcebin Discriminators Fuel type Engine Technology Regulatory Class Model Year Group Engine Size Weight Class Ultimately, these discriminators are strung together in a rigidly defined format and are used as unique database keys in the "emissionrate" or "emissionratebyage" tables in MOVES. Not all source type/pollutant/process combinations require data for all sourcebinid components, and unused components of the sourcebinid can be left as zeros.7 Previous versions of MOVES, including MOVES2010, require that energy rates discriminate by all sourcebinid components other than regulatory class (Table 1-2). 5 Policy Guidance on the Use of MOVES2010 and Subsequent Minor Revisions for State Implementation Plan Development, Transportation Conformity, and Other Purposes, April 2012, http://www.epa.gov/otaq/models/moves/documents/420b 12010.pdf 6 The MOVES design treats energy consumption as an emission rate. Therefore, in this document, the term emissions is interchangeably used to refer to energy. 7 The table "sourcetypepolprocess" in the MOVES DB controls which components of the sourcebinid are required for each sourcetype, pollutant, and process combination. ------- Table 1-2 - MOVES 2004 Energy Sourcebin Discriminators Fuel Type Diesel CXG LPG EthanoI(ES5l MeihanoI(ES5) OK H, Liquid H, Electric Engine Techuologv Model Year Group Loaded Weight Eugiiie Size This contrasts to the emission rates used for criteria pollutants, which use a broader set of criteria (Table 1-3). Table 1-3 - Contrasting Criteria Pollutants and Energy in MOVES2010 Criteria Pollutants Fuel type Engine Technology Regulatory Class Model Year Group Engine Size Weight Class Age Group Energy Fuel type Engine Technology Regulatory Class Model Year Group Engine Size Weight Class Age Group Note: discriminators in bold, italic are used to classify that set of emissions in MOVES. In MOVES2010, heavy duty vehicle running energy consumption was restructured without engine size and weight class sourcebin discriminators.8 MOVES2010a extends this format to all combinations of sourcetypes and energy-related processes (start, running, extended idle). Removing two sourcebin discriminators significantly reduces the size of the database table, and pre-aggregating by engine size and vehicle weight shifts the size/weight calculations from MOVES onto external sources. A summary table of the changes to the energy sourcebin structure is presented below (Table 1-4). Table 1-4 - Changes to Energy Sourcebin Discriminators between MOVES2010 and 2010 Descriptors used in MOVES2010 Fuel type Model year group (decadal) Engine size Vehicle Weight Size and weight distribution by sourcetype Engine Technology Descriptors used in Moves2010a Fuel type Model year group (single year) Regulatory class Report: Development of Emission Rates for Heavy-Duty Vehicles in the Motor Vehicle Emissions Simulator MOVES2010 (EPA-420-B-12-049) ------- 1.3 Structural Changes: 1.3.1 Updating the Database Sourcebinid Structure for Energy Rates Seven database tables were changed to alter the sourcebin discriminators used for energy rates (Table 1-5). These changes aggregated the database so that size and weight were no longer distinguishing characteristics. The database was then re-disaggregated according to regulatory class. As part of this process, the number of engine technologies in the MOVES database was reduced. This change altered four additional database tables (Table 1-5). The MOVES2010 engine technologies included hybrid varieties, fuel cell vehicles, and "advanced internal combustion" vehicles. These technologies were removed from the model, and the associated emission rates were removed from the emissionratebyage table. Table 1-5 - Summary of Database Changes required 1 2 3 4 5 6 7 8 9 10 11 Table Name datasource emissionrate emissionratebyage fuelengfraction enginetech fuelengtechassoc pollutantprocessmodelyear regclassfraction sampl evehi cl epopul ati on sizeweightfraction sourcetypepolprocess Change Summary Added a new datasourceid that refers to this document. Updated energy rates with new values and sourcebinids Removed emission rates for enginetypeids other than conventional internal combustion (1) & electric (30) Updated fuel and engine type combinations to remove enginetypes other than 1 & 30 Removed engine technologies other than 1 & 30 Removed engine technologies other than 1 & 30 Changed the energy polprocessids (9101,9102, 9190) to have single year modelyeargroupids (increase resolution of rates). Removed engine technologies other than 1 & 30. Reflects removal of sizeweightid and engine technologies (engtechid) Truncated Stopped requiring sizeweightid, and began requiring regclassid for energy polprocessids (9101, 9102, 9190) for all sourcetypes. 1.3.2 Converting MOVES2010 rates to the MOVES2010a structure EPA created energy rates for the new sourcebin structure by aggregating the MOVES 2010 energy rates by regulatory class. For those regulatory classes that were mapped to a single source type, the conversion between the MOVES2010 structure and the MOVES2010a structure was a 1:1 correspondence. For those sourcetypeids that mapped to several regulatory classes (Table 1-6), the methodology is described below. ------- able 1-6 - Mapping between Sourceusetypes and Regulatory Classe SourcetypelD 11 21 31,32 41,43,51,52,53,54,61,62 42 Possible Regulatory Classes 10 20 30,41,42 46,47 46,48 Information from the 1997 and 2002 Vehicle Inventory and Use Survey (VIUS) as aggregated in the MOVES2010 database table samplevehiclepopulation (SVP) was used as a mapping tool between regulatory class and source type. The SVP table specifies the distribution of each source type and model year combination across fuel type, engine technology, SCCVtypelD,9 engine size, vehicle weight, and regulatory class, with each row specifying a unique set of attributes. The SVP table was joined to the emissionrate table so that an additional column was added to the SVP with the corresponding MOVES2010 energy emission rate. This process was repeated for start rates, running rates, and extended idle rates. This produced a set of SVP tables, each with an additional emission rate column for the relevant process. In order to create emission rates by regulatory class, we weighted each emission rate attached to the SVP table using year 0 populations from the sourcetypeagepopulation table of the MOVES execution database. The sales for each source type model year combination were distributed to the appropriate row of the SVP using the SVP stmyfraction column. Using the sales-based weighting, the emission rates were aggregated by regulatory class, fuel type, and model year. For start rates, this process was executed for operating mode 108, which is a cold start. The other seven start operating modes are modifications of a cold start with different soak times. As in previous version of MOVES, soak time effects derived from a California Air Resources Board report on uncatalyzed hydrocarbon emissions10 were applied to develop the other seven operating modes (101,102, 103,104,105,106,107). For running rates, the process outlined above was necessary only for motorcycles, passenger cars, passenger trucks, and light commercial trucks. The running rates for other sourcetypes already had been set to be a single set of rates in MOVES2010.11 This process was repeated for each operating mode. In MOVES, only sourcetypeid 62 (long-haul combination truck) has extended idle operation. Therefore, both regulatory class 46 (Medium Heavy Duty (19.5K Ibs < GVWR < 33K Ibs)) and regulatory class 47 (Heavy Heavy Duty (GVWR > 33K Ibs)) were set to have the same extended idle rate as MOVES2010 sourcetypeid 62 vehicles. 9 An SCCvtype, or source classification code vehicle type, is an alternative vehicle identification scheme which is used in the MOVES model. 10 Methodology For Calculating And Redefining Cold And Hot Start Emissions, S. Sabate, March 1996 11 These changes to the heavy duty energy rates are described in the heavy duty vehicles emission rate report. All heavy duty vehicles uses the same energy rates, but are differentiated by drive cycle and weight. Therefore, the vehicle specific power (VSP) distribution of these vehicles differs. ------- 1.3.3 Changes to Engine Technologies Engine technologies other than conventional internal combustion are not used substantially in the MOVES2010 default database. While these engine technologies each have different energy rates (Table 1-7), emission rates for pollutants other than energy are either set equivalent to the rate for conventional internal combustion vehicles or to zero.12'13 Therefore, "conventional internal combustion" in the MOVES2010 database is effectively a description of all engine types other than electric for non-energy emissions. In recognition of this convention, we removed all engine technologies other than conventional and electric from the MOVES2010a database. Table 1-7 - Engine Technologies in MOVES2010 engTechID 1 2 11 12 20 21 22 30 40 50 Engine Technology Name Conventional Internal Combustion Advanced Internal Combustion Moderate Hybrid - Conventional Internal Combustion Full Hybrid - Conventional Internal Combustion Hybrid - Advanced Internal Combustion Moderate Hybrid - Advanced Internal Combustion Full Hybrid - Advanced Internal Combustion Electric Fuel Cell Hybrid - Fuel Cell InMOVES2010a YES YES As reflected in Table 1-7, the database tables were altered to reflect these changes. Additionally, the emission rates supporting these engine technologies (2.8 million rows) were removed from the 4 million row MOVES2010 emissionratebyage table. Approximately 8,600 rows were removed from the emissionrate table. 1.4 Updating Energy Rates After modifying the database structure and populating it with transformed energy rates, several additional changes were made. The 2008 and newer model year light duty vehicles (regulatory classes 20 and 30) were updated based on new data (model year 2008-2009) and rulemaking projections (model year 2010+). We also updated the energy emission rates to reflect the 2011 CAPE rulemaking and the 2012-2016 Light Duty Greenhouse Gas (LD GHG) and CAFE rulemakings. A number of other minor changes were also made.14'15 12 As an example, advanced internal combustion engines have criteria emission rates equivalent to conventional internal combustion engines, but electric engines have criteria emission rates equaling zero. 13 In Draft MOVES2009 and MOVES2010, sourcerypeid 31 and 32 have non-zero penetrations of engtechid 2 in model years 2008 and newer. In earlier model versions, engine tech 2 was used as a means of reaching the fuel economy targets set in the 2008-2011 CAFE light truck rule. The changes described in this document negate the need for the penetration of advanced engine technology. 14 An error was corrected in light duty diesel energy starts. To fix the problem, start-emission rates for model year 2000 and newer light and medium duty diesel vehicles (reg class 20, 30, 41, &42) were set to the MY 1999 rate. This is an approximately 55% reduction from the corresponding rates in the MOVES2010 database. While a large ------- The new energy consumption rates were based on a top-down analysis whereby CO2 emission rates output from MOVES were calibrated to projected CC>2 emission rates. CC>2 emissions were used due to their direct proportionality to energy consumption rates. We assume that the rulemakings affected the quantity of energy consumed, but not the distribution between operating modes, nor the ratio between start and running.16 As a result, we adjusted the energy rates using simple ratios between the old emission rates and the new emission rates (Table 1-8). Baseline values were derived by running MOVES2010 at the national/annual level using an input database that produced emission output only for regulatory classes 20 and 30. Emission quantity was divided by vehicle miles traveled to determine emission rates. Model year 2008 and model year 2009 data were drawn from EPA's "Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends: 1975 through 2009" (EPA420-R-09-014). The "Lab" average CO2 values for each model year were adjusted upward by 25% to reflect real world fuel consumption.17 The gasoline vehicles were set to this value. As the CAFE rules regulate fuel consumption in miles per gallon and treat gasoline and diesel vehicles equally, diesel energy consumption rates were multiplied by approximately 1.15 in order to compensate for the greater energy density of diesel fuel.18 For model year 2011 through 2016, rates were derived from the model year 2012-2016 Light Duty Greenhouse Gas (LD GHG) rulemaking analysis. The projections used in MOVES2010a are based upon the same assumptions as used the emission modeling conducted for the LD GHG rule. Model year 2010 was interpolated as a midpoint between model year 2009 and 2011. Note that the regulatory standards for model year 2011 and newer are in a classification schema that differs from that used in MOVES2010a.19 Using vehicle level data from the rulemaking, we reanalyzed the vehicles to match the MOVES2010a vehicle classification scheme. As a result of this difference in classification scheme, the average CC>2 emission rate shown in this document is not expected to match those in the regulatory documents. fraction of this particular process, light duty diesel energy consumption is approximately 3% of total light and medium duty energy consumption, and start emissions are approximately 3% of light and medium duty diesel energy consumption. The impact of this change on total light and medium duty energy consumption is approximately 0.05%. 15 The 2008-2011 CAFE light truck rule was reflected inMOVES2010 through the use of advanced internal combustion vehicles. For MOVES20 lOa, we removed this engine technology and directly modified the energy rates for regclassid 30 to reflect the CAFE rules. 16 Maintaining the same ratio between running and start energy consumption rates likely overstates the reductions to the start process, and may be revisited in future MOVES model versions. While some technologies that reduce energy consumption (ie, engine downsizing) reduce start energy consumption, many others (such as aerodynamic improvements) do not. As starts are a very small portion of total energy consumption, the choice of approach has little impact. 17 Final Rulemaking: Light-Duty Vehicle Greenhouse Gas Emissions Standards and Corporate Average Fuel Economy Standards (published May 7, 2010). In miles per gallon, there is approximately a 25% gap between laboratory measured and real world achieved fuel economies. 18 The relative energy densities of diesel and gasoline fuel are approximately 129,000 btu/gallon and 115,000 btu/gallon respectively. 19 In MYs 2011 and later, small SUVs are considered cars, rather than light trucks under the CAFE and GHG regulations. ------- Projected improvements in air conditioning system efficiency were included in the energy rates themselves rather than in a modification of the MOVES2010a air conditioning function. However, because the MOVES A/C adjustments are multiplicative, this change will also reduce the energy consumption from air conditioning. For the model year 2011 CAFE standards, a 1.15x adjustment was made for diesel vehicles. For 2012 and beyond, the diesel vehicles were presumed to meet the same CC>2 standard as the gasoline vehicles. Rates for model years after 2016 were set equivalent to model year 2016. The following tables (Table l-9,Table l-10,Table 1-11, & Table 1-12) show the g/mile rate for the laboratory combined Federal Test Procedure (FTP)THighway Fuel Economy Test (FIFET) driving schedules and on-road value equivalents. The tables showing on-road values are what were used to modify the model. Note that no source type is composed solely of regulatory class 30, and that these tables were produced using a set of user input files that isolate the output of this regulatory class. Table 1-8 - Ratios used to develop new rates in MOVES2010a 20 2008 2009 2010 2011 2012 2013 2014 2015 2016 Ratios Used From MOVES2010 to MOVES2010a Trucks Gas 0.904 0.896 0.898 0.831 0.790 0.769 0.747 0.716 0.677 Diesel 0.723 0.716 0.717 0.663 0.550 0.535 0.519 0.497 0.470 Cars Gas 0.981 0.969 0.985 1.002 0.919 0.893 0.868 0.830 0.782 Diesel 1.007 0.995 1.011 1.028 0.823 0.800 0.777 0.743 0.700 20 Note that these ratios were applied against the emissionrate table, and that the model year 2008-2011 light duty truck rule was reflected in MOVES2010 through an engine technology mix. Thus, the CC>2 output from MOVES2010 was actually quite a bit lower than these ratios would indicate. 10 ------- Table 1-9 - Test Cycle MPG 2008 2009 2010 2011 2012 2013 2014 2015 2016 MPG - Test Cycle MOVES2010 Trucks Gas 20.5 20.5 20.6 20.6 20.7 20.7 20.7 20.7 20.8 Diesel 16.4 16.4 16.4 16.4 16.5 16.5 16.5 16.5 16.5 Cars Gas 29.7 29.7 29.8 29.8 29.9 29.9 30.0 30.0 30.0 Diesel 26.7 26.7 26.7 26.8 26.8 26.8 26.8 26.9 26.9 MOVES2010a Trucks Gas 22.7 22.9 22.9 24.8 26.1 26.9 27.7 29.0 30.7 Diesel 22.7 22.9 22.9 24.8 29.9 30.8 31.7 33.2 35.1 Cars Gas 30.5 30.9 30.4 29.9 32.7 33.7 34.7 36.3 38.5 Diesel 30.5 30.9 30.4 29.9 37.4 38.5 39.7 41.5 44.1 Table 1-10 - On-road MPG 2008 2009 2010 2011 2012 2013 2014 2015 2016 MPG - On Road MOVES2010 Trucks Gas 16.4 16.4 16.5 16.5 16.5 16.5 16.6 16.6 16.6 Diesel 13.1 13.1 13.1 13.1 13.2 13.2 13.2 13.2 13.2 Cars Gas 23.8 23.8 23.8 23.9 23.9 23.9 24.0 24.0 24.0 Diesel 21.3 21.4 21.4 21.4 21.4 21.5 21.5 21.5 21.5 MOVES2010a Trucks Gas 18.1 18.3 18.3 19.9 20.9 21.5 22.2 23.2 24.5 Diesel 18.1 18.3 18.3 19.8 23.9 24.6 25.4 26.5 28.1 Cars Gas 24.4 24.7 24.3 24.0 26.2 26.9 27.7 29.0 30.8 Diesel 24.4 24.7 24.3 24.0 30.0 30.8 31.8 33.2 35.3 11 ------- Table 1-11 - Test-Cycle CO2 2008 2009 2010 2011 2012 2013 2014 2015 2016 CO2 - Test Cycle MOVES2010 Trucks Gas 433.9 432.9 431.9 431.1 430.3 429.6 429.0 428.4 427.8 Diesel 621.8 621.0 620.1 619.4 618.7 618.1 617.5 617.0 616.5 Cars Gas 299.2 298.7 298.3 297.8 297.4 297.0 296.7 296.4 296.1 Diesel 381.9 381.3 380.8 380.4 380.0 379.6 379.2 378.9 378.6 MOVES2010a Trucks Gas 392.0 388.0 388.0 358.1 339.9 330.6 320.5 306.6 289.6 Diesel 449.4 444.8 444.8 410.5 340.2 330.9 320.8 306.9 289.9 Cars Gas 291.4 287.6 292.0 296.8 271.9 264.1 256.4 245.0 230.6 Diesel 333.7 329.4 334.5 339.9 271.9 264.1 256.4 245.0 230.6 Table 1-12 - On-road CO2 2008 2009 2010 2011 2012 2013 2014 2015 2016 CO2 - On Road MOVES2010 Trucks Gas 542.3 541.1 539.9 538.9 537.9 537.0 536.2 535.5 534.8 Diesel 777.3 776.2 775.2 774.2 773.4 772.6 771.9 771.2 770.6 Cars Gas 374.1 373.4 372.8 372.3 371.7 371.3 370.8 370.4 370.1 Diesel 477.3 476.7 476.1 475.5 475.0 474.5 474.0 473.6 473.2 MOVES2010a Trucks Gas 490.0 485.0 485.0 447.6 424.9 413.2 400.6 383.2 362.0 Diesel 561.7 556.0 556.0 513.1 425.3 413.6 401.0 383.6 362.3 Cars Gas 364.2 359.5 365.0 370.9 339.8 330.1 320.5 306.3 288.2 Diesel 417.2 411.8 418.1 424.9 339.8 330.1 320.5 306.3 288.2 12 ------- Following the conventions in MOVES2010, for all years, electricity, E85 (85% ethanol/gasoline blends), and compressed natural gas (CNG) energy consumption rates were set equal to gasoline. Based on MOVES2010, CNG start energy rates were set equal to the gasoline rates for starts multiplied by 1.05 1.5 Inventory Impacts of Changes relative to MOVES2010 The structural changes described in this document had little impact on model results. For any pollutant, national annual scale runs conducted for calendar year 2001 with the new database differ by less than 0.1% as compared to MOVES2010. A few specific processes related to energy differ by greater amounts (<10%), but have insignificant impact on total inventories. With one exception, there are no changes in processes unrelated to energy.21 The data changes, which reflect new data and the model year 2012-2016 LD GHG rulemaking, impact the results to a greater extent than the structural changes. As described above, we conducted national annual runs in order to estimate the impact of the database changes. The structural changes were evaluated with a national annual run in calendar year 2001. Calendar year 2001 was chosen because it predates any of the new data in the database. A second run was conducted in calendar year 2021 to assess the impact of the new data and projections for model year 2008 and newer. The MOVES runs were conducted with all vehicle types and all fuel types. 21 Ammonia (NH3) emissions also increase with the new database. The MOVES2010 database did not have NH3 emission rates for engine technologies other than conventional internal combustion. Therefore the advanced internal combustion light trucks in MOVES2010 erroneously did not produce NH3 emissions. MOVES2010a fixes this issue. 13 ------- Table 1-13 - Fuel/Pollutant/Process affected in Calendar Year 2001 Fuel Affected CNG CNG CNG Diesel Diesel Diesel Diesel Diesel Diesel Diesel Diesel Diesel Diesel Diesel CNG Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Pollutant Affected 90 91 93 115 105 31 90 105 115 91 92 93 31 98 98 105 115 115 105 92 31 90 93 91 31 Pollutant (Text) CO2 Energy Energy PM2.5 - Sulfate PM10 - Sulfate SO2 CO2 PM10 PM2.5 Energy Energy Energy SO2 CO2 CO2 PM10- Sulfate PM2.5- Sulfate PM2.5- Sulfate PM10- Sulfate CO2 SO2 Energy Energy Energy SO2 Processes Affected 2 2 2 2 2 16 2 16 16 2 2 2 2 2 2 16 16 2 2 2 2 2 2 2 16 Process (Text) Starts Starts Starts Starts Starts Crankcase - Starts Starts Crankcase - Starts Crankcase - Starts Starts Starts Starts Starts Starts Starts Crankcase - Starts Crankcase - Starts Starts Starts Starts Starts Starts Starts Starts Crankcase - Starts % Change 807 /O 807 /O -8% -4% -4% -4% -4% -4% -4% -4% -4% -4% -4% -4% -2% -1% -1% -1% -1% -1% -1% -1% -1% -1% -1% The calendar year 2001 results shown in Table 1-13 are driven by the modification of the energy rate sourcebins from a size/weight basis to a regulatory class basis. These effects are minimal on most pollutants and processes. Specifically, the organizational changes to the database had no effect on heavy duty running rates, which had already been aggregated in this manner. It also had minimal effect on those source types (passenger cars and motorcycles), which have a 1:1 to relationship with regulatory class. All the processes listed above are related to starts, which have a relatively small impact on total energy consumption. Passenger truck and light commercial trucks are the only source types that were composed of similar regulatory classes in MOVES 2010 but different size/weight distributions. As a result, post-aggregation, the revised energy rates for each of these vehicles converged into a population weighted average of the two sets of energy rates. In regulatory class 30, the diesel fuel type is dominated by light commercial trucks, while the gasoline fuel type is dominated by passenger trucks. For further detail, a narrower light truck inventory comparison between MOVES2010 and MOVES2010a is shown below for calendar year 2007 (Table 1-14): 14 ------- Table 1-14 - Comparison of National CO2 Inventories in Calendar Year 2007 (Million Metric Tons) Gasoline Passenger Truck Gasoline Light Commercial Truck Diesel Passenger Truck Diesel Light Commercial Truck Total MOVES2010 400.6 132.2 10.2 22.6 565.6 MOVES2010a 415.0 122.7 9.8 23.0 570.4 Difference Percentage 3.6% -7.2% -4.7% 1.9% 0.9% In the second MOVES test run (calendar year 2021), we evaluated the impact of the energy rate updates (Table 1-15). As the scope of the impacts is larger, the table below is aggregated by emission process in order to show impacts by fuel and pollutant. Decreases are seen in energy related pollutants such as PM sulfate, energy and CC>2, 862. Smaller reductions are seen in ethanol emissions, as well as those emissions related to refueling and spillage. Table 1-15 - Impacts of Changes in Calendar Year 2021 Fuel Affected Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Gasoline Diesel Diesel Diesel Diesel Diesel Diesel Diesel Diesel Gasoline Diesel Gasoline Pollutant Affected 115 105 92 91 93 90 31 98 21 87 80 79 86 1 92 93 91 90 98 105 115 31 5 30 30 Pollutant (Text) PM2.5 - Sulfate PM10 - Sulfate Energy Energy Energy CO2 SO2 CO2 Ethanol voc NMOG NMHC TOG THC Energy Energy Energy CO2 CO2 PM10 PM2.5 SO2 Methane NH322 NH3 % Change -14% -14% -14% -14% -14% -14% -14% -14% -5% -2% -2% -2% -2% -2% -1% -1% -1% -1% -1% -1% -1% -1% 1% 7% 25% : As noted in 21 above, this increase in ammonia emissions is due to a related fix. 15 ------- 2 Methane and N2O in MOVES2010 In MOVES2004, EPA based its estimates of emissions of methane (CH4) and nitrous oxide (N2O) on test results of the Federal Test Procedure (FTP) and the then current version of EPA's "Inventory of U.S. Greenhouse Gas Emissions and Sinks." For Draft MOVES2009, EPA used both an enlarged database of test results plus a newer version of EPA's "Sources and Sinks" report23 (primarily Table A-88 of its Annex 3). EPA used the estimates from its "Sources and Sinks" report to fill holes its test data (i.e., when either no or limited results from Federal Test Procedure (FTP) were available). Emission rates for N2O and for CH4 in Draft MOVES2009 were estimated for engine starts and for running operation and were not calculated for individual operating modes. This is in contrast to rates for other pollutants (e.g., HC, CO, NOx) for which running emissions are calculated for each of 23 operating modes (based on vehicle speed and power) and for which start emissions are calculated for each of 8 operating modes (based on vehicle soak time prior to engine start). Differences Between MOVES and "Sources and Sinks" EPA publishes an annual report of emissions of greenhouse gases ("Inventory of U.S. Greenhouse Gas Emissions and Sinks"). Although the basic emission rates in EPA's "Sources and Sinks" report are based on technology groups, the basic emission rates in MOVES are based on (among other parameters) model year groups. Therefore , the initial analysis was to estimate emission rates by technology groups and then to convert those to model year groups. The conversion from technology groups to individual model years was based on the distribution of the individual technologies in each model year as detailed in the "Sources and Sinks" report (Tables A-84 through A-87 of the 2008 publication). A second difference between those sets of rates is that the rates in EPA's "Sources and Sinks" report are estimates of emissions over the entire FTP driving cycle (in grams per mile) including the engine start while those in MOVES are given separately for starts (grams per start) and running operation (grams per hour). To estimate running emission rates of N2O and CFLi in the draft MOVES2009 model, EPA used the same approach that it used in the analysis for the MOVES2004 model. That is, EPA assumed that the hourly emissions rate for the Bag-2 portion of the FTP is representative of the overall running rate (in grams per hour). To calculate this rate, EPA multiplied the Bag-2 emissions (in grams per mile) by the average speed of Bag-2 (i.e., 16.023 miles per hour), which produces the requisite emission rate (in units of grams per hour). 23 "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2006," EPA Report No. EPA 430-R-08-005, April 2008. Available at: http://www.epa.gov/climatechange/emissions/usinventoryreport.html 16 ------- Multiplying that hourly rate by the duration of the full LA-4 driving cycle (i.e., 1,372 seconds or 0.381111 hours) yields the total estimated running emissions of the LA-4 (or FTP) in grams. Then, multiplying the composite FTP emissions (in grams per mile) by the length of the LA-4 driving cycle (7.45 miles) yields the estimated total emissions (in grams) produced during the FTP. Subtracting those two quantities (total grams emitted during the FTP minus the total grams from the running emissions) yields an estimate of the emissions (in grams) from a generic start (57 percent hot-start and 43 percent cold- start). It is these two rates (running emissions in grams per hour and generic start emissions in grams per start) that EPA used in the MOVES2004 model and updated in the Draft MOVES2009 model. 17 ------- 2.1 Nitrous Oxide Emission Rates: Table 3-1 compares the nitrous oxide FTP emission rates (by technology group) from EPA's "Sources and Sinks" report, the comparable rates from MOVES2004, and the means of test data obtained from a study by Environment Canada.24 Table 2-1: Comparison of FTP Nitrous Oxide Emissions (grams / mile) Vehicle Type / Control Technology Gasoline Passenger Cars EPA Tier 2 LEVs EPA Tier! EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Light-Duty Trucks EPA Tier 2 LEVs ^ATierl EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Heavy-Duty Vehicles EPA Tier 2 LEVs gp^"^7i EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled "Sources & Sinks" Rnt 0.0036 0.0150 676429 0.0647 o76504 0.0197 0.0197 0.0066 0.0157 0.0871 0.1056 676639 0.0218 0.0220 0.0134 0.0320 O7i75(j 0.2135 O7i3i7 0.0473 0.0497 MOVES2004 0.012 0.012 61)30 0.054 67642 0.017 0.017 0.009 0.009 67667 0.090 67654 0.019 0.019 0.019 0.019 67i"38 0.183 67113 0.041 0.043 FTP Data 0.0050 0.0101 676283 0.0538 — — — — 0.0148 676674 0.0370 676906 — — — — — 0.0814 — — — "Greenhouse Gas Emissions from 1997-2005 Model Year Light Duty Vehicles," Environment Canada Report No. ERMD Report #04-44. 18 ------- Comparison of FTP Nitrous Oxide Emissions (grams / mile) Con't Vehicle Type / Control Technology Diesel Passenger Cars Advanced Moderate Uncontrolled Diesel Light-Duty Trucks Advanced Moderate Uncontrolled Diesel Heavy-Duty Vehicles Advanced Moderate Uncontrolled Motorcycles Non-Catalyst Control Uncontrolled "Sources & Sinks" Rpt 0.0010 0.0010 0.0012 0.0015 0.0014 0.0017 0.0048 0.0048 0.0048 0.0069 0.0087 MOVES2004 0.001 0.001 0.001 0.002 0.002 0.002 0.005 0.005 0.005 0.007 0.009 FTP Data — — — — 0.0049 — — — Twenty-two of the thirty-two technology groups contain no FTP N2O test data. For those rates, we use the "Sources and Sinks" data. 19 ------- In the following table, we take those 32 composite FTP N2O rates (22 based on the "Sources and Sinks" rates and the remaining 10 based on newer FTP test data) and disaggregate them into running rates (in grams per hour) and start rates (in grams per generic start). Table 2-2: Separating Composite FTP N2O Emissions into Running and Start Vehicle Type / Control Technology Gasoline Passenger Cars EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Light-Duty Trucks EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Heavy-Duty Vehicles EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled FTP Comp (g / mile) 0.0050 0.0101 OXJ283 0.0538 670504'' 0.0197 0.0197 0.0066 0.0148 070674 0.0370 076906 0.0218 0.0220 0.0134 0.0320 671750 0.0814 67i'3i7 0.0473 0.0497 Running (g / hour) 0.0399 0.0148 6;23i6 0.6650 a<5235 0.2437 0.2437 0.0436 0.0975 0.6500 0.2323 0.8492 0.2044 0.2062 0.1345 0.3213 L7569 0.8172 L"3222 0.4749 0.4990 Start (g / start) 0.0221 0.0697 671228" 0.1470 61379 0.0539 0.0539 0.0325 0.0728 '672546 0.1869 63513 0.0845 0.0853 0.0486 0.1160 6^6342 0.2950 0';4773 0.1714 0.1801 20 ------- Separating Composite FTP N2O Emissions into Running and Start Con't Vehicle Type / Control Technology Diesel Passenger Cars Advanced Moderate Uncontrolled Diesel Light-Duty Trucks Advanced Moderate Uncontrolled Diesel Heavy-Duty Vehicles Advanced Moderate Uncontrolled Motorcycles Non-Catalyst Control Uncontrolled FTP Comp (g / mile) 0.0010 0.0010 0.0012 0.0015 0.0014 0.0017 0.0049 0.0048 0.0048 0.0069 0.0087 Running (g / hour) 0.0168 0.0168 0.0202 0.0253 0.0236 0.0286 0.0828 0.0809 0.0809 0.0854 0.1076 Start (g / start) 0.0010 0.0010 0.0012 0.0015 0.0014 0.0018 0.0051 0.0049 0.0049 0.0189 0.0238 21 ------- 2.2 Methane Emission Rates: The following table (table 3-3) compares the methane FTP emission rates (by technology groups) from the EPA's "Sources and Sinks" report, the rates from MOVES2004, and the means of the Environment Canada test data. Table 2-3: Comparison of FTP Methane Emissions (grams / mile) Vehicle Type / Control Technology Gasoline Passenger Cars EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Light-Duty Trucks EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Heavy-Duty Vehicles EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled "Sources & Sinks" Rpt 0.0173 0.0105 0.0271 0.0704 0.1355 0.1696 0.1780 0.0163 0.0148 0.0452 0.0776 0.1516 0.1908 0.2024 0.0333 0.0303 0.0655 0.2630 0.2356 0.4181 0.4604 MOVES2004 0.013 0.013 0.020 0.066 0.133 0.162 0.171 0.017 0.017 0.034 0.071 0.143 0.184 0.195 0.034 0.034 0.047 0.218 0.208 0.403 0.445 FTP Data 0.0110 0.0083 0.0242 0.0665 0.1351 0.1568 — — 0.0117 0.0357 0.0708 0.1413 0.0390* — — — 0.0515 0.2487 0.2135 — — * Possible outlier (single test vehicle). 22 ------- Comparison of FTP Methane Emissions (grams / mile) Con't Vehicle Type / Control Technology Diesel Passenger Cars Advanced Moderate Uncontrolled Diesel Light-Duty Trucks Advanced Moderate Uncontrolled Diesel Heavy-Duty Vehicles Advanced Moderate Uncontrolled Motorcycles Non-Catalyst Control Uncontrolled "Sources & Sinks" Rot 0.0005 0.0005 0.0006 0.0010 0.0009 0.0011 0.0051 0.0051 0.0051 0.0672 0.0899 MOVES2004 0.001 0.001 0.001 0.001 0.001 0.002 0.004 0.004 0.004 0.067 0.090 FTP Data — — — — 0.0039 — — — Note that 17 of the 32 technology groups have no FTP CFLt test data. For those rates, the "Sources and Sinks" data for the FTP rates were used. Also, for non-catalyst light-duty gasoline trucks, there was only one FTP result, and that single FTP methane result appears to be an outlier (i.e., too low). Therefore, for that technology group we also used the "Sources and Sinks" rate. In the following table (Table 3-4), those 32 composite FTP CFLt rates (18 based on the "Sources and Sinks" rates and the remaining 14 based on newer FTP test data) were disaggregated into running rates (in grams per hour) and start rates (in grams per generic start). 23 ------- Table 2-4: Separating Composite FTP CH4 Emissions into Running and Start Vehicle Type / Control Technology Gasoline Passenger Cars EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Light-Duty Trucks EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled Gasoline Heavy-Duty Vehicles EPA Tier 2 LEVs EPA Tier 1 EPA Tier 0 Oxidation Catalyst Non-Catalyst Control Uncontrolled FTP Comp (g / mile) 0.0110 0.0083 0.0242 0.0665 0.1351 0.1568 0.1780 0.0163 0.0117 0.0357 0.0708 0.1413 0.1908 0.2024 0.0333 0.0303 0.0515 0.2487 0.2135 0.4181 0.4604 Running (g / hour) 0.1131 0.0632 '673164 0.9952 271613 2.3654 2.6855 0.1114 0.0801 03775 0.9788 2.0255 0.4807 2.4970 0.3111 0.2831 0.48J6 3.6353 2.8555 5.5908 6.1565 Start (g / start) 0.0386 0.0379 '676596 0.1165 671831 0.2666 0.3026 0.0790 0.0568 O7i223 0.1544 072808 0.1071 0.5563 0.1295 0.1179 072005 0.4674 '675026 0.9841 1.0837 24 ------- Separating Composite FTP CH4 Emissions into Running and Start Con't Vehicle Type / Control Technology Diesel Passenger Cars Advanced Moderate Uncontrolled Diesel Light-Duty Trucks Advanced Moderate Uncontrolled Diesel Heavy-Duty Vehicles Advanced Moderate Uncontrolled Motorcycles Non-Catalyst Control Uncontrolled FTP Comp (g / mile) 0.0005 0.0005 0.0006 0.0010 0.0009 0.0011 0.0039 0.0051 0.0051 0.0672 0.0899 Running (g / hour) 0.0098 0.0098 0.0117 0.0195 0.0176 0.0215 0.0765 0.0997 0.0997 1.0138 1.3563 Start (g / start) 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.1143 0.1528 25 ------- 2.3 Alternative Fuels Since no additional FTP data were available, the emission rates of N2O and CFLt in the draft MOVES2009 model are based entirely on EPA's "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2006" (Table A-89 of its Annex 3). Those FTP rates from that report are reproduced in the following table (Table 3-5): Table 2-5 Composite FTP Emissions from Alternative Fuels Vehicle Type / Fuel Type Light-Duty Vehicles Methanol CNG LPG Ethanol Biodiesel (BD20) Heavy-Duty Vehicles Methanol CNG LNG LPG Ethanol Buses Methanol CNG Ethanol N20 (g / mile) 0.067 0.050 0.067 0.067 0.001 0.175 0.175 0.175 0.175 0.175 0.175 0.175 0.175 CH4 (g / mile) 0.018 0.737 0.037 0.055 0.000 0.066 1.966 1.966 0.066 0.197 0.066 1.966 0.197 26 ------- Disaggregating those composite FTP rates into start and running rates yields the following results: Table 2-6: Methane Emission Rates from Alternative Fuels Vehicle Type / Fuel Tvne Light-Duty Vehicles Methanol CNG LPG Ethanol Heavy-Duty Vehicles & Buses Methanol CNG LNG LPG Ethanol Running (g / hour) 0.2192 8.9755 0.4506 0.6698 0.8038 23.9429 23.9429 0.8038 2.3992 Starts (g / start) 0.0506 2.0700 0.1039 0.1545 0.1854 5.5218 5.5218 0.1854 0.5533 Table 2-7: Nitrous Oxide Emission Rates from Alternative Fuels Vehicle Type / Fuel Tvne Light-Duty Vehicles Methanol CNG LPG Ethanol Heavy-Duty Vehicles & Buses Methanol CNG LNG LPG Ethanol Running (g / hour) 0.6431 0.4799 0.6431 0.6431 1.6797 1.6797 1.6797 1.6797 1.6797 Starts (g / start) 0.2541 0.1896 0.2541 0.2541 0.6636 0.6636 0.6636 0.6636 0.6636 27 ------- 3 Updates to the Methane Rates for MOVES 2010a For MOVES2010a, the MOVES calculations to derive methane (CH4 ) from total hydrocarbons (THC) values were updated, rather than as a separate emission rate as in earlier versions of the model. This change more closely aligns the methane calculations with the calculation of other hydrocarbon compounds in MOVES. As an example, volatile organic compounds (VOCs) are calculated in a chained (multiplicative) manner rather than as independent emission rate. Similarly, the chained calculation of methane is based upon the assumption of a direct relationship between CH4 and THC by age, vehicle type, and fuel. As seen earlier in this report, those vehicles that tend to have higher THC (such as heavy duty vehicles) also tend to have higher methane emissions. In the MOVES calculations, methane must be removed from the THC inventory in order to calculate values for other hydrocarbon species needed in air quality analysis. However, as the standalone methane emission rates were neither age nor temperature sensitive, there were some disconnects between THC and methane (where THC varied with age and temperature, but methane did not). "Chaining" the calculation of methane emissions to THC values allows EPA to make these improvements to the methane inventory, as well. Additionally, connecting THC and methane removes a potential issue where methane emissions could have exceeded THC emissions. Where THC and CH4 are both calculated independently in MOVES2010 and earlier MOVES versions, MOVES could calculate a negative amount for these other compounds, which is physically not possible. In MOVES2010a, CH4 is calculated by applying a multiplicative factor (CH4THCRAtio in the MethaneTHCRatio table) to the calculated THC value after all adjustments to THC have been made for all fuel types. Once the CH4 value has been determined, CH4 is used in MOVES as it was before in all further calculations. To create the new rates for pre-model year 2003 vehicles, methane and THC Emission rates for all gasoline and diesel vehicles were read from the movesoutput file and the ratio is computed. Light duty vehicle, light duty truck, and heavy duty gasoline vehicles were the only source types which were run. All of the other source types were filled with these data. Motorcycles were filled with light duty vehicle rates. To create the new ratios for 2004 and newer vehicles, the MOVES 2010a rates were transferred from the MOVES2010 data using a process similar to that described above. The LDV rates are again used for the motorcycles. The methane ratios for 2007 and newer model year diesel trucks were not taken from the MOVES2010 estimates. The constant value of 0.5846 was derived from new technology diesel vehicle emission testing done for the Health Effects Institute (HEI) Advanced Collaborative Emissions Study (ACES)25. 25 HEI ACES: Khalek, I., Rougher, T., and Merritt, P. M. 2009. Phase 1 of the Advanced Collaborative Emissions Study. Prepared by Southwest Research Institute for the Coordinating Research Council and the Health Effects Institute, June 2009. Available at www.crcao.org. 28 ------- Methane ratios for ethanol are a constant value of 0.37 for the running and engine start processes and zero for all other processes. All raw gasoline evaporative methane ratios can be assumed to be zero since gasoline formulations typically contains negligible amounts of methane. 29 ------- |